Fred. Olsen Travel is committed to safeguarding the privacy and security of your personal information. This Privacy Policy outlines how we collect, use, store, and protect your data across all divisions and brands operated by Fred. Olsen Travel, including Fred. Olsen Travel Agents, Fred. Holidays, Fred. Bridge Holidays, Go Cruise & Travel and GoRiverCruise.

Fred. Olsen Travel and its associated brands will use your personal information for the purposes set out in this notice, including communicating with you about our products, services, and promotions. You may withdraw your consent to receive marketing communications from any of our brands at any time by following the unsubscribe instructions included in our communications or by contacting us directly.

Fred. Olsen Travel is committed to being transparent about how we use the personal data of everyone we deal with.

This Privacy Notice is intended to inform you (collectively “you”, “your”, “yours” or “yourself”) how Fred. Olsen Travel ("we”, “us” or “our”) will collect and use your personal data when you do any of the following:

• visit and browse our website www.gocruiseandtravel.co.uk;
• use our website to submit an enquiry, sign up for our newsletter or sign up to one of our mailing lists;
• submit information to make a booking or buy any of our services, including any modification, cancellation, or similar activity;
• contact us, make an enquiry, or communicate with us in any way, including by email, direct message, video chat, phone, and text;
• provide information to us and communicate with us in any way, including through our website, in writing and verbally.

Categories of Personal Data We Collect

The personal data we collect about you depends on whether you are making an enquiry, you are, or may be, a customer, visiting our website or you are, or may be, a supplier.  We will collect and use some or all the following personal data about you (and if you are making a booking, all persons to be included in that booking):

In order to facilitate a booking we are also obligated to obtain personal data of a special category such as contagious disease vaccination information, health and medical information and information that could reveal your race or ethnicity.

We realise that your emergency contact may not have heard of Fred. Olsen Travel previously, and so we ask you to inform them that you will be sharing their information with us. If they have any queries, they can contact us using the details we have provided in this Notice.

You are required to provide personal information to us before we can confirm your booking. If you fail to provide us with this information, then you will not be able to book your holiday.

Receiving Data Through Third-Parties

We are proud to have a wide network of travel partners. If you have concerns that we may have received your information in error or would like to find out where we have received your information from, please contact us using the details in this notice.

Purposes of Processing Your Personal Data and Legal Basis

We process your data for a variety of purposes. As a Travel Agent, we process personal data primarily to facilitate bookings and providing holidays. We always process personal data with a legal basis and the table below demonstrates our intended purposes and the legal basis we use to process your data.

We do not target our website or offer any of our products or services for sale to anyone under the age of 18 (a “Minor”), nor do we knowingly collect personal data from a Minor.  Any adult that submits information about a Minor may only do so on the basis that they are the parent or legal guardian of that Minor and waive all claims in relation to that Minor.

Artificial Intelligence (AI) Tools

We use AI tools which utilise large language models (LLMs), a type of artificial intelligence algorithm that uses deep learning techniques to understand, summarise, predict, and generate content.

The personal data used in AI tools is limited to the categories of personal data shown in the table above.  We restrict how much personal data is processed by AI tools and avoid using any sensitive personal data, such as health or disability information, where we can.  If we need to process special category (sensitive) information about you, we will seek your consent before doing so unless an exemption applies.  We may, for example, process your sensitive information in an emergency if you are unable to give consent yourself.  An exemption also applies if we need to establish, exercise, or defend a legal claim or for judicial proceedings.  

AI Tools help us to improve the efficiency, quality, and speed of our business processes.  We carry out a number of these processes already but using AI to automate these activities allows us to optimise our resources.  For example, AI can help us by summarising information (such as in emails, Teams chat messages and meeting transcripts, documents) and prepare for meetings, create and format documents, analyse data such as public consultation responses, and generate draft emails or presentations. AI also assists with notetaking and idea generation to support efficient communication and decision-making.

Any data, used in AI is stored and stays within our secure UK Microsoft 365 and Azure tenants, and is not used for training foundation models.  

Where we use your personal data, it is processed under the lawful basis of legitimate interest to enhance and improve response times and efficiency, for example in relation to service delivery, complaint handling, providing you with guidance, or investigating a breach.  Alternatively, we may use your information in order to enter into and/or perform a contract with you.

We use AI tools to assist our staff do their job and we do not solely use AI to make automated decisions. Our policy requires that there is always a human intervention to review and approve outputs from the AI tools.  

We will continue to monitor our use of AI tools to review the risks and benefits of this deployment. Any extension of our use will be considered under our risk assessment processes and this privacy notice will be updated accordingly.

Recipients of Your Information

We share information for a variety of reasons, including when you request us to do so, for the prevention and detection of crime, where required by law and regulation, for us to deliver our services, to enhance, improve, develop, and promote our services, and otherwise conduct our business. The list below provides information on the types of third parties that we share information with.

• Package holiday organisers;
• Tailor-made holiday providers: where flight/hotel/transfers are organised by a single company, we will inform you of the company we will transfer your data to when booking those services,
• Airlines: we will inform you of the airline company we will transfer your data to when booking,
• Hoteliers: we will inform you of the airline company we will transfer your data to when booking,
• Rail operators: we will inform you of the rail company we will transfer your data to when booking the train journey,
• Other ancillary service providers; we will inform you of the ancillary service provider we will transfer your data to when booking such a service (for example car hire)
• Specialist service providers, such as where you require a specialist service e.g. medical services
• Health service providers, including NHS Agencies, such as GPs, hospitals, and ambulance services
• Government and public agencies, such the Department of Health and Public Health agencies
• External hosting providers for the administration of our website, for example our video chat host and our email letter distributor
• Mailing houses: for brochures and other mailers
• Our employees and contractors, selected third parties and service providers, including marketing agencies, marketing research agencies, PR agencies and data hosting service providers, so that we can develop, enhance, and promote our business generally and our services and provide customers with information and marketing messages about products and services
• Our affiliates and companies in the Fred. Olsen family of companies, who may use your information in the same way as we can under this notice
• Technology subprocess providers: we may share your data with technology subprocess providers, such as Traveltek (reservations system), Microsoft Fabric, and Google BigQuery (data warehousing), and GlideApps (data management and processing), to facilitate more efficient and accurate processing of your data to support our business operations.
• Third parties as legally required 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, and safety of us and other third-parties.
• Our professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities
• Members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency (anonymised where possible)

We book travel and holiday arrangements for destinations across the world. When liaising with a travel or accommodation provider within Europe, the EEA, and countries on the European Commission’s data protection ‘adequacy’ list, we use the countries’ own data protection regulation as the safeguard for your data over and above the technical and organisational measures we have put in place to secure your data when transferring to them. For recipients outside of this list, we use either our standard contractual clauses with a provider where applicable, or the fulfilment of our contract with you as the appropriate safeguard.

We will never sell your data to any third party.

Retention of Your Personal Data

We retain your personal data for only as long as it reasonably necessary for the uses set out in this Privacy Notice and/or to meet legal, regulatory, and financial reporting requirements.

This includes the data relating to your booking for a minimum of 3 years, which is a requirement for legal purposes.

Information relating to the monetary value of your booking will be retained for a minimum of 6 years from the date of the transaction, to comply with statutory financial reporting requirements.

We retain your contact details until such time where you no longer wish to be contacted by Fred. Olsen Travel.

These retention periods are not inclusive of how long the recipients of your personal information may retain your data.

Your Rights

We are always happy to fulfil any one of your rights wherever possible. Your rights with respect to the personal data that we process on you are:

• Right to information on how your data is processed
• Right of access to the personal data we hold on you
• Right to rectify any inaccurate data we process on you
• Right to object to us processing your personal data
• Right to erasure of your data
• Right to data portability
• Right to lodge a complaint with a data protection regulator
• Right not to be subject to automated decision making

You can invoke any of your rights at any time using the contact details listed in this Notice, subject to us having to keep the data for legitimate business or legal reasons.  Please be aware that we can ask for identification documents to confirm we are disclosing information to the correct person.  If you elect a representative to invoke these rights on your behalf, we will request that the representative can demonstrate they have the authority to act on your behalf and their identity.

We do not conduct any automated decision making or profiling when you make a booking with us.

Data Protection and COVID-19

This is an addendum to Fred. Olsen Travel privacy notice.  It explains how Fred. Olsen Travel (as Data Controller) may use your personal data, specifically in relation to the Covid-19 (Coronavirus) Pandemic and to support the NHS Test& Trace scheme in England and NHS Scotland’s Test and Protect service.

To operate safely and effectively, we may need to ask you for sensitive personal information that you have not already supplied, or use data you have already provided, including whether you have any underlying illnesses or are what is classed as vulnerable.

If we already hold information regarding vulnerability, we may share this for vital health reasons, emergency planning purposes and to protect your vital interests by sharing with services both inside and outside Fred. Olsen Travel.

Your personal data

Personal data relates to a living individual who can be identified from that data.  Some of your personal data is classed as 'special category personal data' because this information is more sensitive e.g. health information, ethnicity and religion etc.

Why we may need to share your personal data

We may share your information with other public authorities, emergency services, and other stakeholders as necessary, and only when necessary, in a proportionate and secure manner.  Contact with you to obtain consent before sharing will not be required for all the reasons described in this notice.  Please be assured that protection of personal data remains a priority at this time after the health and safety of everyone.

We will only share your personal information where the law allows, and we always aim to share the minimum data necessary to achieve the purpose required.  Further, the information will only be used for the purposes listed and retained for limited specific times.

Data protection laws allow us to share information for a wide variety of reasons. These are known as our 'legal bases to process data'.

Data protection laws are written to facilitate valid information sharing, especially in times of emergency which often requires more collaborative working.  The legal bases for processing data at Fred. Olsen Travel while Covid-19 continues to present significant health risks are:

• Protect the public
• Satisfy legal and regulatory requirements
• Provide extra support for individuals with a disability or medical condition
• Safeguard children and individuals at risk

Fred. Olsen Travel will apply the following sections of the General Data Protection Regulation and Data Protection Act 2018 (other elements may be applied dependent upon emerging events):

General Data Protection Regulation

Article 6 – Lawfulness of Processing

• Article 6.1(c) - processing is necessary for compliance with a legal obligation to which the controller is subject.
• Article 6.1(d) - processing is necessary in order to protect the vital interests of the data subject or of another natural (living) person.

Article 9 – Processing of special categories of personal data

• Article 9.2(c) - processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent
• Article 9.2(g) - processing is necessary for reasons of substantial public interest
• Article 9.2(h) - processing is necessary for the purposes of preventative or occupational medicine, where is it necessary for the provision of social care, the provision of health care or treatment or for the management of a health or social care system
• Article 9.2(i) - processing is necessary for reasons of public interest in the area of public health, such as protecting against cross-border threats to health or ensuring high standards of quality and safety of health care

Data Protection Act 2018

SCHEDULE 1, (Special categories of Personal Data), Part 1 Conditions relating to Employment, Health and Research etc

This condition is met if the processing

a) Is necessary for the reasons of public interest in the area of public health and

b) Is carried out -

I.  by or under the responsibility of a health professional, or

II. by another person who in the circumstances owes a duty of confidentiality under an enactment or rule of law

SCHEDULE 1, (Special categories of Personal Data), Part 2, Substantial Public Interest Conditions

Paragraph 16, Support for individuals with a disability or medical condition

This condition is met if the processing

d) can reasonably be carried out without the consent of the data subject

e) is necessary for reasons of substantial public interest

(1) This condition is met if the processing is

a) necessary for the purposes of

I.  protecting an individual from neglect or physical, mental or emotional harm, or

II. protecting the physical, mental or emotional well-being of an individual,

b) the individual is

I.  aged under 18, or

II. aged 18 or over and at risk,

c)  the processing is carried out without the consent of the data subject for one of the reasons listed in sub-paragraph (2), and

d) the processing is necessary for reasons of substantial public interest.

(2) The reasons mentioned in sub-paragraph (1) c) are —

a) in the circumstances, consent to the processing cannot be given by the data subject

b) in the circumstances, the controller cannot reasonably be expected to obtain the consent of the data subject to the processing

(3) For the purposes of this paragraph, an individual aged 18 or over is "at risk" if the controller has reasonable cause to suspect that the individual —

a) has needs for care and support,

b) is experiencing, or at risk of, neglect or physical, mental, or emotional harm, and

c)  as a result of those needs is unable to protect himself or herself against the neglect or harm or the risk of it.

Data Protection Complaints

If you are unhappy with how we handle your personal data, you have the right to lodge a complaint. Please use our Electronic Complaints Form or contact the Data Protection Team at dataprotection@fredolsen.co.uk.

We will acknowledge your complaint within 30 days and will aim to resolve it without undue delay. You also have the right to complain to the Information Commissioner’s Office if you are dissatisfied with our response. You can contact the ICO at https://ico.org.uk/.

How to Contact Us

Fred. Olsen Travel Ltd is a data controller. We collect and process data for several purposes outlined in this Notice. If you ever need to contact us, you can by using the details below:

Address: Fred. Olsen House, 42 White House Road, Ipswich, Suffolk, IP1 5LL

Phone: (+44) 0808 250 8793

If you have a specific query relating to how we process your personal data, you can contact our Data Protection Officer on:

Email: dataprotection@fredolsen.co.uk

Our European Representative

We have appointed a European representative to act on our behalf regarding EU General Data Protection Regulation compliance, and to deal with any supervisory authorities or individuals based in the EEA.

Our European representative is:

Natural Power Consultants (Ireland) Limited

Address: Suite 6, The Mall, Beacon Court, Sandyford, Dublin 18, D18 A3W8, Ireland

Phone: +353 1 697 1344

Email: eu_representative@naturalpower.com

Changes To This Notice

We may change this privacy notice from time to time.  You are encouraged to revisit our website from time to time to view the current version of this notice.