Privacy Policy

This Privacy notice explains what information We collect about you, what We may do with that information, and what your rights are. We have summarized the main circumstances in which We use Your personal data below.

1. Categories and Types of Personal Information We May Collect

We may collect the following categories of data and types of personal information directly from you or from our business partners or third parties according to applicable law:

• Personal and Contact Information: your name, date of birth, place of birth, gender, postal address, email address, telephone number, mobile number and emergency contact information and other similar identifiers;
   
• Health and Medical Information: past medical history, temperature readings, COVID-19 test results and vaccination records, health monitoring information, accessibility information, care in one of our shipboard clinics, medications, allergies or other medical accommodation needs;
   
• Travel and Vacation Preference Information: travel history, flight numbers, hotel bookings, cabin numbers, special occasion dates, special accommodations, VIP program information, dietary preferences, travel companion and family member data or information about the products or services purchased or considered;
   
• Customer Records: Details regarding your previous travels including locations you have visited and travel contacts, details of your play and spend at casinos, and details regarding your interactions with our team members and call centers, including email communications and recordings of your calls;
   
• Government-Issued Documents: passport information, alien resident cards, visas, residency permits, social security numbers, national and state identification numbers, driver’s licenses, and redress numbers;
   
• Other Identifying Information: IP address, usernames, passwords, security answers, geolocation information, and other security information, details regarding your interaction with Our websites, applications and emails We send, such as whether you opened an email We sent, which may permit Us to recognize you across multiple devices, or viewed certain content on Our websites and applications;
   
• Financial Information: credit card, debit card and bank information, transactional history and purchases, amount paid for services, income and business information;
   
• Demographic Information: gender, age, employment information and salary information;
   
• Geolocation Data: precise geolocation data from your browser or device or inferred based on your IP address;
   
• Internet or Other Electronic Activity: your browsing and click history, including information about how you navigate within Our Services and which elements of Our Services you use the most, and what site you came from or what site you visit when you leave Our website.;
   
• Commercial Information: services and products purchased or viewed on Our website;
   
• Employment Application Details: name, employment history, telephone number, address, email address, education history, reference details, military service, and immigration status;
   
• Public Information: Information available via public records and publicly available content on social media platforms;
   
• Analytics Information: Information collected via analytics tools to measure traffic, usage trends, demographic information, mouse movements, scrolling, clicks, and keystroke activities on Our digital platforms.

The above-described information may be collected and provided by you when you: (i) register for an account through Our Services, (ii) complete a travel profile, (iii) book travel with Us or order additional products or Services, (iv) communication with Us or other guests through paper or electronic form, and (v) take advantage of a promotion, survey, contest, or sweepstakes. This list is non-exhaustive.

Data collected when you create an account with Us, purchase Our products or use Our Services may include data about yourself and those traveling with you. By providing Us with the personal data of any third party, you confirm that you are authorized to do so on their behalf and have provided them with the information set forth in this Privacy Policy. The personal information of each person linked to the same travel itinerary may be accessible by all others included in that same itinerary.

Please be aware that there will be photographers on board taking photographs for guests to purchase. If you do not want to be photographed, please let our photographers know and they would be happy to take reasonable steps to comply with your request. We cannot guarantee that you will not be included in photographs incidentally.

1. Data Automatically Collected

When you visit Our Site, use Our Services, read Our emails, or otherwise engage with Us through a computer or mobile device, We and Our third party partners, automatically collect information about how you access and use the Service and information about the device you use to access the Service, which is collected through the use of cookies, embedded scripts, analytics tools, and other device identifying technologies (“Cookies and Tracking Technologies”).

Information about Our use of Cookies and your choices related to same are available in Our Cookie Policy below, including information regarding how to opt out of targeted advertising.

• Cookie Policy

  This Cookie Policy describes the way we use cookies to collect information on our website. When you visit, request information from, or book a cruise with us on our website, your mobile device, or applications (the “Online Services”), we may use cookies and other device identifying technologies (“Cookies”) to provide our Online Services to understand how our Online Services are used and for advertising purposes, as explained in our Privacy Notice. You can read more about the types of Cookies we use, why we use them, and how you can exercise your Cookies choices below.

  When You Use Our Online Services

  We typically collect this information through a variety of tracking technologies, including cookies, Flash Objects, web beacons, embedded scripts, APIs and mobile software development kits (SDKs), location-identifying technologies, and similar technology (collectively, “tracking technologies”), and we may use third party services to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly or receive from other sources.

  Specifically, we, and any third-party partners, may use tracking technologies to automatically collect commercial information, preferences, and internet, network and device information, including:

  Information about how you access the Online Services, such as the site from which you came and the site to which you are going when you leave our site, how frequently you access the Online Services, when and whether you open emails or click the links contained in emails, whether you access the Online Services from multiple devices, and other actions you take on the Online Services.

  Information about how you use the Online Services, such as the pages you visit, the links you click, the ads you view and click on, purchase information and your checkout process, your location when you access or interact with our Online Services, and other similar actions.

  Information about the computer, tablet, smartphone, or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, e.g., a persistent device identifier or an Ad ID), and other such information.

  Analytics information. We may collect analytics data, or use third party analytics tools, to help us measure traffic and usage trends for the Online Services and to understand more about the demographics and behaviors of our users. We may also use analytics tools to record your mouse movements, scrolling, clicks and keystroke activity on our Sites to understand how our users engage with our Sites and to monitor and improve our online offerings.

  This information allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Sites and Online Services, and for other internal purposes. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Sites; (b) provide custom, personalized content, and information; (c) identify and contact you across multiple devices; (d) provide and monitor the effectiveness of our Online Services; (e) perform analytics and detect usage patterns on our Online Services; (f) diagnose or fix technology problems; (g) detect or prevent fraud or other harmful activities, and (h) otherwise to plan for and enhance our Online Services.

  WHAT ARE “COOKIES”?

  Cookies are small text files placed on your computer or mobile device when you visit websites or applications. Your web browser (such as Google Chrome, Safari, or Internet Explorer) then sends these cookies back to these websites on each subsequent visit so that they can remember things like personal details and preferences.

  Cookies are very useful and perform a variety of tasks, such as allowing you to navigate efficiently between pages, remembering your preferences, and generally improving your experience when you are browsing our website. Cookies may also be used to help to ensure that our web content, emails, and advertising better suit you and your interests.

  Cookies can either be served directly by us or served on our behalf, for example by advertisers and data analytics companies.

  Types of Cookies

  Cookies can last for different lengths of time depending on what they are intended to do.

  Session Cookies

  These last only as long as your browser is open and then disappear from your device when the browser is closed.

  Persistent Cookies

  These remain on your computer or mobile device after your browser is closed and last for the time period outlined in the cookie. For example, they recognize your device when you open your browser and browse the internet again.

  How Do We Use Cookies?

  We use four types of cookies:

  (1) Necessary Cookies

  These are cookies that are essential to provide you with services you have requested, which means they cannot be switched on or off through the privacy settings link.  For example, these include cookies that make it possible to stay logged into your account. If you set your browser to block these cookies, then these functions and services will not work for you, and we will not be able to save your preferences about cookies.

  (2) Performance Cookies

  Performance cookies, which are sometimes called analytics cookies, collect information about your use of this Site and enable us to improve the way it works. For example, performance cookies show us which are the most frequently visited pages on the Site, allow us to see the overall patterns of usage on the Site, help us record any difficulties you have with the Site and show us whether our advertising is effective or not.

  (3) Functional Cookies

  In some circumstances, we may use functionality cookies. Functionality cookies allow us to remember the choices you make on our Site and to provide enhanced and personalized features, such as customizing a certain webpage, remembering if we have asked you to participate in a promotion, and for other services you request, like watching a video or commenting on a blog. All of these features help us to improve your visit to the Site.

  (4) Advertising Cookies.

  We and our service providers may use targeting or advertising cookies to deliver ads that we believe are more relevant to you and your interests. For example, we may use targeting or advertising cookies to limit the number of times you see the same ad on our Site and to help measure the effectiveness of our advertising campaigns. These cookies remember what you have looked at on the Site and we may share this information with other organizations, such as advertisers. For more information about third-party advertising networks and similar entities that use these technologies, see www.aboutads.info/consumers, and to opt-out of such ad networks’ and services’ advertising practices, go to www.aboutads.info/choices.

  Opting out of third party targeting or advertising cookies does not necessarily mean that you will not see our advertising on third party websites, only that this advertising will not be targeted to you through the use of third-party cookies.

  We also may collect information on our Site using Google Analytics to collect usage data, analyze how users use the web sites and provide advertisements to you on other websites. For more information about how you can opt-out of having your information used by Google Analytics, please visit https://tools.google.com/dlpage/gaoptout/

  How Do Third Parties Use Cookies on the Site?

  In some circumstances, we may work with third parties to provide services on our Site. Third-party advertisers and other organizations may use their own cookies to collect information about your activities on our Site and/or the advertisements you have clicked on. This information may be used by them to serve advertisements that they believe are most likely to be of interest to you based on content you have viewed. Third-party advertisers may also use this information to measure the effectiveness of their advertisements. We do not control these cookies and to disable or reject third-party cookies, please refer to the relevant third party’s website. You can also learn more about controlling cookies in the “How Can You Control the Use of Cookies” section below. You may be able to use an industry tool to limit use of your information for the purposes of serving interest-based ads by participating third parties by clicking here (or if located in the European Union click here). Please note this tool does not opt you out of being served ads (you will continue to receive generic ads) or from the use of your information for serving interest-based ads by third parties that do not participate in the industry tool. The effectiveness of the industry tool might also be limited if your browser is configured to block third party cookies.

  HOW CAN YOU CONTROL THE USE OF COOKIES?

  You have the right to choose which Cookies to accept or reject. However, they are an important part of how our Online Services operate, so you should be aware that if you choose to refuse or remove Cookies, this could affect the availability and functionality of the Online Services.

  If you don’t want the Online Services to use Cookies, please follow the instructions below.

  Website (Browser) Opt-Out

  Most browsers accept Cookies by default. You may be able to change the settings to have your browser refuse certain Cookies or notify you before accepting Cookies. To do so, please follow the instructions provided by your browser, which are usually located within the “Help,” “Tools,” or “Edit” menus. Some third parties also provide the ability to refuse their Cookies directly by clicking on an opt-out link. Please note that authorized third parties may be able to collect information about your use of the Online Services even if you have set your browser to reject third party cookies. To effectively prevent third party collection via Cookies, you will need to configure your browser to reject all cookies.

  Mobile App Opt-Out

  To limit interest-based advertising on your mobile device, you can review and adjust the settings provided by your device manufacturer, such as “Limit Ad Tracking” for iOS or “Opt-out of interest-based ads” for Android.

  For further information about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, please visit www.allaboutcookies.org and www.youronlinechoices.eu.

1. Information Received from Third-Party Sources

   We may receive personal data about you from third parties as described below and combine the received information with information We may already have about you.

   Business Partners. We may receive information about you collected by other companies such as ME so that information you provide to ME may be used by Us to better provide you Services and communicate with you.

   Service Providers & Partners. From time to time, We may receive personal information about you from Our service providers and other partners, including from Our marketing partners or from third-parties conducting identity or address verification, payment processing, credit checks, processing lines of credit, or from our excursion partners or other partners providing activities and services. We use this information to validate your identity, age, and address, to comply with Our legal obligations, to monitor activity, to identify and provide you with promotions and offers onboard and for future travel, and to prevent fraud, protect Our rights and the rights of others, to inform Our marketing and advertising activities, and to help provide Our Services.

   Other Travelers. We may obtain information about you from other travelers who you are traveling with or who you have traveled with, as well as your emergency contacts. We use this information to book your travel itinerary, communicate with you and your travel companions about the Services, to support public health initiatives, to fulfill the requested Services, and for the purpose for which it was provided to Us.

   Travel Agents. If you purchase Services through a travel agent, the agent may send Us your personal identifiers, commercial information, and information about health or medical conditions. We will use this information to complete the transaction, book your travel itinerary, communicate with you and those traveling with you about the Services, analyze trends, improve Our business, and facilitate your vacation experience. The travel agent may retain a copy of this data and be required to have appropriate safeguards. The travel agent is solely responsible for processing any personal data the travel agent retains. Please review your travel agent’s privacy notice for more information about his/her/its data processing practices.

   Publicly Available Information. We may also collect publicly available information about you, such as information you publicly post or tag us in on social media sites (e.g., Facebook or Google) or elsewhere online, and information contained in public record databases. We may use this information for market research, to verify your identity, to prevent fraud, and to improve Our Services.

   Google Analytics. We may use Google Analytics to collect usage data (e.g. how often you visit a site, the pages you visit on a site, other websites used prior to coming to Our Site, etc.), analyze how users use the Our site, and provide advertisements to you on other websites. Google Analytics collects your IP address when you visit a site and does not collect your name or identifying information. For information about how Google how may use the data it collects on Our Site, click here. For more information about how you can opt-out of having your information used by Google Analytics, click here.

   In addition to the uses described above, We may collect and use personal information for the following purposes:

   • Create, maintain, improve, and operate the Services.
   • Personalize your user experience.
   • Communicate with you to provide technical or administrative support.
   • Conduct, manage, and grow Our organization.
   • Analyze, research, investigate and improve the use of Our Services and interactions with Our guests.
   • Prevent, investigate, and defend against fraud, unlawful or criminal activity, unauthorized access to or use of personal information and Our data system services, and to comply with legal requirements, obligations and other governmental demands.
   • Investigate and resolve disputes and security issues and to enforce Our Terms of Service and any other contracts you have entered into with Us.
   • For any other lawful, legitimate business purpose.

1. Sensitive Personal Data

Some of the data We collect in connection with the provision of Our Services or through the employment application process may constitute sensitive personal data, including but not limited to: racial or ethnic origin, religious, philosophical, or political beliefs, sexual orientation, or data concerning health, such as medical history or dietary restrictions.

We collect this information when you choose to provide it to Us, a service provider (e.g., a travel agent), or through an employment application. This information is used to provide a service at your request, such as medical care on one of Our cruises, or special dietary accommodations, or in connection with your employment application.

We may also collect personal data in relation to an allegation or claim of a personal injury while traveling with Us. The personal data collected would concern the alleged incident, including healthcare information.

1. Facial Recognition Technology

We may provide your disembarkation photograph to U.S. Customs and Border Protection (“CBP”) for purposes of CBP verifying your identity and upon receiving verification of same from CBP, we will immediately delete your disembarkation photograph.

We do not retain your facial recognition data beyond the duration of your cruise or use it for any other purpose other than that described above. For information on how CBP uses your biometric data, please visit www.cbp.gov/travel/biometrics.

1. COVID-19 and Other Communicable Diseases

In response to COVID-19 and for the health and safety of Our guests and crew, We may process and require additional personal data during a pandemic, or any other communicable disease outbreak. At the pier, passengers will undergo COVID-19 screenings and provide Us proof of a negative result. Passengers will also be required to show proof of vaccination and will have their temperature taken. We may also collect such data on board Our ships and at Our ports of call. All passengers two (2) years and older are required to show proof of a negative COVID-19 viral test result from a third-party provider (at-home test results are not sufficient) taken 72 hours or less before embarkation, or documentation of having recovered from COVID-19 in the past 90 days and a letter from your healthcare provider or a public health official stating you were cleared to travel.

If We are made aware that an individual is exhibiting symptoms of COVID-19, We may take appropriate action to mitigate the spread of COVID-19, which may include medical examinations, testing, containment, denial of boarding, and/or disembarkation of the affected person(s).

In response to COVID-19 and to protect against the risks of other communicable illness, all guests may be required to undergo health screenings and we will collect additional information recommended by public health authorities or other government agencies or to otherwise demonstrate Our guests’ ongoing health and fitness to travel, including:

Contact Information. Information such as name, nationality, country of residence, originating address, destination address, telephone, and email;

Symptoms And Health Information. Information regarding the presence or absence of possible COVID-19 or other global pandemic symptoms, which may be collected through temperature scans, tissue sampling, medical examinations, surveys or questionnaires, as well as information about pre-existing medical conditions;

Exposure. Information regarding potential exposure to or infection with COVID-19 or other global pandemic, which may include recent travel history, contacts with guests, crew or other individuals;

As Required by Law. Information collected by Our on-board crew or reservations staff pursuant to directives by public health organizations or other government agencies.

We use physical, technical, and organizational security measures to safeguard your personal data. These measures help ensure the integrity and confidentiality of your personal data. Additionally, We use SSL (Secure Sockets Layer) technology to encrypt and transmit your billing information.

While We take reasonable precautions to attempt to ensure the safety and security of your online transactions and personal information, it is impossible for Us to completely guarantee that your personal data will be immune from malicious attack or compromise. As such, by using Our Services, you understand that the transmission of your personal data is always at your own risk.

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the Controlling Your Personal Information section in subsection (E) below.

1. How We May Use Your Personal Information

• Bookings and Cruise. We may use and process your personal data to deliver Our services to you when you book a cruise with Us, which may include sending you a booking confirmation, managing changes to your booking, checking you in upon boarding Our ships and keeping track of you onboard, providing you with further products and services onboard (e.g., excursions, tours, onboard entertainment, and various onboard purchases).
   
• Customer Service. We may process your personal information when you contact or use Our customer support services to ensure you receive the best customer service possible. A consumer profile of you is created when you sign up using Our Digital Platforms or make a booking, which contains your personal data that We maintain and identifies you. Your consumer profile helps Us deliver a personalized experience when you search for services with Us, contact Us by phone or email, and receive marketing communications. We may use your details to ask for feedback on Our services.
   
• Health, Safety, and Security Reasons. We may process your personal information that you provide during the booking process should you require medical assistance on board one of Our ships. We may also process your personal data to protect the health, safety, and security of all individuals on board Our ships, such as by checking your information against a publicly available criminal record database to protect the safety of Our guests and crew or use your personal data to help prevent the spread of COVID-19 or any other communicable diseases.
   
• Advertisement and Marketing. In accordance with applicable law, We may use your personal data to create a profile about you and place you into marketing segments to understand your preferences better and appropriately customize the marketing messages you receive from Us. Our goal is to provide you more relevant advertising messages, which may be communicated via direct mail, telephone, email, text message, or via applications. Where necessary, We will obtain your consent before contacting you with such marketing communications.
   
• Improve Our Online Services. We may collect and process your personal data when you use any of Our Digital Services for the purposes of ensuring that Our Digital Services work well, improving our Digital Services, making the booking process easier, fixing operational problems to maintain safety and security, and helping Us better understand interest in the different sections of Our Digital Services, Our products, and services sold online.
   
• Process Payments and Invoicing. When you make any purchase through the Digital Platforms We will process your payment information to complete the transaction.
   
• Marketing and Promotional Purposes. We may use your contact details for Our marketing and promotions, to personalize Our marketing communications to you, and to measure engagement with Our marketing campaigns. See Controlling Your Personal Information in subsection (E) 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 marketing messages; and (iv) better understand how players use the onboard casinos.
   
• Compliance with Our Legal Obligations. We may collect, retain, and disclose your personal data in order to comply with legal obligations, requirements, and regulations, such as requirements of agencies or port authorities to allow Our ships to dock or cooperating with law enforcement to facilitate an investigation. Additionally, We may be compelled to turn over your information if compelled by a Court of competent jurisdiction pursuant to the provisions of the United States’ Stored Communications Act (the “SCA”) since We may be considered a provider of electronic communication services.
   
• Business Operations. We may use and process your personal data for business management activities, such as assisting with incident management and conducting reporting, which helps Us to keep track of Our performance, address customer complaints, and improve Our performance.
   
• Potential Employment.  We may process your personal data if you apply for a job with Us, in order to perform any necessary verification, monitor equal opportunity employment, perform medical screenings where necessary and applicable, and running criminal and/or credit history background checks based on Our legitimate interests, to the extent necessary and where permitted under applicable laws and regulations.
   

1. How We May Share Your Personal Information

We may share your personal data with the recipients described below for all the purposes listed above under the following circumstances and as permitted under applicable laws and regulations.

• Classica Cruise Operator, Ltd. Group Companies. We may need to share your information with other members of the Group of companies to which Classica Cruise Operator, Ltd. belongs for the reasons expressed above.
   
• Service Providers. We may share your personal information with third party vendors and service providers that perform services for or on Our behalf, such as identifying and serving targeted advertisements, providing mail or email services, tax and accounting services, product fulfillment, payments processing, photo sharing, data processing and enhancement services, medical and health purposes, fraud prevention, web hosting, analytic services, or other online functionality, subject to appropriate contractual terms protecting the confidentiality and use of such data.
   
• Promotional Partners. We may share some of your personal information with third parties that We partner with who provide promotions, excursions, activities, contests, sweepstakes, or other promotional activities. We typically identify Our promotional partner by name in the promotional communication.
   
• Travel And Excursion Partners. We may share your personal data with companies that provide you with onboard products, services, excursions, or companies that you may book travel arrangement through, either before, during and/or after your cruise in order to facilitate your travel activities and provide your requested services all while providing a seamless service to Our guests. This Privacy Notice does not cover information collected by travel partners and how travel partners use that information. Instead, We recommend you check the travel partner’s privacy policy for details as to how they may process your personal data.
   
• When You Request Us to Share Information. We may share your information, at your request or direction, with your friends and family through Our Services, or with third parties, such as excursion companies, medical providers, or your travel agent. Any reviews or comments you may post on Our website or Our social media sites, may be displayed publicly online.
   
• Marketing and Business Partners. We may share some of your personal data with marketing and business partners, who may use this information for their own business and commercial purposes according to their own privacy policies. In accordance with applicable laws, you may be given the option to opt-in or out of such information sharing.
   
• As Required by Law, Rules, Regulations and Courts. We may need to share your personal data to comply with the laws of countries in which We operate, to comply with local ports and customs authorities to process Our ships in the ports at which they call, to comply with law enforcement agencies when they may require access to personal data to facilitate investigations, or when ordered by a court to disclose personal data or in connection with legal proceedings. We may also share your personal data with other third parties such as trade associations and regulatory bodies, who may contact you to discuss your options and/or provide you support.
   
• To Protect Our Rights or The Rights of a Third Party. We may share your personal data to: (1) identify, investigate, contact, or bring legal action to prevent injury to or interference with Our rights or property or the rights or property of a third person if We believe in good faith that disclosing this personal data is necessary or advisable, (2) to prevent or detect fraud, and (3) to prevent and detect crime and protect vulnerable children and adults.
   
• Corporate Transactions. We may share your personal data with potential third parties in connection with the consideration, negotiation, or completion of a corporate transaction related to Our acquisition or merger with another company or the sale or transfer of all or a portion of Our assets or business, to the extent permitted by applicable law. Should such an acquisition, merger, sale or transfer occur, We will use reasonable efforts to obligate the entity to which We transfer your personal data to use it in a manner that is consistent with this Privacy Policy.
   
• Aggregate & Deidentified Information. We may share aggregate information relating to users of Our Services with affiliated or unaffiliated third parties. We also may use and share some information that has been deidentified in accordance with applicable legal standards.
   

1. Data Retention

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 various legal obligations (e.g., to comply with tax or accounting rules, customs requirements, or reasons related to any legal proceedings); and/or (iv) to comply with Our usual business data retention policies.
 

1. COVID-19 And Other Communicable Diseases

We collect and use your personal health information referenced in Section I(F) above for various reasons including: (i) to comply with certain regulatory public health requirements regarding your fitness to travel, (ii) to ensure the health and safety of Our passengers, crew and the public, (iii) to comply with legal and regulatory requirements applicable in the various jurisdictions in which We operate, and (iv) to perform Our contract with you to provide Our Services.
 

1. Controlling Your Personal Information

• Profile Access & Sharing Settings. You may access and update your profile information, including your username, address, contact information, or billing information, and may change some of your data sharing preferences on your account page.
   
• Geolocation & Device Content. To the extent We may collect your geolocation information, you may control location tracking by adjusting your location services options on the “Settings” app on your mobile device. We may continue to approximate your location using your IP address when you access Our Services through a computer or device. If you would like to update your device content access permissions, such as permissions to access your camera or address book, you can do so in the “Settings” in the app on your mobile device.
   
• Promotional Messages. You can opt-out of receiving promotional email communications from Us by following the “unsubscribe” instructions provided in such communications. We make every effort to promptly process all unsubscribe requests. You may still receive Service-related communications, including account verification, transactional communications, changes/updates to features of the Services, and technical and security notices.
   
• Accessing and Modifying Privacy Settings. You may have the right to request to access, modify, or delete your personal information, or remove your name or comments from Our Services or public content depending on applicable jurisdictional laws. We may not be able to modify or delete your information in all circumstances. If you wish to modify or delete your personal information please take one of the following steps:
• Follow the instructions provided in any of Our communications to you.
• Email privacy@cruisebp.com and identify who you are and your request.
• Call 888.357.3885.

Before we can begin to process your request, We will need to verify your identity, which may require additional personal information from you or require you to log into your account. We may reject a request to exercise the rights described above, particularly where We are unable to verify your identity. If We cannot comply with any aspect of your request, We will explain the reason(s) for doing so.

• Requests For Minor Children. Pursuant to applicable laws, you may submit a request on behalf of your minor child to access, modify or delete information, if we are able to verify your child is the person about whom We collected personal information and verify you are authorized to submit the request on your child’s behalf (i.e., that you are the child’s legal guardian or authorized representative).

1. Children’s Privacy

We adhere to the Children’s Online Privacy Protection Act (“COPPA”). Most of Our Digital Platforms and Services are not intended to be used by children, and We do not have any actual knowledge that children are using Our Digital Platforms and Services. However, when We intend to collect personal information from children online, we take the following additional steps to protect their privacy:

• Notifying and obtaining consent from parents and legal guardians, in accordance with applicable law;
• Limiting collection of personal information to no more than is reasonably necessary to participate in the online activity; and
• Giving parents and legal guardians the ability to access their children’s personal information that We have collected and ability to request that their children’s personal information be deleted or modified.

If you believe that We might have inadvertently collected information from a child without appropriate parental consent, please contact us at privacy@cruisebp.com so that We may delete the information as soon as possible.

When We collect personal information about children, which is typically obtained from information provided by a parent or legal guardian, travel agent or other travel partner, We process that information in a manner consistent with applicable laws aimed at protecting the privacy of children’s data.

1. California Resident Privacy Notice

If you are a California resident using Our Site or other digital platforms while in California, you have certain privacy rights under the California Consumer Privacy Act (“CCPA Rights”). This section describes those rights and how you can exercise them with Us.

Collection and Use of Personal Information. We collect all categories of personal information described in this Privacy Policy. To learn more about the types of personal information We collect, the sources from which We collect it, and the purposes for which We use this information, please refer to Sections I and III of Our Privacy Policy.

Personal Information Sale. Unless you exercise your right to opt-out of personal information sales, We may sell your personal information to third parties for monetary or other valuable consideration who may use such information for their own purposes in accordance with their own privacy policies, which may include reselling your information to other third parties.

In the last 12 months, We have disclosed all categories of personal information We collect from you to third parties for a legitimate business purpose.

In the last 12 months, We have sold the following categories of personal information to third parties: (i) Personal Identifiers; (ii) Commercial Information; (iii) Preferences; (iv) Internet, network and device information.

Your Rights and Choices. As a California resident, you may be able to exercise the following rights:

• The Right to Know and Access any or all of the following personal information that We have collected from you and disclosed in the last 12 months including:

(i) the categories or specific pieces of personal information We have collected about you;

(ii) the categories of sources of the personal information We have collected about you;

(iii) the categories of personal information that We have sold or disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;

(iv) the categories of personal information that We have sold or disclosed to other parties for a business purpose, and the categories of other parties to whom this information was disclosed; and

(v) Our business or commercial purposes for collecting or selling that personal information.

• The Right to Request Deletion of your personal information that We collected from you, subject to certain exceptions.
• The Right to Opt-Out of Sales of Your Personal Information to third parties.
• The Right to be Free of Discrimination for exercising any of your CCPA Rights.

Please note that if the exercise of any of these rights limits Our ability to process your personal information (such as in the case of a deletion request), We may no longer be able to provide you Our products and Services or engage with you in the same or similar manner.

Exercising your CCPA Rights. You may submit a request to exercise your CCPA Rights through one or more of the mechanisms described below. Please provide sufficient information so that We may verify your identity before processing your request. In some instances, We may need to request additional personal information from you or require you to log into your account, if you have one. We may decline or limit your request, particularly where We are unable to verify your identity or locate your information in our systems, or as permitted by law. If we are unable to comply with all or some of your request, we will explain the reasons for declining to comply.

Please note that We can only process CCPA requests for personal information processed by Classica Cruise Operator, Ltd. If you have interacted with another brand in our family of companies or any other third party, you will have to contact that specific brand or third party to exercise your CCPA Requests.

Please use one of the below mechanisms for submitting a request to exercise your CCPA Rights:

• Follow the instructions provided in any of Our communications to you.
• Email privacy@cruisebp.com and identify who you are and your request.
• Call 888.357.3885.

Shine the Light Requests. Pursuant to California Civil Code Section 1798.83, California residents also have the right to request, in writing, the following information from business with whom they have an established business relationship:

(a) a list of the categories of personal data (name, email and mailing address) and the type of services provided to the customer, that a business has disclosed to third parties (including separate legal entity affiliates) during the immediate preceding calendar year for the third parties’ direct marketing purposes; and

(b) the names and addresses of all such third parties.

To request any of the above data, please use one of the below mechanisms:

• Follow the instructions provided in any of Our communications to you.
• Email privacy@cruisebp.com and identify who you are and your request.
• Call 888.357.3885.

We are only required to respond to each customer once per calendar year.

1. Nevada Resident Privacy Notice

If you are a Nevada resident and use Our Site or other digital platforms while in Nevada, you have certain privacy rights under Chapter 603A of Nevada Revised Statute (“NRS”).

A Nevada resident has the right to opt-out of future sales of certain personal information that is collected or will be collected about the resident.

Please use one of the below mechanisms for submitting a request to exercise your rights under NRS Chapter 603A:

• Email privacy@cruisebp.com and identify who you are and your request.
• Call 888.357.3885.

Please ensure that your request includes sufficient information to enable Us to identify you in your email request as We take all reasonable steps to verify your identity and the authenticity of the request.

1. European Union and United Kingdom Resident Privacy Notice

If you are a resident of the European Economic Area (“EEA”) or a UK resident and use Our Site or other digital platforms while in the EEA or UK, you have certain privacy rights under the General Data Protection Regulation (“GDPR Rights”). This section describes those rights and how you can exercise them with Us.

Use of Your Personal Information. We only process your personal data for one or more of the following reasons:

• Where you have consented to the processing of your personal data for a specific purpose;
• Where the processing of your personal data is necessary for Us to perform Our contract with you, provide you services you have requested, or for Us to take steps at your request before We enter into a contract;
• Where We need to process your personal data to protect your vital interests or the vital interests of another person, such as when you are physically or legally incapable of giving consent;
• Where We need to process your personal data to comply with a legal obligation such as a court order or proceeding;
• Where We need to process your personal data where necessary for Us to establish, exercise, or defend a legal claim;
• Where We need to process your personal data for the purposes of Our legitimate interests or a third party’s legitimate interests.

Our Legitimate Interests for Using Personal Data. We use and share your personal information for the following legitimate interests, including:

• Improving Our products and services;
• Understanding how customers travel with Us;
• Marketing and promotional activities;
• Developing and growing Our business;
• Ensuring the security and safety of Our guests and employees.

International Data Transfers. We may need to share your personal data within Our company or with third-party companies for the reasons outlined in this Privacy Notice. This may require Us to transfer your personal data outside the EEA or UK, including to the United Sates since that is where Our servers that store your personal data are located. Such transfers outside the EEA or UK might also be necessary for Us to provide you with your requested products and services.

Your Rights and Choices. As an EEA or UK resident, you may be able to exercise the following rights:

• access your personal data;
• correct your personal data;
• delete your personal data;
• restrict Our use of your personal data;
• object to Our use of your personal data;
• request Us to move your personal data to another organization; or
• object specifically to Us using your personal data for direct marketing purposes.

You also have the right to submit a complaint about how We process your personal data to your data protection supervisory authority. Additionally, 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 would like to withdraw your consent by:

• Emailing privacy@cruisebp.com; or
• Calling 888.357.3885.

Please use one or more of the below mechanisms for submitting a request to exercise your GDPR Rights:

• Follow the instructions provided in any of Our communications to you.
• Email privacy@cruisebp.com and identify who you are and your request.
• Call 888.357.3885.

1. Brazil Resident Privacy Notice

If you are a Brazil resident and use Our Site or other digital platforms while in Brazil you have certain privacy rights under the General Data Protection Law (“LGPD Rights”). This section describes those rights and how you can exercise them with Us.

Your Rights and Choices. As a Brazil resident, you may be able to exercise the following rights:

• access your personal data;
• correct the data We hold about you;
• delete your personal data;
• restrict Our use of your personal data;
• object to Our use of your personal data;
• receive your personal data in a usable electronic format and transmit it to a third party (right to data portability);
• revoke prior consent;
• lodge a complaint with your local data protection authority.

Please use one or more of the below mechanisms for submitting a request to exercise your LGPD Rights:

• Follow the instructions provided in any of Our communications to you.
• Email privacy@cruisebp.com and identify who you are and your request.
• Call 888.357.3885.

Deletion of Personal Data. Your personal information shall be deleted after processing of the information is terminated, within the scope and technical limits of the activities. However, We will conserve your personal information for the following purposes:

• Statutory, regulatory, or legal compliance;
• Transfer to third parties pursuant to the data processing requirements set forth in the LGPD; or
• Exclusive use of the personal information by Us, provided that the personal information is anonymized and third party access to that information is prohibited.

This Privacy Policy may be updated for any reason without prior notice to you. The date this Privacy Policy was last revised can be determined by checking the updated date. Additionally, updates to Our Privacy Policy will be posted on Our Digital Platforms. However, We encourage you to periodically review this Privacy Policy to ensure you understand Our privacy practices.

If you have a registered account, We may notify you of any changes to Our Privacy Policy via email and We may ask you to affirmatively acknowledge and consent to the changes the next time you use Our Services.

We will notify you of any material changes to this Privacy Policy that affect the way We process your information before applying them to that personal data.

For any questions related to this Privacy Policy, please call 877.509.0247 or email privacy@cruisebp.com.