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1.1 References to “We”, “Us”, or “Our” in this privacy notice, mean the following data controllers, who determine how (and for what purposes) your personal data is used:
(a) SP Cruises OpCo Limited and SP Vessel Buyer LLC when:
(i) You use Our websites and mobile applications outside of the European Economic Area (EEA) and/or outside of the United Kingdom (UK);
(ii) You call one of Our call centers which is based outside of the EEA or UK;
(iii) Your data is processed on our vessels; and
(iv) You book a cruise through one of our entities which is based outside the EEA and the UK;
(b) SP Cruises Ireland Limited and SP Vessel Buyer LLC when:
(i) You use Our websites and mobile applications in the European Economic Area (EEA) and/or in of the United Kingdom (UK);
(ii) You call one of Our call centers which is based in the EEA or UK; and
(iii) You book a cruise through one of our entities which is based in the EEA and the UK.
For any privacy matters or concerns, all of the companies referenced above can be contacted by email at Azamara Integrity Hotline
2.1 Your privacy is very important to Us and We want to be open with you about how We use your personal data – that is the information that identifies you as an individual – to make sure that you have the best possible cruise experience. In this privacy notice We explain:
(a) what information We collect about you;
(b) what We may do with it; and
(c) what your rights are.
2.2 We want you to understand how We use your personal data, how We keep it safe and what your rights are. Summarized below are the main circumstances in which We use Your personal data:
(a) We collect your personal data when you use Our websites, mobile application(s), other digital platforms (together, “Digital Platforms”), or call Our call centers. For example, We collect:
(b) We use your personal data to understand what you might be interested in and to make Our emails, texts, social or digital media, and offers relevant to you – We build a profile of your travel patterns and interests to do this.
(c) We need to use your personal data to deliver your onboard experience – When you book with Us, We need your personal data to deliver your cruise vacation. We also process your personal data for customer services purposes and when required by law.
(d) To provide Our services to you, We may need to share your personal data with and receive personal data about you from:
4.1 As a data controller, We are responsible for the personal data you provide to Us and will only share such personal data with the Azamara Group and Our Suppliers and Business Partners if We have a legitimate reason permitted by law, such as your consent.
5.1 The following are examples of the categories of your personal data that We process alongside information on how and/or when We get that personal data:
Personal, contact, ID and payment details - Your full name and contact details (first name, middle name, last name, nickname, suffix, email address, phone number, postal address, country of residence, emergency contact details), age, date of birth, gender, passport details, photograph, video footage (including CCTV footage), job title, visa details, dietary requirements, nationality, marital status, country of birth, payment card details and any publicly available content on social media platforms.
You provide some of these details to Us if you book a cruise, sign up to receive Our emails, join Our loyalty programs, use Our Digital Platforms or interact with Our social media accounts (including by entering competitions).
You might also provide these details to Us if you contact one of Our call centers. Where you book with a travel partner, We may receive these details from the travel partner. If another person books a cruise or contacts Us on your behalf, We will receive these details from them. We may also receive video footage of you from the CCTV cameras onboard Our ships.
Sensitive personal data - We may collect details relating to your health or medical conditions, including but not limited to pathogen test results, vaccination status and vaccination certificates, details of any accessibility requirements, allergies or other health-related requests. We also may collect details of your meal preferences which may tell Us about allergies or other dietary requirements, or potentially indicate your religion or beliefs.
You provide some of these details to Us if you tell Us about medical conditions when you book with Us, check in for your cruise, when your temperature is taken onboard or in port, when you visit a testing center provided by Us or one of our Suppliers, request guest access or other accessibility services, visit one of Our medical facilities in port or onboard and/or sign up to a shore excursion, tour or entertainment onboard a cruise.
You might also provide these details to Us if you contact one of Our call centers. Where you book with a travel partner, We may receive these details from the travel partner. If another person books a cruise or contacts Us on your behalf, We may receive these details from them.
Your photograph and your image - We may collect a facial photograph of you before your cruise or during your cruise.
We use your image for safety and security purposes, as described in 6(2)(c) below and when we need to conduct contact tracing as described in 6(2)(d) below.
Loyalty account details - a unique ID for your loyalty account, points balance, account activity, life milestones (e.g., anniversary date), and loyalty tier.
We create these details for you when you join one of Our loyalty programs and update them as you credit bookings and other activity to your loyalty account.
Booking records - Details of past and future bookings with Us (including booking ID, cruise type, date of cruise, ship, passengers on your booking, destination, duration, price paid, cabin information and the date of booking) and bookings with Our Suppliers (including flight dates, flight number, airport destination, airline and frequent flyer ID).
We compile this personal data from Our records when you book with Us. We also receive this personal data from Our Suppliers if you book with them.
Details about your travel patterns and preferences - The destinations that you travel to with Us, the length and the type of your vacation with Us including whether you travel with household members (e.g., family vacations), your propensity to book certain types of vacations or destinations or to re-book with Us within a specific timeframe and the marketing segments that We add you to.
We compile this information from your booking records and Our profiling and personalized marketing activities, which may include details that we receive from Suppliers – see "Profiling and personalized marketing" below
Your marketing and data processing preferences - Whether you want to receive marketing communications from Us and how you would like Us to contact you.
We keep a record of your marketing preferences when you tell Us about these, including the options you select in your guest account.
Technical information related to use of Our Digital Platforms - Details about the browser, device and internet connection that you use when you browse Our Digital Platforms, technical information, including your IP address, MAC address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. For example, Our Digital Platforms can tell whether you are using a mobile phone or a desktop computer.
Your device provides this information when you use Our Digital Platforms whether or not you are signed into your account or have accepted cookies.
Cookies- Our Digital Platforms store small text files on your device that identify your browser. See Cookies and other tracking technologies below for more details.
When you visit Our Digital Platforms and use Our services, we use your details to identify you (e.g., where you book a cruise, sign into your account, where you want Us to identify you as a member of Our loyalty programs and where We need to remember your preferences). Cookies can also be set when you open Our emails.
Information about your interactions with Our websites - As well as the technical information above, We collect information about your visits to Our websites, including the full web addresses that you access, your path of clicks, through and from Our site (including date and time and whether you used a search engine), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Our customer service number.
When you browse Our websites.
Information about your interactions with Our emails - We use elements embedded in Our emails (e.g., images and clear images) that let Us know whether you have opened or read an email. If you follow links in Our emails, We may also set cookies on your system if you have enabled cookies. This information also tells Us about your propensity to engage with Our emails.
When you open and interact with email that We have sent you (unless you have opted out), We compile information about how you interact with Our emails from Our profiling and personalized marketing activities – see "Profiling and personalized marketing" below.
Information about the purchases you make onboard - We collect information about your purchases along with the loyalty number and transaction information to enable you to purchase products and/or activities as well as to obtain loyalty benefits. We may also use this information to identify whether you have been in close contact with another individual onboard for contact tracing purposes.
If you make purchases with Us prior to or during your cruise, We collect these details at the point of payment including through Our Digital Platforms, call center or from your KeyCard (if the purchase is made onboard).
Information relating to third party promotions and offers - We work with Our Business Partners so that you are able to use promotions and offers. To enable you to use these offers and promotions, We verify your details against those provided by Our Business Partners (such as the voucher number and expiration date).
We receive these details from Our Business Partners if you have opted to receive promotions from them.
6.1 This section explains how We use the personal data listed above and who We share it with.
6.2 We use your personal data:
(a) To manage your bookings with Us and to provide the services or membership benefits that you request before, during and after your cruise
We need to use your personal data to deliver Our services to you when you book a cruise. For example, when you travel with Us We need your personal data to send you a booking confirmation, to manage changes to your booking, to check you in when you board Our ships and to keep track of you onboard, to deliver your benefits for Our loyalty programs, to provide you with further products and services onboard (for example when you book shore excursions, tours or onboard entertainment and when you make purchases in Our shops and restaurants).
(b) To help you contact Our customer support services
When you get in touch with Our customer support services (whether through the Digital Platforms or otherwise), We will process your personal information so that you receive the best customer service possible.
(c) For your safety
Your safety is important to Us, and We use your details to safeguard it. For example, We transfer a record of the personal data you provide during the booking process onto your cruise ship for use if you require medical assistance. Additionally, We check booking details against law enforcement registers and Our internal records for the safety of all customers. We also use closed-circuit television ("CCTV") cameras onboard Our ships, and We may match images against the photograph We have of you if We need to identify you. We may equip Our security staff with body cameras for your safety. If circumstances allow, We will notify you before We begin recording with a body camera.
(d) To protect your health and the health of all guests and crew onboard
We have processes in place to protect you and everyone onboard against the spread of certain transmissible illnesses. We may ask you to provide information about your current state of health to ensure that you are well enough to sail. We may conduct temperature checks before boarding, onboard and at ports of call. We may require that you undertake a test and/or medical examination to identify if you have Covid-19 or another transmissible illness, either before sailing and/or during your cruise. We may use CCTV footage and information about your purchases onboard to help us to identify if you have been in close contact with another individual for contact tracing purposes.
(e) To make Our Digital Platforms easy to use and enhance your cruise-planning experience
The personal data We collect when you use Our Digital Platforms helps Us to make sure that Our Digital Platforms work well (for example, so that We know it is you when you sign into your account). We’re often improving Our Digital Platforms and content therein to enhance your cruise-planning experience, and data about how you use Our site helps Us to do that. We also use this data to help Us understand interest in the different sections of Our Digital Platforms and the products and services that We sell online. We also use your data to make the cruise booking process more convenient. For example, We can remember what you have searched for so you can pick up where you left off. We also use your information to fix operational problems with the Digital Platforms such as software bugs and to maintain the safety and security of the Digital Platforms.
(f) To manage your relationship with Us as a consumer and to deliver personalized service
When you sign up via Our Digital Platforms or make a booking, We create a consumer profile of you in Our systems. This is your digital profile that brings the personal data that We maintain and identifies you across the Azamara Group. Your consumer profile lets Us deliver a personalized experience when you search for cruises, book and travel with Us or contact Us by phone or email. We also use your consumer profile to personalize the marketing communications that We send you. We also sometimes use your details to ask for feedback on Our services.
(g) To process payments and invoicing
When you make a purchase through the Digital Platforms (whether in relation to a cruise or certain products or services such as shore excursions), We will process your payment details to process the transaction.
(h) For marketing and promotional purposes
We use your contact details for Our marketing and promotions, including to send you information about the products and services that We and the Azamara Group offer. We also use your personal data to personalize Our marketing communications to make them more relevant for you and to measure engagement with Our marketing campaigns. See Direct Marketing and Profiling and personalized marketing below for more information, including on how to update your preferences and opt out.
(i) For compliance with Our legal and regulatory obligations
We are sometimes subject to certain legal requirements to collect, retain, and disclose your personal data, for example for customs agencies or port authorities to allow Our ships to dock, or where We need to cooperate with law enforcement agencies, including in relation to criminal investigations and information relating to your health. Pursuant to the United States’ Stored Communications Act (the SCA), We may be considered a provider of electronic communication services for certain services We offer through the Digital Platforms (because We provide users of the Digital Platforms the ability to send or receive wire or electronic communications). In such instances, We will not turn over records or other information pertaining to you unless compelled by a Court of competent jurisdiction pursuant to the provisions of the SCA.
(j) For Our business operations
We may use your personal data for business management activities, including to assist with incident management and to enable Us to conduct reporting. Reports help Us to monitor Our performance and the performance of Our Suppliers. Additionally, We keep records to assist with any complaints you may have or in the event of a legal claim. We also process your feedback to improve Our products and services.
6.3 We may share your personal data with the following recipients for the purposes listed above:
(a) Other members of the Azamara Group
We are a global business and We may need to share your personal data with other members of the Azamara Group for the purposes above.
(b) Travel agents and Our international partners
(c) Our suppliers
We use products and services from Our Suppliers in the operation of Our business. For example, We use travel booking systems to provide flight availability and cost details, and to book flights if required by you in connection with your cruise.
(d) Our Business Partners
We partner with companies, such as tour operators, to complement the products and services that We provide to you. We only do this in compliance with applicable law.
(e) Ports, customs and other government authorities, law enforcement agencies, courts, and parties to litigation
We may need to share your personal data where required under the laws of countries in which We operate. Local ports and customs authorities require passenger details to process Our ships in the ports at which they call. Law enforcement agencies may also require access to personal data, including in connection with criminal investigations and medical information relating to transmissible illnesses, or We may be ordered to disclose personal data by a court or in connection with legal proceedings. We may also share your personal data with other third parties such as trade associations and regulatory bodies, for consumer protection purposes in the event We or our partners cannot fulfil the contracted travel services. In the event We do share such data, the trade association and/or regulatory body may contact you to discuss your options and/or provide support.
(f) Port authorities, health authorities and health care providers
We may share your details with port and health authorities and health care providers to ensure that you receive medical attention as may be required on arrival into port.
(g) Other third parties
We may share your personal data with other third parties at your request. Our Digital Platforms may provide links to websites or other digital tools that We believe may be useful to you in addition to advertisements placed by third parties. These may lead you to websites or digital tools operated by third parties operating under their own privacy policies. We encourage you to review those privacy policies, as We have no control over those third parties nor the information you may submit to those third parties.
7.1 In certain circumstances, We may re-route calls among Our call centers which are located in the United States, Australia and elsewhere in the world. See International transfers below for more details about how We safeguard your personal data when We transfer it abroad.
8.1 Marketing communications from Us - We may contact you for marketing purposes, including to tell you more about Our services, share news or tell you about promotions from time to time. You are in control of the emails and texts that you receive, and you can update your preferences or opt out at any time via your Guest Account, following the links in Our emails or by contacting Us using the details provided below. Even if you have opted out of marketing messages, We will still need to contact you in relation to your bookings with Us.
8.2 Marketing communications from other members of the Azamara Group – Some of the services and activities provided onboard Our ships are managed by other members of the Azamara Group. These members may contact you about those services and activities if you have opted-in to receive marketing communications from the Azamara Group or where permitted by applicable law. You can opt out at any time using the same options above.
9.1 Profiling overview: We think it is important for Us to understand the types of vacations that Our consumers are interested in so that We can make Our marketing relevant and targeted. To do this, We use your personal data to build a profile for you that lets Us work out which of Our cruise voyages would be the best fit for you.
9.2 The personal data We use: From the personal data that We hold about you, which includes the personal data We receive from Our Suppliers and Our Business Partners, Our model may consider your age, gender, household or travel composition, postcode, how you have interacted with Our websites and marketing emails and your booking history (including your destinations, the ships you have sailed on and your chosen accommodation). We do not always use all of these data categories if We do not have the information about you or it is not relevant for Our marketing activities.
9.3 How We build your profile and what We learn from it:
(a) Statistical analysis. We use the data above as inputs for a statistical model, the output of which can tell Us about your previous or likely future booking behavior and help us to identify individuals who would likely have similar preferences, for example, (i) the value or likely value of the bookings you make with Us; (ii) the purchases you make to complement your cruise such as shore excursions; (iii) the timeframe during which you tend to rebook a cruise and the destinations that you tend to book; and (iv) the extent to which you engage with Our marketing emails.
(b) Marketing segments. We try to match every consumer with one or more pre-defined segments that allow Us to broadly tailor Our marketing messages for the right audience. We define Our segments using anonymized demographic data based on broad characteristics and behaviors such as age, household income, or location. You will share a segment with other consumers, so this process is generally not highly individualized.
9.4 Here’s an example: Let’s say you have just signed up on Our websites (giving Us your contact details) and you have never booked a cruise before. Over the next few days you search for cruises that are generally popular with families (giving Us website interaction data). We might use that data to add you to one of Our family segments so that you get relevant emails from Us.
9.5 What this means for you: Tailoring Our marketing campaigns to your profile or segment means you should receive more relevant communications from Us. That’s good for Us because We think you are more likely to book a vacation that matches your requirements. We hope that’s good for you, too, because it helps you to find the vacations that you are interested in. We might also send you special offers on your birthday.
9.6 Targeted advertising on third party social media platforms and websites: We may share your personal data – including your name, email address, address and date of birth – with third party social media platforms, including Facebook, and websites for the purposes of allowing those platforms to display targeted advertisements to you. You can ask Us not to share your personal data with platforms, but you will need to contact the platform with any requests in relation to how the platform uses your personal data because We do not control that. For more information about the use of personal data through social media fan pages, please see the Social Media Fan Page Notice in Section III of this privacy notice.
9.7 You can opt out: You are in control of your personal data. You can update your marketing preferences or opt out of personalized marketing at any time using your Guest Account or, where you do not have a Guest Account, by either clicking a link in an email marketing communication, replying STOP to an SMS text message or by calling the sender of any marketing communication.
11.1. We retain your personal data only for as long as necessary: (i) for the purposes set out in this privacy notice; (ii) to provide Our products and services to you; (iii) to comply with Our legal obligations (e.g., to comply with tax or accounting rules or in connection with legal proceedings); or (iv) to comply with Our usual business data retention policies.
12.1 If you give Us information about another person (or persons), such as another guest, We will understand this to mean that they have appointed and authorized you to act on their behalf. This includes providing consent (to the extent this is required) to:
(a) Us processing their personal data; and
(b) you receiving any information protection notices on their behalf. We may ask you to provide evidence that you have been appointed and authorized to act on behalf of the other person (or persons).
13.1 If you make a multi-guest reservation, all of the guests who are part of the reservation will be able to access the personal data of the other guests on Our Digital Platforms.
13.2 Our Digital Platforms will allow your reservation, as well as your personal data therein, to be associated to another user's guest account provided you have furnished certain credentials or unique identifiers to them. We call this "linking”. If your reservation is linked by another user of Our Digital Platforms, We will allow the user who has linked your account to (1) complete online check-in for you and others in your reservation; (2) view your boarding pass, and the boarding pass of others in your reservation; (3) pay for an onboard or shore product or activity for you or others in your reservation, using their own onboard expense account or their own payment methods; and (4) view eDocs associated to your reservation. However, they will not be able to modify or cancel your reservation, view your folio or use a digital key to access your stateroom.
14.1 Our Digital Platforms seek to promote Our cruise vacations for sale to adults. We do not knowingly solicit personal data from children, unless permitted by applicable law. If a parent or guardian becomes aware that his or her child has provided Us with information without their consent, he or she should contact Us using the contact details below. We will delete such information from Our files.
15.1 Certain States within the United States have enacted laws, including the California Consumer Privacy Act, that require Us to disclose to you whether We sell your personal data to certain third parties or otherwise disclose your personal data to third parties for the third party’s commercial use, as this concept is defined in the respective laws.
We choose Our Suppliers and Business Partners carefully and put in place safeguards to help protect your personal data, including, but not limited to, written agreements. As such, and as of the date of this privacy notice, We do not sell or disclose your personal data in this manner.
Please note, terms in this privacy notice that are defined in these laws shall not be construed as having the definitions and legal significance set forth in these laws.
16.1 Generally. You can use your guest account to update your direct marketing preferences or opt out of profiling and personalized marketing.
16.2 California Consumer Privacy Act (“CCPA”). This sub-section applies to you if you are a California consumer, as that term is defined in the CCPA.
(a) General Notices. See paragraphs 5 and 6, above, regarding the categories of personal data We may collect and the purposes for which We may use that personal data. Certain programs and activities we solicit you to participate in may be construed as offering a financial incentive for sharing your personal data with Us. Your participation is voluntary and is subject to any applicable terms and conditions.
(b) Your Rights. You have the right to ask Us to:
16.3 We do not discriminate, as that term is defined in the CCPA, against anyone lawfully exercising their rights under the CCPA. Please submit your requests to us by email at Azamara Integrity Hotline
17.1 This privacy notice may be updated from time to time for any reason. Updates to Our privacy notice will be posted to the Digital Platforms.
17.2 In the event We are involved in a merger, acquisition, or sale of all or a portion of Our assets, you will be notified via email and/or in a prominent notice on Our Digital Platforms of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
18.1 If you require other information about any part of this notice, you can contact Our Data Protection Officer submitting a request by email to Azamara Integrity Hotline
This section applies to you if:
(a) you use Our Digital Platforms while in the EEA or in the UK;
(b) you buy your cruise ticket from one of Our entities which is based in the EEA or in the UK including SP Cruises Ireland Limited; or
(c) your personal data is processed on one of Our ships.
1.1 Legal basis – We only process your personal data to the extent that at least one of the following applies:
(a) you have consented to the processing of your personal data for a specific purpose – We process your sensitive personal data and send you electronic direct marketing communications based on your consent for Us to do that;
(b) the processing is necessary for Us to perform Our contract with you (e.g., to provide your cruise) or for use to take steps at your request before We enter into the contract;
(c) where We need to process your personal data to comply with a legal obligation that We are subject to;
(d) where We need to process your personal data to protect your vital interests (or somebody else’s), including where you are physically or legally incapable of giving consent, for example in case of a medical emergency;
(e) the processing is necessary for Us to establish, exercise or defend a legal claim; or
(f) the processing is necessary for the purposes of Our legitimate interests or a third party’s legitimate interests.
1.2 Legitimate interests - We rely on several legitimate interests for using and sharing your personal data, including:
(a) improving Our products and services;
(b) understanding how customers travel with Us;
(c) marketing and promotional activities;
(d) identifying and pursuing new ways to develop and grow Our business; and
(e) ensuring the security and safety of Our guests and employees.
2.1 We are a global business and as such We may need to share your personal data with other members of the Azamara Group for the purposes as outlined in this privacy notice. This means that We may transfer your personal data outside of the EEA or in the UK (including to the United States as this is where the servers that We use for Our business and on which your personal data is stored are located). Sometimes transferring your personal data outside the EEA or the UK will be necessary for Us to perform Our contract with you (e.g., to provide your cruise). We use the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your personal data that is transferred outside the EEA or the UK so you can rest assured that the Azamara Group seeks to adhere to the strict European and UK standards of data security and usage.
3.1 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
3.2 Requests shall only be made to Our Data Privacy Officer. To submit any such request, please send an email to firstname.lastname@example.org
3.3 You also have the right to make a complaint about how We process your personal data to your data protection supervisory authority.
3.4 Where you have specifically consented to Our use of your personal data, you have the right to withdraw that consent at any time. To do so, please send an email to Azamara Integrity Hotline
Schedule 1 – Social Media Pages
SP Cruises OpCo Limited
Facebook Azamara Reminiscing Group
Facebook Azamara Travel Partner Group
Twitter Brand Page
Facebook Consumer Page
Facebook Travel Agents Page
Facebook Travel Agents Group
Instagram Travel Agents Page
YouTube Training Videos
SP Cruises Ireland Ltd
Effective Date: July 29, 2022
(ii) You call one of Our call centres which is based outside of the EEA or UK;
(ii) You call one of Our call centres which is based in the EEA or UK; and
(f) To manage your relationship with Us as a consumer and to deliver personalised service
7.1 In certain circumstances, We may re-route calls among Our call centres which are located in the United States, Australia and elsewhere in the world. See International transfers below for more details about how We safeguard your personal data when We transfer it abroad.