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Plain-English summary
This privacy policy raises several concerns regarding the collection, use, and sharing of personal and sensitive data. The company may use advanced software, including facial recognition, to analyze CCTV footage onboard ships (risk_flags-1). Extensive medical history and health screenings, including tests for communicable illnesses, may be required before and during cruises (risk_flags-2). Your health data may be shared with public authorities to control public health risks (risk_flags-3), and you might be required to wear wearable devices for contact tracing (risk_flags-4). Additionally, using the company's digital platforms automatically implies consent to cookies, and your personal data may be shared with social media platforms for targeted advertising. Booking through a travel partner means your data will be shared with them and governed by their own privacy policies (data_use-3). CCTV is used for safety, security, and contact tracing (data_use-4). For multi-guest reservations, all guests can access each other's personal data, and if your reservation is linked, another user can perform various actions on your behalf (gotchas-2).
89% confidence
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Risk Flags
4 findings
Critical issues that pose significant privacy or financial risks.
high90% confidence
Use of Facial Recognition and Other Enhanced Software on CCTV Footage
The company may use enhanced software to analyze CCTV footage, which may include facial recognition techniques or other tools to identify characteristics such as clothing color, and to understand guest movement and identify busy areas on ships.
Why it matters: Your image and facial characteristics may be analyzed using advanced software, including facial recognition, for various purposes such as understanding movement patterns on the ship and identifying crowded areas.
We also use enhanced software to analyse the CCTV footage which may use facial recognition techniques or other tools to identify characteristics, such as the colour of a person’s clothing. We may use information from these systems to understand guests’ flows of movement around the ship, which areas on the ship are busiest (where, for example, it might become more difficult for guests to maintain a social distance if required).
Categories of personal data When/how We get it, paragraph 9 · Citation strength: strong
high95% confidence
Collection of Medical History and Health Screenings
Before your cruise, the company may collect information about your medical history, including vaccinations and current health, to ensure fitness for cruising and to identify symptoms of communicable illnesses. They may also require medical examinations, tests for communicable illnesses, temperature checks, or health documentation at various points.
Why it matters: You may be required to disclose extensive medical history and undergo various health screenings, including tests for communicable illnesses and temperature checks, potentially multiple times during your trip, which could affect your ability to cruise or embark/debark.
We may collect information at the point of purchase of your cruise ticket, through the online check in process, and/or via the app. We may ask you additional questions about your health at the terminal prior to embarkation, and We may require that you undertake a medical examination, undertake a test to identify whether you have a communicable illness, test your body temperature and/or provide documentation about your health, all to ensure that you are healthy enough to travel. We may also repeat some or all of these screening measures at debarkation and/or embarkation in ports of call, and at the point of debarkation at the end of your cruise.
Categories of personal data When/how We get it, paragraph 6 · Citation strength: strong
high90% confidence
Sharing of Health Data with Public Authorities and Health Agencies
The company may be required to share personal data related to your health with public authorities or health agencies to control public health risks, such as those posed by communicable illnesses.
Why it matters: Your health information may be shared with public authorities and health agencies, potentially without your direct consent, in situations involving public health risks.
We may be required to share personal data relating to your health with public authorities or health agencies, in the event that they are working, or example, to control risks to public health posed by communicable illnesses.
We use your personal data:, paragraph 1 · Citation strength: strong
high90% confidence
Use of Wearable Devices for Contact Tracing
The company may require or request that you wear a wearable device to support contact tracing onboard, particularly when there is a threat to health.
Why it matters: You may be required or requested to wear a wearable device for contact tracing purposes, which could track your movements and interactions onboard.
Otherwise, we may require or request that you wear a wearable device to support contact tracing onboard
Categories of personal data When/how We get it, paragraph 7 · Citation strength: strong
Data Use
2 findings
Practices related to the collection, processing, and sharing of user data.
medium90% confidence
Sharing Personal Data with Third-Party Travel Partners
When booking through a Travel Partner, the company will share booking details with that partner. Travel Partners may process this information on their own behalf or make decisions about how and why to process it, and their privacy policies are not covered by the company's privacy notice.
Why it matters: Your personal data will be shared with third-party travel partners when you book through them, and their handling of your data is governed by their own privacy policies, over which the company has no control.
Travel partners - When you book through a Travel Partner, We will need to share details of your booking with that partner. Travel Partners may process your information on Our behalf or may make decisions themselves about how and why to process your information. Our privacy notice does not cover the information collected by Travel Partners and does not cover how Travel Partners use that information. We recommend that you check your Travel Partner’s own privacy policy for details as to how they may process your personal data.
We use your personal data:, paragraph 2 · Citation strength: strong
medium90% confidence
Use of CCTV for Safety, Security, and Contact Tracing
The company uses CCTV cameras onboard ships for safety and security purposes, such as finding missing persons or for contact tracing purposes.
Why it matters: Your image may be captured by CCTV cameras onboard ships and used for safety, security, and potentially contact tracing purposes.
We use CCTV onboard our ships for safety and security purposes such as to find missing persons or for contact tracing purposes.
Categories of personal data When/how We get it, paragraph 9 · Citation strength: strong
Cancellation and Renewal
All clear
Terms related to subscription cancellations, service renewals, and associated billing.
✓
Looking good
No billing surprises spotted
Verbaterm only flags concerns it can cite. No cancellation, auto-renewal, or refund terms needed attention here.
Gotchas
1 finding
Less obvious but potentially impactful clauses for the user.
medium90% confidence
Linking Reservations Gives Other Users Access to Personal Data and Actions
If your reservation is linked by another user, that user will be able to complete online check-in for you, view your boarding pass, pay for onboard products/activities for you using their own accounts, and view eDocs associated with your reservation. They will not be able to modify or cancel your reservation, view your folio, or use a digital key for your stateroom.
Why it matters: If someone links your reservation, they will gain significant access to your reservation details and be able to perform certain actions on your behalf, such as checking you in or making purchases for you.
We call this "linking”. If your reservation is linked by another user of Our Digital Platforms, We will allow the user who has linked your account to (1) complete online check-in for you and others in your reservation, (2) view your boarding pass, and the boarding pass of others in your reservation, (3) pay for an onboard or shore product or activity for you or others in your reservation, using their own onboard expense account or their own payment methods, and (4) view eDocs associated to your reservation. However, they will not be able to modify or cancel your reservation, view your folio or use a digital key to access your stateroom.
○ Our processing their personal data, and, paragraph 5 · Citation strength: strong
Protections
2 findings
Explicit commitments and features that benefit users.
Protection95% confidence
Deletion of Children's Personal Data if Collected Without Consent
If a parent or guardian becomes aware that their child has provided personal data without consent, they should contact the company, and the information will be deleted from their files.
Why it helps: This commitment allows parents to ensure unauthorized data collected from their children is removed, protecting children's privacy.
We do not knowingly solicit personal data from children, unless permitted by applicable law. If a parent or guardian becomes aware that his or her child has provided Us with information without their consent, he or she should contact Us using the contact details below. We will delete such information from Our files.
○ Our processing their personal data, and, paragraph 7 · Citation strength: strong
Protection90% confidence
Right to Opt Out of Sale of Personal Data and Targeted Advertising
Users have the right to opt out of the sale of personal data and targeted advertising, including the sharing of personal data for that purpose. This can be done via the Cookie settings banner or the Cookie Preferences/Do Not Sell/Share My Personal Information link on the website.
Why it helps: Users can control whether their personal data is sold or used for targeted advertising, enhancing their privacy and data autonomy.
Right to opt out. You have the right to opt out of: (i) the sale of personal data; and (ii) targeted advertising, including the sharing of personal data for that purpose.
○ Our processing their personal data, and, paragraph 15 · Citation strength: strong
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