Silversea Cruises Ltd. (“Silversea” or "We") is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us when you (i) access or use our websites; (ii) request information about our products; and/or (iii) purchase our products (collectively the “Services”). This policy applies to information we collect through our Services, in email, text and other electronic communication sent through or in connection with our Services.
If you reside in a country within the European Union, Silversea Cruises (UK) Limited, will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services;
If you reside in any other part of the world, Silversea Cruises Ltd. will be the controller of your personal data provided to, or collected by or form or processed in connection with our Services.
This policy DOES NOT apply to information that you provide to, or that is collected by, any third-party, such as a travel agent that you use in connection with our Services. We encourage you to consult directly with such third-parties about their privacy policies.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing, using, and/or inquiring about or purchasing our Services you are accepting and consenting to the practices described in this policy. If you do not provide the information we require, we may not be able to provide all of our Services to you.
Your data controller is responsible for the collection, use, disclosure, retention, and protection of your personal data in accordance with its privacy standards as well as any applicable national laws. Your data controller my transfer data to other members of Silversea as described in this policy. We may process and retain your personal data on our servers in the United States, where our data center is located, and /or on the servers of those third parties (in or outside the United States), having contractual relationships with Silversea.
This policy may change from time to time, your continued use of our Services after we make any changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Personal Data Collected by Silversea
We collect several types of personal data (“Data”) from and about you when you order brochures from Silversea, plan or purchase a Silversea cruise, register for a Silversea travel programme or otherwise request information or services on our websites. Data is the information that can be associated with a specific person and could be used to identify that specific person whether from that data, or from the data and other information that we have, or are likely to have access to, including but not limited to, your name, company or travel agency, postal address, email address and phone number. We may also ask for other information about you and your interests through forms, surveys, contests or other means. Your participation in these activities is always voluntary. If you do not want to provide this information, please do not participate in these optional activities. This supplemental information allows us to make you aware of products, services and events that may be of interest to you. We do not consider personal data to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
We collect this information:
-Directly when you provide it to us; and
-Automatically as you navigate through our website (information collected automatically may include information collected through cookies).
DATA YOU GIVE US:
We will use the Data you give us:
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• to notify you about changes to our service; and
• to ensure that content from our site is presented in the most effective manner for you and for your computer.
If you contact us for information or request a quotation for a particular cruise, you might do so by telephone, email, face to face, or by filling in a form on our website. At that point, we will begin to collect information about you. The simple contact details we will request are the means to respond to your enquiry: a telephone number, email address, and of course your name, and possibly the names of those who may be travelling with you. Once we proceed beyond the enquiry stage to make a booking for you, additional information will be needed, such as financial and credit card information, full passport names, addresses and contact numbers of all the people travelling on the booking and their dates of birth. There may be a need to collect additional information such as details of next of kin or emergency contacts and personal details you need to pass to us in order to ensure your booking is looked after properly: these can include dietary requirements and medical needs which act as an indicator of other personal details (such as your ethnicity or the state of your health). The information will be used solely for the smooth running of your cruise.
We must pass on certain Data to the companies fulfilling your booking, which include, but is not limited to, airlines, tour operators, port agents and government authorities. This will, in many cases, involve your Data being passed to entities in other countries throughout the world. We will require these companies to also ensure that your Data is adequately protected and your privacy upheld.
We will use your contact details regularly to keep you updated on the progress of your booking, make you aware of ways to enhance your forthcoming cruise, assist you with pre-reservations, and supply all appropriate information.
If you have provided your consent, we may contact you with marketing about our products and services we think may interest you. We will ask you if and how you wish to be contacted.
We also interact with you through different social media platforms. Your interactions with social media companies are governed by their privacy policies.
Please note that calls to our Reservations departments may be monitored and recorded for quality assurance purposes.
HOW WE USE DATA WE COLLECT
We use the personal data we collect from and about you for a variety of purposes, including to:
• Process and respond to your queries.
• Understand our guests, improve the content and features on our website, process and complete your bookings, and make special offers.
• Administer our Services.
• Diagnose technical problems.
• Send you communications that you have requested or that may be of interest to you by way of emails, or courier, or registered post, or telephone calls, or any other mode of communication.
• Generate and review reports and data about, and to conduct research on, our customer base.
• Administer contests and sweepstakes.
• Provide you with customer support.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• Notify you about changes to our Services.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.
HOW WE SHARE DATA WE COLLECT ABOUT YOU:
General Information Disclosures
· To our subsidiaries and affiliates, which are entities under common ownership or control of our ultimate parent company.
· To contractors, advertisers/service providers and other third-parties whom we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Silversea's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Silversea about the users of our Services are among the assets transferred.
· To third-parties to market their products or services to you if you have consented to receive the promotional updates. We contractually require these third-parties to keep personal data confidential and use it only for the purposes for which we disclose it to them.’
· To fulfill the purpose for which you provide it.
· To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
· To improve our website to ensure that content is presented in the most effective manner for you and for your computer.
· As part of our efforts to keep our website safe and secure. · To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
· To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
· For any other purpose disclosed by us when you provide the information.
· Service Providers. We may share your information with outside vendors that we use for a variety of purposes in order to fulfil our Services. We may share information about you with these vendors only to enable them to perform their services.
· Legal Purposes. We may share your information when we believe in good faith that such sharing is reasonably necessary in order to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. We may also share your information to investigate and address threats or potential threats to the physical safety of any person, to investigate and address violations of this policy, or to investigate and address violations of the rights of third parties and/or to protect the rights, property and safety of Silversea, our employees, its vessels or the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations on account of legal request such as subpoena, court order or government demand to comply with the law.
· To enforce or apply our terms and conditions, passage contracts or conditions of carriage and other agreements.
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Silversea, our passengers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
· Consent. We may share your information in any other circumstances where we have your consent.
Payment Card Information
· To use certain of our Services, we may require credit or debit card account information. By submitting your credit or debit card account information through our Services, you expressly consent to the sharing of your information with third-party payment processors, and other third-party service providers (including but not limited to vendors who provide fraud detection services to us and other third parties).
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR DATA
With regard to each of your visits to our website our web server automatically collects and aggregates information about your visit including, but not limited to, your service provider, browser type and operating system. This information does not personally identify you and we analyse this aggregated information only in order to optimise your experience and enhance the time spent with us online.
Silversea utilises the services of reputable third party companies for the transmission of email messages. Silversea shares personal and non-personal data with their email transmission companies for the purpose of targeting future campaigns, upgrading visitor information used in reporting statistics, and for other reasons relating to website administration. For this purpose, Silversea and their email transmission companies use pixel tags (also called clear gifs) to note your interaction with email messages and to record the pages you visit on Silversea’s website. This information allows Silversea to provide information that is tailored to your needs and interests.
Silversea’s website contains the option to provide contact information for others who you believe might be interested in receiving emails from Silversea. Should you choose to provide contact information for others, the provisions in this policy regarding safeguarding of your contact information shall apply to contact information of others that you provide.
There are sections of our website that are not open to the general public and are restricted to Silversea’s past guests and business partners, such as travel professionals. If you are eligible for access to these sections of our website, you will need to enter your membership number (past guests) or password (Travel Professionals) to gain access. As a further security precaution, you may be asked to provide a password when you register or subscribe to a Silversea email newsletters. You may be asked to provide this password to access your personal data via Silversea’s website. You have the option of having your password emailed to you if you have forgotten or misplaced it. To obtain a copy of your password, please click on the appropriate link below.
Non-Personal Data Collected by Silversea Cruises
Silversea also collects IP addresses of those browsing their website as a way of tracking website usage. See the Profiling section below for a discussion on how this information might be used.
To help Silversea improve its website and to ensure that every effort is made to provide you with information and offers that are of interest to you, your personal data may be merged with click-stream data and other non-personal tracking data that Silversea maintains. Also, a non-identifiable profile may be maintained on you based on the pages that you visit within Silversea’s website.
At various times, Silversea may offer promotions, contests or sweepstakes on our website. Should you choose to participate, Silversea may collect personal, identifying information including your name, company or travel agency, postal address, email address, and phone number. The information collected may be used to conduct the promotion and for other business purposes which may include marketing and may be shared with our affiliated companies or with third parties in accordance with this policy. Participation is subject to the Official Rules governing that specific promotion.
You may sign-up to receive newsletters, promotions, or other communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the "Unsubscribe" link found in emails we send to you.
The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received, and take various precautions to protect information from loss and misuse. If you have any questions about the security of your personal data, you can contact us at the address provided below.
We do not knowingly collect, maintain, or use Data from our website about children under the age of 18. We request that persons under the age of 18 not use our website without supervision from a responsible adult. We will never request Data from a child under the age of 18 without verifiable parental consent. If we become aware that a child under the age of 18 has sent Data to us without prior parental consent, we will remove his or her Data from our files.
Transportation Security Administration Secure Flight Notice
The Transportation Security Administration requires you to provide your full name, date of birth and gender pursuant to 49 U.S.C. Section 114, the Intelligence Reform and Terrorism Prevention Act of 2004, and 49 C.F.R. Sections 1540 and 1560 for all commercial air travel within, into or out of the United States. If applicable, you may also provide your Redress Number. If you book commercial air travel within, into or out of the United States in conjunction with your Silversea cruise, we will request this information from you and forward it to the Transportation Security Administration, as required by law. Failure to provide the required information may result in denial of transport or denial of authority to enter the boarding area. The Transportation Security Administration may share information you provide with law enforcement or intelligence agencies or others under its published systems of records notice. For more information regarding this, please visit www.tsa.gov.
Changing Your Personal Data, Contact
You can update your Data at any time or request that we change or delete (where legally possible) your Data by contacting us in writing at the address provided below.
LIMITATION ON STORAGE
We will not keep personal data active longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable actions to destroy, or erase all data from our website and other systems which is no longer required.
EU DATA PROTECTION RIGHTS
Under the EU’s General Data Protection Regulation (“GDPR”), you have the right to ask us to:
a) Provide you with access to the personal data
that we hold about you;
b) Correct your personal data;
c) Erase your personal data;
d) Restrict our processing of your personal data;
e) Object to our processing of your personal data;
f) Request that we move your personal data to another organization; or
g) Object specifically to us using your personal data for profiling for direct marketing purposes
Click on the respective link to submit your request: Guest Data Protection & Privacy Request Form or Marketing Subscriber Data Protection & Privacy Request Form. Please use the ‘Submit an inquiry’ button in these forms to exercise your rights above.
Your right of access can be exercised in accordance with the GDPR. Any access request will be free of charge, although multiple copies will be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you. We will endeavour to provide you with the personal data in the same machine-readable format and will make it capable of porting to a third party data controller, only if it is technically feasible to do so.
You also have the right to make a complaint about how We process your personal data to your data protection supervisory authority.
You should also notify us in writing if any of your personal details change or if you are aware of any inaccuracies so that this can be corrected.
CALIFORNIA PRIVACY RIGHTS
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal data disclosed to those parties. To make such a request, please contact us at the information provided in the Contact section below.
For More Information, Contact
If you have any queries relating to the processing/ usage of information provided by you or our policy, you may click on the respective link to submit your query: Guest Data Protection & Privacy Request Form or Marketing Subscriber Data Protection & Privacy Request Form.