PRIVACY STATEMENT

The Cruise Pro Limited understands and respects the importance of your privacy and we are committed to safeguarding your personal information. In providing our service to you, we must collect personal information from you and this policy outlines how we treat your personal data after it has been collected by any of our channels which include our website, call centre and any future digital services or channels as they evolve.

About Us

This website, our mobile applications and mobile websites (where applicable) (“the Platforms”) are owned and operated by The Cruise Pro Limited, who’s registered office is 20-22 Wenlock Road, London, N1 7GU. This Privacy Statement covers this website and our other Platforms, The Cruise Pro Limited’s operations and our loyalty programmes (where available and applicable) and explains how we use personal information that we may obtain about you.

This website is designed for use within the UK and by accessing this website you agree that the law of England and Wales will apply to any disputes that may arise.

How this Privacy Statement applies

By visiting our Platforms or using any of our products or services, you agree and consent to your personal information being used and disclosed in the manner set out in this Privacy Statement. In certain countries, we will not collect personal information from you unless you have specifically agreed or consented to us doing so (for example through your acceptance of this Privacy Statement or via an electronic tick-box or other similar measures as required by local privacy and data protection laws).

You do not have to provide your personal information to us, but if you do not provide certain information we will only be able to provide limited products and services to you. Where you refuse to provide mandatory travel information or allow us to disclose it to required governmental agencies and as otherwise required, our travel partners will not be able to transport you.

This Privacy Statement applies even if you have booked your travel or other products or services via a third party (such as a travel agent or holiday company), as this Privacy Statement forms part of your contract with us for the travel and/or those products or services.

The personal information that we collect

When you use our Platforms, certain information is collected by us automatically such as your browser type and IP address (which is a series of numbers identifying your internet connection). These may be through the use of cookies (see “Cookies” below) or analytics services (see “Aggregate data, data analytics and social media functionality” below).

We may collect personal data directly from you when you use our Platforms, contact us by telephone, by email or in person when you travel (such as your image).

We may also collect personal information from third parties who you have authorised to provide your personal information to us (e.g., your travel companion, travel agency or tour operator).

We will combine the information that we collect automatically from you with any other information that you collect directly from you or about you. We also collect and store certain personal information as set out below.

Using the Platforms

(1) When you register with us for promotions, competitions, corporate accounts, loyalty programs, marketing lists or similar services we may collect – title, first name, other names, surname, date of birth, phone number, email address, organisation name and contact details and other information relevant to the service you are signing up for;

(2) When you book a product or service with us we will collect personal information from you which may include – title, first name, other names, surname, date of birth, username and password (if applicable), passport details, phone number, email address, country of residence, emergency contact, destination address where required (e.g. the US) and details of next of kin.. In some countries we also need to collect your nationality and other information for tax purposes. If you book a chauffeur or other transport services we will use the information you provide to collect you at your pick up and drop off address (as applicable);

(3) When you are making payment, we will collect different information depending on the payment method. For example, for credit card payments we will collect – credit cardholder name, address, card number, expiry date and CVC code. You may also choose to store your credit card details with us for future use. However, we do not store your CVC/CVV code (the security code on the back of a credit card); and

(4) For adding new information and preferences to your personal or loyalty profile. For example, recording your meal preferences.

From time to time we may update the methods of collection and data fields above. Where there are significant changes we will find a way to notify you, in accordance with the section “Notification of changes to this Privacy Statement” below.

Information about others

You may provide us with information about others, for example:

(1) If you ask us to provide them with information or allow them to manage your booking on your behalf; or

(2) if you make or manage a booking for or on behalf of another person who has allowed you to do so.

We need to know the names of all passengers travelling. If you are booking a flight on behalf of someone else, you must obtain their consent to use their personal information, including their sensitive personal data as described below. We proceed on the basis that you have obtained these consents. Where required by local laws, we would advise you to keep a record of their agreement and provide them with a copy of, or link to, this policy. This is especially the case if you provide us with sensitive information about them (e.g. a reference to an illness or health condition).

You may also provide information about others for purposes such as referring a friend to us, so we can offer them our products or services. You must only contact individuals via our Platforms who you know would be happy to hear from you and you must not use our products or services to send unsolicited ‘spam’ messages.

How we use personal information?

We use the information provided in the following ways:

  • To fulfill our agreement with you and/or dealing with your booking or intended booking, including processing your booking, sending you your itinerary or other details relating to your booking, or contacting you if there is a problem with your booking (for example by sending you a service message to inform you when your booking has not been completed);
  • Managing your wider travel and products or services requirements, for example liaising with and transferring your data to other travel providers, airlines, service providers and/or travel facilitators so that they can facilitate your travel arrangements so any disruption can be minimised;
  • Personalisation of the service you receive, for example being aware of previous travel experiences or preferences, and tailoring the way we provide our products or services to you based on your preferences and profile;
  • Providing Advanced Passenger Information for passengers landing in certain countries. If you do not provide this information our travel providers may not be able to provide travel and may not be able to provide a refund or re-booking;
  • Facial recognition and other biometric technologies for identification purposes may be used by ourselves, our travel providers, immigration authorities and the airports we fly to;
  • Sharing data with loyalty schemes and operators, where you have those accounts;
  • The provision of access to lounges, and other airport products or services;
  • Interaction with you at different touch points throughout your journey (for example we may inform you that your trip departure has changed);
  • We may use location data for our mobile website and mobile app (where applicable) to enable us to provide the most helpful format and content (for example pre-populating the departure airport, airport codes and payment country) providing that you have agreed to the use of your location data;
  • To register you with our Platforms and administer our Platforms’ products or services where you have registered to receive these. You can unsubscribe from these Platform products or services at any time (see Choice/Opt-out below);
  • To personalise the look and feel of our Platforms and our communications with you, so as to align with preferences you may have told us about or which we have inferred from your use of our Platforms, market research and, (where you have agreed to this) via social media and networks;
  • To answer any queries which you may send to us by email or other forms of communication, and we may keep a record of these contacts including call recordings (to the extent permitted by applicable law);
  • In order to conduct customer satisfaction surveys and improve the products and services we offer or create new products and services;
  • To meet our legal compliance obligations or for accounting or audit purposes, including the prevention of fraud for online payments and use of loyalty schemes;
  • To protect our property, rights, and interests as well as the property, rights, and interests of other persons;
  • For legal purposes, such as to respond to a valid legal subpoena or regulatory order;
  • For credit checking and credit scoring purposes;
  • For crime prevention and detection;
  • For direct marketing purposes, as set out in detail below in the section “How do we use your personal information for marketing purposes? and
  • As you may authorise or consent to additionally from time to time.
What sensitive personal data might you require or hold?

Sensitive personal data includes data about an individual’s health and religion and other categories of personal data which are closely protected. We do not generally collect this information from you (or those you are booking for), but where we do, we seek to minimise the collection and use of it. Where you have notified us of a health issue that you or someone in your booking:

  • May require medical permission to fly, or special conditions or assistance whilst travelling (for example oxygen);
  • Is pregnant; or
  • Requires special assistance either on our planes, at destinations or activities or at airports,

you agree that you have voluntarily provided that information to us and that you consent (and those you are booking for consent) for us to use that information to provide you with these products or services and/or determine your fitness to avail yourself of our products or services.

Where your religion or health status could be inferred from meal preferences, we will not link this information or use it in any other way other than to fulfil your meal request.

In each case, you specifically consent (on your behalf and on behalf of those you are booking for) that we can use and transfer outside your local country to anywhere in the world where you are travelling or have travelled from or where we provide products or services from  our service providers do or your travel agent does) (see “To whom do we disclose your personal information” below).

How do we use your personal information for marketing purposes?

Where you have indicated you would like to receive updates from us:

  • we may send marketing to you to tell you about developments in the products and services available through our Platforms and those of our carefully selected partners (provided that we will communicate these to you in conjunction with our own marketing);
  • where we are able to determine, or you have indicated to us that you would like to receive it, other entities in the Emirates Group and/or other third parties may also send you marketing or updates relating to their products or services; and
  • we will use your personal preferences which you have told us about, which we have derived from Cookies (please see our cookie policy) and/or which we have inferred from your service usage (see Aggregate data, data analytics and social media functionality below) or market research. We will use this information to tailor the advertising and communications that you receive to be those of the most relevance and interest to you. You can also unsubscribe from receiving certain electronic messages (see “Withdrawing your consent” below).
To whom do we disclose your personal information?

We may disclose information about you as follows:

  • To governments, border control agencies, regulators and others as permitted or required by law, in relation to Advance Passenger Information or such other legal requirements as apply from time to time when travelling to or from a particular country;
  • To third parties whose products or services you are purchasing such as airlines, tourism agencies, hotel and car hire companies, or to travel agents including if there is a problem with your booking so that they can resolve it with you, and you acknowledge and consent that this may also be sensitive personal data;
  • To our third-party service providers and processors, as set out below;
  • To third party advertising and social media platforms to provide advertising and the information requested by social media platforms to deliver the user’s requested functionality;
  • In operating our loyalty schemes and referrals to other loyalty schemes, as set out in their terms;
  • We may also disclose your personal information as permitted or required by law. For example, we will disclose personal information to those governmental bodies who have authority to obtain it, in order to comply with a warrant or subpoena issued by a court of competent jurisdiction, and to comply with record production requirements;
  • In the event of a sale of all or substantially all of the assets of The Cruise Pro Limited or the sale or transfer of the business we may transfer personal information in our control to a purchaser that agrees to use personal information for the same reasons identified in this Privacy Statement;
  • To anyone to whom we transfer or may transfer our rights and duties under our agreement with you;
  • Your friend, if you make a request to refer a friend or similar;
  • Where you have authorised someone else to manage your booking;
  • To customs and/or immigration departments or other regulatory authorities in your country of departure and/or destination (or countries you transit through or overfly during your journey) in order to comply with the law in those countries;
  • Where you have authorised someone else to manage your booking;
  • If we have a duty to do so or if the law allows us to do so; and to our employees and agents to do any of the above on our behalf, now or in the future.
Working with other service providers

For operational reasons, we transfer personal information to service providers who help us manage our systems and processes, and to deliver our products or services to users. These may include: banks and payment card verification providers, our data warehouse and customer relationship management centre, marketing organisations (who may provide support for marketing and promotional communications); internet service providers who administer our Platforms and provide internet services and host our facilities; chauffeurs, airport ground handling and assistance teams, car services agencies, IT service providers, and consumer research companies that assist us with understanding consumer interests by conducting surveys. We have implemented safeguards to ensure that our service providers treat personal information in a way that is consistent with the terms of this Privacy Statement and applicable laws, and that it is not used except to fulfil products or services to us or where we believe it is necessary for a legitimate reason connected with the products or services we offer, or as set out in the “What sensitive personal data might you require or hold?” section above.

These service providers and group companies may be located in your country, countries in the European Economic Area, or elsewhere in the world. Different privacy laws may apply in these countries See further detail in our “Transfer of Personal Information” section below. For people resident in Australia, your data may be transferred to the UK and where our servers are located from time to time, along with where you are travelling to or from or as required by law.

Retention

We keep records for as long as required to manage bookings and provide the other relevant products or services anticipated by this Privacy Policy, including keeping you up-to-date with our marketing, and where we are required to by law or for records purposes. We also retain your information to make your future interactions with us convenient and to personalise the products, services and communications with you.

Consent

By choosing to provide us with your personal information you are consenting to its use in accordance with the principles outlined in this Privacy Statement and as outlined at the time you are asked to provide any personal information. We may contact you by phone, email, SMS and mobile device messages or notifications (and gaining your consent where we are required to do so) in order to provide you with updates pertaining to our products or services as well as information about additional offers, products, services or events that we believe may be of interest to you.

Withdrawing your consent

You do not have to provide us with your personal information. However, if you choose not to provide certain personal information we request and/or require or consent to its use and disclosure, you will still be able to visit our Platforms, but you may be unable to access certain options, products or services, and in some cases we may not be able to fulfill your booking.

All marketing communications we send to you will provide you with a way to withdraw your consent to future marketing. If you no longer wish to receive promotional materials, you may opt-out of receiving these by contacting us at customer.support@thecruisepro.co.uk

To opt out of mobile device messages or notifications from our applications go into “settings” on your device and turn off notifications for the relevant application. Be aware that if you unsubscribe completely from our marketing communications we may be unable to notify you of tailored offers to meet your needs.

Please note that if you unsubscribe from marketing communications you will still receive operational and service messages from us regarding your booking and responses to your enquiries made to us, and that we may hold your details on a suppression list, so we don’t send you marketing communications in the future.

You also have the ability to change your cookie settings to block certain types of cookie – this is explained in more detail in our Cookie Policy.

Security

We will take appropriate steps to protect the personal information you share with us. We have implemented technology and security features to safeguard the privacy of your personal information. We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

Protecting your details and protecting yourself against internet fraud

Here are some simple steps you can take to ensure your information is kept securely:

  • Keep your booking reference confidential – upon making a booking a unique booking reference will appear on the email confirmation or ticket of each person in your booking. It is important that you keep your booking reference confidential at all times. Other persons may be able to access your booking details through our system if you disclose your booking reference to them.
  • If you are travelling in a group and would prefer that your individual booking details are not available to other passengers, you may choose to have each person make a separate booking (to be paid for individually).
  • Keep your loyalty ID number/Customer log-in details confidential. You should not share your log in details with anyone else. You should also log out when you finish using our Platforms. This is especially important if you are using a publicly accessible computer.
  • Be aware of “Phishing”, which is where someone tries to represent themselves as someone else to gain information from you – always check whether emails from any sender are actually from them, and if in doubt, go directly to their website and do not click on links in emails, as these may take you to “clone” websites which use your information illegally.
Aggregate data, data analytics and social media functionality

We may aggregate personal information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse Platform use, to improve our content and product offerings, and to customize our Platforms’ content, layout, products and services, and we may appoint third parties to do this on our behalf, as set out above.

  • We gather certain usage information like the number and frequency of visitors to our Platforms. This information may include which webpage you just came from, which webpage you next go to, what browser you are using, your device and your IP address. We only use such data in the aggregate. This collective data helps us to determine how much our customers use parts of our Platforms, and do research on our users’ demographics, interests, and behaviour to better understand and serve you.
  • If you use buttons on our Platforms linked to social media or similar sites (for example “Like” and/or “Share” buttons), content from our Platforms may be sent back to that other website or service and, depending on your privacy settings, may be privately or publicly visible (for example to friends, followers or generally to anyone who has access to your profile page).
  • We may aggregate personal information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse Platform use, to improve our content and product offerings, and to customize our Platforms’ content, layout, products and services, and we may appoint third parties to do this on our behalf, as set out above.
  • We gather certain usage information like the number and frequency of visitors to our Platforms. This information may include which webpage you just came from, which webpage you next go to, what browser you are using, your device and your IP address. We only use such data in the aggregate. This collective data helps us to determine how much our customers use parts of our Platforms, and do research on our users’ demographics, interests, and behaviour to better understand and serve you.
  • If you use buttons on our Platforms linked to social media or similar sites (for example “Like” and/or “Share” buttons), content from our Platforms may be sent back to that other website or service and, depending on your privacy settings, may be privately or publicly visible (for example to friends, followers or generally to anyone who has access to your profile page).
Cookies and other tracking technologies

A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our Platforms and the internet and helps us provide better Platform services to you and tailor certain content. For more information on how we use cookies please read our cookie policy where you can also find information, so you can delete cookies or block certain types of cookie. You should note that this may have an impact on our ability to provide the Platform services to you.

See also our section on “Aggregate data, data analytics and social media functionality” above.

Do Not Track

Currently, our systems do not honour browser do-not-track requests; you may delete cookies and other tracking technologies using the processes specified in our cookie policy.

California Shine the Light Disclosure

We may share your information with carefully selected third parties for the third party’s own marketing purposes. If you are a California resident, you may contact us once per year to request the name of that third party/parties and the categories of information shared about you. To do so, please send a request to us as set out below with valid proof of California residency. Please note that it may take up to 30 days to process your request.

Links

Our Platforms may contain links to other web sites. Please be aware that we are not responsible for the privacy practices of web sites not operated by us. We encourage you to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by our Platforms.

Correction / updating of personal information
  • If your personally identifiable information changes or is inaccurate, or if you no longer desire our service, we will provide a way to correct, update or suppress your personal information provided to us.
  • If you are concerned that any of the information we hold about you is incorrect, please contact us at: support@thecruisepro.co.uk
  • These rights are without prejudice to any legal rights you may have in applicable laws, including your right to object to certain processing of data.
Access to your personal information

You may have the right to receive a copy of personal information we keep about you, including the sources of the data, the purposes and methods of processing, any electronic decision-making and the entities with whom we share your data. We will endeavour to provide the information you require within a reasonable time. There may be a small monetary charge for some requests, depending on the information requested, to the extent permitted by applicable laws.

Transfer of your personal information

Some parties that process or store personal information in accordance with this Privacy Statement may be located in jurisdictions outside your country of residence or our country of incorporation. Therefore, you understand and unambiguously agree that your information may be processed and stored in these jurisdictions and that different privacy laws may apply in these countries which may not ensure the same level of data protection as granted in your country of residence. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it is given in your home country.

In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws.

Notification of changes to this Privacy Statement

If we decide to change our Privacy Statement, we will post those changes on our Platforms. If at any point we decide to use personally identifiable information in a manner materially different from that stated at the time it was collected (and/or where we are required under applicable law), we will notify you. You will have a choice as to whether or not we use your information in this different manner. We will use information in accordance with the Privacy Statement under which the information was collected until you agree otherwise, but if you do not accept the amended Privacy Statement, please stop using our Platforms. Each version has a version number and date, so you can check this easily

Our Contact Details

If you have a query regarding your online booking, encountered any problems whilst making your booking, have queries, concerns or complaints regarding your privacy or queries regarding this privacy statement please contact us.

Updates and Changes

As our privacy statement may change due to developments in the law we encourage you to re-read this from time to time so you are aware of any changes in how we gather and use your personal information. Any changes to this Policy will be either posted on our website, brochure and/or made available on request.