Privacy Notice

This Privacy Notice is intended to inform you (referred to in this Privacy Notice as “you”, “your”, “yours” or “yourself” and collectively with others as "users") how Virgin Cruises Intermediate Limited, trading as Virgin Voyages (“Virgin Voyages", "we”, “us” or “our”), as general business practices, may collect, use, share, and disclose your Personal Information and other information through our website located at www.virginvoyages.com, our mobile app (together referred to as the “Website”), and through our pages on other online channels and social media, such as Facebook, Instagram, TikTok, LinkedIn, and Twitter (collectively, the “Social Media”) offline such as telephone calls (together the Website, Social Media and telephone calls referred to as the “Sites”), as well as through third parties.  

Our registered office is located at 1000 S. Pine Island Road, Suite 600, Plantation, Florida 33324.

This Privacy Notice applies to you, in that we will collect data about you and your visit, if you contact us, book a voyage with us, take a voyage with us, apply for employment with us, visit our website, download our mobile app, or sign up for promotions/contests/sweepstakes.  We offer the option or suggest under certain circumstances, in several places in this Privacy Notice, to contact us.  The preferred method is through our Contact Us page, which includes chat, message, and telephone options to get in touch with our “Sailor Services” team.  But you may contact us by mail (post) as well.  If it is a privacy or data matter, you may select “Privacy/Data/CCPA Related Request” on the ”Send Us a Message” dropdown on our Contact Us page, or address your letter to “Privacy Officer” at the above address.
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 on our Contact Us page. 

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

If we change anything important about this Privacy Notice (the information we collect, how we use it or why) we will highlight those changes at the top of the Privacy Notice 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 Notice. You can see the last time that changes to this Privacy Notice have been made by checking the “Last changed” date at the beginning of this Privacy Notice.

The current version of this Privacy Notice is accessible via the footer on each page of our Website and will be clearly accessible from our Social Media pages. We will also bring this Privacy Notice to your attention verbally during telephone calls.

Virgin Voyages will collect, use and disclose your Personal Information and other information as described in this Privacy Notice. The information we hold about you comes from the way you engage with us, for example when you do any of the following:

• use and browse our Website;
• submit information or make a general enquiry via our Website, by email, phone or otherwise;
• complete forms;
• book a cruise, reserve a cabin/suite ("Booking" or "Bookings"), or modify a Booking via our Website or by telephone;
• submit content on the Sites (known as “Your Submissions”);
• submit booking information;
• correspond with us by direct message, email, phone or otherwise;
• submit survey responses and sweepstakes entries; and/or
• contact us by phone, email or communicate in any other way with Virgin Voyages and Virgin Voyages' third party providers with whom you communicate directly.

For the safety and security of Guests, we use closed circuit television (“CCTV”) or other surveillance means onboard the ship. We also deploy body cameras on our Security Team members, which will record interactions with Guests and crew. CCTV and body camera footage may include sound recordings. Additionally, there are photographers and camera crew on board the Ship taking photographs and making videos for you to purchase at the end of the voyage. They are happy to take reasonable steps to avoid filming you where you indicate that this is your preference but you may be included unless you tell us otherwise. We are unable to guarantee that you will not be included in video footage and photographs on an incidental basis.  

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.

Personal Information

Personal Details: We will collect your name, title, email address, telephone number, home address, emergency contact details, date of birth, place of birth, gender, photographs (to include one’s face for security and to use on one’s account). 

Government-issued document information: This includes passport information, visa information, driver’s license numbers.

Onboard Casino play: Details of your play and spend at casinos, loyalty rewards and, if you apply for credit for use at our onboard casinos, credit-related information.

Employment Application details: these include your personal details, employment history, education history, referral details, military service, immigration status, and third party LinkedIn details

Financial Details: This includes credit card information, transactional history and purchases, amount paid for Services, bank information, income, and business information. Note: when you enter credit card information on our website you are actually entering it on the website of a third party service provider (i.e., Fexco Financial Services) which is located in the European Union. While we hold it in memory for a fraction of a second, as soon as you enter your payment information that data is tokenized and credit card information partially masked by the third party processor, then deleted. This all happens instantaneously. We will retain the last four digits of your credit card information to permit us to verify refunds and to facilitate purchases. This information may be shared (i) in bookings funded by multiple cards and (ii) in instances of linked bookings to co-travelers. No Virgin Voyages-affiliated persons can otherwise view or access your credit card information. Notwithstanding the above, in the event you use a third-party digital wallet through a link provided on our website, we do not receive or retain any of your payment information (including the last four digits of your credit card). Rather, we receive notification that your transaction has been funded from the third-party. Please note, if you follow a link to any third-party digital wallet, you will be subject to the third-party’s terms and conditions, including their privacy policies. We do not accept any responsibility or liability for the policies of those third-party websites.

Health Details: these include information as may arise in special requests for onboard services, as well as health information you submit to us, and a health questionnaire before you board. We may also collect body temperature data from onboard kiosks tagged to your mobile device.

Account Information: When one books with us we will provide access to create an account using your email and self-selected password. The account will allow you to login to the Website and mobile app, and to modify or update your account data. 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 make a Booking with us, transaction history, IP address, Site use information, browser information, type of user, type of voyage preference, location information, blogs, stories and all information within Your Submissions.

Communications: When you sign up for an account, make a Booking and/or use certain features of the Website, we may use your personal data to send you marketing communications. We will obtain your consent prior to sending any direct marketing communications to you. You can subsequently manage some of your messaging preferences by clicking "unsubscribe" on marketing emails or by Contacting Us, 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 with our Sailor Services 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 your name, your family members or co-travellers, or details of disabilities / special requests in relation to the Booking. We also augment our leads with key demographic information available via public records and publicly available content on social media platforms.

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.

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 payment details in order to provide the cruise / cabin that you have requested / reserved.
2. this is necessary to assist in providing our cruise line services in a safe and healthful way by monitoring one’s health while on board our ships through non-invasive body temperature monitoring and by enabling contact tracing to track any spread of communicable disease onboard our ships.
3. this is necessary to comply with legal or regulatory requirements – for example, disclosure of information in connection with law enforcement purposes and preventing the spread of communicable diseases onboard our ships.
4. this is necessary as in the public interest – for example, undertaking anti-fraud screening and verifying your identity.
5. we have collected your consent – for example, in order to send you direct marketing messages or should we desire to use imagery/footage collected from our onboard photographers/videographers in our marketing or promotional materials in print, on television, on our website, on our social media sites, or other media. If we post an image without your consent or lawful basis, we ask that you contact us through our Contact Us page and we will work to remove it.
6. this is necessary to protect the health, safety and security of guests and crew -- for example, we may process your personal data by checking your information against a publicly available criminal record database, or use your personal data, including your health data, to protect against the spread of COVID-19 or other communicable diseases. 
7. this is necessary for the purposes of our legitimate interests including:
   • providing you with the services that you request from us;
   • giving you a refund or credit, on-boarding you as a customer, providing products and services to you, communicating with you about your Booking;
   • allowing you to post Your Submissions;
   • to contact you in the course of providing services to you;
   • 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 our products, services and the Sites;
   • understanding and responding to your feedback; 
   • researching and analysing the services you want and the assistance you may need;
   • improving our services;
   • understanding the type of products and services you buy and how you use them;
   • personalising our offers so we're better able to provide offers and ideas that are relevant to you;
   • to administer sweepstakes, contests, competitions or promotions including to check whether you are eligible to enter;
   • maintaining a public profile on both traditional and Social Media;
   • to evaluate you for a job with us;
   • 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.
8. 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).

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

When you enter payment information through our Website we do not collect or store this data.  You provide this information directly to the relevant third party payment provider in the EU who will act as data controller in relation to any payment information. We use such third party payment providers for payment, analytics, and other business services. If you purchase anything from us including via our third party payment providers, they will collect your payment information. 

You can learn more about our third party payment providers, including purposes for processing your Personal Information and read the relevant privacy policy by visiting the applicable third party payment provider's website. 

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

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

We may use certain Personal Information to market to you, by sending you emails to promote our products and services – if required by applicable law we will only do this with your consent.

If we send you emails to promote our services, unsubscribe instructions will be included. You can withdraw your consent (if applicable) and unsubscribe to receiving direct marketing from us at any time by following our email unsubscribe instructions or by Contacting Us. You may not opt-out of receiving communications regarding your transactional, administrative, legal or technical messages about the Sites or our services.

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 to provide advertising to you on other websites (including Social Media networks such as Facebook) by matching  our customers and visitors with a social media channel user in order to provide advertising to them on that social media 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 our use of third party vendors, Contact Us. 

We may share your Personal Information if:

1. you specifically request this, such as when you submit Personal Information to inquire about jobs or submit a job application through the Website (if such functionality is offered by us);
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 determine it is reasonably necessary to prevent illegal activity, to evaluate a possible security breach or vulnerability, or to protect our interests, the security of data we hold, 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. required by 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 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 provide) 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 / or 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. 

Certain States within the United States have enacted laws, including the California Consumer Privacy Act and Virginia Consumer Data Protection Act, that require us to disclose to you whether we sell your personal data to certain third parties or otherwise disclose your personal data to third parties for the third party’s commercial use, as this concept is defined in the respective laws.

We choose our suppliers and business partners carefully and put in place safeguards to help protect your personal data, including, but not limited to, written agreements. As such, and as of the date of this privacy notice, we do not sell or disclose your personal data in this manner.

Please note, terms in this privacy notice that are defined in these laws shall not be construed as having the definitions and legal significance set forth in these laws.

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 you sailed with us in the last three years;
4. whether there are contractual obligations that exist that require us to retain the Personal Information for a specified period of time;
5. 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;
6. whether any applicable law, statute, or regulation allows for a specific retention period; and
7. what the expectation for retention was at the time the Personal Information was provided to us.

As an example, if we institute temperature monitoring protocols onboard our ships due to COVID-19, we will keep your body temperature data collected from those onboard kiosks during the time of your voyage with us. It will be deleted at the end of your voyage, though we may keep it longer if you contract a communicable disease such as COVID-19.

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 virginvoyages.com Website. You may select which cookies you allow on your device.

We have in place industry standard security procedures as to how your Personal Information is stored and used, and to try to prevent any unauthorized access or misuse of it. We run vulnerability assessments, and audit our data practices at least annually.

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 sixteen (16) 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 sixteen (16) 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.

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 unless you are the parent or legal guardian of the referenced child. By submitting Your Submission to us, you represent that you are the parent or legal guardian of any child in Your Submission, and you waive all claims relating to any Personal Information of a child referenced or shown in Your Submission.

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 Notice.

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

In addition to the collection, use and disclosure of your Personal Information described above, you may provide or we will collect the following additional Personal Information as described below when you use the Virgin Voyages App and/or wristband:

Online Check-In Service 

You may complete our online check-in process in advance of boarding the cruise via the Virgin Voyages App. This will speed up the check-in process when you board your cruise.  

To use the online check-in service through the Virgin Voyages App, you must provide:

• details of your Booking;
• your flight information if booked through us (when enabled);
• your parking requirements;
• the name and telephone number of your emergency contact;
• a valid payment method for use on board the cruise;
• a recent photo which meets our requirements (these requirements will be notified to you separately during the check-in process) for security verification for check-in and verifying your identity on board the cruise;
• a copy of your Passport information page;
• a completed health questionnaire; 
• any accompanying legal documentation required for travel such as an Electronic System for Travel Authorisation (ESTA) or visa; and
• any other documentation or information we notify you of during the online check-in process.

If you do not complete the online check-in process in advance of boarding your cruise or if the items you submit do not meet our requirements, you will be required to provide the items listed above or additional information we request when you board the cruise. You will also be required to show your photo identification when you board the cruise.

We will use the Personal Information you provide to us during the online-check in process in order to:

• verify your identity for check-in and when boarding and disembarking the cruise during your voyage;
• provide you with parking and manage our parking facilities;
• contact your emergency contact in the event of an issue or other emergency;
• protect your vital interests; and
• comply with our legal obligations including in relation to identity verification and immigration. 

Our processing of your Personal Information collected during the online check-in process is necessary:

• in order to perform our contract with you;
• in order to protect your vital interests and the vital interests of others; 
• as it is in the public interest;
• in order to comply with our legal obligations; and
• for our legitimate interests (or those of a third party) – please see section WHY AND HOW WE USE YOUR PERSONAL INFORMATION above for further information on our legitimate interests. 

When we process your completed health questionnaire provided to us during the online-check in process we use this information in order to ensure you do not have any symptoms, conditions or illnesses that would mean you are unable to safely enjoy your cruise, have an infectious disease or other conditions or illnesses that could jeopardize the health of you or other passengers on board and to ensure that you are not pregnant. We will also process your health information to ensure we can make any adjustments necessary to cater to your requirements. We may share this health information with our on-board medical team for further medical assessment – if we need to share your health information for this purpose we will let you know. In addition, we may be required to share your health information under applicable law such as with local port authorities.

Our processing of your health information is on the basis that:

• we have your explicit consent;
• it is necessary in order to protect your vital interests and the vital interests of others– this includes disclosure and use of your health information in the event of a medical emergency; and
• it is necessary for reasons of substantial public interest.

Voyage Notifications

We will use push notifications through the Virgin Voyages App to send you reminders or updates relating to your Booking such as itinerary updates for your cruise, reminders to check-in or for excursions or events you have booked (collectively, Voyage Notifications). We may also use push notifications to send you important messages of a functional, urgent and/or critical nature about your cruise (Essential Notifications), for example to notify you of a lifeboat drill.  

You can turn off push notifications for Voyage Notifications through the Virgin Voyages App. However, if you turn off Voyage Notifications you may miss important reminders and updates in relation to your Booking.

You can only turn off push notifications for Essential Notifications through the settings on your mobile device or other handheld device. You cannot turn off Essential Notifications within the Virgin Voyages App.  If you turn off push notifications for Essential Notifications through your mobile device, this will automatically turn off push notifications for Voyage Notifications as well.

If you turn off push notifications for Essential Notifications you will miss important messages regarding your cruise that may impact upon your safety on board.  

Changing these settings will not affect other communications from us (such as transaction confirmations by email) or from other members of the Virgin Group Companies or where you have consented to receive direct marketing from us. 

Wristband

You and each member of your party will receive a wristband approximately six weeks before the departure date for your cruise. Some travel groups and VIPs may receive their Wristband at the terminal upon check-in. Wristbands are provided to you free of charge and are intended for use on board our cruise only. 

Paying Using Your Wristband Or Key Card

You can store payment cards in your account through the Virgin Voyages App. Once you have stored a payment card in your account you will be able to make purchases on board the cruise with your wristband. Alternatively, if you prefer not to use a wristband, you can use a key card to make purchases on board the cruise. 

You can change or remove your stored payment card on your account through the Virgin Voyages App at any time. 

If you enable us to do so through Bluetooth on your mobile device, Virgin Voyages can access your location whilst on board our ships in order to provide you with certain services based on your location such as delivering food and drinks, as well as conducting contact tracing to keep you safe.  (Location Based Services). This is done by granting us permission to do so through Bluetooth on your mobile device.  We do not use location data to track or monitor your movements. Location information is collected periodically and only the last known location is retained by Virgin Voyages, but retention will not extend past the end of your cruise.  Location Based Services include delivering food and beverages ordered through the Virgin Voyages App to your specific location on board the ship. When using Location Based Services your Virgin Voyages App profile photo and exact location will be sent to our crew so they can deliver your purchase.

This feature tracks your location through receivers on board the ship. We will only track your location through the App if you are happy for us to do so. If you do not want us to track your location through your mobile device, you may turn off Location Based Services in the App or leave your mobile device in your cabin.   If you do not enable Location Based Services, you can always order food and drink or other items whilst on board the cruise to your location by simply telling us where you would like those items delivered and use your key card to make payments on board and to open your cabin door.

If you have any queries, comments or complaints regarding this Privacy Notice, please Contact Us or send us a letter or post to Virgin Voyages, 1000 S. Pine Island Road, Suite 600, Plantation, Florida 33324, Attn: Privacy Officer.

Should you as a Consumer wish to exercise a CCPA-related right, or contact someone for more information, you may do so one of four ways: 

1. Going to our Contact Us page, clicking the “Send us a message” option, then clicking the “Data/Privacy/CCPA related request” link, 
2. Emailing your verifiable request to PrivacyOfficer@virginvoyages.com, 
3. Calling us at 888-386-4450, or 
4. Sending a verifiable request by mail to: 

               Virgin Cruises Intermediate Limited
               1000 South Pine Island Road, Suite 600
               Plantation, FL 33324
               Attn: Privacy Officer

A verifiable request must include the Consumer’s name, address, booking number (if s/he booked with us), passport number (if s/he booked with us), and include sufficient detail to allow us to properly understand, evaluate, and respond to it. With all requests, we will consider the factors in section 999.323 of the CCPA Regulations. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request. If we cannot verify the requestor’s identity from the information already maintained by us, we may request additional information, which shall only be used for the purposes of verifying the requestor’s identity and for security or fraud-prevention purposes. If the Consumer uses an authorized agent to submit a request on the Consumer’s behalf, we require the agent to submit proof they have been authorized by the Consumer to act on the Consumer’s behalf. The requestor can expect us to respond within the time limits set by the CCPA.   

A Consumer has the right to request that we disclose what personal information we collect, use, disclose, and sell related to him or her. See above to exercise these rights.

We will collect and disclose information as provided in the Part I of this Privacy Notice. 

While Virgin Voyages may disclose a Consumer’s personal information to our affiliates or other third parties to enable us, or enable them, to deliver services the Consumer requests, we do not and will not sell a Consumer’s data. 

A Consumer has the right to request the deletion of personal information that we hold related to him or her.  See above to exercise these rights. We will use a two-step process to verify a Consumer’s desire to exercise this right as detailed in the CCPA Regulations. However, as applied to the services we provide, this right does not apply where we need to retain the personal information in order to do any of the following:

• Provide goods or services to the Consumer
• Detect or resolve issues security or functionality-related issues
• Comply with the law
• Carry out any actions for internal purposes that the consumer might reasonably expect

Virgin Voyages does not and will not sell personal information.

Virgin Voyages neither buys, receives for the business’s commercial purposes, sells, or shares for commercial purposes, the personal information of 4,000,000 or more consumers.

Virgin Voyages will not discriminate against a Consumer for exercising any of his or her CCPA rights. Even if permitted by CCPA, we will not typically:

• Deny the Consumer goods or services
• Charge the Consumer different prices for services
• Provide the Consumer a different level or quality of services
• Suggest that the Consumer may receive a different rate or price for services or a different level or quality of services

To the extent we collect sensitive personal information, we do not handle it for purposes other than those specified in section 7027(m) of the CCPA Regulations.

For purposes of the Virginia Consumer Data Protection Act, we do not sell your data or profile you in furtherance of decisions that produce legal or similarly significant effects concerning consumers.

Should you as a Consumer wish to exercise a VCDPA-related right, or contact someone for more information, you may do so one of four ways:
 

1. Going to our Contact Us page, clicking the “Send us a message” option, then clicking the “Data/Privacy/CCPA related request” link, 
2. Emailing your authenticated request to PrivacyOfficer@virginvoyages.com, 
3. Calling us at 888-386-4450, or 
4. Sending an authenticated request by mail to:

               Virgin Cruises Intermediate Limited
               1000 South Pine Island Road, Suite 600
               Plantation, FL 33324

               Attn: Privacy Officer

An authenticated request means a request in sufficient detail to allow us to properly understand, evaluate, and respond to it, and permits us to determine that the person making the request is the same person with respect to the personal data at issue. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request. If we cannot verify the requestor’s identity from the information already maintained by us, we may request additional information as reasonably necessary to authenticate the consumer and the consumer's request.

Right to Access: You may have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.

Right to Correction: You may have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.

Right to Deletion: You may have the right to delete the Personal Data provided to us by you.

Right to Data Portability: You may have the right to obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller without hindrance, where the processing is carried out by automated means.

Right to Opt-Out of Sale, Targeted Advertising, and Profiling: For purposes of the CTDPA, a “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation or other valuable consideration. We do not “sell” Personal Information under this definition. Connecticut residents have the right to opt out of the processing of your Personal Data by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Data for such profiling. To opt out of targeted marketing, where applicable, please click the “Unsubscribe” link at the bottom of any email communication from Virgin Voyages.

Right to Appeal: If we decline to take action regarding your request, you have the right to appeal. We will notify you providing our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you contact the Attorney General to submit a complaint.

If any of the rights described in the sections above apply to you, you may make a request by (i) going to our Contact Us page and leaving a message, (ii) emailing us at privacy@virginvoyages.com, or (iii) mail us at: Virgin Voyages, 1000 S. Pine Island Road, Ste. 600, Plantation, FL 33324  ATTN: Privacy Officer. Please indicate that you are making a request pursuant to your “Connecticut Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; and (3) physical address; and (4) date of birth. We will take steps to verify your request by matching the information provided by you with the information we have in our records.

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 exercise, or talk to us about, any of these rights, please reach out to our Privacy Officer through our Contact Us page.

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

If you are a resident of the European Union you 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.

UK GENERAL DATA PROTECTION REGULATION (UK GDPR) - UK REPRESENTATIVE

Pursuant to Article 27 of the UK GDPR, Virgin Cruises Intermediate Limited has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

• by using EDPO's online request form: https://edpo.com/uk-gdpr-data-request/
• by writing to EDPO UK Ltd at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

EU GENERAL DATA PROTECTION REGULATION (GDPR) – EUROPEAN REPRESENTATIVE 

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Virgin Cruises Intermediate Limited has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR: 

• by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
• by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

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

Note we use a third party service provider located in the European Union to process any credit card data you use to make purchases from us.  We do not collect or hold your credit card information.  The United Kingdom has adopted adequacy regulations to permit transfers from the UK to countries in the EEA. 

Please reach out to our Privacy Officer through our Contact Us page if you would like further information on the specific safeguards used by us when transferring your Personal Information.

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 exercise or talk to us about any of these rights, please reach out to our Privacy Officer through our Contact Us page.

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.

 

You also have a right to lodge a complaint with the Canadian Privacy Commissioner, whose office may be reached at https://www.priv.gc.ca/en/report-a-concern/.

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:

The kinds of Personal Information we collect and hold	Refer to Part I - Section for Global Application – What information we collect
How we collect and hold Personal Information	Refer to Part I - Section for Global Application – How we collect information
The purposes for which we collect, hold, use and disclose Personal Information	Refer to Part I - Section for Global Application – Why and how we use your personal information  You may request not to receive direct marketing communications.
How you may access the Personal Information we hold about you	You can ask us if we are holding your Personal Information and, if we are, you can request access to your Personal Information.
How you may correct the Personal Information we hold about you	You can request we correct your Personal Information by contacting our privacy officer by sending an email to PrivacyOfficer@virginvoyages.com, to ensure that the information is accurate, up to date, complete, relevant and not misleading. We will take reasonable steps to correct such information.
How you may complain about a breach of the Australian Privacy Principles or code that binds us and how we will deal with such a complaint	You may complain to us by Contacting Us or by emailing our privacy officer at PrivacyOfficer@virginvoyages.com. We will deal with your complaint. You also have the right to lodge a complaint with the Office of the Australian Information Commissioner by visiting www.privacy.gov.au.
Whether we are likely to disclose Personal Information to  overseas recipients, and if so, the countries such recipients are likely to be located	We store our information in the United States. To ensure your Personal Information is properly protected, we enter into suitable contracts with third party service providers and will only transfer data from the United states where appropriate safeguards are in place to not breach the Australian Privacy Principles.

 

If you want to exercise any of these rights, please reach out to our Privacy Officer through our contact Contact Us page.