PRIVACY POLICY

Introduction

Tickled Pink Travel takes your privacy seriously.  We want you to be tickled pink when using our services and be confident that that your information is safe.  So please take the time to read this Privacy Policy which explains to you how we collect, share and use Personal Information.  Our Booking Terms and Conditions will also provide you further details on some of the Personal Information me may need to collect, use or disclose as part of your cruise holiday.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided on the “Contact Us” page.

About Us

Tickled Pink Travel (“TPT”, “our”, “we”, “us”) is a boutique travel company both in Australia and the USA. We plan, book and co-ordinate large groups onboard cruise ships (the “Services”).  To make sure you have the most unforgettable tickled pink experience with us we need our clients and passengers to provide us with Personal Information.  See below to understand how we keep that information safe.

Find out more about us here.

Key Terms

While reading this Policy, remember that the below terms mean:

“Client” means any person or entity that has agreed to market, sell or organize a cruise with TPT

“Contact” is a person or entity that may contact TPT through our Website(s). For example, if you subscribe to our email marketing or send us a query through our website, you would be considered a Contact

“Passenger” means any person that has paid a deposit for a berth on a cruise

“Prospective Client” means any person or entity that has requested TPT to research options for a cruise

“Personal Information” means any information that identifies or can be used to identify a Client, Contact, Passenger, Prospective Client or Visitor directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, demographic information, your passport details, driver’s licence details, next of kin, emergency contact information, payment information (e.g. your credit card details), information relating to your health and dietary requirements (if any), and your proposed travel and tour arrangements.

“Sensitive Personal Information” means Personal Information that needs additional protection due to certain privacy laws. Some types of Sensitive Personal Information include information about your health, racial or ethnic origin, political opinions, religious beliefs, trade union membership or your sexual orientation. Information concerning criminal convictions and offences is also viewed as sensitive, for example, under European data protection law. We may collect and handle your sensitive Personal Information, for example, when you request special medical or access assistance or if you tell us you have specific dietary requirements relating to your religious beliefs. We will ask you for your consent to handle this type of Personal Information, to the extent required under applicable laws, for example under the Australian Privacy Act or the European General Data Protection Regulation

“You” and “your” means, depending on the context, either a Client, Contact, Passenger, Prospective Client or Visitor.

“Visitor” means any person who visits any of our Websites.

“Website(s)” means any website(s) we own and operate (such as www.tickledpinktravel.com and www.tickledpinktravel.com.au) or any web pages, interactive features, applications, widgets, blogs, social networks, social network “tabs,” or other online, mobile, or wireless offerings that post a link to this privacy policy.

Collection

The core functions of our business and services (i.e. the primary purposes for which we collect and manage Personal Information) are to facilitate the planning, marketing, organizing, booking, and co-ordinating of your dream cruise. So that we can carry out these functions, and provide you with our products and services, we may ask you to provide us with and may manage Personal Information:

Some examples of where we may need this information are to:

  • process your booking and make sure you navigate your way through immigration and onto your cruise;
  • create and process insurance policies;
  • offer you collateral products and shore tours that will make your cruise totally tickled pink;
  • provide your details to immigration officials;
  • handle and respond to inquiries; and

We may collect Personal Information about you in a variety of ways including when you deal with us in person or over the phone, send us correspondence (by email, text or social media or visit one of our web sites or when we receive Personal Information about you from one of our Clients (in accordance with their applicable privacy policies).

We will not collect Personal Information or Sensitive Personal Information unless it is reasonably necessary for us to carry out our core functions or where permitted under law.

As far as it is reasonable or practicable, we will collect your Personal Information directly from you. If it is not reasonable or practicable and personal information is collected from someone else (e.g. another person booking on your behalf), we will take reasonable steps to ensure that you are made aware of the collection of your Personal Information, unless specific exemptions apply. Sensitive Personal Information will only be collected with your consent, unless specific legislative exemptions apply.

Destruction and De-identification of Personal Information

If we receive Personal Information which we did not solicit and we determine within a reasonable period of time that we could not have otherwise collected the Personal Information, where lawful or reasonable to do so, we will destroy the information or ensure that the information is de-identified as soon as practicable.

Use and Disclosure

Our general rule is that we will not use or disclose your personal information other than for the primary purpose for which it is collected, which may be as stated above or at the time of collection. If we propose to use your personal information for another use, we will seek your further consent unless that other purpose is related to the original purpose of collection (the “secondary purpose”). For example, you could reasonably expect us to use or disclose your personal information collected from your booking form for the secondary purpose of us sending you information about special offers and potential discounts.

If we propose to use your sensitive information for a purpose other than for one of our core functions, we will seek your further consent unless it could reasonably be expected that we would use or disclose the information for the other purpose and the other purpose is directly related to the primary purpose (the “secondary purpose”). For example, if we provide you with travel insurance where you disclose a medical condition that should be known to cruise ship staff, you could reasonably expect us to disclose information about your health in an email to the cruise ship alerting them of your needs while onboard.

Where you consent to receiving promotional material from us, you consent to receiving promotional material from all types of media. To opt out of receiving promotional material from certain mediums email us at groups@tickledpinktravel.com, please type ‘Opt out of Affiliate Marketing’ into the subject line, and include your full name and date of birth, if relevant. Please let us know specifically what material you do not wish to receive or whether you would prefer not to receive any promotional material from us at all. Any promotional material that we send to you will contain instructions for how you can opt out of receiving further offers.

Whilst we may retain various third parties to assist us in our booking, marketing and promotional activities (eg. Mailchimp or an off-site database for information concerning our past passengers), we do not disclose your personal information to anyone outside TPT for their promotional use. However, we may disclose your Personal Information to third parties to perform certain activities on our behalf. Examples include:

  • printing companies, mail houses, couriers, e-mail service providers;
  • processing payments: banks, payment service providers;
  • maintaining guest records and analysing data: customer insight and research agencies, data processors, data analysts and data washing companies, credit agencies;
  • providing port services and excursions: port agents;
  • providing travel services: airlines, coach operators, cruise lines.

These third parties have access to Personal Information needed to perform their functions, but are not permitted to use it for other purposes. We seek written assurances from any third parties to whom we may disclose Personal Information to ensure that they will treat that information in accordance with applicable privacy laws.

If we have reasonable grounds to believe that disclosure of your Personal Information or Sensitive Personal Information is necessary to prevent a serious threat to life, health or safety, or we are required to provide information in response to subpoenas, warrants or other legal processes including police inquiries, or inquiries from another government department (including, without limitation, Customs and Immigration) we will disclose your information for those purposes without seeking your consent.

Data Quality

We will take reasonable steps to ensure that the Personal Information we collect, use or disclose is accurate, complete, up to date and relevant, having regard to the purpose for which the information is proposed to be used. We encourage you to contact us if you believe Personal Information we hold about you is incorrect or incomplete in some way.

Access and Correction

If you request access to the Personal Information we have collected about you, we will give you access to the information where reasonable and practicable to do so, within a reasonable amount of time, unless an exception exists under applicable law.

If you request that we correct your Personal Information or we are satisfied that the information we hold is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take such steps as are reasonable in the circumstances to correct the information, having regard to the purpose for which the information is held.

If we correct your Personal Information which we have previously disclosed to another entity and you request that we notify that entity of the correction, except to the extent that it is impracticable or unlawful to do so, we will take such steps as are reasonable in the circumstances to notify that other entity.

If we do not grant your request for access to the Personal Information we have collected about you, or for access to the information in the form requested, we will provide you with a written explanation within a reasonable period of time, including the reasons for our decision and any complaint mechanism available to you.

If we do not grant your request to correct the Personal Information we have collected about you, to the extent that it is reasonable to do so, we will, if requested by you, take such steps as are reasonable in the circumstances, within a reasonable amount of time, to attach to our record of your Personal Information any statement provided by you of the correction, deletion or addition sought.

Data Security

We take such steps as are reasonable in the circumstances to protect the Personal Information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. Stringent security measures are in place on all the cruise ships we use, physical security for our offices in Australia and the USA and electronic security (such as password access, encryption and firewalls) for our office network servers and electronic data transfers.

If we disclose your information to a third party in connection with the provision of a service, we will take reasonable steps to prevent the unauthorised use or disclosure of information contained in the record.

Where we no longer need Personal Information that we hold about you for a primary purpose or secondary purpose and where lawful to do so, we will take such steps as are reasonable in the circumstances to destroy the information or to ensure the information is de-identified. We hold a basic record of guests’ cruise history (name and contact details, booking/cruise number, nights on board) indefinitely for the purpose of maintaining our excellent client service.

Identifiers

We will not use any government related identifier (such as your Medicare or tax file number) as our own identifier to link you with your Personal Information. We will not use or disclose any government related identifier of yours unless required or authorised by law.

Anonymity and Pseudonymity

Where lawful and practicable, we will give you the option of not identifying yourself when dealing with us. For example, at the completion of your cruise we may request that you provide us with specific feedback on our cruise  on an anonymous basis.

Transborder Data Flows

TPT has offices both in Australia and the USA. We may transfer your Personal Information between our offices. Some of our third party service providers are based overseas and our customer database is jointly managed in Australia and the USA. It may also be necessary to disclose your personal information to regulatory or other authorities in the ports of call in your cruise itinerary.

Website Privacy

Our websites www.tickledpinktravel.com.au and www.tickledpinktravel.com are maintained by TPT and other third-parties and are subject to our Terms & Conditions.

In an online environment there are several means by which information may be collected. The type of information collected depends on how you have interacted with our website. When you visit our website (or any Internet site) the server records details of your visit, including:

  • the type of browser and operating system (eg. Mac, PC) you are using
  • the address of the referring site (ie. the previous site that you visited)
  • your IP address (a number unique to the computer through which you are connected to the Internet)
  • the country or region you come from
  • the date and time of your visit
  • the address of the pages accessed and documents you downloaded.

In addition to this we may use software to detect what screen size your computer uses and what plug-ins you have. Plug-ins are used to run features such as our Flash movies and the Quicktime ship and cabin virtual tours. The sole purpose of this is to make sure we can present the best viewing experience for each visitor. If you send us an error report, we use software to detect whether you are browsing from behind a firewall and what type of error you have encountered.

We also use cookies which are pieces of information that a website can transfer to an individual’s computer hard drive for tracking websites browsed by the person. This tracking enables us to customise our site information to your requirements and interests. Cookies are not unusual, most major websites use them. However, you can set your internet browser to refuse the cookies entry into your computer’s hard drive.

If you send us an email via our website or you complete a form on our website the Personal Information submitted may be retained for the purposes of answering your query or complying with your request. Every email we receive is automatically stored on our server and backed up in accordance with our usual data management procedures. If you have completed a web form to request information about our cruises or made a booking, you will be added to our mailing list to ensure that you receive notifications of any special promotions that are on offer. You can opt out of this mailing list at any time.

Any information we collect is treated in accordance with this Privacy Policy and with applicable privacy laws.

Some of our functions are provided by third parties. In those instances, it is necessary for us to supply your information to a third party as part of fulfilling the purpose for which you have provided the information (for example, the entity which administers and maintains our e-newsletter on our behalf). Whilst we do not seek your consent again we do seek an assurance from that third party that the information will only be used for the purpose for which it is supplied and that your information is kept safe and secure in line with our own policies in that regard.

We will seek your consent before sending you marketing communication. Every email you receive from us will have details of how to remove yourself from our email lists. Remember to change your preference for each email address and other contact details you have given us. If you have any difficulty with this process you can email groups@tickledpinktravel.com and specify your request.

Our website may allow you to ‘like’ particular categories using Facebook functionality. If you ‘like’ a particular category you will receive regular notifications on your Facebook page relating to that category. If you no longer wish to receive these notifications you are required to ‘unlike’ the relevant category.

For Customers in the EU

If you are located in the EU, in addition to your rights to access and correction set out above, you are also entitled to the following rights in respect of Personal Information that we hold:

  • Right to erasure. The right to obtain the erasure of your Personal Information without undue delay 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

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. You may contact us to discuss how to exercise those rights by sending an email to groups@tickledpinktravel.com.

You also have the right to lodge a complaint with the relevant data protection authority.

Contact Details

If you would like to request access to or correction of inaccurate, incomplete or out of date Personal Information, lodge a complaint about how we have handled your Personal Information or should you require any further information about our Privacy Policy, please contact us by sending an email to groups@tickledpinktravel.com.

Further Information about Privacy

Please contact your national or local privacy commission or agency. If you are in Australia and you would like further information about privacy generally, please contact the Office of the Australian Information Commissioner by calling 1300 363 992 or visit the Commissioner’s web site at www.privacy.gov.au

Changes to this Privacy Statement

We may amend this Privacy Policy as our business requirements or the law changes. Any changes to this Privacy Policy will be updated on www.tickledpinktravel.com so please visit our website periodically to ensure that you have our most current version.

Our Privacy Policy

If you request a copy of our Privacy Policy, we will take reasonable steps in the circumstances to provide you with a copy. If you would like a copy in non-electronic format, please contact us as detailed above.