Notice of Data Transfer in Connection with Azamara Acquisition
SECTION 1: Section for Global Application
1. Who We are
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) Royal Caribbean Cruises Ltd., 1050 Caribbean Way, Miami, Florida 33132, USA if:
(i) you use Our websites, mobile application(s), or shipboard kiosks outside of the European Economic Area (EEA);
(ii) you call one of Our call centers which is based outside of the EEA;
(iii) your personal data is processed on Our Royal Caribbean International or Azamara Club Cruises vessels; or
(iv) you book a cruise through an entity based outside of the EEA;
(b) Celebrity Cruises Inc.,1050 Caribbean Way, Miami, FL 33132, USA if:
(i) you use Our Websites, mobile application(s), or shipboard kiosks outside of the EEA;
(ii) you call one of Our call centers which is based outside of the EEA;
(iii) your personal data is processed on Our Celebrity vessels; or
(iv) you book a cruise through an entity based outside of the EEA; or
(c) RCL Cruises Ltd., Building 3, The Heights, Brooklands, Weybridge, Surrey KT13 0NY, UK if:
(i) you use Our websites inside the EEA, Australia, and New Zealand;
(ii) you call Our call centers based in the EEA; or
(iii) you book a cruise through an entity based inside of the EEA.
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:
- your contact details and other personal information (which may sometimes include sensitive personal data, such as special needs and dietary requirements);
- details about your bookings and how you travel with Us;
- your travel profile and marketing preferences; and
- information on how you use Our Digital Platforms and interact with Our emails.
(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 give you the best possible onboard experience – When you book with Us, We need your personal data to deliver a great cruise vacation. We also process your personal data for customer service purposes and where 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:
(i) Our global brands (Royal Caribbean International, Celebrity Cruises, and Azamara Club Cruises) and Our affiliates and subsidiaries (hereinafter the “Royal Caribbean Group”); and (ii) Our Suppliers around the world.
(ii) Our Suppliers around the world. When We say "Suppliers" in this privacy notice, We mean the parties who provide Us with products and services that enable Us to run Our business. This includes third parties who help Us to deliver your cruise vacation, such as transport and accommodation vendors, media vendors, port agents, and who assist Us to run Our business, such as accountants, consultants, payment providers, auditors, IT service and platform providers, insurance providers, and legal advisers (together, Our “Suppliers”). We choose Our Suppliers carefully and put in place safeguards to help protect your personal data; and
(iii) Our Business Partners When We refer to "Business Partners" We mean companies with whom We have partnered to complement the products and services We provide to you, such as tour operators.
- Who's responsible for your personal data?
- What personal data do We collect or receive?
- How We use your personal data and who We share it with
- Direct marketing
- Profiling and personalised marketing
- Cookies and other tracking technologies
- International transfers of personal data
- Legal basis for Our use of your personal and legitimate interests
- Data retention
- Your rights
- Contact Us and complaints
#4. Who’s responsible for your personal data?
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 Royal Caribbean Group and Our Suppliers and Business Partners if We have a legitimate reason permitted by law, such as your consent.
#5. What personal data do We collect or receive?
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:
|Categories of personal data||When/how we get it|
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 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, request guest access or other accessibility services, visit one of Our medical facilities during a cruise 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. If We have your consent to do so, We use the photo you provide to identify you during the embarkation process, to make boarding quicker, and We may allow Our Business Partners to access this data to verify your identify (e.g. where you request that Our onboard photographers prepare and send to you photos of you and those people you are travelling with).
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 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 personalised marketing activities – see "Profiling and personalised 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 website - 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 Platform 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 that means We need 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 website - 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 personalised 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.
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 SeaPass (if the purchase is made onboard).
Details relating to your use of on board casinos We track details of your play and spend in onboard casinos (including offer codes, your customer ID, spend, loyalty rewards details and gaming habits). We sometimes use these details to identify guests that may be interested in casino gaming.
If you choose to use casinos onboard during your cruise, We collect these details when you play, including when you use your SeaPass card when you play. If you apply for credit for use at Our onboard casino, We will receive credit related information from Our credit check service provider.
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. How We use your personal data and who we share it with
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, restaurants, and casinos).
(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. With your consent to do so, we compare any photo you provide before your cruise with images taken during embarkation to help identify you and to speed up the boarding process for you. 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 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 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.
(e) 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 Royal Caribbean 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.
(f) 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.
(g) 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 Royal Caribbean 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.
We use personal data for additional marketing and promotional activities relating to onboard casinos by tracking guest play to: (i) deliver related loyalty program benefits; (ii) rank players; (iii) send casino-related direct marketing messages; (iv) grant credit to groups playing casinos; and (v) better understand how players use the onboard casinos.
(h) For compliance with Our legal 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. 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 to do so by a Court of competent jurisdiction pursuant to the provisions of the SCA.
(i) 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 Royal Caribbean Group
We are a global business and We may need to share your personal data with other members of the Royal Caribbean 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, or We may be ordered to disclose personal data by a court or in connection with legal proceedings.
(f) 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. Calling Our call centers
7.1 In certain circumstances, We may re-route calls from Our call centers which are based inside the EEA to call centers based outside of the EEA. In these circumstances, We will let you know at the beginning of your call that your call is being rerouted. See International transfers below for more details about how We safeguard your personal data when We transfer it abroad.
#8. Direct marketing
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 Royal Caribbean Group– Some of the services and activities provided onboard Our ships are managed by other members of the Royal Caribbean Group. These members may contact you about those services and activities – including information and promotions relating to onboard casinos – if you have opted-in to receive marketing communications from the Royal Caribbean Group or where permitted by applicable law. You can opt out at any time using the same options above.
#9. Profiling and personalised marketing
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 marketing segments is 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 proprietary statistical model, the output of which can tell Us about your previous or likely future booking behavior, for example:
- (i) the value or likely value of the bookings you make with Us;
- (ii) whether you tend to re-book within 12 months of your last cruise and the destinations that you tend to book; and
- (iii) 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: 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.
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.
#10. Cookies and other tracking technologies
#11. Data retention
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. Acting on someone else’s behalf
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. Multi-guest reservations and linking reservations
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
- complete online check-in for you and others in your reservation,
- view your boarding pass, and the boarding pass of others in your reservation,
- 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
- 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. Your rights
15.1 You can use your guest account to update your direct marketing preferences or opt out of profiling and personalized marketing.
#16. Changes to this privacy notice
16.1 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.
16.2 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.
#17. Contact Us and complaints
17.1 If you require any other information about any part of this notice, you can contact Our Data Protection Officer at RCL Cruises Limited at the mailing addresses above or by submitting a request via the respective links outlined in Section II.3.1 below.
SECTION 2: Heightened European Union requirements/ compliance with the General Data Protection Regulation
This section applies to you if:
(a) you use Our Digital Platforms while in the EEA;
(b) your data controller is RCL Cruises Ltd. (to determine your data controller, see section I.1 above);
(c) your personal data is processed on one of Our ships.
#1. Legal basis for Our use of your personal data and legitimate interests
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. International data transfers
2.1 We are a global business and as such We may need to share your personal data with other members in the Royal Caribbean Group for the purposes as outlined in this privacy notice. This means that We may transfer your personal data outside of the EEA (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 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 so you can rest assured that the Royal Caribbean Group seeks to adhere to the strict European standards of data security and usage.
#3. Your rights
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
Click on the respective link to submit your request: Guest Data Subject Request Form or Marketing Subscriber Data Subject Request Form. Please use the ‘Submit an inquiry’ button in these forms to exercise your rights under 3.1(f) and (g) above.
3.2 You also have the right to make a complaint about how We process your personal data to your data protection supervisory authority.
3.3 Where you have specifically consented to Our use of your personal data, you have the right to withdraw that consent at any time. Please contact Us if you want to do this. See Our website for contact details or refer to Section II.3.1 above for how to submit your request.