Privacy Policy

SixStarCruises respects your privacy and is committed to protecting your personal data.

This Privacy Policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Any reference to "we", "us" or "SixStarCruises" means WTH (UK) Ltd (or where applicable, our group companies including all subsidiary brands in the WTH (UK) Ltd group) (registered company number 06532160) Our registered office address is at 110A & 112 - 114 Market Street | Chorley | Lancashire | PR7 2SL.

This Privacy Policy sets out the basis on which we collect information from you and how we use the information we collect or which you provide. This includes information which we collect or that you provide manually or via SixStarCruises or via other online services and platforms (together, our "Site").

If you have any questions regarding how we use your information or you wish to exercise any of your rights in relation to your information (as set out in paragraph 9 below), please contact dataprotectionssc@sixstarcruises.co.uk

Our Site may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

You may give us information about you when you do any of the following:

• contact us by phone or by using our ‘Request a call back’ facility by providing your telephone number or by sending us a text message;
• use our ‘live chat’ facility to speak to one of our customer service advisors;
• sign up to receive our various newsletters by email;
• enquire about a cruise holiday e.g. obtain a quote for a cruise holiday by providing us with your email address and information about the date, duration and cruise line of the holiday of interest;
• make a holiday booking;
• by initiating, and/or completing and online booking
• make a booking for associated services e.g. excursions, airport transfers
• apply for a job with us, including submitting an online job application (and/or your CV); and
• consent to be notified of products and/or services that may be of interest to you (based on your purchase history or browsing of our Site).

If you want to use any of these services, you may need to provide us with some additional personal information so that we can liaise with you in order to deal with your request. If you do choose to provide us with your personal information, we will collect that information for our own use and for the purposes described in this Policy.

What type of personal information do we collect?

When you provide personal details to us, we may collect the following personal information from you:

• your full name and date of birth;
• your contact details e.g. address, telephone numbers (including your mobile telephone number) and e-mail address;
• Passenger names and dates of birth
• if you create a “manage my booking account” account - your username and password
• if you make a holiday enquiry and/or booking - financial account information, such as credit/debit card number and other payment information; and contact information which may include your home or work address and telephone number;
• if you submit a job application to us - your employment history, qualifications, references and other relevant employment details you choose to submit to us as part of any job application; and - any personal data such as your date of birth and national insurance number (and which may also include sensitive personal data) which is contained within your CV and/or other supporting documentation provided with (or instead of) your job application form;
• information necessary for legal compliance;
• your social media content (where this is in the public domain), including when you “like” us or make posts on our pages on social networking websites, such as Facebook, Twitter, YouTube and Instagram, and any messages you send us via social media. This information can include posts, comments, pictures and video footage;
• voice recordings for training and monitoring;
• IP (Internet Protocol) address: your IP address indicates your location, unless you are using a VPN service;
• MAC (Media Access Control) address: is a unique identifier, or address, assigned by the manufacturer of your device;
• Device: what type of device you are using (TV, smartphone, laptop, desktop);
• OS (Operation system): what operating system your device has (IOS, Android, Windows, Linux, MAC OS X);
• Browser & browser version: which web browser you are using (Internet Explorer/Edge, Opera, Chrome, Safari, Firefox);
• Domain: depending on your device and browser settings, we sometimes identify the web address of the domain you came from before landing on our website;
• Clickstream data: this is a list of all the web pages that you visited, and the order you viewed them in, on each visit to www.sixstarcruises.co.uk or our Sites. We also record how much time you spend on each web page, and record any actions you make on each page; and/or
• Cookies: these are small text files that our website places on your device, so that our website can remember something about you at a later time. For more information on the specific cookies that we use and their function, please see our Cookie Policyhere.

This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals who you have indicated have agreed for you to provide their personal information e.g. holiday providers, government, tax or law enforcement agencies and other third parties. We may also collect personal information about you from your use of other Company or Group websites or services.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your data by filling in forms or by corresponding with us by post, phone, email or in person or by uploading information to our app or websites, or via third party software providers we use. This includes personal data you provide when you:
• Initiating an online booking on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our Site, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.Please see our Cookie Policy here.
• Obtaining technical data from the following parties:
• analytics providers in the EU;
• advertising networks in the EU; and
• search information providers in the EU.

4. How we use your personal data

Making a Cruise Holiday Enquiry

When you make an enquiry for a cruise holiday enquiry, we will need to collect your contact details (this may include your name, email address, telephone numbers). We will use these details to communicate cruise holiday options to you.

Our Cruise Concierge will use this information to provide the best cruise options available and get in touch usually via telephone, email, text message, social media and/or post. If you decide to use the call back option on our website, your details will be shared with the company who provide this service and allow a Cruise Concierge to get in touch with you. We also record any calls you make to us, or when we call you, to training and quality purposes.

If at any point you want us to stop communicating cruise holiday options to you, you can inform your Cruise Concierge and they will not contact you further.

Making a Cruise Holiday Booking

When making a cruise holiday booking through us, we will need to collect information in order to provide the holiday you ask us to book. As a cruise holiday retailer, this will require us to pass on information to the holiday provider to enable them to fulfil your holiday. The holiday providers we select are required to adhere to all current data protection regulations in protecting your privacy and the security of that data.

We will collect the following data to provide the holiday you ask us to book:

• Passenger Names
• Passenger Dates of Birth
• Contact details of the Lead Passenger (or contact details of the person making the booking if not travelling) which will include postal address, email address and phone number

Some holiday providers may also require us to provide additional details, such as passenger passport information. They may also require travel insurance information relating to the holiday in question and next of kin contact to be used only in the event of an emergency.

Subject to your personal requirements, we may also need to collect and pass to the holiday provider information relating to your medical and dietary needs.

If you do not agree to us collecting this data, we will be unable to accept your booking.

Payment Partners: your information is shared to process payments for your holiday. Our payment partner uses internet standard encryption technology, Secure Socket Layer (SSL) which encodes your credit and debit card details before it is sent.

After you have booked

In order to provide a professional service to you and keep you informed about your booking, we will need to contact you by phone, by email or by letter. Typical reasons are to:

• Tell you what to expect in the lead up to your holiday
• Send your holiday provider’s confirmation invoice to you
• Notify you of any changes to your holiday
• Provide opportunities to enhance your holiday
• Send your holiday tickets and documentation to you

Marketing

Subject to your consent, or under the basis of Legitimate Interests, where required under applicable laws we may use your data to:

• to carry out direct marketing and/or e-mail marketing on behalf of SixStarCruises or other brands within the WTH(UK) Ltd Group;
• to respond to any social media posts or other public comments you make which relate to us;
• for compliance with legal, regulatory and other good governance obligations; and
• to improve and measure the effectiveness of our marketing communications, including online advertising. We also share cookie and other data with entities such as Google and Facebook in order to make our advertising more relevant to you. We require any such third parties to treat your personal information as fully confidential and to fully comply with all applicable data protection legislation.

Recruitment

To evaluate any job application(s) you choose to submit to us and for the administration of the recruitment process following receipt of your application (where your application is successful);

5. Disclosure of your personal data

We only share your information where we can do so in accordance with our legal data protection and privacy obligations. We share the information we collect with:

• Our group companies in order to offer you a wider range of related services.
• Suppliers and sub-contractors for the performance of contracts and marketing services including research.
• People and businesses who help us provide our Site and related services to you, for example, information technology companies who host and/or maintain our Site and payment services companies who enable you to use payment cards with us.
• Our insurers and insurance brokers where required in order for us to be able to obtain insurance against risks we face in running our business. They may retain this information for the purpose of ongoing risk assessment and insurance broking and underwriting services.
• Our auditors, professional advisers, compliance managers, government, law enforcement or regulatory authorities in order to fulfil our legal, statutory and regulatory obligations or as required for tax purposes.
• Our registrars in order to administer our share register, employee share plans, dividend payments, voting, elections, annual report correspondence and identifying relevant products and services.

6. International transfers

In providing services to you, we sometimes transfer your information to other countries. This is because the information may be processed in those other locations by the Holiday Provider. Where we transfer your information outside the U.K, we ensure that all data is treated with the same security measures regardless of location, and in accordance with our standards, policies, regulatory and legal obligations. In all cases where we transfer information across borders, we rely on acceptable and defined legal mechanisms to ensure that we protect data at all times.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, taxation or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You can request details of retention periods for specific aspects of your personal data by contacting us at dataprotectionssc@sixstarcruises.co.uk

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your rights and managing your information

Your rights are summarised below and we will adhere to these. However, we reserve the right not to comply with any requests we receive where we may lawfully do so, for example if we reasonably believe a request to be malicious or vexatious, technically very onerous, will involve disproportionate effort or could be to the detriment of the rights of others, or if we cannot satisfy ourselves as to your identity. In order to protect the person who is the subject of the access request, we will ask you to prove your identity before providing any information.

a) Asking us about your information You have the right to ask us whether we hold information about you and, if so, for us to give you certain details about that information and/or the information itself. This right is commonly known as a ‘subject access request’. If you would like to make a subject access request, you can do so by contacting us by email at dataprotectionssc@sixstarcruises.co.uk

b) Correcting inaccurate information If you consider that any of the information we collect on you may be inaccurate or incomplete, and you cannot correct such inaccuracy or omission yourself through your account with us, please contact us with your queries and/or with the updated information.

c) Erasing information You have the right to ask us to erase your information in the following circumstances:

• the information is no longer necessary for the purposes for which we collected it;
• we need your consent to use the information and you withdraw such consent;
• you object to us using your information (a) for the performance of a task carried out in the public interest; or (b) for the purposes of our legitimate interests (e.g. direct marketing) and there are no overriding legitimate grounds for the processing;
• you unsubscribe from our marketing communications;
• we have used your information unlawfully; or
• deletion of the information is required to comply with a legal obligation applicable to us.

d) Restricting processing You have the right to require us to restrict our use of your information where one of the following applies:

• while we verify the accuracy of the information that we hold about you where you contest the accuracy of the same;
• we have used your information unlawfully, but you request us to restrict its use instead of deleting it;
• we no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
• while we verify that our legitimate grounds override your right to object where you have objected to us using your information.

e) Right to object If we are using your information on the basis of public interest or our legitimate interests, you may object to this at any time by contacting us as set out below.

f) Withdrawal of consent If you have consented to us using your information (e.g. for marketing purposes), you have the right to alter your preferences or withdraw this consent by contacting us as set out below or by speaking to a cruise concierge or by clicking the unsubscribe link in any email communication. This will not affect the lawfulness of any use of your information that we make before you amend your preferences or withdraw your consent.

g) The right to lodge a complaint with a supervisory authority If we are unable to resolve your complaint to your satisfaction you also have the right to complain to a relevant supervisory authority which includes;

The Information Commissioners Office; Wycliffe House, Water Lane, Wilmslow, SK9 5AF or online at https://ico.org.uk/make-a-complaint/

You can contact us with any queries about how we use your information by contacting dataprotectionssc@sixstarcruises.co.uk