Overview WHO WE ARE AND WHO THIS POLICY APPLIES TO

This privacy policy (this “Privacy Policy”) is intended to inform you how Virgin Cruises Limited whose office is located at 1000 S. Pine Island Road, Suite 600, Plantation, Florida 33324 (“Virgin Voyages", "we”, “us” or “our”) may collect, use and disclose your personally identifiable information (“Personal Information”) and other information through our website located at FirstMates.com (the “Website”) as well as through our pages on other online channels and social media, such as Facebook, Instagram, and Twitter (collectively, the “Social Media”) and offline such as telephone calls (together the Website, Social Media and telephone calls referred to as the “Sites”). Your continued use of the Website at any time is deemed conclusive acceptance of this Privacy Policy, and amendments thereto that may be made by us from time to time in our sole discretion.  

This Privacy Policy applies for travel agents, travel agencies and their employees and agents and Virgin Voyages' business contacts who:

1. Are registered employees of or representatives acting on behalf of travel agencies that sell Virgin Voyages;
2. Apply to or register to become a First Mate on the Website; and
3. Communicate with or submit an enquiry to Virgin Voyages (for example, via the Website as defined below) ("Your Submissions"),“you”, “your”, “yours”, “yourself”, and collectively with others as "users".

We have a philosophy about the way we interact with our users. If you hear from us, we will always aim to be respectful, relevant and appropriate. If at any time you don’t feel we’ve lived up to our philosophy, please let us know straight away by getting in touch with us at FirstMates@virginvoyages.com or by post to 1000 S. Pine Island Road, Suite 600, Plantation, Florida 33324or by telephone (954) 361-9500. 

This Privacy Policy applies to any Personal Information provided within any voyage or cabin bookings ("Booking" or "Bookings") made through the Website for a customer, guest or traveller ("Customer" or "Customers"), but does not apply to any Bookings made via the VirginVoyages.com Customer website.

Modifications HOW THE TERMS OF THE PRIVACY POLICY MAY BE MODIFIED

We may change, modify, alter or otherwise update this Privacy Policy and how we handle the Personal Information we collect and process at any time. 

If we change anything important about this Privacy Policy (the information we collect, how we use it or why) we will highlight those changes at the top of the Privacy Policy and provide a prominent link to it for a reasonable length of time following the change and/or send you an email highlighting the key changes.

Any material changes in the way we use Personal Information will apply only to Personal Information collected after the relevant material change, unless we obtain your consent in accordance with applicable law. All other changes and modifications are effective upon posting of the new Privacy Policy.

The current version of this Privacy Policy is accessible via the footer on each page of our Website and will be clearly accessible from our Social Media pages.

How we collect information

The information we hold about you comes from the way you engage with us, for example by doing any of the following:

• completing forms, submitting information or making a general enquiry via our Website;
• submitting Customer Booking information and purchasing / reserving cruises and cabins for Customers;
• registering your interest in partnering with us to become a First Mate;
• providing information in the course of or following your application to register as a First Mate;
• providing information in the course of negotiating and/or entering into contractual agreements with us; and
• corresponding with us by email, phone or otherwise.

The Website allows users to submit content known as Your Submissions. Virgin Voyages will collect, use and disclose your Personal Information and other information as described in this Privacy Policy, including collection of your Personal Information and other information via Your Submissions, phone calls and other communications with Virgin Voyages and Virgin Voyages third party providers with whom you communicate directly.

We may obtain Personal Information or non-Personal Information from third parties such as our service providers, vendors, independent contractors, business partners, sponsors, and other sources (such as from offline records or publicly available information). We may combine Personal Information we collect with information that we obtain from these sources. We will treat any such combined information as Personal Information.

What information we collect

Personal Information

Account Information: We will provide you with an account ID and password that allows you to login to the Website and modify or update your account data on the Website. You shall be solely responsible for the confidentiality of your ID and password and for any authorized or unauthorized access to the Website by any person using your ID and/or password. You agree to notify us immediately of any unauthorized use of your password, ID, or any other breach of security discovered by you.

Sites Use: We may receive and store any information you enter through your account, the Sites or provide to us in any other way. The types of Personal Information collected may include, where applicable, your name, user name, address, citizenship, residency, email address, phone number, gender, birthdate, account ID and password, your image, words, and actions in photos or videos that you upload through your account or the Website, information you provide when you contact us or, when applicable, to reserve cabins or book cruises with us, transaction history, IP address, Site use information, browser information, type of user, type of cruise preference, location information, blogs, stories and all information within Your Submissions. 

Communications: When you sign up for a account, book or reserve a cruise / cabin for a Customer, and/or use certain features of the Website, you may opt-in to receive marketing communications from us. You can subsequently manage some of your messaging preferences by clicking "unsubscribe" on marketing emails or contacting FirstMates@virginvoyages.com, but note that you cannot opt out of receiving transactional, administrative, legal or technical messages from us. 

We may collect information you provide us through correspondence and general feedback. We may store Personal Information that you provide through communications to us, including information received from phone calls, letters, emails and other electronic messages, or in person.

Other information: We may collect information sent to us by you that may be relevant to the fulfilment of a Booking request. This information may, but, is not limited to the names of Customers' family members, or details of disabilities / special requests in relation to the Booking.

Technical Information and Non-Personal Information

We may collect and store technical information provided by your computer or mobile device in connection with your use of the Sites, such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, phone number, unique device identifier, advertising identifier, location (including geolocation, beacon based location, and GPS location) and requested and referring URLs. 

We may de-identify or aggregate Personal Information to create Non-Personal Information. We may combine certain information about your use of the Sites with similar information that we obtain from other users for use in an aggregate or anonymous manner. We will treat as Personal Information any non-Personal Information that is combined with Personal Information.

Personal information WHY AND HOW WE USE YOUR PERSONAL INFORMATION

We will use your Personal Information where:

1. This is necessary to enter into or perform our contract with you, including, but not limited to, the processing and administration of Bookings – for example, using your contact details and your Customers' information in order to provide the cruise / cabin that you have requested / reserved / purchased on behalf of your Customer.
2. This is necessary to comply with legal or regulatory requirements – for example, disclosure of information in connection with law enforcement purposes.
3. This is necessary as in the public interest – for example, undertaking anti-fraud screening and verifying your identity.
4. We have collected your consent – for example, in order to send you direct marketing messages.  
5. This is necessary for the purposes of our legitimate interests including: 

• providing you with the services that you request from us.
• processing or confirming information on a requested Booking on behalf of Customers, on-boarding you as First Mate, providing products and services to you, communicating with you about a Booking;
• to contact you in the course of providing services to you;
• to enable us to have payments processed to you such as commission / bonus payments;
• for internal record keeping and account creation;
• improving the content of the Sites;
• to adapt the Sites to your needs;
• to carry out surveys;
• understanding how you use the Sites;
• understanding and responding to your feedback; 
• researching and analysing the services you want and the assistance you may need;
• personalising our offers so we're better able to provide offers and ideas that are relevant to you;
• to administer promotions including to check whether you are eligible to enter;
• maintaining a public profile on both traditional and Social Media;
• ensuring that debts are paid;
• maintaining suppression records to ensure we have a record of your objection to direct marketing (if given);
• assessing the number of visitors, posts, page views, reviews and followers in order to optimise future marketing campaigns; 
• for insight purposes (for example, to analyse market trends and demographics, and develop the service which we offer to you or other individuals in the future); and
• transfer of personal data in relation to the sale, transfer or re-organisation of all or part of our business and the acquisition of business.

We take great precautions to keep the information you share with us safe and private. We will not disclose your Personal Mobile Phone Information to any persons or third parties/affiliates outside of our company, nor lease, license, rent, transfer, disclose, disseminate or otherwise grant access to such information for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. Cookies will enable the personalization of your mobile messaging experience (e.g., sending you personalized text messages such as shopping cart or booking hold reminders).

Legal requirements

We need to collect certain types of information for compliance with legal requirements relating to your identity verification obligations. If suitable identity documentation (such as a valid passport) is not provided we cannot agree to provide our products or services to you.

Your Personal Information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claims. We will not delete Personal Information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

Payment information

When you enter Customer payment information through our Website, we do not collect or store this data, and you provide this information directly to a third party payment processor who will act as data controller in relation to any payment information. In relation to Customer payment information relevant third party payment provider will be specified on the payment input screen after you have chosen how you would like to pay for the Booking.

We use a third party payment processor for payment, analytics, and other business services. If you purchase anything from us including via our third party payment processor, they will collect your payment information. 

You can learn more about our third party payment processor, including purposes for processing your Personal Information and read the relevant privacy policy sending us a request for information via firstmates@virginvoyages.com

The following information that could be requested for the payment processing and Booking services available via the Website:

• Customer contact information provided to us, by you, in order for us to fulfil a Booking request;
• Customer contact details, such as name, postal address, telephone number, email address;
• financial and transaction data of Customers, such as credit, debit card or bank account information; and
• other Customer personal data, such as date of birth.

Direct marketing

We may use certain Personal Information to market to you, by sending you emails to promote our products and services but only with your consent. 

If we send you emails to promote our services, unsubscribe instructions will be included. You can withdraw your consent to receiving direct marketing from us at any time by following these unsubscribe instructions or by emailing us at FirstMates@virginvoyages.com. You may not opt-out of receiving communications regarding your transactional, administrative, legal or technical messages about the Sites or our services.

Analysis and marketing

We may display offers, promotions, products or services from us or from our business partners or advertisers on the Sites, which we think will interest you based upon the Personal Information we collect from you.

We also use third party tools, including Facebook Custom Audience and related tools provided by Facebook to provide advertising to you on other websites (including Social Media networks such as Facebook). Facebook Custom Audience is a tool provided by Facebook which matches our customers and visitors with a Facebook user in order to provide advertising to them on the Facebook platform. For this purpose, we share your information with these third party providers (for example Facebook) and use cookies or similar technologies on our Sites to analyse the effectiveness of our advertising including on other websites. For more information about the use of data by Facebook, please click on the following link: https://www.facebook.com/privacy/explanation.To opt-out of Facebook Custom Audiences, please adjust your social advertising settings at https://www.facebook.com/ads/settings or use the opt-out features in the Facebook advertisement.

Information Sharing WHEN AND WHY WE SHARE YOUR PERSONAL INFORMATION

We may share your Personal Information if:

1. You specifically request this;
2. We are required to do so to comply with the law, regulations, subpoenas, or with the direction of the courts, regulators or other authorities;
3. We feel it is reasonably necessary to prevent illegal activity or to protect our interests or the safety of others;
4. In connection with the sale, transfer or other sharing of some or all of our assets including without limitation, in connection with a merger, reorganization, or sale of assets, or in the event of bankruptcy;
5. External hosting providers in order for the administration of our Sites (or any other online platform operated by us); and / or
6. Our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities.

We share your Personal Information with our employees, contractors, and other third party service providers, to help provide and improve our services to you, so that third party service providers can provide services (such as regarding the trips and activities that such third party service providers) requested by you and to carry out surveys and user analysis to understand your needs and preferences. For instance, we will share your Personal Information with our email host and our email newsletter distributor. 

We also may share your Personal Information in any manner in its de-identified or aggregated form, including sharing some broader statistics and user profiling information with third parties (provided always that all information shared is de-identified or aggregated and as such you cannot be identified from such information).

Keep in mind, when you share and post Your Submissions using the Sites, Your Submissions may be public and may be viewed by and available to anyone and can be seen or accessed through online search engines, APIs, and offline media.

Information Retention HOW LONG WE KEEP YOUR INFORMATION

We will keep your Personal Information for as long as it is reasonably necessary. How long we keep it depends very much on the type of Personal Information and purpose for which it was collected.

The criteria we use to determine the retention period for certain categories of Personal Information is as follows:

1. Whether you have an account with us;
2. Whether you have outstanding Bookings;
3. Whether there are contractual obligations that exist that require us to retain the Personal Information for a specified period of time;
4. Whether there is any ongoing legal claim that relates to any Booking you have made with us, or that is otherwise related to your relationship with us;
5. Whether any applicable law, statute, or regulation allows for a specific retention period; and
6. What the expectation for retention was at the time the Personal Information was provided to us.

Cookies

We use cookies that identify your browser or device. They collect and store information when you visit our Website about how you use it. For more information about cookies, the types of cookies we use and how we use them please see our Cookie Policy which may be found at the footer of the Firstmates.com Website.

Website security THE EFFORTS WE MAKE TO SECURE THE WEBSITE

We have in place industry standard security procedures as to how your Personal Information is stored and used in order to prevent any unauthorized access or misuse of it. We take security extremely seriously, but as no system is 100% secure so we can’t completely guarantee the protection of your Personal Information, any more than any other organization can. Thus, we cannot guarantee that such information will not be lost, disclosed or accessed by accidental circumstances or by the unauthorized acts of others.

Children OUR POLICIES REGARDING INFORMATION ABOUT CHILDREN

The Sites are intended for general use of persons who have reached the age of majority or consent in their jurisdiction of residence. Persons between thirteen (13) years of age and the age of majority or consent in their jurisdiction of residence may only use the Sites with consent and supervision of a parent or legal guardian. The Sites are not targeted to anyone under eighteen (18) years of age. As one may book a voyage two years in advance, and our minimum age to sail is eighteen (18) years of age, Virgin Voyages does not knowingly collect Personal Information from anyone under sixteen (16) years of age. If we learn that we have inadvertently collected Personal Information from anyone under sixteen (16) years of age, we will promptly delete or redact such information from our records. If you believe that we have collected information from a person under the majority or consent in their jurisdiction of residence, please contact us at FirstMates@virginvoyages.com.

If Your Submission contains images or Personal Information related to anyone under the age of majority or consent in their jurisdiction of residence, you may not post, upload, or share Your Submission. By submitting Your Submission to us, you represent that all persons in your submission are over eighteen (18) years of age in Your Submission, and you waive all claims relating to any Personal Information of a child referenced or shown in Your Submission.

Links to other websites

The Sites may contain links to websites or Social Media of third parties. We don’t have any control over the content of any of the sites or Social Media at these links, and we take no responsibility for any information you may give the websites or other Social Media. Other websites have different privacy and security policies. Once you visit another website, you are subject to the provisions of the privacy policy and other terms of such website and not by this Privacy Policy.

Sending us your information

We are based in the United States and when you submit Personal Information through our Sites this is sent to us in the United States.

California Residents NOTICE OF PRIVACY RIGHTS OF CALIFORNIA RESIDENTS

Virgin Voyages may disclose your Personal Information to our affiliates or other third parties for their use in the marketing of their products or services to you unless you request that we do not do so (“Opt-Out Policy”). You may make such a request by sending us an email at FirstMates@virginvoyages.com or mailing your request to:

Virgin Cruises Intermediate Limited

1000 South Pine Island Road, Suite 600

Plantation, FL 33324

RE: Disclosure Request

When contacting us, please indicate your name, address, email address, to which of the Sites your request pertains, and what Personal Information you do not want us to share with third parties for their direct marketing purposes. There is no charge for controlling the sharing of your Personal Information or for processing this request.

If you are a California resident and have provided Personal Information to a business with an Opt-Out Policy and that business is required to respond to such requests, you may be entitled by law to request certain information regarding disclosures of Personal Information made by to third parties for the third parties’ direct marketing purposes during the immediately preceding calendar year (“Disclosure Request”). Such a business is not required to respond to more than one Disclosure Request per customer each year, or to respond to requests made by means other than through the contact information designated by the business for such purposes. 

If you are interested in making a Disclosure Request, please send us an email at FirstMates@virginvoyages.com. In the Disclosure Request, specify that you seek your “California Customer Choice Privacy Notice.” Please allow thirty (30) days for a response, but understand that we are entitled by law to respond to your Disclosure Request by notifying you of your right to prevent the disclosure of Personal Information pursuant to our Opt-Out Policy, and by providing you with a cost-free means to exercise that right.

Talk to us

If you have any queries, comments or complaints regarding this Privacy Policy, please just get in touch with us at FirstMates@virginvoyages.com or by post at 1000 S. Pine Island Road, Suite 600, Plantation, Florida 33324or by calling (954) 361-9500.

EU and GDPR ENHANCED EUROPEAN UNION REQUIREMENTS AND COMPLIANCE WITH THE GENERAL DATA PROTECTION REGULATION ("GDPR")

This section applies if GDPR applies to you, for example, if you use our Sites while in the EEA.

YOUR RIGHTS

Depending on various factors, you may have rights in relation to your Personal Information. These rights will apply only some of the time. If you would like to use, or talk to us about, any of these rights, please contact us at FirstMates@virginvoyages.com. 

• Access: You can ask us if we are using or storing your Personal Information and, if we are, you can request a copy of your Personal Information. This means you can receive a copy of the Personal Information we hold about you and some other information about it to check that we are lawfully processing it.  
• Correction: You can request that any incomplete or inaccurate Personal Information we hold about you is corrected. If you notice that any Personal Information we hold about you is not right, please let us know and we can arrange for this to be corrected.
• Erasure: You can ask us to delete or remove Personal Information in some circumstances. We may refuse a request for erasure such as where the personal data is required for compliance with law or in connection with legal claims.   
• Restriction: You can ask us to suspend the processing of your Personal Information for example if you want us to check the Personal Information is correct or the reason we are using your Personal Information.
• Transfer: You may request the transfer of certain of your Personal Information to another party. 
• Objection: Where we are using your Personal Information based on our legitimate interests (or those of a third party) you may challenge this.  However we may be entitled to continue processing your Personal Information based on the our legitimate interests or where this is relevant to legal claims.  

If you want to exercise any of these rights, please contact our data officer in writing at PrivacyOfficer@virginvoyages.com.

You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident where we are based or where an alleged infringement of Data Protection law has taken place. 

If you are resident in the UK you can make a complaint to the Information Commissioner's Office (Tel: 0303 123 1113 or at www.ico.org.uk).

INTERNATIONAL DATA TRANSFERS

We store our information in the United States which does not have equivalent data protection laws to those applicable in the EU and UK. However, to ensure your Personal Information is properly protected in line with EU and UK data protection law, we will only transfer data from the United States to jurisdictions outside the scope of the GDPR where the appropriate safeguards set out in the GDPR are in place. 

Please contact us at FirstMates@virginvoyages.com if you would like further information on the countries to which we may transfer Personal Information and the specific safeguard used by us when transferring your Personal Information outside of the scope of the GDPR.

Canada ENHANCED CANADIAN REQUIREMENTS

This section applies if Canadian law applies to you, for example, if you use our Sites while in Canada.

YOUR RIGHTS

Depending on various factors, you may have rights in relation to your Personal Information. These rights will apply only some of the time. If you would like to use, or talk to us about, any of these rights, please contact us at PrivacyOfficer@virginvoyages.com. 

• Access: You can ask us if we are using or storing your Personal Information and, if we are, you can request a copy of your Personal Information. This means you can receive a copy of the Personal Information we hold about you and some other information about it to check that we are lawfully processing it.  
• Correction: You can request that any incomplete or inaccurate Personal Information we hold about you is corrected. If you notice that any Personal Information we hold about you is not right, please let us know and we can arrange for this to be corrected.

If you want to exercise any of these rights, please contact our privacy officer in writing at PrivacyOfficer@virginvoyages.com.

You also have a right to lodge a complaint with the Canadian Privacy Commissioner.

Australia ENHANCED AUSTRALIAN REQUIREMENTS

This section applies to our management of your personal information if Australian law applies to you, for example, if you use our Sites while in Australia. 

This section supplements your rights found above in Part I - Section for Global Application.

Your personal information will be managed in an open and transparent way in compliance with Australian Privacy Principles. We provide this information:

If you want to exercise any of these rights, please contact our privacy officer in writing by e-mail at PrivacyOfficer@virginvoyages.com.

Mobile messaging

By joining the Virgin Voyages First Mates mobile alerts program, you have consented to receive promotional and personalized marketing text messages (ex: booking hold reminders). For help call +1 800 430 5308  or email firstmates@virginvoyages.com. To stop receiving messages at any time, text STOP to 53279. For HELP, text HELP to 53279. 

Your consent to receive text messages is not a condition of purchase. Msg&Data rates may apply. Carriers are not liable for delayed or undelivered messages. The Virgin Voyages mobile alerts program is available in the US only.

Standard messaging rates apply to your entry or submission message to any Virgin Voyages text message service, our confirmation, and all subsequent text message correspondence. Please contact your wireless carrier for information about your messaging and data plan(s). Your carrier may impose message or charge limitations on your account that are outside our control. All associated charges are billed by and payable to your mobile service provider.

Data obtained from you in connection with our text message service may include your cell phone number, your carrier's name, and the date, time and content of your messages to us and other information that you may provide. We may use this information to contact you and to provide the services you request from us, and to otherwise operate, develop and improve the service. We and third-party partners collect information using cookies, pixel tags, plugins, or similar Proprietary & Confidential technologies. For example, we may use pixel tags to recognize and alert you of booking reminders. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Your wireless carrier and other service providers may also collect data about your text usage, and their practices are governed by their own policies. We will only use the information you provide to the service to transmit your text message. We reserve the right at all times to disclose any information as necessary to satisfy any law, regulation, or governmental request, to avoid liability, or to protect our rights or property.