WPG, LLC, the owners of Sea Escapes, are committed to protecting and respecting your privacy. This policy and other documents referred to by this policy sets out the basis upon which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules that we follow on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”), as published by the European Union Parliament and widely recognized in the United States and around the world as the standard in personal data privacy management.
Data Controller – A controller determines the purposes and means of processing personal data.
Data Processor – A processor is responsible for processing personal data on behalf of a controller.
Data Subject – A natural person, like you.
Categories of Data – Personal data and special categories of personal data.
Personal Data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example, name, passport number, home address, or email address. Online identifiers include IP addresses and cookies.
Special Categories Personal Data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Who Are We?
WPG, LLC, doing business as Sea Escapes, is a company that sells cruises and other travel-related services and products, as well as various software technologies of interest to our business partners. Our address is 11770 Haynes Bridge Road, Suite 205-309, Alpharetta, GA, 30009, USA; our phone number is +1 678-736-1848. We are classified as a data controller, which means we decide how your personal data is processed and for what purposes as described in this privacy notice. For all data and privacy matters, you can contact us at firstname.lastname@example.org.
The Purposes of Processing Your Personal Data
We collect and process your personal information to aid you in the selection, booking, and management of various travel services, such as cruises, hotels, and tours. Your personal information is used to identify your booking records for both your benefit and the ultimate provider of the travel services (cruise lines, hotel groups, tour operators, etc.)
Providing any of your personal information to us is optional. But if you weren’t to provide it, we and your travel service providers wouldn’t be able to properly track your reservations and tickets.
What Information We Collect
We collect the following types of personal data:
- Full name
- Email address
- Phone number(s)
- Home address
- Cookies (only as needed for the efficient operation of the software, and never for tracking of personal behaviors).
Certain of our partners may also collect your payment information, namely credit card number, but you’ll be redirected to appropriate booking sites to provide this information; we never collect payment or credit card information on our website.
What Is Our Legal Basis For Processing Your Personal Data?
Our lawful basis for processing your general personal data is for the completion of business transactions in purchasing desired travel services. It’s in your best interest for us and our travel partners to be able to track and associate your personal information with your reserved services. More information on lawful processing can be found on the ICO website.
How We Use Your Information
WPG will process—meaning to collect, store, and use—the personal information provided in a manner that is compatible with the EU’s General Data Privacy Regulation (GDPR). Our aim is not to be intrusive, we undertake not to ask irrelevant or unnecessary questions, and it is not in the interest of efficient utilization of our websites and systems to collect unnecessary data from you. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.
How Long Do We Keep Your Personal Data?
We will endeavor to keep your information accurate and up to date and not keep it for longer than is necessary for the purpose for which it was provided in order to ensure accurate records of your travel reservations and marketing or subscription requests. We will keep your information longer if we are required by law to have other legitimate reasons to keep it longer, for example if the information is needed for ongoing legal proceedings. In some instances, the law sets the length of time information must be kept, but in most cases WPG will use its discretion to ensure that we do not keep records outside of our normal business requirements.
Your Rights And Your Personal Data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the “right to data portability”), (where applicable, i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, where applicable (i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
Automated Decision Making (such as profiling)
Our websites and systems do not use any form of automated decision making as defined in the GDPR.
Sharing Your Personal Data (including sub-processors)
You personal data will be treated as strictly confidential and will be shared only with parties as necessary to complete business transactions, if any. If your data is shared with any such third parties, it will be solely for the efficient operation of the system and for the completion of business transactions you have initiated, and you will be notified of such within the system under the notifications section of the software.
Employees, contractors, and third party business partners of WPG are contractually obligated to keep your details securely and use them only in the efficient management and utilization of our website and systems. At your request, and barring any other statutory requirements to the contrary, such third parties will dispose of the details in line with their statutory retention requirements. We will never pass your personal data on to a third party unless with your consent, or legally compelled to do so.
Transfer Of Data Abroad (for individuals in the EU)
The data we collect about you may be transferred to a destination outside of the European Economic Area (“EEA”) due to third party software suppliers supporting their line of business applications. It may also be processed by staff operating outside of the EEA who work for us or for one of our suppliers.
If we transfer information to a third party outside the EEA we will ensure the transfer is protected by the appropriate safeguards defined and allowed by GDPR, require the supplier and any of its agents and/or suppliers to comply with the requirements of GDPR, and take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Fair Processing Notice.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
How To Make A Complaint
To exercise all relevant rights, queries or complaints please in the first instance contact: WPG, LLC, Attn: GDPR Compliance, 11770 Haynes Bridge Road, Suite 205-309, Alpharetta, GA 30009, USA.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.