Your Privacy Rights
In this document, the Redwood Travel Partners Privacy Notice, you will find an explanation of how we use your Personal Data – that’s the data that identifies you as an individual – to make sure that you have the best possible travel experience. We also explain what information we collect about you, what we do with it, and what your rights are. Redwood Travel Partners does NOT sell your personal information.
References to “We”, “Us”, or “Our” in this Privacy Notice, refers to your Redwood Travel Partners Travel Advisor, as well as Redwood Travel Partners, LLC, and dba Cruise Planners. For privacy notices related specifically to Cruise Planners® and for more information on Cruise Planners®, CP Franchising, LLC and Vecto Technology LLC (together referred to as “Cruise Planners”) at 3111 N. University Drive, Suite 800, Coral Springs, Florida 33065, USA, visit www.cruiseplanners.com/privacynotices
Your Privacy is Very Important to Us
It is our goal to be open with you about how We use your Personal Data to make sure that you have the best possible travel experience. We want you to understand how We use your Personal Data, how We keep it safe and what your rights are.
In this Privacy Notice We Explain:
1. What information We collect about you
2. Who is responsible for your Personal Data
3. What Personal Data We collect or receive
4. How We use your Personal Data
5. Who We share it with
6. Direct marketing
7. Profiling and personalized marketing
8. Cookies and other tracking technologies
9. Data retention
10. Acting on Someone’s Behalf
12. Your rights
13. Changes to Our Privacy Notice
14. How to Contact Us or make a complaint
1. What Information We Collect About You (and Why)
We collect your Personal Data when you use Our websites, mobile application(s), other digital platforms (together, “Digital Platforms”), or call a Redwood Travel Partners Travel Advisor.
For example, We collect:
o your contact details and other personal information (which may sometimes include sensitive Personal Data, such as special needs and dietary requirements);
o details about your bookings and reservations;
o your travel profile and marketing preferences; and
o information on how you use Our Digital Platforms and interact with Our emails.
We use your Personal Data to understand what you might be interested in and to make Our emails, texts, social or digital media, and offers relevant to you – We build a profile of your travel patterns and interests to do this.
We need to use your Personal Data to offer you the best possible travel experiences – When you book with Us, We need your Personal Data to book your vacation. We also process your Personal Data for customer service purposes and where required by law.
To provide Our services to you, We may need to share your Personal Data with:
o Our Suppliers around the world. We choose Our Suppliers carefully and put in place safeguards to help protect your Personal Data.
o When We say “Suppliers” in this Privacy Notice, We mean the parties who provide Us with products and services that enable Us to run Our business. This includes travel vendors such as cruise lines, hotels, transport and accommodation vendors, media vendors, port agents, and service providers who assist Us to run Our business, such as accountants, consultants, payment providers, auditors, IT service and platform providers, insurance providers, and legal advisers (together, Our “Suppliers”).
o Our Business Partners.
o When We refer to “Business Partners” We mean companies with whom We have partnered to complement the products and services We provide to you.
2. Who is Responsible for Your Personal Data?
As a data controller, We are responsible for the Personal Data you provide to Us and will only share such Personal Data with Our Suppliers and Business Partners if We have a legitimate reason permitted by law, such as your consent.
3. What Personal Data Do We Collect or Receive?
The following are examples of the categories of your Personal Data that We process alongside information on how and/or when We get that Personal Data:
4. How We Use Your Personal Data and Who We Share it with
A. We use your Personal Data:
i. To manage your bookings with Us and to provide the services that you request before, during and after your trip. We need to use your Personal Data to deliver Our services to you when you book travel with us. For example, when you book travel with Us We need your Personal Data to send you a booking confirmation, to manage changes to your booking, and to provide you with further products and services. If you sign-up for the CP Rewards program, we will share your personal information with, a service provider which manages the program on our behalf.
ii. To make Our Digital Platforms easy to use and enhance your travel planning experience. The Personal Data We collect when you use Our Digital Platforms helps Us to make sure that Our Digital Platforms work well (for example, so that We know it is you when you sign into your account). We’re often improving Our Digital Platforms and content therein to enhance your travel planning experience, and data about how you use Our site helps Us to do that. We also use this data to help Us understand interest in the different sections of Our Digital Platforms and the products and services that We offer online or otherwise. We also use your data to make the travel booking process more convenient. For example, We can remember what you have searched for so you can pick up where you left off. We also use your information to fix operational problems with the Digital Platforms such as software bugs and to maintain the safety and security of the Digital Platforms.
iii. To manage your relationship with Us as a consumer and to deliver personalized service. When you sign up via Our Digital Platforms or make a booking, We create a consumer profile of you in Our systems. This is your digital profile that contains the Personal Data that We maintain and identifies you within our Redwood Travel Partners and Cruise Planners systems. Your consumer profile lets Us deliver a personalized experience when you search for cruises, and book travel with Us or contact Us by phone or email. We also use your consumer profile to personalize the marketing communications that We send you. We also sometimes use your details to ask for feedback on Our services.
iv. To process payments and invoicing. When you make a purchase through the Digital Platforms (whether in relation to a cruise, other travel reservation or certain products or services such as tours and travel insurance), We will process your payment details to process the transaction. If you have chosen to store your credit card information for booking purposes, it will be maintained by a Payment Card Industry (PCI) certified data vault provider.
v. For marketing and promotional purposes. We use your contact details for Our marketing and promotions, including to send you information about the products and services that We and our Suppliers offer. We also use your Personal Data to personalize Our marketing communications to make them more relevant for you and to measure engagement with Our marketing campaigns. Your data is shared with a direct marketing company for the purpose of distributing and tracking these marketing efforts. See Direct Marketing and Profiling and personalized marketing below for more information, including on how to update your preferences and opt out.
vi. To comply with Our legal obligations. We need to cooperate with law enforcement agencies, including in relation to criminal investigations. Pursuant to the United States’ Stored Communications Act (the SCA), We may be considered a provider of electronic communication services for certain services We offer through the Digital Platforms (because We provide users of the Digital Platforms the ability to send or receive wire or electronic communications). In such instances, We will not turn over records or other information pertaining to you unless compelled to do so by a Court of competent jurisdiction pursuant to the provisions of the SCA.
vii. For Our business operations. We may use your Personal Data for business management activities, including to assist with incident management and to enable Us to conduct reporting. Reports help Us to monitor Our performance. Additionally, We keep records to assist with any complaints you may have or in the event of a legal claim. We also process your feedback to improve Our products and services.
B. We may share your Personal Data with:
i. Suppliers and Our international partners. We will need to send details of your booking to the Suppliers such as cruise line, hotel, airline, tour operators etc. Suppliers may make decisions themselves about how and why to process your information, or they may or may not process your information on Our behalf. Our Privacy Notice will not cover the information collected by Suppliers and it will not cover how Suppliers use that information. We recommend that you check your travel partner’s own Privacy Notice for details as to how they may process your Personal Data. We also use products and services from some Suppliers in the operation of Our business. For example, We use travel booking systems to provide flight, cruise, excursions, transfers, hotel availability and cost details, and to make bookings you request.
ii. Government authorities, law enforcement agencies, courts, and parties to litigation. We may need to share your Personal Data where required under applicable law. Law enforcement agencies may also require access to Personal Data, including in connection with criminal investigations, or We may be ordered to disclose Personal Data by a court or in connection with legal proceedings.
iii. Other third parties. We may share your Personal Data with other third parties at your request. Our Digital Platforms may provide links to websites or other digital tools that We believe may be useful to you in addition to advertisements placed by third parties. These may lead you to websites or digital tools operated by third parties operating under their own privacy policies. We encourage you to review those privacy policies, as We have no control over those third parties nor the information you may submit to those third parties. Additionally, your Personal Data may be processed by our Managed Security Services provider in relation to the provision of their services for the Business Purpose of detecting and thwarting current and future security events. In the event of the termination or sale of Redwood Travel Partners, LLC or CP Franchising, LLC, your data will be shared with the new owner/franchise for future travel agency services.
5. Direct Marketing
Marketing communications from Us – We may contact you for marketing purposes, including to tell you more about Our services, share news or tell you about promotions from time to time. You are in control of the emails and texts that you receive, and you can update your preferences or opt out at any time via your Account, following the links in Our emails or by contacting Us using the details provided below. Even if you have opted out of marketing messages, We will still need to contact you in relation to your bookings with Us.
6. Profiling and Personalized Marketing
i. Profiling overview: We think it is important for Us to understand the types of vacations that Our consumers are interested in so that We can make Our marketing relevant and targeted. To do this, we may collect socioeconomic information from a separately contracted credit bureau which is used in conjunction with personal information you provided to build a profile for you that lets Us work out which of Our marketing segments is the best fit for you.
ii. The Personal Data We use: From the Personal Data that We hold about you, Our model may consider your age, gender, household or travel composition, postcode, how you have interacted with Our websites and marketing emails and your booking history (including your destinations, the Suppliers you prefer and your chosen accommodation). We do not always use all of these data categories if We do not have the information about you or it is not relevant for Our marketing activities.
iii. How We build your profile and what We learn from it:
a. Statistical analysis – We use the data to learn about your previous or likely future booking behavior, for example:
i. the value or likely value of the bookings you make with Us;
ii. whether you tend to re-book within 12 months of your last trip and the destinations that you tend to book; and
iii. the extent to which you engage with Our marketing emails.
b. Marketing segments – We try to match consumers with one or more predefined segments that allow Us to broadly tailor Our marketing messages for the right audience. We define Our segments using anonymized demographic data based on broad characteristics and behaviors such as age, household income, or location. You may share a segment with other consumers, so this process is generally not highly individualized. Here’s an example: Let’s say you have just signed up on Our websites (giving Us your contact details) and you have never booked a trip with us before. Over the next few days you search for vacation packages that are generally popular with families (giving Us website interaction data). We might use that data to add you to one of Our family segments so that you get relevant emails from Us.
iv. What this means for you:
a. Tailoring Our marketing campaigns to your profile or segment means you should receive more relevant communications from Us. That’s good for Us because We think you are more likely to book a vacation that matches your requirements. We hope that’s good for you, too, because it helps you to find the vacations that you are interested in. We might also send you special offers on your birthday.
v. Targeted advertising on third party social media platforms and websites: We may share your Personal Data – including your name, email address, address and date of birth – with third party social media platforms, including Facebook, and websites for the purposes of allowing those platforms to display targeted advertisements to you. You can ask Us not to share your Personal Data with platforms, but you will need to contact the platform with any requests in relation to how the platform uses your Personal Data because We do not control that.
vi. You can opt out: You are in control of your Personal Data. You can update your marketing preferences or opt out of personalized marketing at any time using your Account or by either clicking a link in an email marketing communication, replying STOP to an SMS text message or by calling the sender of any marketing communication.
8. Cookies and other tracking technologies.
viii. Cookies may be placed by Redwood Travel Partners or Cruise Planners (“first-party cookies”) or by other companies (“third-party cookies”). For example, we use Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie (_ga) with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use GA to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness.
ix. We also use other technologies that function like cookies, such as pixel tags and web beacons which are small images on a web page or e-mail which can collect information about your browser and device settings and can set cookies or store non-personal information on your computer.
x. Depending on the tracking being used, different types of data may be stored and/or used. Most of our tracking uses anonymous data. We may use IP addresses to build anonymous information about general groups of users. If you are already logged into services such as Google or Facebook when you visit our site, they may link your visit to the data that they have about you. We do not receive any such data. We do not track or store any Personal Data for third parties to access or use.
xi. Most web browsers have an option that allows you to turn off all cookies or have your computer inform you each time that a request to place a cookie is being made. If you turn cookies off (or refuse to accept a request to place a cookie), you may not have access to some features on Our websites and some of Our services, such as booking a trip or being automatically recognized as an existing client. We also might not be able to remember your preferences, including in relation to marketing materials on Our websites, without using cookies.
xii. Some cookies and tracking technologies can be controlled by using these methods:
xiii. To opt-out of the use, and sharing of data with Google Analytics, you can install the Google Analytics Opt-out browser extension. https://tools.google.com/dlpage/gaoptout
a. Digital Advertising Alliance (DAA): http://www.aboutads.info/choices/ For supported Android or iOS devices, options for many cookies and tracking mechanisms can be set through this app: http://youradchoices.com/appchoices/ Download the app and set your preferences.
b. Network Advertising Initiative (NAI): http://www.networkadvertising.org/choices/
9. Data retention
We retain your Personal Data only for as long as necessary: (i) for the purposes set out in this Privacy Notice; (ii) to provide Our products and services to you; (iii) to comply with Our legal obligations (e.g., to comply with tax or accounting rules or in connection with legal proceedings); or (iv) to comply with Our usual business data retention policies.
10. Acting on someone else’s behalf
If you give Us information about another person (or persons), such as family members or friends traveling with you, We will understand this to mean that they have appointed and authorized you to act on their behalf. This includes providing consent (to the extent this is required) to:
i. Us processing their Personal Data; and
ii. you receiving any information protection notices on their behalf. We may ask you to provide evidence that you have been appointed and authorized to act on behalf of the other person (or persons).
Our Digital Platforms seek to promote Our vacation and travel services to adults. We do not knowingly solicit Personal Data from children, unless permitted by applicable law. If a parent or guardian becomes aware that his or her child has provided Us with information without their consent, he or she should contact Us using the contact details below. We will delete such information from Our files.
12. Your rights
You can update your direct marketing preferences by utilizing the unsubscribe link found in our emails or opt out of profiling and personalized marketing by emailing email@example.com
13. Changes to Our Privacy Notice. This Privacy Notice may be updated from time to time for any reason. Updates to Our Privacy Notice will be posted to the Digital Platforms. In the event We are involved in a merger, acquisition, or sale of all or a portion of Our assets, you will be notified via email and/or in a prominent notice on Our Digital Platforms of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
14. Contacting Us and Complaints. If you require any other information about any part of this notice, you can contact us at firstname.lastname@example.org
CALIFORNIA PRIVACY RIGHTS
This section applies to you if you are a California resident. California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.
Additional information regarding the collection and use of Personal Data:
A. Your Rights
1. Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
2. Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. In response to your access request, to the extent feasible We will provide the information in an electronic and readily usable format.
3. Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will remove or pseudonymous (and direct our service providers to remove) your Personal Information from our records, unless an applicable legal exception applies.
4. Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate against you in any way for exercising your privacy rights conferred by the California Consumer Privacy Act.
B. To Request Access to or Deletion of Your Data (or other privacy inquiries and complaints):
1. Call us toll free at 1-888-471-3313
2. Complete the Privacy Rights Request Form
3. Submit a request via e-mail to email@example.com
Upon receipt of your request, we will confirm receipt of your request by sending you an email or returning your call. To protect your privacy and maintain security, we must take steps to verify your identity before being able to provide or delete personal information.
For requests to know or delete your Specific Data we will seek appropriate information to verify your identity. We will also ask you to complete and sign a declaration which will be emailed to you to electronically sign.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.
COMPLIANCE WITH THE GENERAL DATA PROTECTION REGULATION
This section applies to you if you use our Digital Platforms while in the European Economic Area (EEA).
1. Legal basis for Our use of your Personal Data and legitimate interests
We only process your Personal Data to the extent that at least one of the following applies:
i. you have consented to the processing of your Personal Data for a specific purpose – We process your sensitive Personal Data and send you electronic direct marketing communications based on your consent for Us to do that;
ii. the processing is necessary for Us to perform Our contract with you (e.g., to book your cruise) or for use to take steps at your request before We enter into the contract;
iii. where We need to process your Personal Data to comply with a legal obligation that We are subject to;
iv. where We need to process your Personal Data to protect your vital interests (or somebody else’s), including where you are physically or legally incapable of giving consent, for example in case of a medical emergency;
v. the processing is necessary for Us to establish, exercise or defend a legal claim; or
vi. the processing is necessary for the purposes of Our legitimate interests or a third party’s legitimate interest.
B. We rely on several legitimate interests for using and sharing your Personal Data, including:
i. improving Our products and services;
ii. marketing and promotional activities;
iii. identifying and pursuing new ways to develop and grow Our business; and
iv. ensuring the security and safety of Our clients and employees.
2. International Data Transfers
We are a US based business and as such We store and process your Personal Data in the United States as this is where the servers that We use for Our business and on which your Personal Data is stored are located. The transfer of your Personal Data outside the EEA will be necessary for Us to perform Our contract with you (e.g., to book your vacation).
3. Your rights
You have the right to ask Us to:
i. restrict Our processing of your Personal Data
ii. object to Our processing of your Personal Data
iii. request that We move your Personal Data to another organization
iv. object specifically to Us using your Personal Data for profiling for direct marketing purposes
v. provide a copy of your Personal Data in an easily accessible format
You also have the right to make a complaint about how We process your Personal Data to your data protection supervisory authority.
Where you have specifically consented to Our use of your Personal Data, you have the right to withdraw that consent at any time by contacting us at firstname.lastname@example.org