Star Clippers 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 enquire and book with us, and demonstrates our fair processing practices.
Star Clippers is a cruise line with headquarters in Monaco, and Fred. Olsen Travel is the General Sales Agent (GSA) of Star Clippers in the UK. Both Star Clippers and Fred. Olsen Travel are data controllers. We collect and process data for a number of purposes outlined in this Notice. If you ever need to contact Fred. Olsen Travel you can by using the details below:
Address: Fred Olsen House, 42 White House Road, Ipswich IP1 5LL
Phone: (+44) 0808 250 8793
If you have a specific query relating to how we process your personal data, you can contact the Fred. Olsen Travel Data Protection Officer on:
Categories of Personal Data We Process
In order for us to facilitate your booking, we require the following personal information about you:
- Name as per passport (including middle names)
- Phone Number
- Payment Information
- Place of birth
- Passport Number
- Passport Issue/Expiry Date
- Date of Birth
- Email address
We are also obligated to obtain information that could reveal your race or ethnicity - such as nationality - and personal data of a special category such as health and medical information where necessary.
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 Star Clippers 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. If you fail to provide us with this information then you will not be able to book your cruise.
For enquiries, we can collect less information, which will include name and contact details as a minimum.
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 and Legal Basis
We process your data for a variety of purposes. As a GSA, we process your personal data to facilitate the booking and provisioning of your holiday and we have outlined these purposes in the table below. Please note that whilst on board the vessels, Star Clippers conduct additional processes with the personal data of our customers, and these purposes are also outlined below. 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.
|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 to us.
You can withdraw or decline consent, however without knowing your nationality we will not be able to book your holiday, and without knowing any medical conditions we could not ensure adequate medical care or provision.
|Call recording||Legitimate Interests|
|Contacting you with information relating to your booking||Contractual Obligation|
|Arranging flights, hotels, and transfers||Contractual Obligation|
|Amending your booking at your request||Contractual Obligation|
|Contacting you with information on additional services relating to your holiday. For example: information on excursions, upgrades and special events||Legitimate Interests (‘soft opt-in’ & opt-out)|
|Contacting you via email and post about Star Clippers
(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 (‘soft opt-in’ & opt-out)|
|Using aggregated data to identify trends in bookings and for business reporting purposes||Legitimate Interests|
|Contacting your emergency contact||Contractual obligation|
Star Clippers always process personal data on board their cruise vessels with a legal basis. The table below demonstrates the intended purposes and the legal basis they use to process your data.
|Uploading your information to the passenger management system||Contractual Obligation|
|Retaining your passport for customs and port inspection||Legal Obligation|
|Preparing and sharing manifests and security lists for port agents and port authorities at the designated port-of-call||Legal Obligation|
|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.
|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 this information; however, this will affect your ability to receive treatments at the Spa on board.
|Communicating with you about information that directly relates to you via on board mailing to your cabin||Contractual Obligation|
Recipients of Your Information
In order for us to deliver our services to you, we have to transfer your information to third parties. The list below provides information on the types of third parties with whom we share information. It is challenging to name specifically all of the third parties that we will transfer data to, and so we have provided some categories of recipients for you instead.
- Star Clippers, Miami and Monaco
- Airlines; we will inform you of the airline company we will transfer your data to when booking the flight,
- Hoteliers; we will inform you of the hotel company we will transfer your data to when booking the hotel,
- Transfers; we will inform you of the taxi/transfer company we will transfer your data to when booking the transfers to/ from the vessels,
- Tailor-made holiday providers; where flight/hotel/transfers are organised by a single company, we will inform you of the company we will transfer your data to when booking those services,
- Specialist service providers; in the event you require a specialist service e.g. medical services
- Mailing houses; for brochures and other mailers.
In turn, Star Clippers Miami will share your information with:
- Star Clippers, Monaco,
- Star Clippers vessels and key personnel on board,
- Port agents and port authorities.
Star Clippers vessels travel all over the world and the recipients of your personal information can be in any one of the ports called at. 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 and Star Clippers Miami and Monaco 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.
Star Clippers has GSA operations out in Miami, Florida, USA. The safeguard we use to protect data transferred to the United States is use of an online, secure portal managed by Star Clippers.
We will never sell your data to any third party.
Retention of Your Personal Data
We retain your personal data for only as long as it is necessary for the uses set out in this Privacy Notice and/or to meet legal, regulatory, and financial reporting requirements.
This includes the data relating to your booking for a minimum of 3 years, which is a requirement for legal purposes.
Information relating to the monetary value of your booking will be retained for a minimum of 6 years from the date of the transaction, in order to comply with statutory financial reporting requirements.
Star Clippers vessels retain medical information that they collect on you whilst on board until it is no longer needed as dictated by yourself or by a medical professional acting on your authority.
We retain your contact details until such time where you no longer wish to be contacted by Star Clippers.
These retention periods are not inclusive of how long the recipients of your personal information may retain your data.
We are always happy to fulfil any one of your rights wherever possible. 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 any time using the contact details listed in this Notice, subject to us having to keep the data for legitimate business or legal reasons.
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.
Data Protection and COVID-19
This is an addendum to Fred. Olsen Travel privacy notice. It explains how Fred.Olsen Travel (as Data Controller) may use your personal data, specifically in relation to the Covid-19 (Coronavirus) Pandemic and to support the NHS Test& Trace scheme in England and NHS Scotland’s Test and Protect service.
To operate safely and effectively, we may need to ask you for sensitive personal information that you have not already supplied, or use data you have already provided, including whether you have any underlying illnesses or are what is classed as vulnerable.
If we already hold information regarding vulnerability, we may share this for vital health reasons, emergency planning purposes and to protect your vital interests by sharing with services both inside and outside Fred. Olsen Travel.
Your personal data
Personal data relates to a living individual who can be identified from that data. Some of your personal data is classed as 'special category personal data' because this information is more sensitive e.g. health information, ethnicity and religion etc.
Why we may need to share your personal data
In this current pandemic, we may share your information with other public authorities, emergency services, and other stakeholders as necessary, and only when necessary, in a proportionate and secure manner. Contact with you to obtain consent before sharing will not be required for all the reasons described in this notice. Please be assured that protection of personal data remains a priority at this time after the health and safety of everyone.
We will only share your personal information where the law allows, and we always aim to share the minimum data necessary to achieve the purpose required. Further, the information will only be used for the purposes listed and retained for limited specific times.
The General Data Protection Regulation and Data Protection Act 2018 allow us to share information for a wide variety of reasons. These are known as our 'legal bases to process data'.
Data protection laws are written to facilitate valid information sharing, especially in times of emergency which often requires more collaborative working. The legal bases for processing data at Fred.Olsen Travel while Covid-19 continues to present significant health risks areas follows:
· Protect the public
· Satisfy legal and regulatory requirements
· Provide extra support for individuals with a disability or medical condition
· Safeguard children and individuals at risk
Elements of data protection law applicable at this time
Fred. Olsen Travel will apply the following sections of the General Data Protection Regulation and Data Protection Act 2018 (other elements may be applied dependent upon emerging events):
GENERAL DATA PROTECTION REGULATION
Article 6 – Lawfulness of Processing
· Article 6.1(c) - processing is necessary for compliance with a legal obligation to which the controller is subject.
· Article 6.1(d) - processing is necessary in order to protect the vital interests of the data subject or of another natural (living) person.
Article 9 – Processing of special categories of personal data
· Article 9.2(c) - processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent
· Article 9.2(g) - processing is necessary for reasons of substantial public interest
· Article 9.2(h) - processing is necessary for the purposes of preventative or occupational medicine, where is it necessary for the provision of social care,the provision of health care or treatment or for the management of a health or social care system
· Article 9.2(i) - processing is necessary for reasons of public interest in the area of public health, such as protecting against cross-border threats to health or ensuring high standards of quality and safety of health care
DATA PROTECTION ACT 2018
SCHEDULE 1, (Special categories of Personal Data), Part 1 Conditions relating to Employment, Health and Research etc
This condition is met if the processing
a) Is necessary for the reasons of public interest in the area of public health and
b) Is carried out -
I. by or under the responsibility of a health professional, or
II. by another person who in the circumstances owes a duty of confidentiality under an enactment or rule of law
SCHEDULE 1, (Special categories of Personal Data), Part 2, Substantial Public Interest Conditions
Paragraph 16, Support for individuals with a disability or medical condition
This condition is met if the processing
d) can reasonably be carried out without the consent of the data subject
e) is necessary for reasons of substantial public interest
(1) This condition is met if the processing is
a) necessary for the purposes of
I. protecting an individual from neglect or physical, mental or emotional harm, or
II. protecting the physical, mental or emotional well-being of an individual,
b) the individual is
I. aged under 18, or
II. aged 18 or over and at risk,
c) the processing is carried out without the consent of the data subject for one of the reasons listed in sub-paragraph (2), and
d) the processing is necessary for reasons of substantial public interest.
(2) The reasons mentioned in sub-paragraph (1) c) are —
a) in the circumstances, consent to the processing cannot be given by the data subject
b) in the circumstances, the controller cannot reasonably be expected to obtain the consent of the data subject to the processing
(3) For the purposes of this paragraph,an individual aged 18 or over is "at risk" if the controller has reasonable cause to suspect that the individual —
a) has needs for care and support,
b) is experiencing, or at risk of, neglect or physical, mental or emotional harm, and
c) as a result of those needs is unable to protect himself or herself against the neglect or harm or the risk of it.
You have several rights with respect to your personal data. You can find full details on the Information Commissioner’s Office website. Any requests regarding your rights should be submitted to the Data Protection Officer. There may be a delay in responding fully to all requests within one calendar month, but we will strive to keep requestors updated with the progress of their request.