Privacy and Cookies Statement 2022

PRIVACY AND COOKIES STATEMENT

Effective: 3/16/2021

We know that sharing your personal information with us is based on trust. We take this seriously and are committed to ensuring that we respect your privacy when you visit our website or use our services. Please review this privacy and cookies statement (“Statement”) carefully to learn about our privacy practices.

We operate an online service that provides users with recommendations for travel and travel planning, including cruises, vacations, travel packages, travel guides and lots more. In this Statement, these are collectively referred to as our Services.

Our Services are owned and operated by Independent Traveler, Inc, which is owned and operated by TripAdvisor LLC. By visiting our websites and related applications, whether on a computer, phone, tablet or similar device (these are all referred to as a “Device”), you are accepting the practices described below.

As a global company, we operate in a number of countries and territories where the laws and customs differ. This Statement provides a general overview of our privacy practices; you can view certain country-specific information by selecting your place of residence in the jurisdiction links at the bottom of this Statement.

Information Collected

We may also collect, in instances where you have provided it, information about other travellers, including their email address and other travel-related information. If you are sharing information with us about other individuals, you must obtain their consent. You must obtain the consent of any other individuals if you are providing their data to us.

In addition to the categories noted above, we may also collect location information if you have instructed your Device to send such information via the privacy settings on that Device, or, for example, if you have uploaded photos tagged with location information. We may use your location information directly and/or share your location with third parties. We collect and share location information in order to provide you with relevant content, to analyze your use of our Services, to improve our Services and to provide contextual advertising or recommendations. For example, we may use your location to show you reviews of business or attractions near you when you are travelling.

You can change the privacy settings of your Device at any time in order to turn off the functionality that collects and shares location information and/or the functionality to tag your photos with location information. However, turning off location-sharing may affect certain features that we offer. If you have any questions about the privacy settings of your Device, we suggest you contact the manufacturer of your Device or your mobile service provider for help.

Please see the section on Cookies below for more information regarding the use of cookies and other technology described in this section, including regarding your choices relating to such technologies.

Information Uses

Please note some information about you is required in order for us to provide you with relevant offerings from us, our affiliates and our partners and to enable you to enjoy other benefits of being a registered user. Please review the “Information Choices” section below with respect to your choices related to the collection and use of your information

Information Sharing

Third parties may only collect or access information as needed to perform their permitted functions. Certain Device operating system versions permit you to opt out of certain types of information sharing, including to certain advertising networks. Please check your Device settings if you want to limit such tracking.

Information Choices

You have options with respect to the collection and use of your information.

Your options:

You may choose the way we communicate with you. You can choose not to provide us with certain information, although it may be needed to take advantage of certain features offered on our websites.
You can prevent the collection of geolocation information, but note that turning off location sharing may affect certain features of our Services.
You also can add or update information and close your account. If you close your account, we will deactivate your account and remove your profile information from active view. We may retain some information associated with your account (including past transactions) for internal purposes including backups, fraud prevention, dispute resolution, investigations and legal compliance for the period necessary to fulfil the purposes outlined in this Statement.
As a registered member, you can modify your marketing subscriptions, including email subscription choices, at any time within your member settings. You also will be given the opportunity to unsubscribe from promotional messages, including emails with travel-related opportunities, in any such email we send

Information Transfers

We are a global company and we operate in many different jurisdictions. If we transfer your information to other countries, we will use and protect that information as described in this Statement and in accordance with applicable law.

Information Security

We have implemented appropriate administrative, technical and physical security procedures to help protect your information.

We only authorise specific employees to access personal information and they may do so only for permitted business functions. We use encryption when transmitting your information between your system and ours, and between our system and those of the parties with whom we share information. We also employ firewalls and intrusion detection systems to help prevent unauthorised access to your information. However, we cannot guarantee the security of information from unauthorised entry or use, hardware or software failure or other circumstances outside of our control.

Information Retention

We will retain copies of your information for as long as you maintain your account or as necessary in connection with the purposes set out in this Statement, unless applicable law requires a longer retention period. In addition, we may retain your information for the duration of any period necessary to establish, exercise or defend any legal rights.

Do Not Track Signals

Our website is not designed to currently respond to “Do Not Track” (“DNT”) signal requests from browsers. This is due to the lack of global standardised interpretation that defines “Do Not Track” signals. Once the industry has settled on standards related to this issue, we may re-evaluate this approach.

Cookies

We want your access to our Services to be as easy, efficient and useful as possible. To help us do this, we use cookies and similar technologies to improve your experience, to enhance site security and to show you relevant advertising.

What are cookies?

Cookies are small text files that are automatically placed on your Device when you visit almost any website. They are stored by your internet browser and contain basic information about your internet use. Your browser sends these cookies back to a website every time you revisit it, so it can recognise your Device and improve your experience by, among other things, providing you with personalised content. We also use cookies to remember your login details, so you don’t have to re-enter them repeatedly when you use our Services. Other cookies help us understand your preferences.

The cookies we use fall into three categories:

Cookie Consent Tool

To give you control, we provide you with a Cookie Consent Tool, which allows you to review the first-party and third-party cookies placed through our website and adjust your cookie settings, including whether to accept such cookies or not.

You can access the Cookie Consent Tool at any time through the “Cookie Consent” link at the bottom of every page or in our cookie banner. In addition, you can manage cookies through the settings of your internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies or delete all cookies.

Most advertising networks offer you a way to opt out of advertising cookies. See www.aboutads.info/choices/ and www.youronlinechoices.com/uk/ for useful information on how to do this.

If you delete your cookies, your access to some functionality and areas of our Services might be degraded or restricted.

Our use of any information we collect through cookies is subject to this Statement, which is linked on every page of our website.

Statement Changes and Notification

We may update this Statement in the future. If we believe any changes are material, we will let you know by doing one or more of the following: sending you a communication about the changes to the email address you have provided us, and/or by placing a notice on the website and/or posting an updated Statement on the website. We will note at the top of this Statement when it was most recently updated. We encourage you to check back from time to time to review the most current version and to periodically review this Statement for the latest information on our privacy practices.

Contact

If you have any questions or concerns about this Statement or data processing, or if you would like to reach out to us, please access our dedicated privacy team by emailing privacy@cruisecritic.com with the email reference “Cruise Critic.”

General Data Protection Regulation Privacy Statement (“GDPR Statement”)

This GDPR Statement applies to persons in the European Economic Area (“EEA”), including those based in the United Kingdom. This GDPR Statement supplements our Statement; however, where the Statement conflicts with the GDPR Statement, the GDPR Statement will prevail as to persons in the EEA.

Controller of Personal Information

The Independent Traveller Inc. is the data controller of the personal information we collect, however, in accordance with applicable data privacy law, we have appointed a representative within the European Union and United Kingdom.

The contact details of our European Union representative are:

The contact details of our United Kingdom representative are:

Tripadvisor Ireland Limited and Tripadvisor Limited’s role in this respect are limited solely to being a contact point for questions on data protection from European residents and data protection supervisory authorities. For the avoidance of doubt, neither Tripadvisor Ireland Limited and Tripadvisor Limited can field other communications or legal process on behalf of TripAdvisor LLC.

Your rights under GDPR

This GDPR Statement applies to persons in the European Economic Area (“EEA”), including those based in the United Kingdom. This GDPR Statement supplements our Statement; however, where the Statement conflicts with the GDPR Statement, the GDPR Statement will prevail as to persons in the EEA.

You have certain rights regarding your personal data.

Your rights with respect to your own personal data include the following:

The right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
The right to request to correct your personal data if it is inaccurate. You may also supplement any incomplete personal data we have, taking into account the purposes of the processing.
The right to request the deletion of your personal data if:
• your personal data is no longer necessary for the purposes for which we collected or processed it; or
• you withdraw your consent if the processing of your personal data is based on consent and no other legal ground exists; or
• you object to the processing of your personal data and we do not have an overriding legitimate ground for processing; or
• your personal data is unlawfully processed; or
• your personal data must be deleted for compliance with a legal obligation.
The right to object to the processing of your personal data. We will comply with your request, unless we have a compelling, overriding, legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.
The right to restrict the processing of personal data, if:
• the accuracy of your personal data is contested by you, for the period in which we have to verify the accuracy of the personal data; or
• the processing is unlawful and you oppose the deletion of your personal data and request restriction; or
• we no longer need your personal data for the purposes of processing, but your personal data is required by you for legal claims; or
• you have objected to the processing, for the period in which we have to verify overriding legitimate grounds.
The right to data portability. You may request that we send this personal data to a third party, where feasible. You only have this right if it relates to personal data you have provided to us where the processing is based on consent or necessity for the performance of a contract between you and us, and the processing is conducted by automated means.
You also have the right to lodge a complaint before your national data protection authority.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights described in this Statement). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In an effort to speed up our response, we may also contact you to ask you for further information in relation to your request. You can exercise several of your rights through the personal information section of your account. To exercise your other rights you can file a request by emailing us at privacy@cruisecritic.com .

Information Uses

We will only use your personal data when the law allows us to.

Pursuant to GDPR, we will use your personal data in one or more of the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
Where we need to comply with a legal or regulatory obligation
With your consent

International Transfers

Your personal data may be stored or transferred to countries outside the EEA for the purposes described in this Statement. When we store or transfer your personal data outside the EEA, we take the following precautions to ensure that your personal data is properly protected.

Whenever we store or transfer your personal data outside the EEA, we will do so in accordance with applicable law and we will ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. Transfers of personal data are made:

to a country recognised by the European Commission as providing an adequate level of protection; or
to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

By using our services, you understand that your personal data may be transferred to our facilities and those third parties with whom we share it as described in this Statement.

California Consumer Privacy Act Privacy Statement(“CCPA Statement”)

This CCPA Statement is provided pursuant to the California Consumer Privacy Act(“CCPA”) and applies to California residents and supplements our overall Statement with additional disclosures and rights.

Your rights under CCPA

As of 1st January 2020, California law permits residents of California to request certain details about how their personal information is shared with third parties or affiliated companies for direct marketing purposes.

To take advantage of any of these rights, please contact us via our dedicated privacy portal by emailing us at privacy@cruisecritic.com . We may need to verify your identity to enable us to process your request.We value your privacy and will not discriminate in response to your exercise of privacy rights.We will respond to your request within 45 days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.