Orcades Cruises respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or engage with our services and tell you about your privacy rights and how the law protects you. This privacy notice supplements any other privacy notice we may provide from time to time and is not intended to override them.
1. Important information and who we are
Sheena Inglis trading as Orcades Cruises is the controller and responsible for your personal data (collectively referred to as “Orcades Cruises”, “we”, “us” or “our” in this privacy notice). Our data protection contact is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection contact.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, title and date of birth.
- Contact Data includes correspondence address, home address, email address and telephone numbers.
- Financial Data includes bank account, payment card details and payments to and from you regarding the use of our services.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or in order to provide our services to you and you fail to provide that data when requested, we may not be able to provide you with our services. In this case, we may have to cancel any contract with you for the use of our services but we will notify you if this is the case at the time.
How is your personal data collected?
We may collect data from and about you through direct interactions with you in person either in person or corresponding with you by post, phone, email or otherwise. We may also receive personal data about you from various third parties and public sources including providers of technical, payment and delivery services and from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to perform the contract you have entered into with us to provide services, where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, and where we need to comply with a legal or regulatory obligation.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish details about the specific legal ground we are relying on to process your personal data, please contact our data protection contact.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think may be of interest to you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or used our services previously and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these information marketing messages, this will not apply to personal data provided to us as a result of instructing us to provide services.
4. Disclosures of your personal data
We may have to share your personal data with External Third Parties including:
- Professional advisers acting as processors including auditors, insurers and accountants who provide consultancy and insurance services.
- HM Revenue & Customs, regulators and other authorities acting as processors who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal data are available by contacting our data protection contact.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data including:
- Request access to your personal data – to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you – to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data – to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data – to ask us to suspend the processing of your personal data in order to establish the data’s accuracy, or where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, or where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Any manual records or papers may only be transferred under a legal mandate.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our data protection contact. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10. How to contact us
Data Protection Contact: Sheena Inglis