PRIVACY NOTICE
Viking River Cruises UK Limited (the “Company”, “We”, “Us” or “Our”) is committed to respecting and protecting Your privacy. This Privacy Notice is provided for our prospective, existing and former customers (“You”, “Your”).
This Privacy Notice (together with Our Cookie Notice published on our Website, and the terms of use published at www.vikingcruises.co.uk/terms-conditions/index.html) (the “Notices”) tells You about how We process your personal data, including Our collection, usage and sharing of Your personal data, and including in relation to Your use of our website at www.vikingcruises.co.uk (the “Website”).
We will only process Your personal data in accordance with the Notices (and any other information we give to you about how we process Your personal data), and in accordance with the Data Protection Legislation.
In this Privacy Notice the terms “personal data”, “Data Controller”, “Data Processor” each have a special meaning that is set by legislation (the “Data Protection Legislation”). The Data Protection Legislation is: the Data Protection Act 2018 and the EU General Data Protection Regulation (2016/679) as applied in English law (“GDPR”).
YOUR DATA CONTROLLER
We are a Data Controller in relation to Your personal data. Our address is Viking, Nelsons House, 83 Wimbledon Park Side, London SW19 5LP.
The Company may be contacted by email at data.protection@vikingcruises.com and by telephone on 0800 458 69 00.
DATA PROTECTION OFFICER
Our Data Protection Officer can be contacted at data.protection@vikingcruises.com.
INFORMATION WE COLLECT ABOUT YOU
We obtain Your personal data from the following sources:
Directly from you
You will know what personal data We obtain from You, because You (or someone who You trust, and who You have authorised Us to deal with, such as a member of Your family) provide it to Us. Examples of how We obtain personal data from You include: when You make an enquiry (such as asking for a brochure), when You enter one of Our competitions, promotions or surveys, when you give Us information via email or online private mail systems, during a telephone conversation or online chat with Us, information you provide via our Website (such as registering as a user, booking, or posting on Our online forums), via social media messages or if You report something to Us such as a problem with Our Website.
From your travel agent
The information that We need from Your travel agent for Us to complete a booking or provide a personalised cruise plan for You is the same as We need when we obtain the personal data directly from You (see above).
From marketing sources
We love to receive new customers as a result of recommendations from Our existing customers, and We also actively seek new customers via marketing. We obtain personal data about prospective new customers from:
You being on third party marketing lists, which We obtain via Webalytix Ltd, and which provides Us with contact details for You and an indication of why You may be interested in Our products or services;
Your responses to Our online marketing or direct marketing to You, whether You respond by electronic mail, online chat, telephone, post, social media or other means;
Your interactions with our online advertising (which is optimised to present our adverts to internet users who interact with Us via the internet) and advertisements placed by Our online advertising service providers. See Our Cookie Notice for information about Our service providers.
We also use the same sources to learn more about Our existing customers, their preferences and interests, using information about where they visit on the internet.
From Our other service providers
We receive personal data about You from the following third parties who provide services to Us:
- Our bank or providers who process payments from You, to confirm the outcome of payment transactions;
- Other third parties in Viking’s supply chain, Airlines, other carriers, Border control agencies, Contractors e.g. ship crews.
SPECIAL CATEGORY DATA WE COLLECT ABOUT YOU
Under the Data Protection Legislation the following categories of personal data, which We may collect from You, have special status (the “special category data”): personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, and genetic data, biometric data that uniquely identifies a living person, data concerning health, or data concerning a living person’s sex life or sexual orientation, and data relating to actual or alleged crimes. We may obtain special category data when We collect it directly from You, or from Your travel agent. We do not obtain special category data from other third parties.
RECORDING AND MONITORING
In addition to storing written materials received from You and that we provide to You, and Our own records of our transactions and interactions with You, We may monitor and/or record: (1) telephone calls, (2) traffic data produced by electronic devices, applications and online services about the date and location of Your electronic activities with Us, and (3) Your online activities within Our control, including via social media traffic as well as via the Website. All recordings and derivative materials are and shall remain Our sole property.
CHILDREN
We do not provide products or services for purchase by children. If you are under 18, Your parents are responsible for providing Your personal data to Us.
HOW WE MAY CONTACT YOU
From August 2017 onwards, We have provided the ability for You to select and tell Us how You would like to be contacted by Us.
USE OF TOOLS/COOKIES
If Our contact and dealing with You is via the Website(s), or on third party online services where Our advertising is displayed, cookies may be used. Generally, Our cookies do not obtain or use personal data. However, if You permit cookies, We may process the following items of Your personal data using cookies:
- application cookies may assign a unique ID to Our Website registered users, and may record their approximate location;
- behavioural cookies may use Your historical transaction data;
- analytics cookies may assign a unique ID to Our Website visitors;
- marketing cookies will assign a unique ID to internet users.
To find out more about what types of cookies We use, how We use cookies, how to disable them or to change Your cookie preferences, please refer to our Cookies Notice.
YOUR CHOICES ABOUT WHAT WE COLLECT
To complete a booking, or to provide personalised cruise plans for You, as a minimum We need the following: Name and contact details, preferred destination and dates, facilities required on the cruise, whether You consider yourself to have a disability, medical needs and dietary needs. If You provide to Us personal data regarding Your medical needs and whether or not You consider Yourself to have a disability, this is special category data and We will only use it with Your consent.
This information may be given to third parties such as airlines, other carriers and ships to facilitate Your travel arrangements.
If You prefer for Us to use less personal data, You can choose to make less available to Us.
HOW TO WITHHOLD PERSONAL DATA
You can control all of Our sources of Your personal data. You can:
- provide less personal data than We request;
- limit what personal data You give to Your travel agent;
- instruct Your travel agent to withhold items of personal data from Us;
- not respond to Our marketing and communications (and You also have rights to stop Our direct marketing to You: see below);
- change Your internet browser settings to prohibit cookies.
IMPACT OF WITHHOLDING PERSONAL DATA
Withholding Your personal data from Us will mean the updates, offers and communications (via advertisements, direct marketing or messages) You receive from Us are not personalised or relevant to You, or that You do not receive them at all. If You make an enquiry or booking with
Us, withholding Your personal data may mean that Our response to Your enquiry, and the booking (and thus your cruise), is not personalised or fully suitable for You. As We record all telephone calls, to avoid being recorded You will be unable to correspond with us by phone.
OUR USE OF YOUR PERSONAL DATA
For as long as We have access to Your personal data, We will use it for the following purposes, unless otherwise required as a result of You exercising Your data protection rights. We may use Your personal data for any of the following purposes, whether We obtained it directly from You (or someone You trust) or Your travel agent, or another source:
| PURPOSE | LEGAL BASIS |
|---|---|
| (1) To provide You with Our services in accordance with Our contract with You, once You have completed a booking. | If you provide Us with special category data (such as your medical needs): We will ask You for explicit consent, and it is likely that We will be unable to process this special category data without Your consent. For Your other personal data: processing by Us, and by our Data Processors, is necessary for Us to perform the contract with You. |
| (2) To process Your payment for Our services. | Our legitimate interest in obtaining payment before performing Our contract with You. |
(3) To provide You with information that You request from Us, or responding to Your enquiries made directly to Us or via Your travel agent. |
Our legitimate interest in responding to Your requests and enquiries, e.g. by email, telephone, post or social media (or Your preferred one, if you tell us Your preferences). |
(4) To understand and identify Your requirements of Us, by building a profile about You and Your preferences relevant to Your interest in cruises. (5) To send You solicited or unsolicited direct marketing (unless You ask Us to stop), consisting of relevant information about future cruises and similar services that We provide, such as offers of goods and services, brochures, new products, forthcoming events, loyalty programmes, clubs or competitions from Us or Our group companies. (6) To measure the effectiveness of Our advertising and marketing to You. |
If You are an existing customer: Our legitimate interest in staying in touch with You, as part of Our after-cruise service and to seek repeat business. If You are a prospective customer: Your consent for Us to obtain Your personal data and send unsolicited direct marketing to You. We may send notifications by e.g. by email, telephone, post or social media (or Your preferred one, if You tell us Your preferences). You can stop the above notifications at any time by contacting data.protection@vikingcruises.com. |
(7) To ensure that features and content from the Website are available for You (if you choose to use them) and are presented in the most effective manner for You and for Your devices. (8) To check and confirm that We carry out Your instructions accurately, to enable Us to review and improve Our products, services and operations and develop new and changed products, services and operations. |
Our legitimate interest in providing products, services, choices, operations and Websites that meet the requirements of Our existing and prospective customers. |
| (9) To carry out credit checking. services and operations and develop new and changed products, services and operations. | Our legitimate interest in assessing Your credit-worthiness before offering or committing to provide You with credit. |
| (10) To help Us detect and take action against security breaches, fraud and other crimes, and other risks to Us. | Our legitimate interest in addressing security breaches, frauds and other crimes or risks that may affect Our business. |
| (11) For Us to take legal or administrative action, including to collect debts, resolve disputes with You, and to deal with regulators. | In the case of personal data: Our legitimate interest in enforcing Our contract with You and in resolving any disputes with You and in dealing with regulators. In the case of special category data: as necessary for Us to establish, exercise or defend legal claims. |
| (12) To contact You by email. | For prospective customers: Normally We will ask for Your consent and will not contact You by email if You have specifically withheld or withdrawn Your consent to this. See above, “How We may contact You”. For existing customers: It is lawful for Us to contact You by email provided that We give You an easy method to unsubscribe. You can stop Us contacting you by email at any time by contacting |
| (13) To contact You by telephone. | We will ask for Your explicit consent, and will not contact You by telephone unless We have Your consent, unless covered by legitimate interest. |
| (14) To transfer Your personal data overseas (see below). | We will ask for Your explicit consent and may be unable to process Your personal data unless We have Your consent. |
| (15) To use other people’s personal data that You provide to Us. | Our legitimate interest in providing Our service to You. We do ask You to ensure that You have the other people’s permission for You to share their personal data, and that You make them aware that you have shared it with Us for use as described in this Privacy Notice. |
HOW LONG WE RETAIN YOUR PERSONAL DATA
We will hold Your personal data until We find Your contact details are not current, or You can’t be reached after 6 months of trying, or we are notified that You are deceased, or You or a regulator ask Us to stop processing Your personal data.
DISCLOSURE OF YOUR PERSONAL DATA
For as long as We have access to Your personal data, We may share any of it with any of the following to the extent that they need to have access to Your personal data in order to perform their role:
(1) Anyone within Our organisation which includes, without limitation, Our sales and marketing teams, and Our finance team.
(2) Other companies in Our group, such as Our parent company, Viking River Cruises (Bermuda) Ltd. When We store and use Your personal data in electronic format, We use IT systems that are operated by Our parent company, and located in the United States. See the section "Our transfer of your personal data abroad", below, for more information.
(3) Selected third parties who help Us to perform Our contract with you. This includes third parties who help Us directly (such as airlines and service providers on the ship, which operate globally and both in the United Kingdom and Your intended cruise destination(s)), and third parties who help Us indirectly (such as our IT service providers, marketing mailing houses who may create and/or distribute Our marketing materials to You). We do not share Your personal data with third parties for their own marketing purposes. We may provide You with services from third party suppliers.
(4) Your travel agent.
(5) Our banks and other payment processing service providers who process Your payments to Us.
(6) The law enforcement authorities of the United Kingdom and other jurisdictions, and in particular their border control, anti-terrorism and related functions. See the section "Our transfer of your personal data abroad", below, for more information.
(7) Our IT service providers who provide, maintain, improve, manage, optimise or fix the IT facilities that We use or rely on in our business, including computing devices, computer networks, connectivity, telecommunications, software, our Website.
(8) Our online service providers, who provide marketing and advertising placement services for Us, including providers of search engines, analytics services, behavioural marketing services, and online applications and services including social media.
(9) Our professional service providers, such as accountants, auditors and insurance brokers.
(10) Credit reference agencies that We use to assess Your credit score where this is a condition of Us entering into a contract with You.
(11) Your and Our insurers and their agents, and Your and Our medical staff and legal advisers.
(12) Any third party company or companies in the event that We go through a business transition, such as a merger, being acquired by another person or company, or selling a portion of Our assets.
We reserve the right to disclose Your personal data to other third parties if We have lawful grounds to do so, or are under a legal obligation to disclose or share it with them, or in order to established, exercise or defend Our legal rights, or to protect the rights, property, or safety of the Company. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
OUR TRANSFER OF YOUR PERSONAL DATA ABROAD
As stated above, in some cases We will transfer Your personal data to a location that is outside the United Kingdom. Decisions as to, whether or not States outside the European Economic Area have "adequate" safeguards for personal data will be made in accordance with Data Protection Legislation. In the absence of such decisions, the transfer of Your personal data outside the UK or EEA can still be lawful if safeguards are in place, or if We have Your explicit consent or some other permission recognised by GDPR. • In the case of the United States, it is not currently considered to provide adequate safeguards. We have a contract in place with Our parent company to safeguard Your personal data. • If Your intended cruise destination(s) is/are outside the United Kingdom, the relevant state(s) may not provide adequate safeguards. We can lawfully make necessary transfers of Your personal data to these overseas locations if We have Your explicit consent. If We ask You for Your explicit consent, it may be the case that We will be unable to make the necessary transfer(s) of Your personal data to these overseas locations unless We obtain Your consent. This may impact on Our ability to process Your personal data using Our electronic systems, and/or it may result in You being denied entry to Your intended cruise destination(s). .
• In the case of the United States, it is not currently considered to provide adequate safeguards, although its Government operates Privacy Shield and members of that scheme are considered to have “adequate” safeguards.
• If Your intended cruise destination(s) is/are outside the European Economic Area, the relevant state(s) may not provide adequate safeguards. We can lawfully make necessary transfers of Your personal data to these overseas locations if We have Your explicit consent. If We ask You for Your explicit consent, it may be the case that We will be unable to make the necessary transfer(s) of Your personal data to these overseas locations unless We obtain your consent. This may impact on Our ability to process Your personal data using Our electronic systems, and/or it may result in You being denied entry to Your intended cruise destination(s).
YOUR RIGHTS UNDER THE DATA PROTECTION LEGISLATION:
(1) You have the right to access personal data that We hold about You. Your right of access can be exercised in accordance with the Data Protection Legislation. You can submit a data access request at any time. In order to do this, please contact Us at data.protection@viking.com.
(2) If You become aware of any inaccuracies in Your personal data which We process on Your behalf, You have a right to ask Us to rectify the inaccuracies. On receiving Your request We will either fulfil it or explain why We have decided not to.
(3) To the extent that (a) We no longer need to use Your personal data (e.g. You no longer wish to receive marketing from Us, or You tell us that You no longer wish to go on cruises) for purposes described in our Notices, or (b) We rely on Your consent and You have withdrawn it, or (c) You object to Our legitimate interests for using Your personal data and no exception applies to permit Us to keep using it, or (d) it is established that We did not have the lawful right to process Your personal data, or (e) the law requires Us to erase Your personal data, You may ask Us to erase Your personal data. If we erase Your personal data, Your ability to use Our services will be affected, as described above.
(4) You have the right to ask Us not to process Your personal data for marketing purposes (including profiling). You may unsubscribe at any time by emailing Us directly at data.protection@viking.com.
(5) You have the right to object to Our processing of Your personal data to the extent that (a) We use the personal data on grounds of Our legitimate interests and no exception applies to permit Us to keep using it, or (b) We use it for direct marketing purposes, or (c) We use it for scientific or historical research purposes or statistical purposes and no exception applies to permit Us to keep using it.
(6) You have the right to ask Us to restrict Our processing of your personal data to the extent that (a) You have questioned the accuracy of the personal data and We are still checking its accuracy, (b) it is established that We did not have the lawful right to process the personal data,
(c) We no longer need to use Your personal data for the purposes We collected or used it for but You need it to be preserved for the purposes of legal claims, or (d) You have exercised Your right to object to Our use of your personal data and no exception applies to permit Us to keep using it.
(7) You have the right to request that We provide to You, or to another data controller on Your behalf, a copy of any of Your personal data which We process using automated means based on your consent, so that You may reuse such personal data for Your own purposes on alternative services.
(8) You have the right not to be subject to automated processing which significantly affects You, unless We need to carry out the automated decision-making to enter into or perform Our contract with You, or We are authorised by law to use the personal data for automated decision- making, or We have Your explicit consent.
(9) You have the right to complain to the Information Commissioner (http://www.ico.gov.uk/) if You have any concerns in respect of the handling of Your personal data by the Company.
If You would like to exercise any of the above rights, including to withdraw Your consent (where Our processing of Your personal information relies on Your consent), please contact Us at data.protection@viking.com.
OUR PROTECTION OF YOUR PERSONAL INFORMATION
We have taken reasonable steps to put in place appropriate security measures to protect Your personal data when it is processed by Us or on our behalf.
We do not accept any responsibility for the policies of third party Data Controllers, such as providers of search engines and social media services. Your use of such third parties, their websites and services is at Your own risk.
Please check the third parties’ Privacy Notices before You submit any personal data to them.
CHANGES TO PRIVACY NOTICE
We reserve the right to make changes to this Privacy Notice from time to time. If this Privacy Notice changes in any way, We will place an updated version on our Website. Regularly reviewing our Website ensures that You are always aware of what information We collect, how We use it and under what circumstances, if any, We will share it with other parties.
If You do not agree to the changes that we make from time to time, please tell Us via data.protection@viking.com. If material changes are made to this Privacy Notice, We will notify You by placing a prominent notice on the Website.
YOUR COMMENTS ARE APPRECIATED
If You have any questions or comments regarding the Privacy Notice, You can send Us an email at data.protection@viking.com .
YOUR KEY RIGHTS UNDER THE PACKAGE TRAVEL AND LINKED TRAVEL ARRANGEMENTS REGULATIONS 2018
General
The combination of travel services offered to you is a package within the meaning of the Package Travel and Linked Travel Arrangements Regulations 2018.
Therefore you will benefit from all EU rights applying to the packages. Viking River Cruises UK Limited will be fully responsible for the proper performance of the package as a whole.
Additionally, as required by law, Viking River Cruises UK Limited has protection in place to refund your payments and, where transport is included in the package, to ensure your repatriation in the event that it becomes insolvent.
KEY RIGHTS UNDER THE PACKAGE TRAVEL AND LINKED TRAVEL ARRANGEMENTS REGULATIONS 2018
• Travellers will receive all essential information about the package before concluding the package travel contract.
• There is always at least one trader who is liable for the proper performance of all the travel services included in the contract.
• Travellers are given an emergency telephone number or details of a contact point where they can get in touch with the organiser or the travel agent.
• Travellers may transfer the package to another person, on reasonable notice and possibly subject to additional costs.
• The price of the package may only be increased if specific costs rise (for instance fuel prices), and if expressly provided for in the contract, and in any event not later than 20 days before the start of the package. If the price increase exceeds 8% of the price of the package, the traveller may terminate the contract. If the organiser reserves the right to a price increase, the traveller has a right to a price reduction if there is a decrease in the relevant costs.
• Travellers may terminate the contract without paying any termination fee and get a full refund of any payments if any of the essential elements of the package, other than the price, has changed significantly. If before the start of the package the trader responsible for the package cancels the package, travellers are entitled to a refund and compensation where appropriate.
• Travellers may terminate the contract without paying any termination fee before the start of the package in the event of exceptional circumstances, for instance if there are serious security problems at the destination which are likely to affect the package.
• Additionally, travellers may at any time before the start of the package terminate the contract in return for an appropriate and justifiable termination fee.
• If, after the start of the package, significant elements of the package cannot be provided as agreed, suitable alternative arrangements will have to be offered to the traveller at no extra cost. Travellers may terminate the contract without paying any termination fee, where services are not performed in accordance with the contract and this substantially affects the performance of the package and the organiser fails to remedy the problem.
• Travellers are also entitled to a price reduction or compensation for damages or both where the travel services are not performed or are improperly performed.
• The organiser has to provide assistance if the traveller is in difficulty.
• If the organiser or the retailer becomes insolvent, payments will be refunded. If the organiser or, where applicable, the retailer becomes insolvent after the start of the package and if transport is included in the package, repatriation of the travellers is secured. Viking River Cruises UK Limited has taken out insolvency protection with the following entities:
For flight inclusive holidays: Civil Aviation Authority of 45-59 Kingsway, London WC2B 6TE, www.caa.co.uk, telephone: 0330 103 6350, email: claims@caa.co.uk
For package holidays that do not include a flight: ABTA – the Travel Association at 30 Park Street, London SE1 9EQ, www.abta.com, telephone: 0203 7588779, email:customerprotection@abta.co.uk
THE PACKAGE TRAVEL AND LINKED TRAVEL ARRANGEMENTS REGULATIONS 2018
Can be found at: www.legislation.gov.uk/uksi/2018/634/contents/made
