Privacy and Cookies Policy

Fred. Olsen Cruise Lines (FOCL) recognises the importance of protecting your privacy. Please be assured that we follow a strict policy of not selling or trading any personal or sensitive information about our customers or prospective customers to any company, organisation or person outside of the Fred. Olsen Group or our associated companies.

Fred. Olsen Cruise Lines are committed to protecting the privacy of everybody that travels with us. This privacy notice is our way of being transparent to you on how we use your personal data when you book with us and demonstrate our fair processing practices.

Categories of Personal Data We Process

In order for us to facilitate your booking we require the following personal information about you and all persons on the booking:

Name; as on passport
Address
Phone Number(s)
Email
Payment method information
Nationality
Passport Number
Passport Expiry Date
Passport Issue Date
Place of Passport Issue
Date of Birth
Place of Birth
Gender
Emergency contact
- Name
- Contact details
- Relationship to the traveller
Travel Insurance Company, Policy Number & 24 hour medical emergency number

We are also obligated to obtain personal data of a special category such as health and medical information and information that could reveal your race or ethnicity, such as nationality.

We request the name and phone number of an emergency contact and their relationship to you. We realise that your emergency contact may not have heard of Fred. Olsen previously and so we ask you to inform them that you will be sharing their information with us. If they have any queries they can contact us using the details we have provided in this notice.

You are required to provide this information to us before we can confirm your booking and accept you on the cruise. If you fail to provide us with this information then you will not be able to board the Ship.

Receiving Data Through Third-Parties

We are proud to have a wide network of travel agents and travel partners. If you book through a travel agent we will receive your data through the travel agent of your choosing. If you have concerns that we may have received your information in error or would like to find out where we have received your information from, please contact us using the details in this notice.

Purposes of processing your personal data legal basis

We process your data for a variety of purposes both shoreside and when you are onboard with us. We always process personal data with a legal basis and the table below demonstrates our intended purposes and the legal basis we use to process your data.

Shoreside

Purpose	Legal Basis
Making your booking	Contractual Obligation
Obtaining medical information and information that can reveal race or ethnicity	Contractual obligation with explicit consent Your explicit consent is obtained through the provision of this information from yourself directly or the third party passing us this information. You can withdraw or decline consent however you will not be able to board our Ship without providing us with this information
Contacting you with information relating to your booking including itinerary changes and costs.	Contractual Obligation
Arranging flights or hotels	Contractual Obligation
Amending and transferring your booking at your request	Contractual Obligation
Contacting you from call centre if phone is cut off or call back requested	Legitimate Interest
Transferring your call to Holiday Extras in the event you require travel insurance or any other additions	Legitimate Interest
Contacting you with information on additional services relating to your cruise. For example: information on tours, upgrades, Ocean’s Club and special events	Legitimate Interests
Contacting you via email, phone and post about Fred. Olsen Cruises (we will always give the option to opt-out of this at the point we capture your information and in every subsequent communication with you.	Legitimate Interests
Call recording	Legitimate Interests
Using aggregated data to identify trends in bookings and for business reporting purposes	Legitimate Interests
Contacting you or your emergency contact in the event of an emergency	Vital Interests

Onboard

Purpose	Legal Basis
Uploading your information to the passenger management system	Contractual Obligation
Providing information to Immigration Authorities, customs and port inspection, Interpol and Police.	Legal Obligation
Preparing and sharing manifests and security lists for port agents and port authorities at the designated port-of-call	Legal Obligation
Retaining financial records of spend onboard	Legal Obligation
Fulfilling specialist dietary requirements	Vital Interests
Providing medical care	Vital Interests
Sharing medical consultation	Consent Consent is requested and captured at the point of the medical consultation. You can decline consent however this could limit your access to medical resources.
Contacting you or your emergency contact in the event of an emergency	Vital Interests
Storing passenger information in crew accessible areas at muster stations	Legitimate Interests
Filling in a Spa consultation form prior to treatment (contains medical information)	Legitimate interests with your explicit consent captured by you filling in the handwritten form. You may withdraw your consent to provide us with this information however this will affect your ability to receive treatments at our Spa onboard.
Communicating with you about information that directly relates to you. We do this using onboard mailing to your cabin	Contractual Obligation
We offer a facility that allows you to book or find out more information on future cruises	Legitimate Interests
CCTV	Legitimate Interests
Processing a guest’s image to validate the correct person is embarking and disembarking	Legitimate Interests
Recording financial details to settle onboard accounts	Legal Obligation
Recording feedback and complaints	Legitimate Interests
Taking videos and photographs of guests and crew to produce media including the Cruise Video	Legitimate Interests (Please inform a member of staff if you do not wish to be featured in these)

Recipients of your information

In order for us to deliver our cruise and services to you we have to transfer your information to third parties. The list below provides information on the types of third parties that we share information with. It is challenging to name specifically the third parties that we will transfer data and so we have provided categories of recipients for you instead.

Port Agents and Port Authorities
Tour Providers: if you book a tour through us
Specialist service providers; in the event you require a specialist service e.g. medical
Holiday Extras; if you need travel insurance – you will provide your information to Holiday Extras and provide us with the policy number
Fred Olsen Business Travel: if you require additional travel to board the Ship
Mailing houses; we transfer your name and address to mailing houses to send out brochures
Marketing and PR agency; Total Media

We travel all over the world and the recipients of your personal information can be in any one of the ports we can call at around the world. When docking and liaising with a recipient within Europe, the EEA and countries on the European Commission’s data protection ‘adequacy’ list; we use the countries own data protection regulation as the safeguard for your data over and above the technical and organisational measures we have put in place to secure your data. For recipients outside of this list we use either our contractual clauses or the fulfilment of our contract with you as the appropriate safeguard.

We will never sell your data to any third party.

Retention of your personal data

We retain the data relating to your booking for a minimum of 4 years which is a requirement for our ABTA regulatory compliance.

Information relating to the monetary value of your booking including financial transactions conducted onboard will be retained for a minimum of 7 years from the date of the transaction.

We retain medical information that we collect on you whilst onboard until such time as it is no longer needed as dictated by yourself, your insurers or by a medical professional involved in your treatment or care.

These retention periods are not inclusive of how long the recipients of your personal information may retain your data for.

Your Rights

We are always happy to fulfil any one of your rights. Your rights with respect to the personal data that we process on you are:

Right to information on how your data is processed
Right of access to the personal data we hold on you
Right to rectify any inaccurate data we process on you
Right to object to us processing your personal data
Right to erasure of your data
Right to data portability
Right to lodge a complaint with a data protection regulator
Right not to be subject to automated decision making

You can invoke any of your rights at anytime using the contact details listed in this notice. Please be aware that we can ask for identification documents to confirm we are disclosing information to the correct person. If you elect a representative to invoke these rights on your behalf we will request that the representative can demonstrate they have the authority to act on your behalf and their identity.

We do not conduct any automated decision making or profiling when you make a booking with us.

We do conduct some high-level profiling based on geographic location of bookers.

Data Controller

Fred. Olsen Cruise Lines is a data controller. We collect and process data for a number of purposes outlined in this notice. If you ever need to contact us you can by using the details below:

Address: Fred. Olsen House, White House Road, Ipswich, Suffolk, IP1 5LL

Phone: (+44) 01473 292 200

If you have a specific query relating to how we process your personal data you can contact our Data Protection Officer on:

Email: dataprotection@fredolsen.co.uk

Marketing Notice

This notice provides you with information on how we use data for marketing. We are committed to fair and transparent processing of people’s data and always offer the option to opt-out of our marketing communications.

Data Controller

Fred. Olsen Cruise Lines is a data controller. We collect and process data for a number of purposes outlined in this notice. If you ever need to contact us you can by using the details below:

Address: Fred. Olsen House, White House Road, Ipswich, Suffolk, IP1 5LL

Phone: (+44) 01473 292 200

If you have a specific query relating to how we process your personal data you can contact our Data Protection Officer on:

Email: dataprotection@fredolsen.co.uk

How we market

There are a few mediums through which we conduct marketing activities that require our use of people’s personal data. These are:

Online
Email
Postal
Telephone

We have detailed the way we use data to conduct these marketing activities below. We also market through press releases, billboard and publications but these do not require us to process our customers’ or prospective customers’ personal data.

Online

Social Media

What we do

We are on Facebook @fredolsencruiselines, Twitter @FredOlsenCruise, and Instagram @fred.olsencruiselines. We use these channels to promote our brand and connect with our customer base and, from time to time, advertise to potential future customers.

Some of these marketing channels allow us to place advertisements on the platform. There are several ways this can be achieved, listed below:

Uploading a post and paying to ‘boost’ the post to a specific demographic of people

With this method we do not see any of the personal information you have shared with the social media organisation but if the personal information you have shared matches the criteria for our demographic you will see the advert.

Uploading emails to the social media platform

Using this method of social media advertising we use the social media platform’s marketing engine to analyse email addresses that we upload to find similar profiles to the ones associated with the emails that we have uploaded. This practice is commonly known as ‘look-a-like’ modelling as it allows us to find potential new customers based on information on existing customer profiles.

Tracking pixel

Some social media platforms enable the ability for organisations to place a cookie or ‘pixel’ on the organisation’s website. This allows us to see the success of our social media advertising campaigns and also allow us to reach a wider audience through our advertising. We obtain your consent to place this cookie on your browser. Please refer to our cookie notice to understand how we use cookies and how you can withdraw your consent.

When we advertise through social media we never directly receive any of the information that you have submitted to the social media platform. We use the social platform as a catalyst to find the most appropriate people to present our advertisements to.

We strongly recommend that you review the privacy information of the social media platforms that you use and your privacy settings for the platform.

Web Advertising

What we do

We use online adverts to display on the internet when you browse. The placement of these adverts relies on cookies which are small files placed on your browser that personalise your internet browsing experience. The cookie obtains behavioural data about areas of the website you browse, links you click on and pages you visit.

We only place these cookies with your consent. Please refer to our cookie notice to understand how we use cookies and how you can withdraw your consent.

Email Marketing

What we do

We obtain email addresses through customers that book with us or enquire about our offering. Enquiries and bookings can come directly to us or through one of our associate Travel Agents. The Travel Agent should always make you aware that they are transferring your data to us. We can always tell you what source we received your data from and you will be able to opt-out of receiving email marketing communications when you provide your data to us and on every subsequent email communication using our unsubscribe link.

When we undertake an email marketing campaign, we design our marketing materials and select the email recipients we believe the communication would be most relevant to. As part of this process, we remove those addresses, known as having opted out email communications. We then load the email addresses into our third-party email communication platform. This platform offers a second stage of removing anyone opted out. Once this process has been completed we send the email out. We have a Non-Disclosure Agreement (NDA) with our email communication platform (Evomail).

The email communication platform also enables us to track how many unsubscribes, opens and link clicks (if there are website links in the email) have occurred.

We email market to people who have enquired with us or have made bookings previously. From time to time, we purchase lists of potential customers’ email addresses. We use the ‘soft opt-in’ provision of the Privacy and Electronics Communications Regulations (PECR) as our legal basis to conduct our marketing activities in this way, in-line with our legitimate interests as a data controller.

Postal Marketing

What we do

There are two methods we use to run a postal marketing campaign.

Mailing to people we have the address for
Mailing to people whose address we do not have; commonly known as ‘door drops’

Mailing to people we have the address for

We send out postal marketing communications to people whose addresses we have on file to promote additional options for existing bookings or our direct mail to promote our cruise programme and offers.

In order to deliver our mail to you we use a few different third parties. Often we print the name of the desired recipient and their address directly on our brochure, magazine or general mailer. To do this we use a specialist third party printing organisations to print this information directly onto the item we are sending out.

As part of this process, we use a postage consolidator. We send data to this third party so that they may process it, before printing, to increase postage efficiencies and reduce postage costs. The postage consolidator we use is Onepost.

We obtain guarantees to ensure that all third parties that we send personal data to comply with data protection regulations and our information security standards.

Mailing to people whose address we do not have

We are always interested in expanding our customer base and we use unsolicited mail as method to achieve this. When we decide to carry out an unsolicited mailing campaign we determine which area we would like to send our communications to using common providers that work off aggregated data sets such as Whistl.

When doing this type of marketing we do not base the strategy on personal data but may use information that we have obtained through bookings to determine the best geographical location to send out mailers to.

Telephone Marketing

On the Fred. Olsen Cruise Lines website we offer users the chance to request a call back. This requires the user to provide their name and telephone number in order for a member of our Reservations Department to outbound call and assist with the enquiry. This service is provided by Optilead.

We utilise marketing specific telephone numbers on promotional material to enable us to track response to specific campaigns. We also capture inbound call numbers for business intelligence reporting purposes this is a service provided to us by ResponseTap and Daisy Communications.

If we are unable to take your call we will call you back on the number that you have called on. If you have booked or enquired with us previously we can contact you about related products. You can always opt-out of telephone calls.

Your rights and our commitment to ethical marketing practices

We are committed to ensuring that we only market through ethical practices. We uphold your rights with respect to privacy and data protection. These rights are:

Right to information on how your data is processed
Right of access to the personal data we hold on you
Right to rectify any inaccurate data we process on you
Right to object to us processing your personal data
Right to erasure of your data
Right to data portability
Right to lodge a complaint with a data protection regulator
Right not to be subject to automated decision making

You can invoke any of your rights at any time using the contact details listed in this notice. Please be aware that we can ask for identification documents to confirm we are disclosing information to the correct person. If you elect a representative to invoke these rights on your behalf we will request that the representative can demonstrate they have the authority to act on your behalf and their identity.

Retention

We retain marketing data until such time as when requested to remove data or if the marketing department feel in their professional opinion it is best to remove marketing data.

Obligation to provide information

You are not obligated to provide your information for marketing purposes. However, we will use the information you disclose, when booking or enquiring with us, for marketing purposes.

Opt-out

You are always able to opt-out of marketing communications in the following ways:

For email marketing – at the time we capture your email and on the unsubscribe line at the bottom of the email
For telephone marketing – on the phone call
Social media marketing – settings on the social media platform
Postal marketing – on the mailer that has been sent there is information on how to opt-out

If you have any questions relating to opting out please contact us using the details we have provided in this notice.

Obtaining data through third parties

In such circumstance we obtain personal data through a third party we will be able to tell you our source of your data.

Cookies

Fred. Olsen are committed to protecting the privacy of everybody that travels with us. This privacy notice is our way of being transparent to you on how we use your browsing data when you visit our website. We use cookies on our website which can collect personal data as you browse our website.

Data controller

Fred. Olsen Cruise Lines the data controller. We collect and process data for a number of purposes outlined in this notice. If you ever need to contact us you can by using the details below:

Address: Fred. Olsen House, White House Road, Ipswich, Suffolk, IP1 5LL

Phone: (+44) 01473 292 200

If you have a specific query relating to how we process your personal data you can contact our Data Protection Officer on:

Email: dataprotection@fredolsen.com

Categories of personal data we process

Here is a list of personal data that we collect when you visit our website.

Cookies:

Internet Protocol (IP) address
Device type
Browser type
Web pages visited
Links clicked
Phone number
Website navigation
Social media profile information

We also obtain data on our web forms for taking enquiries and bookings, you can find out more about how we use this data in our Bookings and Marketing privacy notices. Below is a list of cookies we use and their purpose:

Necessary Cookies

Name	Cookie Name	Purpose
Simpeclick	overlay_5a96a50f6c723f146ce6857e overlay_5a96d8790d2c04139cdd8164	This cookie is used to prevent an overlay showing multiple times during the users session.
Simpeclick	agencyModal	Remembers that you have seen the agency user modal for the current session so it is not shown again. This cookie is deleted when you close your browser.
Simpeclick	AlertViewed-5a9fd98480b43c477aff5ed	This cookie is used to adhere to the users request to hide and alert and to prevent it being shown again unless the alert is amended.
Simpeclick	ASP.NET_SessionId	This cookie is essential for the website to recognise you as a unique visitor amongst all people currently on the site, and to enable the site to respond to your browsing choices. This cookie is deleted when you close your browser. For more information about this cookie please visit Microsoft's support article about how and why Microsoft ASP.NET session IDs are used.
Simpeclick	b1P	This cookie contains a number which identifies which of our load-balanced servers you are accessing in order to view our website. This helps to ensure your connection to our website is not interrupted during your visit. This cookie is deleted when you close your browser.
Simpeclick	cookieconsent_dismissed	Records if your consent to our cookies has been explicitly given by closing the cookie notification bar, or if your consent is only presumed at this point. Once consent has been given, the cookie will record this for one year.
Simpeclick	ExitIntent	In the booking engine, sets this to true if the exit intent popup has been shown, so it is not shown again during the current session
Simpeclick	lastviewedcabinfare
Simpeclick	remember-me.token	This cookie remebers your travel agent login information when you wish for us to remember you so that you do not need to continue entering your details.
Simpeclick	session.id session.id.oceans session.id.rivers	These cookie is essential for the website to recognise you as a unique visitor amongst all people currently on the site, and to enable the site to respond to your browsing choices. This cookie is deleted when you close your browser.
Simpeclick	simpleclick_config_cookies	This cookie enables us to controm which cookies are set for the user depending on which category the user has consented / not consented to.
Incapsula	incap_ses_#_# visid_incap_#	These cookies are used by a third party service in order to filter any malicious requests.
Live Person	LPSID-# LPSID LPSessionID IpTabId IpTestCookie# IpLastVisit-# LPVisitorID	Used by Live Person, these cookies check if the user's browser supports cookies and for the real time messaging platform to recognise active mesages and returning visits.
Facebook	fr	Used by Facebook to support Facebook login for My Cruises
Google+	APISID SSID	Used by Google to support Google+ login for My Cruises
Feefo	feefo.translations feefo.translationsUpdatedAt	These cookies detect the language of the users PC to display reviews accordingly.
CloudFare	__cfduid	Used by a third party service to identify trusted website traffic.

Preference cookies

Name	Cookie Name	Purpose
SimpleClick	Accordions Homepage_SocialFeed	These cookies remembers and records the open/close of accordions and social tabs on the website. These cookies are deleted when you close your browser.
SimpleClick	HideRecentlyViewed	Remembers a user's preference to hide the recently viewed cruises section on the website.
SimpleClick	session_code	This cookie is used as an identifier which tracks what cruises you view and how many times in order for us to highlight cruises you may also like.
SimpleClick	ViewedCruises	Tracks the cruises being viewed to allow us to surface cruises that have also been viewed by users on the cruise details pages

Statistic cookies

Name	Cookie Name	Purpose
Google Analytics	_ga _gat_UA-2014671-1 _gat_gtag_UA_2014671_1 _gid collect G_ENABLED_IDPS	These cookie helps us to improve the content on our website by giving us tracking information. For example (and not restricted to), the number of times a user has visited, which search engine you came from and the keyword you used.
Share This	__unam __sharethis_cookie_test__	Associated with the ShareThis social sharing widget placed in a site to enable sharing of content across various social networks. It counts clicks and shares of a particular webpage.
Response Tap	adiErr adiLP adiS adiV adiVi JSESSIONID	Used to collect anonymous information about the visitors who call us using the telephone numbers on the website. To learn more about ResponseTap please visit www.responsetap.com.
VE Interactive	__ssid {Guid}	This cookie may collect the following information and store it against an anonymous user ID: Product code from merchant sites the visitor has browsed and other information relevant to shopping behaviour on mainstream shopping sites. This information is used to serve targeted adverts to the visitor on an anonymous basis.

Marketing cookies

Name	Cookie Name	Purpose
Adalyser	__adal_ca __adal_cw __adal_id __adal_ses adal_out_queue_adalyserTracker_get tracking/track/v3/p	These cookies are used for TV tracking to store campaign and visit data.
Google Adwords	ads/ga-audiences pluto pluto2 fastclick	Used by Google Adwords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites. Pluto2 is a temporary cookie that is created in the case when no PLUTO cookie is set AND the user hits the advertiser site where a Re-Targeting pixel has been executed. Pluto is used to track preference information. Fastclick tells the delivery system that the browser had opted out of the network.
	sentisum_session	Persistent cookies are the cookies that are preserved through browser shutdowns. This means, even if you close this page today and ever return there in future, the website will know you’re a returning visitor. This may be used for “remember me” features, as well as persistent user tracking. These cookies, especially if set by third party organisations, are powerful tool for monitoring your activities across all the websites you visit.
Facebook	tr act, c_user, datr, dpr, js_ver, presence, sb, wd, xs	Facebook uses cookies for a vast range of purposes, from functionality and performance, to advertisements and measurements.
Doubleclick	_drt_ id IDE test_cookie	This cookie is used by Google AdSense DoubleClick for online advertising frequency capping and avoiding the duplication of ads on a page, meaning a user will not have to view the same ad over and over again. Used by Google DoubleClick to register and report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user
Yahoo	B	Collects anonymous data related to the user's website visits, such as the number of visits, average time spent on the website and what pages have been loaded. The registered data is used to categorise the users' interest and demographical profiles with the purpose of customising the website content depending on the visitor.
Google Preferences	NID PREF	These cookies allow our websites to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in.
Google+	APISID SSID	These cookies are used in conjunction with the Google+1 button to enable you to share information publicly, as part of your Google Profile.
Google security	SID SAPISID HSID	Google use these which contain digitally signed and encrypted records of a user’s Google account ID and most recent sign-in time. The combination of these two cookies allows Google to block many types of attack, such as attempts to steal the content of forms that you complete on web pages.

Receiving Data Through Third-Parties

We use third-party cookies to obtain some of the personal data listed above. The third party collects the data via a cookie and we obtain the data that has been collected through our website management platforms.

Purposes of processing your personal data legal basis

The cookies that we place that capture personal data are placed with your consent. We use your consent as the lawful basis for us to process data that is collected by a cookie. You may withdraw your consent at anytime by going to the cookies settings link in the website footer, removing the cookies placed from your browser settings and preventing cookies from being set in your browser settings. Please note that we have to store a cookie to confirm your preference. This will contain no other data than your cookie preference.

We process cookie data for the following purposes:

Analysing website performance
Ensuring our advertisements reach the right people
Tailoring our website to our visitors
Judging the effectiveness of online advertisements
Recording website visitor locations

Recipients of your information

Once we have captured information through a cookie the data largely stays in our website platform management solutions. Occasionally we share anonymised data with our marketing and PR company Total Media based in the UK.

Your Rights

We are always happy to fulfil any one of your rights. Your rights with respect to the personal data that we process on you are:

Right to information on how your data is processed
Right of access to the personal data we hold on you
Right to rectify any inaccurate data we process on you
Right to object to us processing your personal data
Right to erasure of your data
Right to data portability
Right to lodge a complaint with a data protection regulator
Right not to be subject to automated decision making

Where requests for data are collected through cookies we will need to ask specific questions before responding to the rights above. We are dedicated to being fair and transparent in the data that we process.

Provision of personal information and automated decision making

It is not mandatory for you to allow cookies before entering and browsing on our website. Some of the cookies we utilise use aggregated data in order to tailor the browsing experience. This is a form of profiling. You can opt-out of this type of profiling at any time by removing our cookies from your web browser and preventing cookies from being placed in the web browser settings.

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