Last Updated: August 14, 2020
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1. About This Document
2. Our Commitment
We respect your right to privacy and we aim to ensure that you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information that you entrust to us.
3.1 Our customers
3.2 Examples of who this policy covers
3.3 When we are an information processor only
3.4 Terms used in this policy
When we refer to "process" or "processing" of your personal information, this includes collecting, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, and blocking, erasing or destroying it.
When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also include any services that we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.
4. Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates; records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; records of enquiries and searches for vacation and travel products made by or on your behalf; details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the vacation, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / vacationers traveling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.
Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any vacation or other travel services, and information relating to payments to be made.
Information collected or generated out of any surveys we conduct.
Information collected or generated out of any competitions or promotions we run.
Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.
Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.
We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of information we collect will depend on how you interact with our website.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (CalFIPA), and the Driver's Privacy Protection Act of 1994 (DPPA).
5. How We Collect or Generate Your Personal Information
This section sets out the ways in which we may collect or generate personal information concerning you. We obtain categories of personal information listed above from the following categories of sources:
5.1 Visiting our website
By visiting and using our website you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.
5.2 Data you provide
Your personal information will include information you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filling in any field or form on a website; by posting on our social media channel; by posting on any forum referencing us; by filling in any printed form we provide you; by email; from documents you provide us; and from updates to any information you provide from time to time. This includes when you: register for or subscribe to any service, account, members or loyalty program, or make an enquiry or booking for a vacation or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.
If you do not provide us with your personal information, we will be unable to provide you with information or book travel services for or on your behalf.
5.3 User Generated Content (UGC)
We may process information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites if you have given consent to let Uniworld River Cruises, Inc. and The Travel Corporation (TTC) subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:
Print materials; on our website; email activities; social posts; images of our trips; images provided to our trade partners to use on their websites, email marketing and other marketing initiatives; UGC made available in our content feeds—we would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods; any other information provided to us by or in relation to you which concerns you as an individual.
5.4 Data obtained from third parties
We may obtain personal information concerning you from third parties, including from: people making enquiries or bookings on your behalf; providers of any vacations, holidays, accommodation, or other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organizations; from any business or organization you are associated with; from telephone numbers identified by the telephone system when you telephone us.
5.5 Data generated by us
We and any suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or information gained from your use of our website. We may record telephone calls with you.
6. What Do We Use Your Personal Information For
We commit to use your personal information only for the purposes listed below and for as long as it is necessary to achieve these purposes.
6.1 Operate our website
To operate and provide the search, booking, accounts, review, forums and other services, facilities, and functions of our websites. This includes customizing your online experience by providing you with more relevant online offers and updates, managing any accounts or registrations you have with our websites, and making changes to your settings and profile at your request.
6.2 Provide information and respond to enquiries
To provide information to you about our website, systems, and services, including to respond to booking enquiries and searches for vacations and travel, and to keep you updated generally.
6.3 Bookings and other contracts
To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorized or made with us which relate to you.
To collect and make payments due and administer our accounts.
6.5 Communication with customers
To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.
6.6 Record keeping
To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.
6.7 Manage and improve our business
To analyze, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyze the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising, and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.
6.8 Direct marketing
To carry out direct marketing to you. See next section below for further information.
To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.
For any purpose for which we have obtained your consent.
7. Use of Your Personal Information for Direct Marketing
We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to do so, such as through an opt-in or opt-out checkbox on any form or website of ours.
7.1 Direct marketing by us
Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, advertisements, and promotions relating to travel services that we provide or which can be booked with third parties through us.
Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, advertisements, and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as Uniworld River Cruises, Inc. and The Travel Corporation (TTC), or third parties selected by us.
7.2 Direct marketing by third parties
Where you have consented to this, we may disclose your personal information that is contact information (such as name, email, postal address, telephone, mobile or fax number) to any other company in the same group of companies as Uniworld River Cruises, Inc. and The Travel Corporation (TTC), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, advertisements, and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are upon request, and you should contact them directly concerning this.
8. Disclosure of Your Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and to not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Protected classification characteristics under California or federal law.
- Commercial information.
- Internet or other similar network activity.
- Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have sold personal information for direct marketing purposes, where you have given your prior consent.
We transfer your personal information to third parties in the following circumstances:
8.1 Credit checks
We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud, and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention, and to pursue debtors.
8.2 Bookings and performance of contracts
We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include: to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).
8.3 Suppliers of travel and other services
We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) to whome we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third-party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
If any application is made through us for any travel or other insurance coverage for you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.
8.5 Business function outsourcing
Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or to carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then we may provide your personal information to them as required for use for or processing as part of those purposes.
8.6 Public forums, etc.
Where any facility on our website is clearly designed to make certain of your personal information public (e.g. posts you make to any public forum or reviews facility), then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.
8.7 Legal requirements
We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas, and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.
8.8 Direct marketing by third parties
We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent. See the direct marketing section above.
8.9 Customer representatives
If our customer is a business or organization, and we are holding your personal information in your capacity as an associate of that business or organization (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.
8.10 Business acquirers
If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.
9. Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
9.1 Access to specific information and data portability rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
9.2 Correction of inaccuracies
You have the right to ask us to rectify, block, erase or destroy any inaccurate personal information we hold about you.
9.3 Deletion request rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another customer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with customer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
9.4 Exercising your rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable request to us by either:
- Telephone at (800) 687-1002.
- Email to email@example.com OR raise a request through this link https://ttc.com/privacy-policy/us/usa-personal-data-request-us/.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
9.5 Response timing and format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
9.6 Personal information sales opt-out and opt-in rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. You can manage your communication preferences at any time from your account. You (or your authorized representative) may also exercise the right to opt-out by submitting a request to us by visiting the following page: https://ttc.com/privacy-policy/us/usa-personal-data-request-us/ and filling in the dedicated form, or sending us an email to firstname.lastname@example.org.
Once you submit an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by managing your communication preferences in your account on our website. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.
9.9 Complaints to applicable authority
The laws we comply with are regulated by the US Department of Consumer Affairs. In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator, who has powers to compel us to comply with applicable laws and fine us for non-compliance. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.
10. How Third Parties Will Handle Your Personal Information
Where we provide your personal information to a third party one of the following two circumstances will apply:
10.1 Processing on our behalf
10.2 Processing on their own account
11. Location of Your Personal Information
11.1 Transfer of personal information overseas
We (and any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to: (1) our overseas offices; (2) information processors (including operators of global travel distribution systems); (3) airlines, hotels and other travel service products; and (4) information technology and business service providers.
In many cases the transfer is necessary to initiate or complete a booking or other transaction on your behalf in response to a request by you or for the purpose of entering a contract with a third party on your behalf.
Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world.
In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.
11.2 Countries to which your personal information is transferred
The countries to which we transfer your personal information depends on your booking. Generally, such countries include those in Asia Pacific, Africa, North and South America and Europe.
12. Keeping Your Data Secure
12.1 Our security measures
12.11 Our general commitment
We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organizational measures against unauthorized or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules, and technical measures with a view to achieving this.
12.1.2 Transmissions between your web browser and our servers
We use Secure Sockets Layer ("SSL") software in order to encrypt the personal information that you provide to us while it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key in the browser address bar or on the bottom bar of your browser window and by checking that the prefix for the web address in the browser address bar has changed from "http" to "https."
12.1.3 Storage of your personal information
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology, and other reasonable security measures.
12.2 Your security measures
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any emails you may send to us, including payment card information.
We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.
13. How Long Do We Keep Your Personal Information?
We keep your personal information for as long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.
14. "Do Not Track"
We are required to let you know how we respond to web browser Do Not Track (DNT) signals.
We do not respond to such signals at this time.
16. Contacting Us
- Email to email@example.com.
- Telephone on (800) 687-1002
- Post to 5551 Katella Ave. Cypress, CA, 90630
17. Copyright Notice
This document, and all content of our websites is Copyright© 2020 Uniworld River Cruises, Inc. All Rights Reserved.
18. Applicable Law and Disputes
19. EU-US and Swiss-US Privacy Shield
The Travel Corporation Inc. (TTC) including all its entities and Subsidiaries in the US complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.
Under Privacy Shield Frameworks, we are subject to the authority of the U.S. Federal Trade Commission.
If you have any questions or concerns relating to our use and disclosure of your personal information in accordance with the Privacy Shield Principles, contact firstname.lastname@example.org; we will respond to a complaint or inquiry within 45 days of receipt.
We commit to cooperate with the EU data protection authorities or the Swiss Federal Data Protection and Information Commissioner (‘DPAs’), as applicable, and comply with their advice with regards to personal information transfers from the EU or Switzerland. If you believe that your questions or concerns were not addressed by us to your satisfaction, you may also contact the DPA of your place of residence. The dispute resolution by DPAs will be provided at no cost to you.
In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.