Last Updated: [March 2023]
Seabourn Cruise Line Limited (“Seabourn,” “we,” “our,” or “us”) is a division of Carnival Corporation & plc. We recognize that your privacy is important. Your choice to share information with us is an important part of how we provide a world-class travel experience. We’ve developed this Privacy Summary to give you a quick understanding of how and why we collect, use, and share your information both online and in the real world.

If you want more information, you can read the full version of the Seabourn Privacy Notice.

We collect many categories of personal information. The categories we collect may include: Contact and profile information; comments and suggestions, chat and opinions; Payment and transaction information; Location information; Information provided by social networks; Information provided by third parties; Information about fraudulent or criminal activity related to your account.

This information is collected from you in many ways, which are described in the full notice. A few examples include:

• WHEN YOU PROVIDE PERSONAL INFORMATION TO US.  We collect personal information about you when you register for an account, make a purchase, sign up for marketing communications, participate in an offer, or send it to us.
• WHILE YOU ARE ON YOUR VACATION.  We collect personal information about you when you choose to use our or our third-party partners’ services, including amenities, excursions, casinos, and otherwise through photo and video footage of our ships.
• WHEN YOU USE OUR ONLINE SERVICES.  We collect some personal information about you automatically as you use our Service and during your vacation.
• FROM THIRD-PARTY SOURCES.  We may also collect personal information from our third-party partners who help us to provide the Service or from other third- party partners to supplement or enhance our information.
  
  

We use personal information to facilitate your vacation and our other Services, to fulfill your requests, process transactions and contact you; to send you personalized advertising and promotional content and materials; to analyze and improve our Services and our business; and for other reasons described more fully in our Privacy Notice below.

If you are travelling on an Ocean Medallion Class® vessel, we collect information about your use of OCEAN® services, including our applications, websites, and the on-board interactive features during your trip. Please see the MedallionClass™ sections of our Privacy Notice for more information.

To learn more about the information we collect and how we use it, see our full Privacy Notice.

We want you to understand your choices regarding how we may process your personal information. Depending on how you use the Service, these choices may include the following:

• With our affiliates and companies in the Carnival Corporation & plc family of companies, who may use your information in the same way as we can under our Privacy Notice.
• With travel partners and providers, such as travel agencies, airlines, and excursion operators to facilitate your travel experience.
• With third party partners and service providers to facilitate our Services, fulfill your orders or requests, when you choose to share your activities on Seabourn Cruise Line Limited with your friends and contacts, or when you engage in promotional activities we provide with third party partners.
• With select third parties, so that they can provide you with information and marketing messages about products and services you may enjoy.
• In connection with a corporate transaction, such as a merger, sale, reorganization, financing, or in the event of a bankruptcy or related or similar proceeding.
• Where we believe such disclosure is reasonably necessary to protect the personal safety or health of our guests, family members or others or support the health and wellbeing of our crew and the broader public.
• As required by law or subpoena where necessary to comply with law and law enforcement, to enforce our Terms, to protect the security or integrity of our Services, and to exercise or protect the rights, property, health and safety of us and other third-parties.To learn more about these and other ways in which we may share your personal information, please see our full Privacy Notice.
  

We want you to understand your choices regarding how we may process your personal information. Depending on how you use the Service, these choices may include the following:

• ABOUT OUR ADS.  We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history.  To learn more about our advertising practices and your choices relating to advertising, please see the About Our Ads section for more information.
• PROFILE ACCESS & SHARING SETTINGS.  You may access and update your profile information, such as your user name, address, or billing information, and may change some of your data sharing preferences on your account page.
• DEVICE SETTINGS.  If you would like to update your device access permissions, such as permissions to access your geolocation, camera or address book, you can do so in the "Settings" app on your mobile device.
• PROMOTIONAL MESSAGES.  You can stop receiving promotional email communications from us by following the “unsubscribe” instructions provided in such communications. We make every effort to promptly process all unsubscribe requests. You may still receive Service-related communications, including account verification, transactional communications, changes/updates to features of the Services, and technical and security notices.
  
  

Please be sure to check the full Privacy Notice for more information about your choices.

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

• If you are a resident of the State of California in the United States, please the California-specific privacy rights section for more information.
• If you are a resident of the State of Nevada in the United States, please visit the Nevada-specific privacy rights for more information.
• If you are located in the European Economic Area, Switzerland and the UK (“EEA”), please visit the EEA-specific privacy rights section for more information.
• If you are located in Brazil, please visit the Brazil-specific privacy rights section for more information.
• If you are located in the People’s Republic of China (excluding Hong Kong, Macau and Taiwan), please visit the China-specific privacy rights section for more information.

For more questions about our Privacy Notice, please feel free to email us at privacysbn@seabourn.com

Seabourn Cruise Line Limited (“Seabourn”,” “we,” “our,” or “us”) is a division of Carnival Corporation & plc. We recognize that your privacy is important. Your choice to share information with us is an important part of how we provide a world-class travel experience. We’ve developed this Privacy Notice to explain how your personal information is collected, used, stored, processed, transferred and disclosed by Seabourn Cruise Line, both online and in the real world.

Our Services. This Privacy Notice applies to our websites and applications, including seabourn.com and any other website, mobile application, or other online service that links to this Notice (collectively, our “Sites”) and describes how we collect, use and process your personal information in connection with our Sites, marketing and promotional activities and your interactions with us before, during and after one of our vacation experiences (collectively with our Sites, our “Services”).

Please note that this privacy notice does not apply to our processing of information about employees, crew, contractors or our vendor contacts.

By providing us with your personal information or otherwise using our Services, you acknowledge that you have read, understood and agree to the terms of this Privacy Notice and our Terms of Service.

Click on the links below to jump to each section:

• HOW WE COLLECT AND USE YOUR INFORMATION
• HOW WE SHARE YOUR INFORMATION
• CHOICES ABOUT YOUR INFORMATION
• COVID-19 NOTICE
• CHILDREN’S PRIVACY
• REGION-SPECIFIC DISCLOSURES
• HOW WE PROTECT YOUR INFORMATION
• TSA SECURE FLIGHT NOTICE
• LINKS TO THIRD-PARTY SERVICES
• CHANGES TO OUR PRIVACY NOTICE
• QUESTION? COMMENTS? CONTACT US

We collect personal information in various ways, for example, when you visit our online sites and services, book travel, create an account, enjoy our vacation experiences while on a voyage, communicate with us or otherwise engage with our Services. All of the information collected through our Services may be combined to provide a seamless, personalized experience, regardless of how you interact with us.

The categories of personal information we collect can include:

Personal identifiers such as your name, email address, mailing address, phone number, date of birth or similar identifiers.

Customer records such as your identification documents, payment information (credit or debit card or other financial information).

Commercial information such as your travel history, account data, participation in a loyalty or rewards program, or information about the products or services purchased or considered.

Health or medical information such as health monitoring information, accessibility information, care in one of our shipboard clinics, medications, allergies or other medical accommodation needs.

Sensory information such as photos and videos of you and audio recordings of phone calls between you and us, where permitted by law.

Biometric information, including facial identifiers that can recognize you from photos and video.

Preferences you provide to us or generated through your use of the Services, including inferences we may make based on our experience with you.

Internet, network and device information from the browser or device you use to access our Services, which could include your IP address, device ID, cookie identifiers, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and or clickstream data.

Geolocation data including precise geolocation data from your browser or device or inferred based on your IP address.

Background check information that we may receive from third-party sources, such as criminal and sex offender registry information.

Professional information if you submit a job application or in connection with your role as a travel partner or agent.

Keep reading to learn more about how we collect personal information you provide to us directly, information we collect through your use of the Services or your travel experience, and information we receive through third parties, and the purposes for which we use your information.

A. When You Provide Personal Information to Us.

• REGISTRATION & PROFILE. If you register for an account through our Services or complete your traveler profile, we collect your personal identifiers, customer records, commercial information and, if you provide it, information about health or medical conditions. We use this information to create and administer your account, provide you with the relevant Services and information, communicate with you regarding your account and your use of the Services, provide rewards and loyalty program perks, for customer support purposes, and to send you marketing communications by email, push notification, or by text message, in accordance with your preferences.
  
  
• TRAVEL BOOKINGS & ORDERS. If you book travel with us or order additional products or Services, we collect a variety of information, including your personal identifiers, customer records, commercial information and, if you provide it, information about health or medical conditions, as well as any other information you choose to provide to us. We use this information to process your transaction, complete and ship your purchase, book and confirm your travel itinerary, communicate with you and those traveling with you about your itinerary and to administer the Services.
  
  
• INQUIRIES & COMMUNICATIONS. If you communicate with us or other guests through any paper or electronic form to request an itinerary, deck plan, brochure, ebrochure or video, or to otherwise inquire or communicate with us or other guests, we collect your personal identifiers, commercial information, and any other personal information you choose to provide in the content of your message. We use this information to investigate and respond to your inquiries, to facilitate communication with us and the other guests, to provide you with requested information, to enhance the services we offer to our guests, and to manage and grow our business. If you represent a company or agency interested in partnering with us, we will also collect your professional and employment information in order to respond to your inquiries, communicate with you, to manage and grow our organization and to facilitate a business relationship.
  
  
• SURVEYS & SWEEPSTAKES. If you choose to take advantage of a promotion, respond to a survey, or enter a contest or sweepstakes, we collect your personal identifiers, customer records and any other personal information you are requested to provide at the time, or choose to provide to us. We use this information to administer and facilitate the Services, to respond to your submission, to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
  
  
• DEVICE CONTENT (CONTACTS AND PHOTOS). With your permission, we will collect content from the device you use to access our online Services, such as photos from your device camera roll and camera and the contacts from your address book. We use this information to share photos and video you take during your vacation or to communicate with your contacts. For more information on how to withdraw your permission, please see the Choices About Your Information section below.
  
  

You may provide personal information for yourself and those traveling with you. By providing us with the travel or contact information of any third party, you confirm that you have the authority to do so on their behalf and have provided them with the information set out in this Privacy Notice. The personal information of each person whose personal information is linked to the same travel itinerary may be accessible by all others included in that same itinerary.

B. While You Are On Your Vacation

When you take part in the Services aboard one of our ships or at one of our properties, we collect information about your visit, including information about your interactions with our staff, programming and with the technology-enhanced features of our ships and hotels.

There are a few different types of vacation experiences where we may collect and use your information:

• AMENITIES, EXCURSIONS & ADD-ON SERVICES. If you choose to take advantage of our amenities or enhance your vacation with on-board purchases of goods or Services, we collect your personal identifiers, customer records, and commercial information. Depending on the Service, we may also need to collect information about your health or medical conditions. We use this information to process your transaction, book and administer your Services, to communicate with you and those traveling with you about your Services, and to inform our advertising and marketing activities. Where the Services are provided by third-party companies, we will use your information to coordinate and facilitate their provision of the Service.
  
  
• INCIDENTS AND HEALTH SCREENINGS. If, while traveling with us, you suffer a personal injury, fall ill, submit a claim about a personal injury, or are otherwise involved in an incident, we collect your personal identifiers, health or medical information and details about the incident. We may also screen you for symptoms of potential contagions, such as COVID-19, that may present a risk to the other guests and crew members aboard our ships, including through temperature checks, self-assessment questionnaires and tissue sampling. We use this information to attend to your medical and safety needs and those of our guests and crew, maintain records of incidents, facilitate investigations and remedies, to protect our rights and the rights of our guests, for security and public health purposes, to prevent fraud, and to improve our Services.
  
  
• PHOTO & VIDEO FOOTAGE. We collect a security photo at or before you board our ships. We operate closed circuit television (CCTV) cameras on board our ships, including at all access points and throughout the public areas. These CCTV cameras record continually and images of you may appear in these recordings ("CCTV images"). Photographers and camera crews take photographs and make films for guests to purchase at the end of their vacation or for our own promotional use. They are happy to take reasonable steps to avoid filming or photographing you where you indicate to the person with the camera that this is your preference , but we are unable to guarantee that your images will not be included on an incidental basis. We use this information for our own promotional purposes, to maintain records of incidents, facilitate investigations and remedies, to protect our rights and the rights of our guests, for security purposes, to enable public health measures, to prevent fraud, and to improve our Services. We may apply facial recognition technology to your security photo to facilitate camera-enabled rapid embarkation, debarkation, at entry and exit of the vessel at ports of call. We may also use facial recognition to link the pictures and videos taken by onboard photographers or videographers to you for ease of ordering and to reduce paper waste. After sailing, you will still be able to access your linked photos and videos via our connection with a third-party photo library service. We delete facial biometric identifiers promptly following completion of the voyage though we may retain any photos that have been identified and linked to a guest account for up to two (2) years to enable guest access and purchase of photos and photo memorabilia after the end of the voyage.
  
  
• CASINO. If you choose to play or use the services in one of our Casinos or gaming arcades and/or participate in one or more bingo sessions or online gaming experiences, we may collect your personal identifiers, customer records and commercial information. We also collect information about your gaming activity, such as the games you play, duration of play, results of play, total amount wagered, and amount of winnings. We may use this information to validate your identity and age, to determine your eligibility for promotions and offers during your vacation and for future travel, to inform our marketing and advertising activities, and to communicate directly with you. In addition, we may use this information to generate win/loss statement, to conduct credit checks, process lines of credit, or otherwise as needed to comply with our legal obligations and to prevent or investigate fraud. Note: guest casino sites may only be available in international waters or locations where permitted by applicable jurisdictional laws.
  
  
• MEDALLIONCLASS™. Where available on MedallionClass™ ships and at certain resorts or destinations, we collect information from and linked to your use of your Medallion® wearable (the “Medallion®”), as well as information collected through OCEAN® websites and applications, including MedallionClass™, PlayOcean®, and Ocean® Casino ( together with MedallionClass™ ships and destinations, the “MedallionClass™ Services”), your use of the Medallion® during your vacation, and from your booking and interactions with our Services on-board and in select resorts. The wearable Medallion® allows us to collect your position and movement information through sensors and readers located throughout our MedallionClass™ ships and in certain resorts and properties which emit a signal that detects the presence of the Medallion®. This allows us to gather information about your position and location within the ship and your movements on-board. The Medallion® technology is not a global positioning system and cannot detect the precise geolocation (lat/long) of an individual. The Medallion® is linked to your other personal information associated with your registration and traveler profile. We use this information to enable certain personalized features and Services online and during your vacation. For example, we use this information to locate you during your vacation and enable you to locate other members of your family, to contact you and deliver requested Services to your location (e.g., food delivery), to send you content or messaging relevant to your location and to customize your interactions with our Services. We may also use this information to monitor and protect the health and safety of our guests, including to conduct contact tracing, or investigate wrongful acts or allegations as appropriate. We may also use this information, individually and in aggregate, to develop and improve our Services and to understand the movement patterns and behaviors of guests on our ship. When you make a purchase through the MedallionClass™ Services using your Medallion®, we will process the commercial information you have on file in order to complete your transaction, detect and prevent fraud, and to inform our advertising and marketing.
  
  

C. When You Use Our Online Services

When you visit our Sites or use our Services, read our emails, or otherwise engage with us through a computer or mobile device, we and our third party partners automatically collect information about how you access and use the Service and information about the device you use to access the Service.

We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, APIs and mobile software development kits (SDKs), location-identifying technologies, and similar technology (collectively, “tracking technologies”), and we may use third party services to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly or receive from other sources.

Specifically, we and our third party partners may use tracking technologies to automatically collect commercial information, preferences, and internet, network and device information, including:

• Information about how you access the Service, such as the site from which you came and the site to which you are going when you leave our Sites, how frequently you access the Service, when and whether you open emails or click the links contained in emails, whether you access the Service from multiple devices and other actions you take on the Service.
  
  
• Information about how you use the Service, such as the pages you visit, the links you click, the ads you view and click on, purchase information and your checkout process, your location when you access or interact with our Service, and other similar actions.
  
  
• Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, e.g., a persistent device identifier or an Ad ID), and other such information.
  
  
• Analytics information. We may collect analytics data, or use third party analytics tools, to help us measure traffic and usage trends for the Service and to understand more about the demographics and behaviors of our users. We may also use analytics tools to record your mouse movements, scrolling, clicks and keystroke activity on our Sites to understand how our users engage with our Sites and to monitor and improve our online offerings.
  
  

This information allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Sites and Services, and for other internal purposes. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Sites; (b) provide custom, personalized content, and information; (c) identify and contact you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) perform analytics and detect usage patterns on our Service; (f) diagnose or fix technology problems; (g) detect or prevent fraud or other harmful activities, and (h) otherwise to plan for and enhance our Service.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note, however, that disabling our cookies may mean that you will not be able to take full advantage of our Services.

Deleting cookies or controlling cookies through browser settings does not delete non-cookie tracking technologies such as Flash objects and HTMP5 Local Storage Objects (LSOs). To manage Flash cookie settings and preferences, you must use the settings manager on Adobe’s website or by http://www.aboutcookies.org/how-to-control-cookies. Please note, however, that disabling our cookies may mean that you will not be able to take full advantage of our Services.

Deleting cookies or controlling cookies through browser settings does not delete non-cookie tracking technologies such as Flash objects and HTMP5 Local Storage Objects (LSOs). To manage Flash cookie settings and preferences, you must use the settings manager on Adobe’s website or by clicking here. If you choose to delete Flash objects from our Service, then you may not be able to access and use all or part of the Service or benefit from the information and services offered.

We and our third party partners may collect information through tracking technologies for personalized advertising purposes. See “About Our Ads” to learn more.

D. Information From Third-Party Sources

We may receive personal information about you from other users or our business partners and service providers and combine this information with other information we have.

• AFFILIATES. We may receive information about you collected by other Carnival Corporation companies, businesses, brands and affiliated entities in our family of companies, so that information you provide to one brand may be used by us to better provide you Services and communicate with you.
  
  
• SINGLE SIGN-ON. We use single sign-on to allow a user to enter login information from a third-party platform to access the Services. If you create or log into your account through a third-party social media site, such as Facebook or Google, these services will authenticate your identity and provide you the option to share certain personal information with us, which could include your personal identifiers. We may use this information to authenticate your account, to provide you Services, to communicate with you, and for advertising and marketing purposes. The data we receive is dependent on the third-party’s policies and your privacy settings on that third-party site. To learn more about the use of data collection technologies by social media sites, please visit each site’s privacy policy.
  
  
• SERVICE PROVIDERS & PARTNERS. From time to time, we may receive personal information about you from our service providers and other partners, including from our marketing partners or from third-parties conducting identity or address verification, payment processing, credit checks, processing lines of credit, or from our excursion partners or other partners providing activities. We use this information to validate your identity, age and address, to comply with our legal obligations, to monitor activity to identify and provide you with promotions and offers onboard and for future travel, and to prevent fraud, protect our rights and the rights of others, to inform our marketing and advertising activities, and to help provide our Services.
  
  
• OTHER TRAVELERS. We may obtain information about you from other travelers who are traveling with you or who have traveled with you, as well as your emergency contacts. We use this information to book your travel itinerary, communicate with you and those traveling with you about the Services, to support public health initiatives, to administer the Services, and for the purpose for which it was provided to us
  
  
• TRAVEL AGENTS. If you purchase travel through a travel agent, the agent may send us your personal identifiers, commercial information and information about health or medical conditions. We will use this information to complete the transaction, book your travel itinerary, communicate with you and those traveling with you about the Services, analyze trends, improve our business, and facilitate your vacation experience. They may retain a copy of this data and are required to have appropriate admin, technical and other safeguards. The travel agent is solely responsible for the processing of personal data they retain. Please review privacy notice of each applicable travel agent for more information about their processing practices.
  
  
• PUBLICLY AVAILABLE INFORMATION. We may also collect information about you that is publicly available. For example, we may collect information you publicly post or tag us in on social media sites, such as Facebook or Google, elsewhere online, and information contained in public records databases. We will use this information to conduct market research, verify your identity, prevent fraud, and improve our Services and any other contracts you have entered into with us
  
  

In addition to the uses described above, we may collect and use personal information for the following purposes:

• To create, maintain, improve, and operate the Services.
  
  
• To personalize your user experience.
  
  
• To communicate with you to provide technical or administrative support.
  
  
• To conduct, manage, and grow our organization.
  
  
• To analyze, research, investigate and improve the use of our Services and interactions with our guests.
  
  
• To prevent, investigate, and defend against fraud, unlawful or criminal activity, unauthorized access to or use of personal information and our data system services, and to comply with legal requirements, obligations and other governmental demands.
  
  
• To investigate and resolve disputes and security issues and to enforce our Terms of Service.
  
  
• For any other lawful, legitimate business purpose.

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Choices About Your Information” section below.

We may share your personal information in the following ways:

• AFFILIATES. We may share personal information with our other Carnival Corporation companies, businesses, brands and affiliated entities in our family of companies, who may use your personal information in the manner described in this Privacy Notice. Please visit our website to learn more about the different brands in the Carnival Corporation family of companies, including how to contact each with privacy related inquiries.
  
  
• SERVICE PROVIDERS. We share information with third party vendors and service providers that perform services for or on our behalf, which may include identifying and serving targeted advertisements, providing mailing or email services, tax and accounting services, product fulfillment, payments processing, photo sharing, data processing and enhancement services, medical and health purposes, fraud prevention, web hosting, analytic services, or other online functionality, subject to appropriate contractual terms protecting the confidentiality and use of such data.
  
  
• PROMOTIONAL PARTNERS. We may share limited personal information with third parties with whom we partner to provide promotions, excursions, activities, contests, and sweepstakes, or other promotional activities. The partner will usually be identified by name in our promotion, contest, or sweepstakes communication
  
  
• WITH TRAVEL AND EXCURSION PARTNERS. Some onboard products and services, excursions and other activities are provided by other companies or you may book a travel through multiple operators, such as a travel agent or airline. We may share personal identifiers and similar information before, during and after your cruise to facilitate your travel activities, provide your requested services, and provide a seamless service to our guests.
  
  
• AT YOUR REQUEST. With your consent or at your direction, we may share your information with your friends and family through the Services or on various social media networks, or with third parties to whom you direct us to share information, such as excursion partners, medical providers or your travel agent. If you post a product review on our website or a comment on our social media sites, the information you provide may be displayed on publicly online for others to view.
  
  
• SELECT MARKETING AND STRATEGIC BUSINESS PARTNERS: We may share limited data with our marketing and strategic business partners, who may use this information for their own business and commercial purposes in accordance with their own privacy policies. For example, these partners may send you emails to provide you with information and marketing messages about products or services that may interest you. You may be given the option to opt-in or opt-out of such sharing, consistent with the laws of the applicable jurisdiction.
  
  
• CORPORATE TRANSACTIONS: Personal information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of any or all of our assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy or related or similar proceedings; and
  
  
• FOR HEALTH AND SAFETY REASONS: Your health and safety is important to us. We may share personal information with third parties or individuals if we reasonably believe in good faith that such action is necessary to protect the personal safety or health of our guests, crew, family members or other individuals. For example, we may disclose your personal identifiers and medical information if you require medical assistance or if we believe that such disclosure is reasonably necessary to inform health care and we may disclose similar information to your family members and emergency contacts, insurance providers, medical providers and family assistance companies in the event of health or safety incident. We may also disclose personal identifiers and health or medical information to our personnel and contractors, port agents and authorities, government officials, health agencies or any other individual or institution as reasonably needed to support public health initiatives, comply with our legal or regulatory obligations, attend to your medical and safety needs, facilitate investigations and remedies, track and mitigate risks of communicable illness including COVID-19, and to protect the rights, health and safety of our guests, crew, and others.
  
  
• LAW ENFORCEMENT, GOVERNMENT AUTHORITIES, REGULATORS AND FOR SAFETY OR LEGAL REASONS: We may share personal information with third-parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the our legal obligations under the laws in the jurisdictions in which we operate; (b) to comply with the lawful or reasonable requests of law enforcement, government authorities, courts or to respond to legal process; (c) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (d) to exercise or protect the rights, property, or personal safety or health of us, our guests, online visitors, or any other third-party. For example, and we may be required to disclose your personal identifiers, customer records and other information to customs agencies or port authorities in the locations where we stop in port.
  
  

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you.

All the above categories exclude text messaging originator opt-in data and consent, which will not be shared with any third parties, except as follows: (1) sharing with vendors, consultants, and other service providers who need access to such information to carry out work on our behalf, and who will not use such information for their own purposes; (2) if we believe disclosure is required by any applicable law, rule, or regulation, or is necessary to comply with law enforcement or other legal process; (3) if you consent to our sharing of such information; or (4) sharing that is otherwise allowed by law and is in accordance with carrier terms and conditions.

PROFILE ACCESS & SHARING SETTINGS. You may access and update your profile information, such as your user name, address, or billing information, and may change some of your data sharing preferences on your account page.

GEOLOCATION & DEVICE CONTENT. You may control location tracking by adjusting your location services options on the “Settings” app on your mobile device. We may continue to approximate your location based on your IP address when you access the Services through a computer or device. If you would like to update your device content access permissions, such as permissions to access your camera or address book, you can do so in the "Settings" app on your mobile device.

MEDALLIONCLASS™. To avoid the collection of your position and movement data collected, do not use the Medallion®. You may contact the staff on board the ship to request a card to access your guest room and pay for on board transactions in lieu of the Medallion®. The sensors will still be able to detect your on board position when you use the card to access your room, make a payment, or take a photo, but the card cannot be read by the long-range sensors to track movement data around the ship. Some features of the MedallionClass™ Services will not be available to you if you do not use the Medallion®.

PROMOTIONAL MESSAGES. You can stop receiving promotional email communications from us by following the “unsubscribe” instructions provided in such communications. We make every effort to promptly process all unsubscribe requests. You may still receive Service-related communications, including account verification, transactional communications, changes/updates to features of the Services, and technical and security notices.

ACCESSING, MODIFYING OR DELETING YOUR INFORMATION. In accordance with the applicable jurisdictional laws, you may have the right to request to access, modify, or delete your personal information, or remove your name or comments from our website or publicly displayed content. We may not be able to modify or delete your information in all circumstances.

• To access, modify or delete your personal information, please submit a request by:
  • Emailing privacysbn@seabourn.com
  • Calling 1–866-755-5619/
    
    
  We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account.
  In certain circumstances, we may decline a request to exercise the requests described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
  
  
• REQUESTS FOR MINOR CHILDREN. If you wish to submit a request to access, modify or delete information on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., that you are the child’s legal guardian or authorized representative).
  
  

In certain circumstances, we may decline a request to exercise the requests described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

• REQUESTS FOR MINOR CHILDREN. If you wish to submit a request to access, modify or delete information on behalf of your minor child, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., that you are the child’s legal guardian or authorized representative).
  
  

ABOUT OUR ADS. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. To learn more about our advertising practices and your choices relating to advertising, please see the About Our Ads notice for more information.

In response to the global coronavirus pandemic and to protect against the risks of other communicable illness, all guests may be required to undergo health screenings and we will collect additional information recommended by public health authorities or other government agencies or to otherwise demonstrate our guests’ ongoing health and fitness to travel, including:

• CONTACT INFORMATION. Information such as name, nationality, country of residence, originating address, destination address, telephone, and email;
  
  
• SYMPTOMS AND HEALTH INFORMATION. Information regarding the presence or absence of possible COVID-19 or other global pandemic symptoms, which may be collected through temperature scans, tissue sampling, medical examinations, surveys or questionnaires, as well as information about pre-existing medical conditions;
  
  
• EXPOSURE. Information regarding potential exposure to or infection with COVID-19 or other global pandemic, which may include recent travel history, contacts with guests, crew or other individuals.;
  
  
• CONTACT TRACING VIA WEARABLE DEVICE TECHNOLOGY AND OCEANORBIT™ CONTACT TRACING SYSTEM. Information about on-board contacts with crew, guests or other individuals collected via wearable technology such as the Medallion® on MedallionClass™ ships and properties and/or the OceanOrbit™ Contract Tracing system. These devices collect data, such as personal contact, time stamp, duration of contact and frequency of contact with others.
  
  
• AS REQUIRED BY LAW. Information collected by our on-board crew or reservations staff pursuant to directives by public health organizations or other government agencies.
  
  

We collect and use this information because:

• we must comply with certain regulatory requirements regarding public health, including to determine your fitness to travel consistent with applicable government regulations and guidelines;
  
  
• we have a legitimate business interest in ensuring the health and safety of our passengers, crew and the public;
  
  
• we have a legitimate business interest in complying with legal and regulatory requirements applicable in the various jurisdictions in which we operate;
  
  
• we need to use this information to perform our contract with you to provide our vacation experiences.
  
  

Contact Tracing through OceanOrbit™ Contract Tracing System. To help mitigate and manage the potential spread of COVID-19 or other global pandemic illnesses, we use wearable device technology to identify individuals who may have been exposed to COVID-19 and to rapidly detect potential secondary cases that may arise after transmission from an infected individual. The OceanOrbit™ device is a wearable portable electronic device that collects data as guests and crew interact with one another in public and in private areas by broadcasting and recording the presence and proximity of other OceanOrbit™ devices. The OceanOrbit™ system collects time stamps, duration of contact and frequency of contacts. The raw data is associated with the device ID number but will be correlated with guest or crew personal information in the event that contract tracing is called for. On MedallionClass™ ships, we may use on board contact data collected in connection with the Medallion®, rather than the OceanOrbit™ system, which will be linked to your personal information in the same manner as all other OCEAN® data. As part of our contract tracing efforts, we take reasonable precautions to respect our Guests’ privacy and confidentiality by communicating contact exposure information in a manner that is not personally identifiable. However, information about you may be disclosed in a manner that could allow the recipient to determine your identity. For example, if we determine that it is necessary to disclose to a guest that she was in contact with an individual who tested positive for COVID-19 for a period of 1-2 hours on a particular date, that guest may be able to ascertain the likely identity of the unnamed individual based on her personal experience.

We may disclose your personal information, contacts and health information with third parties or individuals to attend to your medical and safety needs and those of our guests and crew; to comply with legal and regulatory requirements; to facilitate public health response initiaves; to conduct contract tracing of individuals who are exposed to or test positive for COVID-19 or other communicable illness while staying with us; or if we reasonably believe that such disclosure is necessary to inform your health care or to protect the personal safety or health of our guests, crew, or other individuals. For example, we may disclose personal identifiers and health or medical information to our personnel and contractors, port agents and authorities, government officials, health agencies or any other individual or institution as reasonably needed to support public health initiatives, comply with our legal or regulatory obligations, attend to your medical and safety needs, facilitate investigations and remedies, track and mitigate risks of communicable illness including COVID-19, and to protect the rights, health and safety of our guests, crew, and others.

Though Seabourn Cruise Line provides fun for families of all ages, most of our online Services are not intended to be used by children, nor do we have actual knowledge that children are using these online Services. When we intend to collect personal information from children online, we take additional steps to protect their privacy, including:

• notifying and obtaining consent from parents and legal guardians, in accordance with applicable law,
  
  
• limiting our collection of personal information from children to no more than is reasonably necessary to participate in the online activity, and
  
  
• giving parents and legal guardians the ability of access personal information that we have collected from their children and to request the personal information be deleted or modified
  
  

If you believe that we might have inadvertently collected information from a child without appropriate parental consent, please contact us at privacysbn@seabourn.com so that we may delete the information as soon as possible.

Where we collect personal information about children (for instance, information provided by a parent or legal guardian, travel agent or other travel partner), we process such information in a manner consistent with applicable laws protecting the privacy of children’s data. For additional information about our practices regarding the collection of information from children, please read our Children’s Privacy Notice.

This section applies to you if you are a resident of the state of California, Colorado, Connecticut, Utah, or Virginia, and provides additional information about our personal information processing practices relating to individual residents of these states.

COLLECTION AND USE OF PERSONAL INFORMATION.  In the last 12 months, we have collected all of the categories of personal information described in our Privacy Notice.  To learn more about the types of personal information we collect, the sources from which we collect it, and the purposes for which we use this information, please refer to How We Collect and Use Your Information [O1] of the Privacy Notice.

Sensitive Information. Some of the categories of personal information described in our Privacy Notice may be classified as “sensitive” under certain U.S. state privacy laws (“sensitive information”), including social security number, driver’s license number, and passport number; payment card number plus expiration date and security code, and financial account number and routing number; information concerning your health; biometric information for the purposes of uniquely identifying guests; your username and password; personal information collected from a child; and precise geolocation data. We use this sensitive information for the purposes set forth in the  How We Collect and Use Your Information Privacy Notice to the extent necessary for the operation of our Services, to enter into and perform a contract with you, to comply with legal and regulatory requirements, to protect the life or physical safety of anyone or as otherwise permissible for our own internal purposes consistent with law.

Deidentified Information. We may at times receive, or process personal information to create, deidentified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.

DISCLOSURE OF PERSONAL INFORMATION. We share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales. The categories of third parties to whom we sell or disclose your personal information for a business purpose include: (i) other brands and affiliates in our family of companies; (ii) our service providers; (iii) marketing and strategic partners; (iv) promotional partners; (v) ad networks and advertising partners; (vi) analytics providers; (vii) social networks; and (viii) government authorities. To learn more about how we disclose data to third parties, please refer to How We Share Your Information[O5  of the Privacy Notice.

Unless you have exercised your Right to Opt Out of personal information sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.

In the previous 12 months, we have disclosed the all of the categories of personal information we collect to third parties for a business purpose.

In the previous 12 months, we have sold the following categories of personal information to third parties: (i) Personal Identifiers; (ii) Commercial Information; (iii) Preferences; (iv) Internet, network and device information.

We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising. However, depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our processing of sensitive information (as described in the Your Rights and Choices section below), except for where the processing of your sensitive information is necessary to provide you the services or otherwise required by law. 

YOUR RIGHTS AND CHOICES. Depending on your state of residence, and subject to certain legal limitations and exceptions, you may be able to exercise the following rights:

·         The Right to Know whether we are processing any personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you, including : the categories or specific pieces of personal information we have collected about you; the categories of sources of the personal information; the categories of personal information that we have sold or disclosed to third parties for a business purpose, and the categories of recipients to whom personal information was shared, sold or disclosed; and the business or commercial purposes for collecting or selling the personal information.

·         The Right to Access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

·         The Right to Correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

·         The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.

·         The Right to Limit Use and Disclosure of Sensitive Information and exercise control over our collection and processing of certain sensitive information.

·         The Right to Opt Out of Personal Information Sales to third parties now or in the future.

·         The Right to Opt Out of Sharing Personal Information for Targeted Advertising based on your activity across businesses, distinctly-branded websites, applications, or services.

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

You also have the right to be free of retaliatory or discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

How to Exercise your Rights.  You may submit a request to exercise your privacy rights through one of the mechanisms described below. We will need to verify your identity and confirm your state of residence before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one.  These rights may not be available to all U.S. residents. We will process your request in accordance with applicable state law. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

Please note that we can only process privacy rights requests for personal information processed by Seabourn.  If you have interacted with another brand in our family of companies or any other third party, you will have to contact that brand or third party to exercise your California Consumer Requests.

To access, modify or delete your personal information, please submit a request by:

·         Filling out our Request Form, or

·         Calling 1-866-755-5619

To submit a request to opt-out of personal information sales, please submit a request using our Do Not Sell or Share My Personal Information form to be added to our suppression list.

Additionally, as is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third party businesses collect and disclose personal information (including preferences, rough geolocation, commercial information and internet, network and device information) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. These third parties use this information for the purposes of serving targeted ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting and may sell and share that information to other businesses for advertising and other purposes. By visiting PrivacyRights.info,, you can opt out from sales of this type of personal information by businesses that participate in the opt-out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices.  To learn more about how third parties collect information through tracking technologies and what other choices you may have in relation to those activities, please see About Our Ads.

Minors.  We do not sell or, for the purposes of targeted advertising, share the personal information of consumers we know to be less than 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at privacysbn@seabourn.com.  We may not be able to modify or delete your information in all circumstances.

If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., that you are the child’s legal guardian or authorized representative).

Authorized Agents.  In certain circumstances, you may permit an authorized agent to submit requests on your behalf.  The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf, or must provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney. 

For security purposes, we may need to verify your identity and confirm directly with you that you have provided the authorized agent permission to submit the request, and it may take additional time to fulfil agent-submitted requests. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.  Please note that for privacy and security reasons, we will direct future communications to the data subject on whose behalf the request was made.

Notice of Financial Incentive. Notice of Financial Incentive. We offer various financial incentives. For example, the financial incentives we may provide include:

·         Discounts, coupons and special offers via email when you sign up for our email list or create an account.

·         Rewards when you refer a friend who has never sailed or booked with us before.

·         Loyalty programs, where you earn rewards based upon your past travel or spend with us, or through co-branded credit cards such as SEABOURN CLUB 

When you sign up for our email list or create an account, you opt-in to participate in a financial incentive program. Participation in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, you may unsubscribe from our emails (for email-based incentives), close your account (for loyalty and reward program incentives) or submit a request to delete your information. The financial incentives we offer to consumers are reasonable related to the value of the consumer’s data to our business, based on our reasonable but sole determination. We estimate the value of consumers’ personal information by considering the expense incurred by the business related to the collection, storage and retention of consumers’ personal information in the context of the financial incentive program and the expenses related to the provision of the financial incentive. Interested individuals can opt-in to these financial incentives by following the instructions presented at the time the offer is made. Participating individuals may withdraw from our programs and other offerings at any time by following the instructions provided in connection with each offering or by contacting us with the information found in the Contact Us section below.

“Shine The Light” Law.  California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click Do Not Sell or Share My Personal Information and provide your contact information to be added to our suppression list.   

Data Subject Rights Metrics 2020. The following data reflects the California consumer rights requests that we have processed in the 2020 calendar year (January 2020 – December 2020):
 

B . NEVADA PRIVACY RIGHTS

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. If you are a Nevada resident, you may submit a request to opt out of potential future sales under Nevada law by emailing us at privacysbn@Seabourn.com or completing the Do Not Sell My Personal Information Request Form. Please include sufficient information for us to identify you in your email, such as information about previous voyages, or, if applicable, your account information. Please note we will take reasonable steps to verify your identity and the authenticity of the request.  

C.       EUROPEAN PRIVACY RIGHTS

This section applies to you if you are a resident of a member state of the European Economic Area, the United Kingdom and Switzerland. The European Data Protection Regulation and corresponding law in the other European States not being member of the European Union requires us to to disclose certain information regarding the personal information we collect about you and your rights in respect of personal information that we hold.

Legal Basis for the Processing of Your Personal Information.  Our processing of your personal information as described in the Section “How We Collect and Use Your Personal Information”is based on the following legal grounds:

·         Consent: We may need your consent in connection with our promotional activities in particular, such as sending you promotional messages, if you decide to participate in sweepstakes, to deploy certain cookies when you use our online services and where you use certain Services where we collect location information or information about your health or medical conditions.

Where we need your consent, you have the right not to provide consent, or to withdraw it at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal information before your withdrawal. If you have granted us consent to use your personal information, we will use it only for the purposes specified in the consent declaration. Please note that to the extent our processing is based on your consent and you deny your consent or withdraw it, we may not be able to provide the Service relating thereto. Besides from that, neither the initial denial nor a withdrawal will have any negative consequences for you.

·         Perform or enter into a contract or quasi contractual relationship with you: We rely on this legal basis in particular in the following cases:

o    to manage your travel bookings and orders;

o    to provide you with our Services, e.g., process your on-board purchases of goods or Services,

o    to communicate with you to provide technical or administrative support, or

o    to be able to provide our online Services.

·         Compliance with legal obligations: We may be obliged to process personal information to comply with our legal obligations, for example where we are required to retain data for tax law or commercial purposes or where we must comply with regulatory requirements regarding public health or gambling.

·         Legitimate interests: We may base the processing of your personal information on our legitimate interests where (i) neither of the afore listed legal bases apply and (ii) where the processing of your personal information is necessary for our legitimate interests. Such cases may include the following in particular:

o    to conduct customer surveys in order to enhance and optimize your vacation experience;

o    to protect our rights and the rights of our guests;to prevent, investigate, and defend against fraud, unlawful or criminal activity, unauthorized access to or use of personal information and our data system services;

o    to investigate and resolve disputes and security issues;

o    to provide you with personalized Services;

o    to communicate with you and reply to your questions or comments submitted to us by any means; and

o    to pursue or defend against legal claims.

Where we process your personal information based on our legitimate interests, we will only do so where we have appropriately assessed and balanced our interests against your right to privacy.

Additional Information on How Your Personal Information Is Transferred Globally.  In case your personal information is transferred to jurisdictions located outside of the European Economic Area, the United Kingdom or Switzerland, for example, to the United States or any other country where we have operations, we will ensure that appropriate safeguards exist and are taken, such as:

·         the recipient of the personal information is located within a country that benefits from an “adequacy” decision of the European Commission;

·         the recipient has signed a contract based on the standard contractual clauses  approved by the European Commission, obliging them to protect your personal information;

·         or in the absence of the above appropriate safeguards, we will ask you for your explicit consent for the cross-border transfer of your personal information or take any other measures that are recognized as providing a sufficient level of protection for your personal information.

Please be aware that the United States’ laws have not yet been acknowledged as providing for a data protection standard which is adequate to the ones within your jurisdiction.

For more information about the safeguards relating to personal information transfers you may contact our Data Protection Officer by sending an email to privacysbn@seabourn.com.

Your Rights: You are entitled to the following rights in respect of personal information that we hold:

·         RIGHT OF ACCESS. The right to obtain access to your personal information.

·         RIGHT TO RECTIFICATION: The right to obtain rectification of your personal information where that personal information is inaccurate or incomplete.

·         RIGHT TO ERASURE. The right to obtain the erasure of your personal information in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.

·         RIGHT TO RESTRICTION. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.

·         RIGHT TO OBJECT. You have the right to object to any processing justified by legitimate interests based on grounds relating to your particular situation at any time. Should you decide to object to the processing of your personal information, we will stop processing personal information concerning you, unless we can demonstrate compelling reasons for continuing to process your personal information that override your interests, rights and freedoms or in the case that we establish, exercise, or defend our legal claims. You can object to direct marketing activities at any time for any reason whatsoever.

·         RIGHT TO DATA PORTABILITY. You have the right to obtain a copy of your personal information in a structured, commonly used and machine-readable format and transmit such data to another provider or have such data transmitted to another provider under certain circumstances.

·         RIGHT TO WITHDRAW CONSENT. If you have given us your consent to process your personal information but change your mind later, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal information before your withdrawal. If you want to withdraw your consent with regard to receiving promotional communications, you can unsubscribe through the method described in each promotional message.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

For further information on how to exercise those rights, you may contact our Data Protection Officer by sending an email to privacysbn@Seabourn.com. You also have the right to lodge a complaint with the competent data protection supervisory authority. Information about how to contact your local data protection supervisory authority is available here .

D.      BRAZILIAN PRIVACY RIGHTS

This section applies to you if your personal information: (i) is processed in the Brazilian territory;  or (ii) has been collected in the Brazilian territory. Also, this section applies to you if the purpose of the processing activity is the offer or supply of goods or services within the Brazilian territory.

·         Your Rights. According to the Brazilian General Data Protection Law, Law No. 13.709/18 (“LGPD”), you may be able to exercise the following rights, at any time upon request:

o    confirmation of the existence of processing;

o    access to the personal information;

o    correction of incomplete, inaccurate or outdated personal information;

o    anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the provisions of the LGPD;

o    portability of your personal information to other service providers or suppliers of product, at the express request, and observing our business and industrial secrets;

o    elimination of the personal information processed with the consent, except in the events set forth on the topic “Termination of the processing” below;

o    information of the public and private entities with which the controller carried out the shared use of personal information;

o    information on the possibility of not providing consent and on the consequences of the denial;

o    revocation of the consent.

Termination of the Processing. Your personal information shall be eliminated after termination of the processing thereof, within the scope and technical limits of the activities, and conservation thereof shall be authorized for the following purposes:

·         compliance with a statutory or regulatory obligation by Seabourn;

·         transfer to third parties in accordance with the data processing requirements set forth in the LGPD; or

·         exclusive use of the personal information by Seabourn, providing the personal information are anonymized and that the access thereto by third parties will be prohibited by Seabourn.

E.       CHINESE PRIVACY RIGHTS

This section applies to you if: (i) your personal information is processed within the territory of the People’s Republic of China (excluding Hong Kong, Macau and Taiwan, the “PRC”), or (ii) you are within the territory of China and your personal information is processed outside of China for the purposes of providing goods or services to you, or analyzing or evaluating your behaviors. PRC law requires us to disclose certain information set forth below.

Processing of Sensitive Personal Information.  Under the PRC law, sensitive personal information includes information regarding such as biometrics, religious beliefs, race, ethnicity, medical health, financial accounts, and location tracking, as well as the personal information of minors under the age of 14 (“Minor(s)”). For example, we may process your sensitive personal information in an incident, for health screenings, or for security purposes. We may process certain of your sensitive personal information only when we have your consent or another legal basis to do so. Where your consent is the legal basis for processing your sensitive personal information (such as related to our MedallionClass™ Services), we will seek your prior consent separately. For more information on our processing of your sensitive personal information, please refer to the How We Collect and Use Your Information section of the Privacy Notice.

Before processing a Minor’s personal information, we will seek consent from their parent or other legal guardian.  

Legal Basis for the Processing of Your Personal Information.  Our processing of your personal information as described in the Section “How We Collect and Use Your Information” is based on the following legal grounds:

·         Consent: We may need your consent in connection with our promotional activities in particular, such as sending you promotional messages, if you decide to participate in sweepstakes, to deploy certain cookies when you use our online services and where you use certain Services where we collect location information or information about your health or medical conditions.

Where we need your consent, you have the right not to provide consent, or to withdraw it at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal information before your withdrawal. If you have granted us consent to use your personal information, we will use it only for the purposes specified in the consent declaration. Please note that to the extent our processing is based on your consent and you deny your consent or withdraw it, we may not be able to provide the Service relating thereto. Besides from that, neither the initial denial nor a withdrawal will have any negative consequences for you.

·         Enter into or perform a contract with you: We rely on this legal basis in particular in the following cases:

o    to manage your travel bookings and orders;

o    to provide you with our Services, e.g., process your on-board purchases of goods or Services,

o    to communicate with you to provide technical or administrative support, or

o    to be able to provide our online Services.

·         Carry out legal responsibilities or legal obligations: We may be obliged to process personal information to carry out our legal responsibilities or legal obligations, for example where we are required to retain data for tax law or commercial purposes or where we must comply with regulatory requirements regarding public health or gambling.

·         Respond to an emergency: We may collect and process your personal information in order to respond to a public health emergency or to protect a natural person’s life, health and property safety in an emergency.

·         Reasonably process legitimately published personal information:  We may reasonably process your personal information that has been published by you or otherwise has been published legitimately.

Data Retention. We will only store your personal information for as long as necessary to achieve the purposes of collection as set out in this Privacy Notice in accordance with our data retention policies, unless a longer retention period is required by applicable law. If we are required by applicable law to store your personal information beyond this period (e.g., for tax and commercial law reasons), we will delete the personal information after the end of this storage period.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use and disclosure of your personal information, the purposes for which we process the personal information, and the applicable legal requirements. After the expiry of the aforementioned retention periods, we will delete or anonymize your personal information.

If, after you sign up for our promotional emails, you unsubscribe from receiving our promotional emails, we will delete your personal information from our mailing lists. However, we might store your email address in a blacklist to ensure that you will not receive any further communication.

Your Rights: You are entitled to the following rights in respect of your personal information that we hold:

·         RIGHT TO KNOW AND DECIDE. You have the right to know and to decide about processing of your personal information unless the law provides otherwise. For example, we may be obligated by law to keep certain information confidential or may be exempted from notification under certain circumstances. You also have the right to request us to explain our rules on processing your personal information.

·         RIGHT TO RESTRICT OR OBJECT. You have the right to restrict or object to any processing of your personal information unless the law provides otherwise. For example, you may not be able to restrict or object to processing that is made on a legal basis other than your consent.

·         RIGHT TO ACCESS AND REPRODUCE. You have the right to access your personal information or to obtain a copy of your personal information unless we are obligated by law to keep certain information confidential.

·         RIGHT TO TRANSFER. You have the right to transfer your personal information to another processor appointed by you, provided that the transfer meets the requirements set forth by the Cyberspace Administration of China.

·         RIGHT TO RECTIFY AND SUPPLEMENT. You have the right to have your personal information rectified or supplemented where that personal information is inaccurate or incomplete.

·         RIGHT TO ERASE. You have the right to request the erasure of your personal information.  However, if we are obligated by law to retain your personal information for a longer period of time, or it is technically unfeasible to erase your personal information, we will retain your personal information with necessary security protection measures and will not otherwise process your personal information.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Please also note that after an individual passed away, their next of kin may be able to exercise the individual rights of the deceased in accordance with law.

For further information on how to exercise those rights, you may contact our Data Protection Officer by sending an email to privacysbn@seabourn.com. You also have the right to lodge a complaint with a competent personal information protection authority.

F.       JAPAN PRIVACY RIGHTS
This section applies to you if you are a resident of Japan, in accordance with the Act of Protection of Personal Information (the “APPI”) of Japan.

Inquiries and Complaints.  We shall respond appropriately to requests permitted under the APPI including requests for inquiries and complaints regarding the handling of personal information. Please submit a request in the same way prescribed in “ACCESSING, MODIFYING OR DELETING YOUR INFORMATION

We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%.

In the event that any information under our control is compromised as a result of a breach of security, we will take steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws and regulations.

While we take steps to protect your personal information and keep it secure, you also play a role in protecting your information. You can help to maintain the security of your online and mobile transactions by not sharing your reservation number, username, or password with anyone.

DATA RETENTION. We will only store your personal information for as long as necessary to achieve the purpose of collection as set out in this Privacy Notice in accordance with our data retention policies, unless a longer retention period is required by applicable law. If we are required by applicable law to store your personal information beyond this period (e.g., for tax and commercial law reasons), we will delete the personal information after the end of this storage period.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use and disclosure of your personal information, the purposes for which we process the personal information, and the applicable legal requirements. After the expiry of the aforementioned retention periods, we will delete or anonymize your personal information.

If, after you sign up for our promotional emails, you unsubscribe from receiving our promotional emails, we will delete your personal information from our mailing lists. However, we might store your email address in a blacklist to ensure that you will not receive any further communication.

The Transportation Security Administration (TSA) requires you to provide your full name, date of birth and gender for the purpose of watch list screening under the authority of 49 U.S.C. section 114, the Intelligence Reform and Terrorism Prevention Act of 2004 and 49 C.F.R. parts 1540 and 1560 for all commercial air travel within, into or out of the United States which is booked on or after August 15, 2009. You may also provide your Redress Number, if available.

If you book commercial air travel within, into or out of the United States in conjunction with your voyage we will request this information from you and forward it to the TSA as required by law. Failure to provide your full name, date of birth, and gender may result in denial of transport or denial of authority to enter the boarding area.

TSA may share information you provide with law enforcement or intelligence agencies or others under its published system of records notice. For more on TSA privacy policies or to review the system of records notice and the privacy impact assessment, please see the TSA Web site at www.tsa.gov.

TThe Services may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.

We may modify or update this Privacy Notice from time to time to reflect the changes in our business and practices, and you should review this page periodically. We will update the “Last Updated” date at the top of this page when we post changes to this Notice. If you object to any changes, you may close your account. Continuing to use our Services after we publish changes to this Privacy Notice means that you are consenting to the changes.

If you have any questions about this Privacy Notice or the website, please Contact Customer Service 1-866-329-2870.

Data Protection Officer: Please email privacysbn@seabourn.com.