Vegan Travel and Cruise & Maritime Voyages Ltd (part of the CMV Holdings London Travel & Leisure Group) collect and process data about enquirers and guests to promote, deliver and improve our services. This privacy notice describes what personal data we collect, how we use that personal data, and how to ensure that our processing meets your expectations.
Why we process your personal data
We process personal data about enquirers and guests before, during and after their cruises to support our customers and our business interests, which include:
- Making enquirers and guests aware of news and offers from Cruise & Maritime Voyages Ltd and Vegan Travel
- Providing services to our guests and documenting what services we have provided
- Managing the health, welfare, safety, and security of our guests
- Handling enquiries, complaints, and investigations
- Operating Columbus Club loyalty programmes
- Monitoring and improving the quality of our training and services
- Researching and understanding your preferences and needs to improve our marketing effectiveness
- Working with our partners such as onboard boutiques, casino, photo gallery and spas to manage billing and improve the quality of their services
We also process personal data about job applicants, current and former employees, service providers, travel agents and other groups of individuals during employment and business operations, and this data is subject to our internal privacy policies.
What personal data we collect
We collect your personal data when you enquire, book, sail, or communicate with us. Below are examples of the data we collect when you communicate with us.
- Enquiry: Personal details such as name, gender, age etc. Contact information such as home address, phone number, email address, holiday preferences
- Booking: Personal details, contact information, booking preferences, financial details (credit/debit card, bank details), travel documents (passport details), care needs (medical, dietary, mobility etc.), dining preferences, other travel details (vehicle registration, excursion bookings)
- Onboard Activity: Financial details, bookings, and billing for onboard services and shore excursions photographs taken during the cruise
- Enquiries & Complaints: Personal details, contact information, enquiry or complaint details
- Loyalty Programme: Personal details, contact information, communications preferences, cruise history
- Health & Medical: Medical, dietary and mobility details provided to us before, during or after the cruise
- Security & Safety: Travel documents, facial photography, incident reports or witness statements
- Surveys & Market Research: Responses to post-cruise surveys
- Additional Services: If you purchase services, a gift or surprise booking, we will record your details as needed in relation to the individual(s) for whom the gift or surprise booking was purchased.
Personal data generated by your interactions with us
Your interactions with us will result in personal data being created and stored by us. Examples include:
- Booking: Booking party details, reference numbers, travel itineraries, flight bookings, manifests, immigration details;
- Onboard Activity: On-board spending, boutique spending, casino spending, spa/gym specialist interactions, dining records;
- Enquiries & Complaints: Enquiries or complaints and associated investigation and correspondence before, during or after a cruise;
- Loyalty Programme: Nights on board, cumulative spending;
- Health & Welfare: Medical reports, billing data, welfare reports, correspondence;
- Security & Safety: Accident/incident reports, witness statements, embarkation/disembarkation logs, CCTV recordings, police reports.
Personal data we create
We analyse the personal data we hold to improve the effectiveness of our direct marketing communications or to deliver our loyalty programmes. This can, in turn, generate personal data; for example, helping us to decide which marketing communications are likely to be of interest to you or to determine your loyalty status.
Personal data from other organisations
We receive personal data from other individuals or third-party organisations. For example, when making a booking we will receive details of all members of the booking party from the guest making the booking. We may receive personal data from third-party organisations including travel agents processing bookings on a guest’s behalf, from competitions or promotions where personal data has been provided as part of the competition or promotion, or from social media where personal data has been posted on our social media pages. We use publicly accessible data sources such as data brokers to maintain the accuracy of our enquirer and guest records and may from time to time use external sources to help us to resolve disputes or recover unpaid accounts. Sensitive personal data
Sensitive personal data
We do not process sensitive personal data about you except where there is a legal reason to do so. Sensitive personal data can include:
- Health: We collect personal data about guest health as part of the booking and embarkation processes, or where guests use medical services on board ship. This may be retained for subsequent care purposes and to facilitate billing for services provided.
- Biometrics: We use photographs of our guests to maintain security and safety whilst they are on board our ships. These are not retained or used for other purposes.
- Sexual orientation: Enquirers and guests may from time to time choose to provide data to us relating to their sexual orientation or gender identity so that we can maintain their health, welfare, and enjoyment of the services we provide (though we will not actively seek to collect such information).
We process personal data about children to provide services when they are guests on our ships. We do not collect personal data about children for any other purpose.
We may from time to time be asked to process sensitive personal data relating to the criminal history of individuals, for example, if we receive a request from law enforcement authorities, or when investigating security matters that might involve law enforcement.
How we process personal data
We process personal data with your explicit consent, or where it is necessary to:
- Enter into a contract and deliver services for you
- Comply with a legal duty
- Protect your vital interests or the vital interests of those around you
- For our own lawful legitimate interests or those of other organisations, provided your rights don’t override these
We will only use personal data about you for the purpose it was collected for or closely related purposes and will inform you or seek your consent if we need to use it for other purposes.
If you enquire about our products or other promotional activities that we provide, we may ask your consent to provide you with news and offers about our services that you may find of interest. Depending on your preferences, our communications with you may include:
- By Email – We monitor our email communications, including where emails are undelivered and if they appear to have been read. We may cease sending you email communications should we be unable to deliver email to you.
- By Post – We may from time to time send postal communications including brochures, newsletters, and offers. Where letters are returned to us, or where external data providers notify us of changes, we take steps to update our records. We may cease sending you postal communications if we believe we are no longer able to contact you at the address on file.
- Calls – Calls made to us, and calls received from us may be recorded for the purposes of training and the monitoring of services provided by us.
- Web – Visitors to our website may be tracked using analytics methods described in our Cookies Policy which can be viewed on our website at https://www.cruiseandmaritime.com/main/cookie-policy
You may withdraw or amend your consent to receive news and offers at any time.
When you make a booking, we will collect personal data about you and other travellers in your group, including your names, genders, dates of birth, home addresses, phone, email, details of any medical, care or dietary requirements, specific preferences relating to the booking you have selected, and your payment details. We need this data to enter into a contract with you.
If you provide us with personal data about any other individuals included in a booking, you must have the authority of those individuals to provide their personal data to us for the purposes set out in this Privacy Notice and will remain accountable for the information provided. It is the responsibility of the lead passenger to ensure that personal data about the group members is accurate and up to date.
Managing My Cruise
After you book a cruise, you can access our online Manage My Cruise service via our website to provide additional personal data about you and your travel party. This additional mandatory personal data including passport, insurance and emergency contact details for you and your booking group is necessary to complete your booking.
You may optionally book or purchase onboard products and services, excursions and other activities, which may require you to provide further personal data. We may have to share your personal data with other companies such as spa operators, shore excursion agents or travel operators to provide these services.
Manage My Cruise contains data about a group of individuals in a booking, including personal data, outstanding balance, additional purchases such as gift packs and shore excursions. To improve security, we do not display sensitive personal information after it has been in submitted.
Safety & Security
We will use personal data about you for the purposes of carrying out security checks. Personal data about you may be shared with recognised law enforcement agencies prior to boarding, during your cruise, or after disembarkation, for security and immigration purposes. Personal data may also be shared with these agencies to prevent and detect crime as well as to safeguard children and vulnerable adults. These checks may involve sending personal data between different countries, including countries outside the European Union where controls on data protection may not be as strong as the legal requirements within the European Union.
For the safety and security of each ship and its passengers, and to maintain health and safety, we operate closed circuit television (CCTV) cameras on board our ships throughout the public areas. These are recording continually with footage being retained and stored for a set period. Images taken from these cameras may be used internally for identification purposes and to assist with the investigation of safety or security related matters. Images may also be shared with law enforcement agencies (in any jurisdiction) in order to detect or prevent criminal activity or to assist in the apprehension and prosecution of offenders.
Health & Welfare
In the unlikely event that you are involved in an accident or require medical treatment on our ships, we may use personal data already provided to us, or obtained from you, to deliver your treatment. We may share that personal data with third-party healthcare providers with your consent or where it is in your vital interests or the public interest to do so and retain a record of treatment provided for billing and obligatory record-keeping purposes.
Before the end of your cruise, we will provide you with a questionnaire to seek feedback on your experience to understand your satisfaction level so that we can improve the quality of services we offer, and to assess the performance of our onboard staff and their associated rewards. The information you provide will not be used for any other purpose.
Columbus Club Loyalty Programme
We operate loyalty programmes that allow you to benefit from your time spent on our ships, through future offers that may include discounts, upgrades, early booking, competitions, gifts and other rewards. For this reason, we retain a basic record of cruises you have taken including your name, contact details, cruise numbers, dates, and any loyalty offers that you have redeemed with us. If you believe we hold incorrect historical cruise details, you can contact us with evidence of those cruises to correct your record.
We will contact you with details of our loyalty programme when you book your first cruise, and if you join you will receive further communications thereafter including details of your loyalty status and benefits. You may opt out of the loyalty programme and programme-related communications at any time.
Sharing personal data
We process personal data about enquirers and guests in the UK and onboard our ships worldwide. We contract other companies and individuals to perform certain activities on our behalf, such as;
- Fulfilling requests for brochures and promotional materials: printers, fulfillment service providers
- Processing payments: banks, payment service providers;
- Sending postal mail and e-mail communications: postal services, couriers, e-mail service providers;
- Maintaining guest records and analysing data: customer insight agencies, credit agencies;
- Providing port services and excursions:
- Providing travel services: airlines, coach operators, travel agents.
These contractors have access only to the personal information needed to perform their duties and are not permitted to use it for other purposes.
If you make a booking we may pass your personal information on to other relevant suppliers of your travel arrangements such as airlines, hotels and transport companies. Your personal information may also be passed to travel agents, security and credit checking companies, credit and charge card companies. We are required to co-operate with government and law enforcement agencies and the public authorities of any country in your itinerary, including customs and immigration authorities.
Transferring personal data to third countries
We collect and process personal data in the European Union (EU). We may need to process your personal data worldwide, including onboard our ships, depending upon the destinations you travel to with us, for example, if we have to provide personal data to immigration authorities, port agents or excursion operators in destination countries. This may involve sending your personal information between different countries, including countries outside the EU where controls on data protection may not be as strong as the legal requirements in the EU.
From time to time personal data may need to be shared with other parts of the CMV travel & Leisure Group outside of the EU to provide the services you request from us. We use legal mechanisms (‘binding corporate rules’), technical and procedural controls to safeguard your personal data in these circumstances.
Your rights concerning your personal data
You have rights over how we use your personal data and can exercise those rights by contacting our Data Protection Officer, Cruise & Maritime Voyages Ltd, Gateway House, Stonehouse Lane, Purfleet, Essex RM19 1NS, or email firstname.lastname@example.org.
In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
Withdrawing consent to the processing
Where we have obtained your consent for the processing of personal data about you, you have the right to withdraw your consent at any time. Where we process personal data about you in ways for which your consent is not required, for example, to record your cruise history, you may ask us to cease processing, or restrict the nature of the processing, if you wish.
Accessing the personal data we hold about you
You may request a copy of the personal data we hold about you. This includes obtaining personal data about you in electronic form to provide to a third party should you wish to do so.
Ensuring the accuracy of personal data we hold about you
We will update or amend personal data we hold about you if you inform us of inaccuracies. We use publicly accessible data sources such as data brokers to maintain the accuracy of data.
Deleting personal data we hold about you
We retain personal data for the period required for processing, and where we are under a legal obligation to do so, for example, billing data is retained in accordance with anti-money laundering and financial records keeping requirements.
We hold a basic record of passenger cruise history (name and contact details, booking/cruise number, nights onboard) indefinitely for maintaining our loyalty scheme.
We will delete personal data we hold about you if you ask us to do so, except where certain exemptions apply.
How to complain about our processing of personal data
If you have a concern or complaint about our processing of personal data, please contact our Data Protection Officer by post at Data Protection Officer, Cruise & Maritime Voyages Ltd, Gateway House, Stonehouse Lane, Purfleet, Essex RM19 1NS, or email email@example.com.
If you are not satisfied with our processing of personal data, how we have responded to your complaint about the processing of personal data, or you believe our processing of personal data is not in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO) by calling +44 (0) 303 123 1113, or by visiting https://ico.org.uk/concerns/
Securing your personal data
We take the security of your personal data seriously, and use security policies, standards, technologies and ongoing training to safeguard the personal data we process from improper access, use, alteration, destruction, and loss.
Where we share your personal data with other companies as described above, we require those companies to process your personal data to an equivalent level of security.
Cruise & Maritime Voyages Ltd is part of the CMV Holdings London Travel & Leisure Group.
Cruise & Maritime Voyages Limited is a company registered in England and Wales. Registered number: 07665897 and is registered as a data controller with the Information Commissioner’s Office, registration number Z3193924.
All enquiries relating to data protection, including communications with our Data Protection Officer, should be sent to the Data Protection Officer, Cruise & Maritime Voyages Ltd, Gateway House, Stonehouse Lane, Purfleet, Essex RM19 1NS, or email firstname.lastname@example.org.
Please send all cruise related enquiries to Vegan Travel.
This policy was updated on 22nd May 2018 and is reviewed at least annually.
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