Virgin Voyages will collect, use and disclose your Personal Information and other information as described in this Privacy Notice. The information we hold about you comes from the way you engage with us, for example when you do any of the following:

• use and browse our Website;
• submit information or make a general enquiry via our Website, by email, phone or otherwise;
• complete forms;
• book a cruise, reserve a cabin/suite ("Booking" or "Bookings"), or modify a Booking via our Website or by telephone;
• submit content on the Sites (known as “Your Submissions”);
• submit booking information;
• correspond with us by direct message, email, phone or otherwise;
• submit survey responses and sweepstakes entries; and/or
• contact us by phone, email or communicate in any other way with Virgin Voyages and Virgin Voyages' third party providers with whom you communicate directly.

For the safety and security of Guests, we use closed circuit television (“CCTV”) or other surveillance means onboard the ship. We also deploy body cameras on our Security Team members, which will record interactions with Guests and crew. CCTV and body camera footage may include sound recordings. Additionally, there are photographers and camera crew on board the Ship taking photographs and making videos for you to purchase at the end of the voyage. They are happy to take reasonable steps to avoid filming you where you indicate that this is your preference but you may be included unless you tell us otherwise. We are unable to guarantee that you will not be included in video footage and photographs on an incidental basis.  

We may obtain Personal Information or non-Personal Information from third parties such as our service providers, vendors, independent contractors, business partners, sponsors, and other sources (such as from offline records or publicly available information). We may combine Personal Information we collect with information that we obtain from these sources. We will treat any such combined information as Personal Information.

1. this is necessary to enter into or perform our contract with you, including, but not limited to, the processing and administration of Bookings – for example, using your contact details and payment details in order to provide the cruise / cabin that you have requested / reserved.
2. this is necessary to assist in providing our cruise line services in a safe and healthful way by monitoring one’s health while on board our ships through non-invasive body temperature monitoring and by enabling contact tracing to track any spread of communicable disease onboard our ships.
3. this is necessary to comply with legal or regulatory requirements – for example, to comply with applicable law or regulations, subpoenas, or at the direction of relevant courts, regulators, immigration and other authorities, in connection with other law enforcement purposes, or preventing the spread of communicable diseases onboard our ships.
4. this is necessary as in the public interest – for example, undertaking anti-fraud screening and verifying your identity.
5. we have collected your consent – for example, in order to send you direct marketing messages or should we desire to use imagery/footage collected from our onboard photographers/videographers in our marketing or promotional materials in print, on television, on our website, on our social media sites, or other media. If we post an image without your consent or lawful basis, we ask that you contact us through our Contact Us page and we will work to remove it.
6. this is necessary to protect the health, safety and security of guests and crew – for example, we may process your personal data by checking your information against a publicly available criminal record database, or use your personal data, including your health data, to protect against the spread of communicable diseases. 
7. this is necessary for the purposes of our legitimate interests including:
   • providing you with the services that you request from us;
   • giving you a refund or credit, on-boarding you as a customer, providing products and services to you, communicating with you about your Booking;
   • allowing you to post Your Submissions;
   • to contact you in the course of providing services to you; for internal record keeping and account creation;
   • improving the content of the Sites;
   • to adapt the Sites to your needs; to carry out surveys;
   • understanding how you use our products, services and the Sites; understanding and responding to your feedback; 
   • researching and analysing the services you want and the assistance you may need;
   • improving our services;
   • understanding the type of products and services you buy and how you use them;
   • personalising our offers so we're better able to provide offers and ideas that are relevant to you;
   • to administer sweepstakes, contests, competitions or promotions including to check whether you are eligible to enter;
   • maintaining a public profile on both traditional and Social Media;
   • to evaluate you for a job with us;
   • maintaining suppression records to ensure we have a record of your objection to direct marketing (if given);
   • assessing the number of visitors, posts, page views, reviews and followers in order to optimise future marketing campaigns; 
   • for insight purposes (for example, to analyse market trends and demographics, and develop the service which we offer to you or other individuals in the future); and
   • transfer of personal data in relation to the sale, transfer or re-organisation of all or part of our business and the acquisition of business.
8. We take great precautions to keep the information you share with us safe and private. We will not disclose your Personal Information to any persons or third parties/affiliates outside of our company, nor lease, license, rent, transfer, disclose, disseminate or otherwise grant access to such information for marketing/promotional purposes unless permitted by law. In those cases where disclosure is not permitted without your opt-in, we will not do so unless you opt-in and permit us to do so. Cookies will enable the personalization of your mobile messaging experience (e.g., sending you personalized text messages such as shopping cart or booking hold reminders).
9. Profiling and Automated Processing
   We may process your Personal Data to carry out profiling activities. This involves the use of cookies and other automated data-collection technologies to automatically evaluate certain personal aspects relating to you, such as your onboard purchases, voyage history, and previous behaviors or interests. This analysis helps us better understand your preferences and predict potential future interests, enabling us to offer cruise packages, onboard services, promotions, and experiences that are tailored to your travel preferences. By understanding what you enjoy, we can enhance your experience through more relevant and personalized offers and recommendations.
   Where required by applicable law, this processing is carried out only with your consent, which you may withdraw at any time.
   For U.S. Sailors, we process Personal Data for these purposes based on our legitimate business interests. You have the right to opt out of this processing at any time, including profiling in furtherance of targeted advertising, as required by applicable U.S. state privacy laws.
   We do not make decisions that produce legal effects or similarly significant effects concerning you based solely on automated processing. Where automated processing is used to support our decisions, appropriate safeguards are in place, including meaningful human involvement where required by law.

10. Identity Matching and Customer Profile Management

    When a reservation is created, we may compare information you provide such as your first name, last name, date of birth, and email address — with existing customer records to determine whether you already have a customer profile. If an existing profile is identified through an exact match of these data elements, we may associate the reservation with that profile instead of creating a duplicate account. If no matching profile is found, a new customer profile may be created. We use this process to maintain accurate customer records, improve customer service, support reservation management, and reduce duplicate accounts.

We need to collect certain types of information for compliance with legal requirements relating to our customer identity verification obligations. If suitable identity documentation (such as a valid passport) is not provided we cannot agree to provide our cruises or other products or services to you.

Your Personal Information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defense of a legal claims. We will not delete Personal Information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

Where applicable and required by law, you have the right to:

• Object to the processing of your Personal Data for profiling purposes;
• Opt out of profiling in furtherance of targeted advertising;
• Request information about the logic involved in automated processing; and
• Request human review of certain automated processing activities.

Automated Processing or Automated Decision-Making means the processing of personal information by automated means, without human involvement in each individual decision or assessment. This includes the use of algorithms, software, artificial intelligence, or other machine-based systems to analyze, evaluate, predict, or classify personal information.

When you enter payment information through our Website we do not collect or store this data. You provide this information directly to the relevant third party payment provider in the EU who will act as data controller in relation to any payment information. We use such third party payment providers for payment, analytics, and other business services. If you purchase anything from us including via our third party payment providers, they will collect your payment information. 

You can learn more about our third party payment providers, including purposes for processing your Personal Information and read the relevant privacy policy or privacy notice by visiting the applicable third party payment provider's website.

The information that could be requested for the payment processing and Booking services available via the Website includes:

• contact information provided to us, by you, in order for us to fulfill a Booking request;
• contact details, such as name, postal address, telephone number, email address;
• financial and transaction data, such as credit, debit card or bank account information; and
• other personal data, such as date of birth.

We may use certain Personal Information to market to you, by sending you emails to promote our products and services – if required by applicable law we will only do this with your consent.

If we send you emails to promote our services, unsubscribe instructions will be included. You can withdraw your consent (if applicable) and unsubscribe to receiving direct marketing from us at any time by following our email unsubscribe instructions or by Contacting Us. You may not opt-out of receiving communications regarding your transactional, administrative, legal or technical messages about the Sites or our services.

We may display offers, promotions, products or services from us or from our business partners or advertisers on the Sites, which we think will interest you based upon the Personal Information we collect from you.

We also use third party tools to provide advertising to you on other websites (including Social Media networks such as Facebook) by matching  our customers and visitors with a social media channel user in order to provide advertising to them on that social media platform. For this purpose, we share your information with these third party providers (for example Facebook) and use cookies or similar technologies on our Sites to analyse the effectiveness of our advertising including on other websites. For more information about our use of third party vendors, Contact Us. 

We may share your Personal Information if:

1. you specifically request this, such as when you submit Personal Information to inquire about jobs or submit a job application through the Website (if such functionality is offered by us);
2. we are required to do so to comply with the law, regulations, subpoenas, or with the direction of the courts, regulators or other authorities;
3. we determine it is reasonably necessary to prevent illegal activity, to evaluate a possible security breach or vulnerability, or to protect our interests, the security of data we hold, or the safety of others; 
4. in connection with the sale, transfer or other sharing of some or all of our assets including without limitation, in connection with a merger, reorganization, or sale of assets, or in the event of bankruptcy;
5. external hosting providers in order for the administration of our Sites (or any other online platform operated by us); and / or
6. required by our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities.

We share your Personal Information with our employees, contractors, and third party service providers to help provide and improve our services to you, so that third party service providers can provide services (such as regarding the trips and activities that such third party service providers provide) requested by you and to carry out surveys and user analysis to understand your needs and preferences. For instance, we will share your Personal Information with our email host and / or our email newsletter distributor, and our shipboard crew may share their observations of unreported illness with our onboard security team and/or medical services provider.

We also may share your Personal Information in any manner in its de-identified or aggregated form, including sharing some broader statistics and user profiling information with third parties (provided always that all information shared is de-identified or aggregated and as such you cannot be identified from such information).

To the extent that we use short message services (“SMS”) messaging, any information related to SMS opt-in or phone numbers used for SMS will not be shared.

Keep in mind, when you share and post Your Submissions using the Sites, Your Submissions may be public and may be viewed by and available to anyone and can be seen or accessed through online search engines, APIs, and offline media. 

We will keep your Personal Information for as long as it is reasonably necessary. How long we keep it depends very much on the type of Personal Information and purpose for which it was collected.

The criteria we use to determine the retention period for certain categories of Personal Information is as follows:

1. whether you have an account with us;
2. whether you have outstanding Bookings;
3. whether you sailed with us in the last three years;
4. whether there are contractual obligations that exist that require us to retain the Personal Information for a specified period of time;
5. whether there is any ongoing legal claim that relates to any Booking you have made with us, or that is otherwise related to your relationship with us;
6. whether any applicable law, statute, or regulation allows for a specific retention period; and
7. what the expectation for retention was at the time the Personal Information was provided to us.

If you submit a request to exercise your privacy rights, we retain records of those requests so that we can comply with them (for example, so that we remember your request to opt out of marketing messages) and so that we can demonstrate that we have complied. In each case, we determine how long to retain information based on how long it is needed to fulfill the purpose for which it was collected, whether we need to retain it for an additional window to comply with record-keeping obligations or to defend against legal claims or prevent fraud.

We have in place industry standard security procedures as to how your Personal Information is stored and used, and to try to prevent any unauthorized access or misuse of it. We run vulnerability assessments, and audit our data practices at least annually.

The Sites are intended for general use of persons who have reached the age of majority or consent in their jurisdiction of residence. Persons between sixteen (16) years of age and the age of majority or consent in their jurisdiction of residence may only use the Sites with consent and supervision of a parent or legal guardian. The Sites are not targeted to anyone under sixteen (16) years of age. Virgin Voyages does not knowingly collect Personal Information from anyone under sixteen (16) years of age. If we learn that we have inadvertently collected Personal Information from anyone under sixteen (16) years of age, we will promptly delete or redact such information from our records. If you believe that we have collected information from a person under the majority or consent in their jurisdiction of residence, please Contact Us.

If Your Submission contains images or Personal Information related to anyone under the age of majority or consent in their jurisdiction of residence, you may not post, upload, or share Your Submission unless you are the parent or legal guardian of the referenced child. By submitting Your Submission to us, you represent that you are the parent or legal guardian of any child in Your Submission, and you waive all claims relating to any Personal Information of a child referenced or shown in Your Submission.

We are based in the United States. When you submit Personal Information through our Sites this is sent to us in the United States.

In addition to the collection, use and disclosure of your Personal Information described above, you may provide or we will collect the following additional Personal Information as described below when you use the Virgin Voyages App and/or wristband:

Online Check-In Service 

You may complete our online check-in process in advance of boarding the cruise via the Virgin Voyages App. This will speed up the check-in process when you board your cruise.  

To use the online check-in service through the Virgin Voyages App, you must provide:

• details of your Booking;
• your flight information if booked through us (when enabled);
• your parking requirements;
• the name and telephone number of your emergency contact;
• a valid payment method for use on board the cruise;
• a recent photo which meets our requirements (these requirements will be notified to you separately during the check-in process) for security verification for check-in and verifying your identity on board the cruise;
• a copy of your Passport information page;
• a completed health questionnaire; 
• any accompanying legal documentation required for travel such as an Electronic System for Travel Authorisation (ESTA) or visa; and
• any other documentation or information we notify you of during the online check-in process.

If you do not complete the online check-in process in advance of boarding your cruise or if the items you submit do not meet our requirements, you will be required to provide the items listed above or additional information we request when you board the cruise. You will also be required to show your photo identification when you board the cruise.

We will use the Personal Information you provide to us during the online-check in process in order to:

• verify your identity for check-in and when boarding and disembarking the cruise during your voyage;
• provide you with parking and manage our parking facilities;
• contact your emergency contact in the event of an issue or other emergency;
• protect your vital interests; and
• comply with our legal obligations including in relation to identity verification and immigration. 

Our processing of your Personal Information collected during the online check-in process is necessary:

• in order to perform our contract with you;
• in order to protect your vital interests and the vital interests of others; 
• as it is in the public interest;
• in order to comply with our legal obligations; and
• for our legitimate interests (or those of a third party) – please see section WHY AND HOW WE USE YOUR PERSONAL INFORMATION above for further information on our legitimate interests. 

When we process your completed health questionnaire provided to us during the online-check in process we use this information in order to ensure you do not have any symptoms, conditions or illnesses that would mean you are unable to safely enjoy your cruise, have an infectious disease or other conditions or illnesses that could jeopardize the health of you or other passengers on board and to ensure that you are not pregnant. We will also process your health information to ensure we can make any adjustments necessary to cater to your requirements. We may share this health information with our on-board medical team for further medical assessment – if we need to share your health information for this purpose we will let you know. In addition, we may be required to share your health information under applicable law such as with local port authorities.

Our processing of your health information is on the basis that:

• we have your explicit consent;
• it is necessary in order to protect your vital interests and the vital interests of others– this includes disclosure and use of your health information in the event of a medical emergency; and
• it is necessary for reasons of substantial public interest.

Voyage Notifications

We will use push notifications through the Virgin Voyages App to send you reminders or updates relating to your Booking such as itinerary updates for your cruise, reminders to check-in or for excursions or events you have booked (collectively, Voyage Notifications). We may also use push notifications to send you important messages of a functional, urgent and/or critical nature about your cruise (Essential Notifications), for example to notify you of a lifeboat drill.  

You can turn off push notifications for Voyage Notifications through the Virgin Voyages App. However, if you turn off Voyage Notifications you may miss important reminders and updates in relation to your Booking.

You can only turn off push notifications for Essential Notifications through the settings on your mobile device or other handheld device. You cannot turn off Essential Notifications within the Virgin Voyages App. If you turn off push notifications for Essential Notifications through your mobile device, this will automatically turn off push notifications for Voyage Notifications as well.

If you turn off push notifications for Essential Notifications you will miss important messages regarding your cruise that may impact upon your safety on board.  

Changing these settings will not affect other communications from us (such as transaction confirmations by email) or from other members of the Virgin Group Companies or where you have consented to receive direct marketing from us. 

Wearable/Wristband

You and each member of your party will receive a wristband at the terminal upon check-in. Wristbands are provided to you free of charge and are intended for use on board our cruise only.

Paying Using Your Wristband Or Key Card

You can store payment cards in your account through the Virgin Voyages App. Once you have stored a payment card in your account you will be able to make purchases on board the cruise with your wristband. Alternatively, if you prefer not to use a wristband, you can use a key card to make purchases on board the cruise. 

You can change or remove your stored payment card on your account through the Virgin Voyages App at any time. 

If you enable us to do so through Bluetooth on your mobile device, Virgin Voyages can access your location whilst on board our ships in order to provide you with certain services based on your location such as delivering food and drinks, as well as conducting contact tracing to keep you safe. (Location Based Services). This is done by granting us permission to do so through Bluetooth on your mobile device. We do not use location data to track or monitor your movements. Location information is collected periodically and only the last known location is retained by Virgin Voyages, but retention will not extend past the end of your cruise. Location Based Services include delivering food and beverages ordered through the Virgin Voyages App to your specific location on board the ship. When using Location Based Services your Virgin Voyages App profile photo and exact location will be sent to our crew so they can deliver your purchase.

This feature tracks your location through receivers on board the ship. We will only track your location through the App if you are happy for us to do so. If you do not want us to track your location through your mobile device, you may turn off Location Based Services in the App or leave your mobile device in your cabin. If you do not enable Location Based Services, you can always order food and drink or other items whilst on board the cruise to your location by simply telling us where you would like those items delivered and use your key card to make payments on board and to open your cabin door.

If you have any queries, comments or complaints regarding this Privacy Notice, please Contact Us or send us a letter or post to Virgin Voyages, 1000 S. Pine Island Road, Suite 600, Plantation, Florida 33324, Attn: Privacy Officer.

1. Confirm that we process your personal data and to access your personal data (right of access)
2. Receive your personal data in a portable and readily usable format that allows you to transmit it to a third party (right to data portability/transfer)
3. Correct inaccuracies to your personal data (right to correction)
4. Erase your personal data (right to deletion)
5. Opt out of the processing of your personal data for profiling or for targeted advertising purposes
6. Object to automated processing
7. Limit Use and disclosure of sensitive information and exercise control and processing of certain sensitive information 
8. Right to designate an authorized agent to make a request under state law on your behalf; 
9. Appeal a decision made by us related to your personal data (right to appeal)

1. Going to our Contact Us page, clicking the “Send us a message” option, then clicking the “Data/Privacy/CCPA related request” link,
2. Emailing your authenticated request to PrivacyOfficer@virginvoyages.com, 
3. Calling us at 888-386-4450, or 
4. Sending an authenticated request by mail to:

Depending on various factors, you may have rights in relation to your Personal Information. These rights will apply only some of the time. If you would like to exercise, or talk to us about, any of these rights, please reach out to our Privacy Officer through our Contact Us page.

You may contact our DPO at dpo@virginvoyages.com.

If you are resident in the United Kingdom you have a right to make a complaint to the Information Commissioner's Office (Tel: 0303 123 1113 or at www.ico.org.uk). 

If you are a resident of the European Union you have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually reside, where we are based, or where an alleged infringement of Data Protection law has taken place.

Pursuant to Article 27 of the UK GDPR, Virgin Cruises Intermediate Limited has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

• by using EDPO's online request form: https://edpo.com/uk-gdpr-data-request/
• by writing to EDPO UK Ltd at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Virgin Cruises Intermediate Limited has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR: 

• by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
• by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

We store our information in the United States which does not have equivalent data protection laws to those applicable in the EU or UK. However, to ensure your Personal Information is properly protected in line with EU and UK data protection laws we enter into suitable contracts with third party service providers, and we will only transfer data from the United States to jurisdictions outside the scope of the EU or UK GDPR where the appropriate safeguards set out in the EU or UK GDPR are in place. 

Note we use a third party service provider located in the European Union to process any credit card data you use to make purchases from us. We do not collect or hold your credit card information. The United Kingdom has adopted adequacy regulations to permit transfers from the UK to countries in the EEA. 

Please reach out to our Privacy Officer through our Contact Us page if you would like further information on the specific safeguards used by us when transferring your Personal Information.

Depending on various factors, you may have rights in relation to your Personal Information. These rights will apply only some of the time. If you would like to exercise or talk to us about any of these rights, please reach out to our Privacy Officer through our Contact Us page.

You also have a right to lodge a complaint with the Canadian Privacy Commissioner, whose office may be reached at https://www.priv.gc.ca/en/report-a-concern/.

This section supplements your rights found above in Part I - Section for Global Application.

Your Personal Information will be managed in an open and transparent way in compliance with Australian Privacy Principles. We provide this information:

If you want to exercise any of these rights, please reach out to our Privacy Officer through our contact Contact Us page.