CLIA GDPR Privacy Policy - Complete

 

This privacy policy was last updated on 9/18/18.

Introduction

Cruise Lines International Association (CLIA) presents this privacy policy (together with our Membership Terms and Conditions) 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.

Important information and who we are

  • Purpose of this privacy policy

    This privacy policy aims to give you information on how we process the personal data that you provide to us, or we collect from you, when you visit our website www.cruising.org, register to become a member of the CLIA cruise industry trade association (Member, and the term Membership shall be construed accordingly), create a personal profile on our website, sign up to receive our marketing communications, request any of our products or services from us (Services), make an enquiry and/or otherwise interact with us.

    This website is not intended for children and we do not knowingly collect data relating to children.

    It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

  • Controller

    Cruise Lines International Association is made up of different legal entities based in North and South America, Europe, Asia and Australia, details of which can be found here (the CLIA Group).

    This privacy policy is issued on behalf of the CLIA Group so when we mention CLIA, we, us or our in this privacy policy, we are referring to the relevant company in the CLIA Group responsible for processing your data (i.e. the controller, for the purposes of European data protection law). We will let you know which entity will be the controller for your data when you register to become a Member or otherwise interact with us.

    Cruise Lines International Association is the controller and responsible for this website.

    We will comply with all data protection and privacy laws which are applicable in the country in which we collect your personal data.

    Our companies which are based in the European Union (EU), or which offer goods or services to, or monitor the behaviour of, data subjects in the EU, will at all times comply with the General Data Protection Regulation (EU) 2016/679 (GDPR).

    We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (as detailed below), please contact the data protection manager using the details set out below.

  • Contact details

    Our full details are:

    Full name of legal entity: Cruise Lines International Association

    Name of data protection manager: Peter Plourd, VP Information Technology.

    Email address: itdept@cruising.org

    Postal address: 1201 F Street NW, Suite 250, Washington, DC 2000 USA

    Telephone number: +1 202 759 6772

  • Changes to the privacy policy and your duty to inform us of changes

    We may make changes to this privacy policy from time to time to time. We will post a copy of the updated privacy policy on our website prior to any change becoming effective. If we make any material changes we will also notify you of such change by email in advance. Your continued use of the website and/or our services following any changes to the privacy policy (which will be notified to you as described above) signifies your acceptance of those changes.

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  • Third-party links

    This website 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 policy of every website you visit.

    If you engage in any interaction with CLIA, other end-users or any third party on any social media pages or through social media tools or "plug-ins," you should be aware that: (a) the personal data that you submit by and through such social media pages: (i) can be read, collected and/or used by other end-users of the website and/or social media websites, as applicable and depending on your privacy settings associated with your accounts with the applicable social media websites; and (ii) could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where CLIA responds to any interaction on such social media pages, your account name/handle may be viewable by any and all members/users of CLIA's social media accounts. 

    We are not responsible for the personal data that you choose to submit on any social media websites.  The social media websites operate independently from CLIA, and we are not responsible for such social media websites' interfaces or privacy or security practices.  We encourage you to review the privacy policies and settings of the social media websites with which you interact to help you understand those social media websites' privacy practices.  If you have questions about the security and privacy settings of any social media websites that you use, please refer to their applicable privacy notices or policies.

Data and Personal Information

  • The data we collect about you

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    • Identity Data includes first name, maiden name, last name, username or similar identifier, title, marital status, date of birth, gender, job title, membership reference number, passport details, photograph, training details and accreditations, ABTA membership number, agency name.
    • Contact Data includes billing address, home / office address, email address and telephone numbers.
    • Financial Data includes bank account and payment card details.
    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
    • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
    • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • Usage Data includes information about how you use our website, products and services.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Third party personal data that we collect
    When you ask us to register your employees, directors and/or officers (Users) in connection with your Membership, we will need to ask for personal data (including Identity Data and Contact Data) belonging to your Users. It is your obligation to ensure that you make such third parties aware of this Privacy Policy.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

    We may sometimes collect information relating to your dietary requirements, which may reveal details of your religious beliefs and/or medical conditions. We do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  • If you fail to provide personal data

    Where we need to collect under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the benefits that you are entitled to as a Member). In this case, we may not be able to provide any product or service that you have requested from us and/or we may have to cancel your Membership (and our standard cancellation terms will apply), but we will notify you if this is the case at the time.

  • 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 Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • register to become a Member;
    • create a personal profile on our website;
    • request and/or purchase our products or services (via our website, email, telephone or other method);
    • sign up to receive our marketing communications;
    • request information in relation to, or sign up to attend, an event, activity or programme;
    • enter a competition, promotion or survey; or
    • make an enquiry or give us some feedback
    • Cookies and Similar Technologies. When an end-user visits the our website, we send one (1) or more cookies and/or gif files (collectively, "Cookies") to assign an anonymous, unique identifier to the applicable end-user's computer and/or mobile device, as applicable. A Cookie is a piece of data stored on your hard drive and/or mobile device, as applicable, containing information about you. Cookies have many benefits to enhance your experience at the our website. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the website, including for storing end-user preferences and tracking user trends (such as pages opened and length of stay at the Site).
    • Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where an end-user rejects a Cookie, he or she may still use the website; provided, however, that certain functions of the website may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.
    • Action Tags, Web Beacons and other Data Collection Methods. An action tag or a web-beacon (also known as a clear gif or a pixel tag) is a method used to track responses or actions by visitors who view certain advertisements and/or other information on the website. Action tags are 1x1 pixel images embedded in a website page that are used to transparently collect information. We may use action tags to count the number of times that visitors click on a particular banner ad or visit the pages of the Site, and to provide information about what offerings, products and/or services are viewed, selected and/or purchased, as applicable. We reserve the right to retain this action tag data indefinitely.
  • How we use your personal data

    We will only use your personal data when applicable law allows us to, such as for customer service purposes, to provide you with information that you may request, to customize your experience on the website and/or to contact you when necessary in connection with transactions entered into by you through the CLIA website or our services. We may also use your personal data (including Special Categories of Personal Data) for internal business purposes, such as analyzing and managing our business.

    Where the GDPR applies, we will most commonly use your personal data in the following circumstances:

    • where it is necessary for us to process your personal data in order to perform our contractual obligations in relation to your Membership (as detailed in our Membership Terms and Conditions or in order to respond to any enquiries that you make about becoming a Member;
    • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
    • where we need to comply with a legal or regulatory obligation;
    • For our Members and User, we will send you direct marketing communications via email, telephone, text message and/or post as part of the Services that we provide as part of your Membership (i.e. such processing is necessary for use to perform our contractual obligations to the Member and for legitimate interests in order to provide the User with the benefit of the Services) unless you have told us that you do not want us to contact you for this purpose or by any particular method of communication. If you are not a Member or a User (e.g. if you make an enquiry or otherwise interact with us) we will only send you direct marketing communication where you have provided your explicit consent to such processing of your data. You have the right to withdraw consent to such marketing at any time by contacting us.
  • Purposes for which we will use your personal data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Data Subject Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
    Member or prospective Member To register you as a Member
    1. Identity
    2. Contact
    3. Financial
    Performance of a contract with you
    Users (i.e. Member's employees, directors or officers) To register an individual as a User (in connection with employer's Membership)
    1. Identity
    2. Contact
    Legitimate Interests (to provide the benefits of Membership to Users)
    Member or User To provide you with products or services that you have requested or purchased from us, including the provision of information in relation to training courses, events, activities or programmes that we offer.
    1. Identity
    2. Contact
    3. Financial
    1. Performance of a contract with you
    2. Legitimate Interests (to provide the benefits of Membership to Users)
    Member or User To collect and process information relating to dietary requirements, which may reveal details of your religious beliefs and/or medical conditions, where such information is relevant in respect of a training course, event, activities or programmes that you are attending.
    1. Identity
    2. Categories of Sensitive Personal Data
    1. Member's or User's explicit consent
    Member or User To administer your Membership, including to:
    1. Add Users to your Membership;
    2. Keep records of your or User's training details and accreditations;
    3. Notify you of any renewal of your Membership fees which are due;
    4. Manage payments, fees and charges
    5. Collect and recover money owed to us
    1. Identity
    2. Contact
    3. Financial
    4. Transaction
    5. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to keep our records updated and to recover debts due to us)
    Member or User To manage our relationship with you which will include:
    1. Notifying you about changes to our terms and conditions or this privacy policy
    2. Asking you to leave a review or take a survey
    1. Identity
    2. Contact
    3. Profile
    4. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary to comply with a legal obligation
    3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
    Member or User To enable you to partake in a prize draw, competition or complete a survey
    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
    Member or User To upload Members' or User's details to our "Who's Who" Directory (available to the public online on our website or in hard copy)
    1. Identity
    2. (b) Contact
    1. (a)Legitimate Interests (to provide the benefits of Membership to Members and Users, so Members and users can develop business opportunities)
    2. (b) Member's or User's Consent
    Member To keep a record of transactions for our own tax, legal and other record keeping requirements
    1. Identity
    2. Contact
    3. Transaction
    1. Necessary to comply with a legal obligation
    2. Necessary for our legitimate interests (to keep our records updated)
    Member, User or visitor to our website To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
    1. Identity
    2. Contact
    3. Technical
    1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
    2. Necessary to comply with a legal obligation
    Member, User or visitor to our website To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications
    6. Technical
    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
    Member, User or visitor to our website To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
    1. Technical
    2. Usage
    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
    Member or User Sending direct marketing communications about products and services (including events, conferences, etc) which may be of interest to you
    1. Identity
    2. Contact
    3. Technical
    4. Usage
    5. Profile
    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (to develop our products/services and grow our business

    (c) Member's or User's consent

    Visitor to our website or other individual who is not a Member or User Sending direct marketing communications about products and services (including events, conferences, etc) which may be of interest to you
    1. Identity
    2. Contact
    3. Technical
    4. Usage
    5. Profile
    Data Subject's
    consent
    Member or User If you opt-out of receiving direct marketing communications, to keep a record of this on our suppression list
    1. Identity
    2. Contact
    Necessary for our legitimate interests (to keep our records updated)
  • Marketing

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Particularly around marketing and advertising.

    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). We do this to ensure you always get a great service fully tailored to your preferences, but if you would prefer we do not use these kinds of profiling techniques you can opt out. If you opt out, you may find your communications from us become less relevant to you.

  • Email Marketing

    We regularly sends out communications about events, training courses, events, activities or programmes that we offer via email to all existing Members and Users (unless they have 'opted-out' of receiving such communications), which we provide as part of the Services that you have signed up to receive.

    Alternatively, if you are not an existing Member or User, you can sign up to receive marketing communication from us by opting-in via our website.

    Third-party marketing

    We will get your express opt-in consent before we share your personal data with any company outside the CLIA Group of companies for marketing purposes.

  • Opting out

    You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in connection with your Membership, a product/service purchase or other transactions.

  • Change of purpose

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  • Disclosures of your personal data

    We may share your personal data with any member of the CLIA Group and other third party processors for the purposes set out in the table in paragraph 4 above.

    Such third party processors may include:

    • our business partners, suppliers and subcontractors for the performance of any contract we enter into with you;
    • where we outsource any of our business functions under which we collect or store your data, such as service providers that we use for marketing and promotional purposes or for payment processing purposes;
    • where we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
    • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Membership Terms & Conditions and other agreements; or to protect our rights, property, or safety of our employees, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    • For a full list of all our third party processors please see the table below:
    Provider Personal data processed by them Purpose(s) of the processing Personal data stored / processed outside the EEA
    • Interactive Strategies (USA cruising.org)
    • Frontpage (UK, Europe & Australasia websites)
    • Oxygene (French JAC partnership website)
    Identity Data
    Contact Data
    Financial Data
    Technical Data
    Transaction Data
    Profile Data
    Usage Data
    Dellar Davies

    The Content
    Studio

    Identity Data
    Contact Data
    Dellar Davies Eventbrite Identity Data
    Contact Data
    Financial Data
    Transaction Data
    Profile Data
    Usage Data

    Marketing and

    Communications Data

    Event Hotels Identity Data
    Contact Data
    Financial Data
    Transaction Data

    Marketing and

    Communications Data

    Cruise Lines Identity Data
    Contact Data
    Financial Data
    Transaction Data

    Marketing and

    Communications Data

    Microsoft Office 365

    KeepandShare

    Adobe Creative Cloud

    Gathercontent

    [Please complete this section.]
    Dropbox Google Sheets One Drive SharePoint Identify Data
    Contact Data
    Financial Data
    Transaction Data
    Profile Data
    Aptify Identity Data
    Contact Data
    Financial Data
    Transaction Data
    Profile Data
    Coresoft [Please complete this section.]
    Mailchimp Constant Contact Real Magnet Identity Data
    Contact Data
    Usage Data

    Marketing and

    Communications Data

    Social Media Management:

    HootSuite

    Identity Data
    Contact Data
    Usage Data
    Profile Data
    Survey Monkey Identity Data
    Contact Data
    Profile Data
    Attendify Identity Data
    Contact Data
    Usage Data
    Profile Data
    Cloud Server Identify Data
    Contact Data
    Financial Data
    Transaction Data
    Profile Data
  • Your California Privacy Rights
    • If you are a resident of the State of California and would like to learn how your "personal information" (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, what categories of personal information that we have shared with third-parties in the preceding year, as well as the names and addresses of those third-parties, you may request this information once per calendar year by e-mailing us at: info@cruising.org; calling us at: (202) 759-9370; or sending mail to: 1201 F Street NW, Suite 250, Washington, DC 20004.
    • Further, if you are a resident of the State of California and would like to opt out from the disclosure of your personal information to any third-party for marketing purposes, please e-mail us at: info@cruising.org; call us at: (202) 759-9370; or send us mail to1201 F Street NW, Suite 250, Washington, DC 20004. Please be advised that where California State residents opt out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our written instructions.

    Without limiting the generality of the foregoing, we reserve the right to share, sell, rent, lease and/or otherwise distribute any and all information that is anonymized or aggregated with/to any third party for any and all uses permitted by this privacy policy and applicable law.

  • International transfers

    CLIA are an international association with members all over the world and, as such, the data we collect may be transferred to, and stored at, a destination outside the European Economic Area (EEA). All our data is stored on our server based in Washington, USA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services

    In compliance with the GDPR, whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it as would be the case within the EEA by ensuring at least one of the following safeguards is implemented:

    • we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en;
    • where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en; or
    • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.

    Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  • 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.

  • 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, 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.
    • By law we have to keep basic information about our Members (including Contact, Identity, Financial and Transaction Data) for six years after they cease being Members for tax purposes.
    • In some circumstances you can ask us to delete your data: see Request erasure section below for further information click here.
    • 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.
  • CONTROLLING Your personal data

    At your request, we will: (a) inform you of what personal data we have on file for you; (b) amend the personal data that we have on file for you; and/or (c) remove personal data that you have provided to us, or that we have collected. You may do so by contacting us via e-mail at: info@cruising.org; provided, however, that we ask individuals to identify themselves and the information requested to be accessed, amended or removed before processing such requests and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

    If you are an individual that visits our website from the European Economic Area or Switzerland, under certain circumstances, you have additional rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

    • Request access to your personal data.
    • Request correction of your personal data.
    • Request erasure of your personal data.
    • Object to processing of your personal data.
    • Request restriction of processing your personal data.
    • Request transfer of your personal data.
    • Right to withdraw consent.

    If you wish to exercise any of the rights set out above, please contact us.

    For the purposes of the GDPR we are obliged to tell you that, if you consider that our processing of your personal data does not comply with applicable European data protection law, you have the right to make a complaint to the national supervisory authority in the EU Member State of your habitual residence, place of work or place of the alleged infringement. Details of the national supervisory authorities can be found at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

  • No fee usually required

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

  • What we may need from you

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  • Time limit to respond

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

  • LAWFUL BASIS
    • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
    • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
    • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
  • YOUR LEGAL RIGHTS

    If you are an individual that visits our website from the European Economic Area or Switzerland, you are afforded the following rights:

    Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.