PRIVACY POLICY

A von Brockdorff Services Ltd. understands and respects the importance of your privacy. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, online or offline, will be processed by us. Please read the following information carefully.

For the purpose of the General Data Protection Regulation (GDPR), we, as A von Brockdorff Services Ltd. and also under our trading name as the Cruise and Travel Group, are the Data Controller both offline and online (at www.avbsl.com, www.avonbrockdorff.com, www.vonbrockdorff.com and www.cruiseandtravel.eu).

You are responsible for ensuring that the other members of your party are aware of the content of this Privacy Policy and are in agreement with you supplying their personal data to us to make a booking or other purchase on their behalf.

By making a booking/purchase or submitting your personal data directly or via these web sites, you agree to the transfer, storing or processing of it as set out below. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. If you do not agree to our use of your personal data as set out below we cannot accept your booking and you should not use these web sites.

Information we may collect from you and why we collect it:

When you make a booking or other purchase from us, we will collect certain personal data about you and about any other person you include on your booking. The sort of personal data we collect will be information such as name, address, email address, telephone number, date of birth, and personal travel preferences. We need to collect this information in order to arrange the travel and other services you are requesting. In some cases we may also need to collect more sensitive personal data such as Passport / ID Cards, information concerning medical conditions, disabilities and special requirements, so as to be able to consider your particular needs in relation to a booking. Data will be stored only until it is considered necessary for operational, marketing, research and/or legal purposes. We shall only store data until it is absolutely necessary.

We may also collect personal data about you in the following circumstances: If we ask you for your contact details for future marketing use (which may be by email, post or phone text messages) or if you actively sign up to receive email newsletters from us, (although you will be given the option to opt-out of such use). If you contact us, we may keep a record of your email or other correspondence, and if you call us by telephone, we may monitor and/or record phone conversations for training and customer service reasons.

We may collect details of your visits to these sites (including, but not limited to, traffic data and location data) whether this is required for our own purposes or otherwise, and the

resources that you access. We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration purposes and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

Transfer of your information:

When you make a travel booking or other purchase, some of the personal data you provide will need to be passed to and processed and stored by relevant third parties, such as airlines, hoteliers, insurance companies and ground handling agents, so that they can provide you with the arrangements you require. Some of these third parties may be based outside of the

European Economic Area (“EEA”). Organisations that are based outside of the EEA may not be subject to the same level of controls in regard to data protection as exist within the EEA.

In order for you to travel overseas, we may be required to disclose personal data to government bodies or other authorities in Malta and in other countries, such as those responsible for immigration, border control, security and anti-terrorism. Even if it is not mandatory for us to provide information to such authorities, we may exercise our discretion to assist them where appropriate.

How We Use Your Information:

We use information held about you for the purposes as stated and in the following ways: To carry out our obligations arising in connection with any contracts entered into between you and us, or between you and a third party supplier;

• To communicate with you regarding your booking or other purchase;
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service;
• For improving the quality of our service and the products offered;
• For internal research/analysis and customer profiling;
• For resolving complaints and dealing with disputes;
• For preventing and detecting fraudulent or criminal activity;
• For debt collection or credit vetting

Marketing Use:

If you have made an enquiry or purchase, your personal data may be used by us and other A von Brockdorff Services Ltd. companies to contact you by post and/or by electronic means (email or text message) with information and offers relating to products or services similar to those about which you enquired or which you purchased.

We will only do this if you did not opt out of such marketing at the point where we collected your contact details. If you have not made an enquiry or purchase, we will only send you information and offers by email or text message relating to products and services offered by A von Brockdorff Services Ltd. companies if you sign up (opt in) to receive such marketing.

We may use your data for marketing purposes of travel and travel related products and services.

We will not pass your contact details to a third party outside of A von Brockdorff Services Ltd. for marketing purposes unless you have expressly agreed that we may do so.

Opting Out Of Marketing Use:

You have the right at any time to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by ticking/un-ticking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by sending an unsubscribe request to :

The Data Protection Officer, A von Brockdorff Services Ltd., Level 7, Airways House, High Street, Sliema SLM 1551 or by e-mail to dpo@avbsl.com.

Your right to access any personal data we hold:

The General Data Protection Regulation (GDPR) gives you the right to check that your personal data is being processed lawfully (“subject access right”). Your subject access right can be exercised in accordance with the Regulation. Any subject access request must be 24th May 2018 made in writing to: The Data Protection Officer, A von Brockdorff Services Ltd., Level 7, Airways House, High Street, Sliema SLM 1551 or by e-mail to dpo@avbsl.com.

Your right to be forgotten:

The General Data Protection Regulation (GDPR) gives you the ‘right to be forgotten’. You have the right to erase your personal data at any time, subject it that doesn’t compromise the ability to research and any legal requirements can be exercised in accordance with the regulation. Any such request must be made in writing to: The Data Protection Officer, A von Brockdorff Services Ltd., Level 7, Airways House, High Street, Sliema SLM 1551 or by e-mail to dpo@avbsl.com.

Data Security:

The transmission of information via the internet is not completely secure, and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to this web site; therefore any transmission is at your own risk. Once we have received your information, we will take all reasonable steps to keep your personal data secure and to try to prevent any unauthorised access to it. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.

Links To Third Party Web Sites:

Our site contains links to and from the websites of our principals, suppliers, advertisers and other third parties. If you follow a link to any of these other websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or for these 3rd party websites. Please check these policies before you submit any personal data to these websites.

COOKIES

Our Sites uses cookies to distinguish you from other users. Some of these cookies are essential to make these Sites work properly, to allow you to make your travel booking or other purchases, and to enable us to fulfil your purchase requests. Other types of cookie help us to provide you with a good experience when you browse our Sites, allow us to improve our Sites or the way we provide our service to customers, or are used to provide you with information or offers from A von Brockdorff Services Ltd. or third parties that may be of interest to you.

Changes to our privacy policy

We reserve the right to update or alter this Privacy Policy from time to time without notice to you.