Last Updated: January 1, 2023

Cruise Yacht OpCo Ltd and Next-Gen Cruises Ltd, both doing business as The Ritz-Carlton Yacht Collection (“RCYC”, “we”, “our” or “us”) value you as our guest and recognize that privacy is important to you. This Global Privacy Policy applies to the activities across all our entities. RCYC operates under a license from The Ritz-Carlton Hotel Company, L.L.C., and is not an affiliate of or related to The Ritz-Carlton. RCYC will collect, use, and share Personal Information (defined below) with strategic business partners, including Marriott International, Inc. and its affiliates, including Luxury Hotels Limited and The Ritz-Carlton (collectively, the “Marriott Group”). The Marriott Group will collect, use and share Personal Information in accordance with its Global Privacy Statement, available at Marriott Online Privacy Policy | Hotel Privacy Policy Information. You may at any time request access, correction or deletion of your Personal Information collected by the Marriott Group, or object to the use or processing of your data by emailing privacy@marriott.com or by visiting the Marriott Individual Rights Portal.

This Global Privacy Policy describes the types of data collected, how RCYC collects data and the privacy practices for data that RCYC collects from end-users (“User,” “you” or “your”):

• through websites operated by RCYC from which you are accessing this Global Privacy Policy, including www.ritzcarltonyachtcollection.com and other websites owned or controlled by RCYC (collectively, the “Websites”)
• through access and/or links to various featured websites, products and/or services (“Links”), including Links to web venues owned and/or operated by the Marriott Group as featured on the Site
• through the software applications made available by RCYC for use on or through computers and mobile devices (the “Apps”)
• through text, video and/or other information pertaining to yacht cruises and hospitality-related products and/or services made available on the Site (the “Informational Content,” and together with the Links, the “Content”);
• through our social media pages that we control from which you are accessing this Global Privacy Policy including accessing links to RCYC’s social media pages/accounts featured on third-party social media websites, such as Facebook®, Instagram®, LinkedIn®, Twitter® and YouTube® (collectively, our “Social Media Pages”)
• through HTML-formatted email messages that RCYC may send you that link to this Global Privacy Policy and through your communications with RCYC;
• when you apply for employment via the Site or linked websites RCYC may use for the purposes of employment; 
• when you provide your information for inclusion in our guest, prospective guest, or travel professional partner database via phone, email, or any other method; 
• when you make a reservation.

 

Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services” and, together with offline channels, the “Services.” By using the Services, you agree to the terms and conditions of this Global Privacy Policy.

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

Personal Information Collected

At touchpoints throughout your guest journey, we collect Personal Information in accordance with the law, and to provide you with exemplary services. Personal Information is information that may identify you as an individual or relate to you as an identifiable individual. We collect and process the following types of Personal Information about you, collectively called “Contact Data”):

• Name
• Gender
• Postal address
• Telephone number
• Email address
• Financial information (such as credit and debit card number or other payment data)
• Language preference
• Date and place of birth
• Nationality, passport, visa, or other government-issued identification data
• Important dates: birthdays, anniversaries, and special occasions
• Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
• Employer details (for business-related bookings)
• Travel itinerary, tour group, or activity data
•  Prior guest stays or interactions, goods and services purchased, special service and amenity requests
• Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts

 

Upon submitting your information by and through the Site or by making a Cruise Booking, you may be contacted by RCYC and/or one (1) or more members of RCYC regarding your submission.  Where RCYC contacts you in connection with your submission of your Contact Data, a RCYC representative may request additional information over the telephone.  In connection with your Cruise Booking, we may also collect data about family members, images, video, and audio data through onboard security cameras as well as preferences that may be used for your current Cruise Booking or for future Cruise Bookings.

By providing your wireless phone number to RCYC, you agree and acknowledge that RCYC may send text messages (SMS messages) to your wireless phone number for any purpose, including marketing purposes. You agree that these text messages may be regarding the products and/or services that you have previously purchased and products and/or services that RCYC may market to you. You understand and agree that text messages may be sent using automated technology. You understand that you may unsubscribe from receiving text messages from RCYC at any time by replying “STOP” to text messages. If you need assistance, contact RCYC at privacy@ritz-carltonyachtcollection.com or 
Americas & Australia:

(833) 999-7292 (U.S. & Canada) 
+1 (305) 907-7099 (Outside the U.S. & Canada)
Europe, Asia, the Middle East & Africa:
356 2778 0076 (Outside the U.K.) 
08000 488667 (U.K.)

If you unsubscribe from receiving text messages from RCYC, you may continue to receive text messages for a short period while RCYC processes your request(s). When you provide a phone number to RCYC, you warrant that you are the current subscriber or authorized user of the phone number. If you change, forfeit, or deactivate the phone number you provided to RCYC, you agree to notify RCYC immediately. Failure to do so constitutes a material breach of this Global Privacy Policy. You may review RCYC’s Mobile Services Terms and Conditions in full at https://www.ritzcarltonyachtcollection.com/legal/sms. 
 

Use of Personal Information
Other than as set forth in this Global Privacy Policy, or where you separately provide your express consent, RCYC will never share, sell, rent, exchange, or barter your Personal Information to or with any third-party, except as set forth herein, for financial gain or marketing purposes.

We may, however, employ other companies and individuals to perform certain functions on our behalf.  Examples include sending direct and electronic mail (email), removing duplicate information from User lists, analyzing data, and providing marketing analysis.  The agents performing these limited functions on our behalf shall have access to our Users’ Personal Information as needed to perform these functions for us, but we do not permit them to use User personal information for other purposes.

By submitting your Personal Information, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations.  As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express written consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive, from RCYC, telephone calls, including artificial voice calls, pre-recorded messages and/or calls (including text alerts via SMS text messages delivered via automated technology, to the telephone number(s) that you provided.  Please note that you are not required to provide this consent to obtain access to the Site Offerings, and your consent simply allows RCYC to contact you via these means.  Please be advised that by agreeing to this Global Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes.  Without limiting the foregoing, if you: (a) have your telephone number reassigned to another person or entity; (b) give up your telephone number so that it is no longer used by you; (c) port your telephone number to a landline or vice versa; or (d) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify RCYC of the Phone Number Change via e-mail at: privacy@ritz-carltonyachtcollection.com, or by using one of the methods set forth in the “Contact Us” section below.

We reserve the right to release current or past personal information: (i) in the event that we believe that the Site Offerings are being or have been used in violation of our Website Terms of Use or to commit unlawful acts; (ii) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or (iii) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if RCYC is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via e-mail and/or a prominent notice on the Site of any change in ownership or uses of your Personal Information, as well as any choices that you may have regarding your personal information. 

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate and authorized by this Global Privacy Policy including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time to time.  Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit Personal Information to be shared or transferred to third parties without permission. 

Why We Collect Your Data (Legal Bases)

Category	Types of Information	Purposes for Collection of Consumers' Personal Information
Cookies & Online Behavioral Tracking (Website, Email and Applications)	"Cookies" are small pieces of information that a website sends to your device while you are viewing a website that may also return information about your website usage (including if you are logged in). We use both our own cookies, and cookies placed by third parties. We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). Among other things, cookies allow us to provide you with a more personal and interactive experience tailored to your interests and to improve our marketing efforts. Cookies may be managed by following instructions provided by your browser, or in jurisdictions where it is required by law, by choosing to allow or disallow cookies from the cookie consent module. If you choose to disable cookies some areas or features of our websites may not work properly. We also use similar tracking mechanisms to view your interactions with our applications and emails we send, including whether you have opened those emails.	We use this information to make our websites operate efficiently, to improve user experience on our websites, emails, and applications, and to understand website, email and application traffic and how our websites, emails and applications are being used. We also participate in behavior-based advertising. This means that a third party may use a cookie or other behavioral tracking technology to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our websites, or on other websites. You can opt-out of receiving advertising based upon your browsing behavior from some network advertising companies by going to the Network Advertising Initiative and the Digital Advertising Alliance websites.  We use this information to provide advertising about products and services tailored to our user’s interest.
Web Logs	We collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet), domain name, click-activity, referring website, app configuration information, and/or a date/time stamp for your visit.	We have a legitimate interest in monitoring our networks and the visitors to our websites and mobile applications. Among other things, it helps us understand which of our services is the most popular.
Device Identifying Technology	We collect information from your internet-enabled device, including mobile devices, such as unique identifying information broadcast from your device when visiting our website and/or guest application. RCYC tracks Users’ use of the Site Offerings across various devices, including your personal computer and mobile device, in order to optimize and personalize your Site Offerings experience.  RCYC may collect certain of your personal information across various devices.	We have a legitimate interest in identifying unique visitors across disparate devices, and in understanding how users interact with us across the various internet-enabled devices they use.
Loyalty or Rewards Programs	If you sign up for a program in which we participate, we collect your loyalty number and other account identifying information (such as email address, first and last name), as well as information regarding loyalty earnings and rewards, loyalty status, and other information regarding travel interests and preferences held by the loyalty program provider.	We have a legitimate interest administering our loyalty and rewards programs. That administration includes communicating with you about program benefits, providing you with membership benefits, detecting security incidents, and protecting against malicious, deceptive, fraudulent, or illegal activity.
Phone, Mail, Email, SMS and other Marketing Lists	When you sign up for one of our phone, mail, email, SMS or other marketing lists we collect your name, phone number, email address, postal address and/or other information about your physical location as well as the nature of your signup (for example, signups made in conjunction with a request for information about a specific voyage, region and/or promotion).	Where required by law, we have obtained your consent to share information about our products or services via phone, email/digital, postal mail, SMS and other communication channels, and we use your name, email address, postal address and/or other provided data to share such information. We also have a legitimate interest in sharing information about our products or services, and we use your email address or postal address to share such information. We may disclose your information to companies within the Marriott Group for the purpose of facilitating travel and vacation plans that you may have with one or more Marriott Group members as well as to facilitate the provision of various Marriott Group member products and/or services previously obtained by you.
Registering Your Interest/ Request a Quote/ Support Request	When using the Contact Services or communicating with us directly via phone, email or any other means, you may be required to submit Contact Data,. This information will be provided by you by filling the online form on our Site, or verbally or in-writing if phoning or emailing us. If you provide us feedback or contact us for support or inquiries, we will collect your name and e-mail address and possibly other personal information, as well as any other content that you send to us in order to reply.	We have a legitimate interest in receiving, and acting upon, your: feedback; concerns or issues; or interest in the products and services we offer for sale. The information will be (i) used so that our representatives can contact you in response to your inquiry or with further details about the products and services we offer; and (ii) processed by us on the basis of your request for information prior to making a Cruise Booking. In certain instances, it may be used to determine interest in larger product and service categories.
Booking a Cruise	When booking a cruise with us we ask you to sign up to our Cruise Booking terms and conditions and cruise contract, which can be accessed at www.ritzcarltonyachtcollection.com.  You will also be asked to provide and confirm your name, surname, passport details or other government identification document details, address, contact details including email address or mobile phone number or both as well as credit card or other payment details. We may ask you for preference information (including dietary, special occasions, etc.), information regarding your travel to and from the yacht (e.g. flight and hotel information), emergency contact information, email address information, and mailing address information. Applicable health details will also be collected. This information is required of both you and guests traveling with you. By providing us with information of any third party, you confirm you have the authority to provide this information on their behalf, and that you have provided them with the information contained within this privacy policy. If you choose to work with a travel professional (travel agent), they may process your information on our behalf.	This information is necessary for us to establish a legally binding contract with you and to process payments due for the cruises booked, including any deposits and payments of final balance. Once you make a Cruise Booking, the processing of your personal data will be subject to both the Cruise Booking terms and conditions, the cruise contract and associated privacy statement, all of which can be accessed at www.ritzcarltonyachtcollection.com We will also use your personal information to send important notices, such as changes to the Cruise Documents.  Because this information is important to your interaction with RCYC and your Cruise Booking you may not opt out of receiving these communications.
Purchase of Non-Cruise Products	After booking a voyage with us, we offer for sale products and services such as airfare, hotel stays, shore excursions and spa appointments. We may collect information including guest first and last name, age, gender, passport information, address, and other information needed for you to safely and securely utilize the product or service offered. This information will be shared with third parties who provide these products and services, as needed.	We have a legitimate interest in fulfilling the products and services we offer for sale. We also must comply with legal and regulatory requirements, including those incumbent upon us through our relationship with third-party product and service providers.
Interactions with our Call Center	We retain Contact Data and details regarding your interactions with our call center, both inbound and outbound, including phone number, call time, call length, call content summaries, and recordings of your calls.	We use this information to administer services for our guests, to ensure quality in our call center and general compliance.
Employment Information	When you apply for a job using our online portal, you will be required to submit address information, resume, employment history, education information, and work eligibility information. Optionally, candidates may submit gender, ethnicity, disability and veteran status information.	We use this information to evaluate job candidates for employment, to contact you and in compliance with labor laws.
Travel Interests and Preferences	We may collect information either directly from you, or from third parties, about your interest in destinations/regions, vacation length, timeframe, suite category, price points, advance purchase time and other characteristics that distinguish preference among the products and services we offer. This information may also be used to place you in specific marketing segment(s).	We may use your personal data, where permitted, to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. It is in our legitimate interest to provide more relevant and interesting advertising messages. We may contact you with marketing communications via direct mail, phone call, email, text messages, or via notifications from applications. Where required by law, we will obtain your consent before contacting you with such marketing communications.
Travel Professional Information	We may collect information and Contact Data either directly from travel professionals, from their employers or host agencies, or from other third party organizations such as travel agent consortia including full name, email address, phone number, mobile phone number, address, office location, IATA/CLIA/other credentialing information, membership in travel consortia or other certifications and other information to facilitate the sale of our products and to provide you with resources to which you may be entitled. We will collect VAT or other tax identification information necessary to process payments to associated travel partner entities. We may also record the relationship between our guests and the travel professionals they elect to use, if appropriate.	This information is necessary for us to establish a legally binding contract with you and to process commission or other payments due for the cruises booked. Once you book a cruise, the processing of your personal data will be subject to an additional associated privacy statement(s). We will process your personal data on the basis of the Cruise Documents in order to perform the cruise services and otherwise to comply with our legal and regulatory requirements. To the extent you, asa travel professional (travel agent), collect information provided by your clients for your own use, you must make all relevant privacy policies available for your client to review. If your client  makes a Cruise Booking through you, as a travel professional, you must disclose that you will communicate all necessary information with us on their behalf.

 

Aggregate Data
RCYC reserves the right to transfer and/or sell aggregate or group data about Users of the Site Offerings for lawful purposes.  Aggregate or group data is data that describes the demographics, usage, and other characteristics of Users as a group, without disclosing personally identifiable information.

Social Media Websites
If you engage in any interaction with RCYC, other Users or any third-party on any Social Media Websites, you should be aware that: (a) the personal information that you submit by and through such Social Media Websites can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where RCYC responds to any interaction on such Social Media Websites, your account name/handle may be viewable by any and all members/users of RCYC’s social media accounts. 

We are not responsible for the Personal Information that you choose to submit on any Social Media Websites.  The Social Media Websites operate independently from RCYC, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices.  We encourage you to review the privacy policies and settings of the Social Media Websites with which you interact to help you understand those Social Media Websites’ respective privacy practices.  If you have questions about the security and privacy settings of any Social Media Websites that you use, please refer to their applicable privacy notices or policies.
 

Third-Party Websites
Our websites, applications, including mobile applications, and social media pages/online services include links to other websites whose privacy practices may differ from our practices. If you submit personal data to any of those sites, your information is governed by their privacy policies. We are not responsible for the privacy practices or the content of any sites to which our websites, applications, including mobile applications, and social media sites provide links. We encourage you to carefully read the privacy policy of any website you visit.

Opt-Out/Unsubscribe
To opt-out of receiving e-mail and other forms of communication from us, you can: 
(a) follow the instructions included in the applicable e-mail message or other communication; 
(b) visit https://www.ritzcarltonyachtcollection.com/guest/my-profile (or for travel professionals at https://www.ritzcarltonyachtcollection.com/travel-agent/my-profile) and sign in to your account to update your preferences; or 
(c) e-mail us at: Privacy@ritz-cartlonyachtcollection.com.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site Offerings, as well as to respond to any inquiry or request made by you.  To opt-out of receiving Site Offerings-related and/or inquiry response-related messages from RCYC, you must cease requesting and/or utilizing the Site Offerings and/or cease submitting inquiries to RCYC, as applicable.

Once a request to opt-out is received, we may take a reasonable amount of time to action the request. This is typically within thirty (30) days, unless otherwise specified by local laws or regulations, notwithstanding failures or deficiencies of underlaying technology systems or processes required to process the opt-out request.
 

Deleting, Modifying and Updating Your Information
Where required by law, at your request we will: (a) inform you of what personal information we have on file for you; (b) amend the Personal Information that we have on file for you; and/or (c) remove Personal Information that you have provided to us, or that we have collected.  You may do so by e-mailing us at: privacy@ritz-carltonyachtcollection.com.  We ask individual Users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your Personal Information may terminate your access to certain of the Site Offerings.  If you wish to continue using the full complement of Site Offerings, you may not be able to delete all the Personal Information that we have on file for you.
Please be further advised that, after you delete your Personal Information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
 

SPECIAL NOTICE FOR CALIFORNIA RESIDENTS
In compliance with California law, we provide California residents residing in California with certain information upon request (“CA Consumer Request”). This Section of the Global Privacy Policy outlines how California residents can request information and what you can receive. If you would like to submit a CA Consumer Request, you can contact us at privacy@ritz-carltonyachtcollection.com or + (833) 999-7292. If you choose to submit a CA Consumer Request, you must provide us with enough information to identify you and enough specificity on the requested data. RCYC will only use the information it receives to respond to your request. RCYC will not be able to disclose information if it cannot verify that the person making the CA Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf.

1.    Request to Access. You may submit a CA Consumer Request to obtain a copy of or access to the personal information that RCYC has collected on you. 
2.    Request to Know. You may submit a CA Consumer Request to receive information about RCYC’s data collection practices. You may request information on the categories of personal information (as defined by California law) RCYC has collected about you; the categories of data collection sources; RCYC’s business or commercial purpose for collecting or selling personal information; the categories of third parties with whom RCYC shares personal information, if any; and the specific pieces of personal information we have collected about you. Please note that the categories of Personal Information and sources will not exceed what is contained in this Global Privacy Policy. Additionally, RCYC is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. RCYC is also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.
3.    Request to Delete. You may request that RCYC deletes your Personal Information. Subject to certain exceptions set out below we will, on receipt of a verifiable CA Consumer Request, delete your Personal Information from our records and direct any service providers to do the same. Please note that we may not delete your Personal Information if it is necessary to:
a.    complete the transaction for which the personal information was collected;
b.    provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
c.    detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk;
d.    debug and repair internal information technology as necessary; undertake internal research for technological development and demonstration;
e.    exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
f.    comply with the California Electronic Communications Privacy Act;
g.    engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
h.    enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
i.    comply with an existing legal obligation; or
j.    otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

RCYC may not, and will not, treat you differently because of your Consumer Request activity. As a result of your CA Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your Personal Information.

SPECIAL NOTICE FOR NEVADA RESIDENTS
In compliance with Nevada law, we provide Nevada residents residing in Nevada with certain information upon request (“NV Consumer Request”). RCYC does not sell, rent, or lease your personally identifiable information to third parties. You are permitted to opt out of future sales of certain covered information that we may have collected or will collect about you. However, if you are a resident of Nevada and would like to submit a request to opt-out and/or not to sell your personally identifiable information, you may do so by emailing us at privacy@ritz-carltonyachtcollection.com or + (833) 999-7292. If you choose to submit a request, you must provide us with enough information to identify you and enough specificity on the requested data. RCYC will only use the information it receives to respond to your request. RCYC will not be able to disclose information if it cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf.

RCYC may not, and will not, treat you differently because of your NV Consumer Request activity. As a result of your NV Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your Personal Information.
 

SPECIAL NOTICE FOR VIRGINIA RESIDENTS
In compliance with Virginia law, we provide Virginia residents residing in Virginia with certain information upon request (“VA Consumer Request”). This Section of the Global Privacy Policy outlines how Virginia residents can request information, what you will receive and how to ot-out. If you would like to submit a VA Consumer Request, you can contact us at privacy@ritz-carltonyachtcollection.com or + (833) 999-7292. If you choose to submit a VA Consumer Request, you must provide us with enough information to identify you and enough specificity on the requested data. RCYC will only use the information it receives to respond to your request. RCYC will not be able to disclose information if it cannot verify that the person making the VA Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf. You have:

a.    the right to know and confirm whether we are processing your personal data, and to access the data;
b.    the right to correct inaccuracies in your personal data;
c.    the right to delete your personal data, subject to a number of exceptions in each case;
d.    the right to obtain a copy of your personal data, in a readily usable format;
e.    the right to opt out of the processing of your personal data for targeted advertising purposes;
f.    the right to opt out of the sale of your personal data; and
g.    the right to opt out of profiling based upon your personal data.
 

RCYC may not, and will not, treat you differently because of your VA Consumer Request activity. As a result of your VA Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your Personal Information.
 

SPECIAL NOTICE FOR COLORADO RESIDENTS
In compliance with Colorado law, we provide Colorado residents residing in Colorado with certain information upon request (“CO Consumer Request”). This Section of the Global Privacy Policy outlines how Colorado residents can request information and what you can receive. If you would like to submit a CO Consumer Request, you can contact us at privacy@ritz-carltonyachtcollection.com or + (833) 999-7292. If you choose to submit a CO Consumer Request, you must provide us with enough information to identify you and enough specificity on the requested data. RCYC will only use the information it receives to respond to your request. RCYC will not be able to disclose information if it cannot verify that the person making the CO Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf. RCYC does not sell, rent, or lease your personally identifiable information to third parties.

1.    Request to Access. You may submit a CO Consumer Request to obtain a copy of or access to the Personal Information that RCYC has collected on you. 
2.    Request to Know. You may submit a CO Consumer Request to receive information about RCYC’s data collection practices. You may request information on the categories of personal information (as defined by Colorado law) RCYC has collected about you; the categories of data collection sources; RCYC’s business or commercial purpose for collecting or selling personal information; the categories of third parties with whom RCYC shares personal information, if any; and the specific pieces of Personal Information we have collected about you. Please note that the categories of Personal Information and sources will not exceed what is contained in this Global Privacy Policy. Additionally, RCYC is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. RCYC is also not required to reidentify personal information if it is not stored in that manner already. 
3.    Request to Delete. You may request that RCYC deletes your Personal Information. Subject to certain exceptions set out below we will, on receipt of a verifiable CO Consumer Request, delete your personal information from our records and direct any service providers to do the same. Please note that we may not delete your Personal Information if it is necessary to:
a.    complete the transaction for which the Personal Information was collected;
b.    provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
c.    detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk;
d.    debug and repair internal information technology as necessary; undertake internal research for technological development and demonstration;
e.    exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
f.    engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
g.    enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
h.    comply with an existing legal obligation; or
i.    otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
4.    Request to Correct. You may request that RCYC correct inaccuracies in your Personal Information.
5.    Request to Opt-Out. You may request to opt-out of the processing of your personal data for purposes of targeted advertising or the sale of Personal Information.
6.    Right to Data Portability. You have the right to obtain a copy of your personal data, that you previously provided to RCYC, in a format that: to the extent technically feasible, is portable; to the extent practicable, is readily usable; and allows you to transmit the data to another without impediment, where the processing is carried out by automated means.

RCYC may not, and will not, treat you differently because of your CO Consumer Request activity. As a result of your CO Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your Personal Information.
 

SPECIAL NOTICE FOR CONNECTICUT RESIDENTS
In compliance with Connecticut law, we provide Connecticut residents residing in Connecticut with certain information upon request (“CT Consumer Request”). This Section of the Global Privacy Policy outlines how Connecticut residents can request information and what you can receive. If you would like to submit a CT Consumer Request, you can contact us at privacy@ritz-carltonyachtcollection.com or + (833) 999-7292. If you choose to submit a CT Consumer Request, you must provide us with enough information to identify you and enough specificity on the requested data. RCYC will only use the information it receives to respond to your request. RCYC will not be able to disclose information if it cannot verify that the person making the CT Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf. RCYC does not sell, rent, or lease your personally identifiable information to third parties.

1.    Request to Access. You may submit a CT Consumer Request to obtain a copy of or access to the Personal Information that RCYC has collected on you. 
2.    Request to Know. You may submit a CT Consumer Request to receive information about RCYC’s data collection practices. You may request information on the categories of Personal Information (as defined by Connecticut law) RCYC has collected about you; the categories of data collection sources; RCYC’s business or commercial purpose for collecting or selling personal information; the categories of third parties with whom RCYC shares personal information, if any; and the specific pieces of Personal Information we have collected about you. Please note that the categories of Personal Information and sources will not exceed what is contained in this Global Privacy Policy. Additionally, RCYC is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. RCYC is also not required to reidentify Personal Information if it is not stored in that manner already. 
3.    Request to Delete. You may request that RCYC deletes your Personal Information. Subject to certain exceptions set out below we will, on receipt of a verifiable CT Consumer Request, delete your personal information from our records and direct any service providers to do the same. Please note that we may not delete your personal information if it is necessary to:
a.    complete the transaction for which the personal information was collected;
b.    provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
c.    detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk;
d.    debug and repair internal information technology as necessary; undertake internal research for technological development and demonstration;
e.    exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
f.    engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
g.    enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
h.    comply with an existing legal obligation; or
i.    otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
4.    Request to Correct. You may request that RCYC correct inaccuracies in your Personal Information.
5.    Request to Opt-Out. You may request to opt-out of the processing of your personal data for purposes of targeted advertising or the sale of Personal Information.
6.    Right to Data Portability. You have the right to obtain a copy of your personal data, that you previously provided to RCYC, in a format that: to the extent technically feasible, is portable; to the extent practicable, is readily usable; and allows you to transmit the data to another without impediment, where the processing is carried out by automated means.

RCYC may not, and will not, treat you differently because of your CT Consumer Request activity. As a result of your CT Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.

SPECIAL NOTICE FOR UTAH RESIDENTS
In compliance with Utah law, we provide Utah residents residing in Utah with certain information upon request (“UT Consumer Request”). This Section of the Global Privacy Policy outlines how Utah residents can request information and what you can receive. If you would like to submit a UT Consumer Request, you can contact us at privacy@ritz-carltonyachtcollection.com or + (833) 999-7292. If you choose to submit a UT Consumer Request, you must provide us with enough information to identify you and enough specificity on the requested data. RCYC will only use the information it receives to respond to your request. RCYC will not be able to disclose information if it cannot verify that the person making the UT Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf. RCYC does not sell, rent, or lease your personally identifiable information to third parties.

a.    Right to access. You have the right to confirm if we are processing your Personal Information and to access your Personal Information.
b.    Right to delete. You have the right to delete the Personal Information that you provided to RCYC. 
c.    Right to data portability. You have the right to obtain a copy of your Personal Information, that you previously provided to RCYC, in a format that: to the extent technically feasible, is portable; to the extent practicable, is readily usable; and allows you to transmit the data to another without impediment, where the processing is carried out by automated means.
d.    Right to opt out of certain processing. You have the right to opt out of the processing of your Personal Information for the purposes of targeted advertising, or the sale of personal data.
RCYC may not, and will not, treat you differently because of your UT Consumer Request activity. As a result of your UT Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.
 

SPECIAL NOTICE FOR EU RESIDENTS
In compliance with EU law, we provide EU residents residing in the EU with certain information upon request (“EU Consumer Request”). If you choose to submit a request, you must provide us with enough information to identify you and enough specificity on the requested data. RCYC will only use the information it receives to respond to your request. RCYC will not be able to disclose information if it cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf.

1.    Right of Access. The right to obtain access to your Personal Information. You may, at any time submit a request to know what information is held in your regard, if any. You can ask us for a copy of your Personal Information; confirmation as to whether your Personal Information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the European Economic Area ("EEA").
2.    Right to Rectification: The right to obtain rectification of your Personal Information without undue delay where that personal information is inaccurate or incomplete. We will use our best endeavors to update and maintain the data as accurate as possible within a reasonable time. You may, at any time, submit a request to have any inaccuracies corrected. We assume no responsibility or liability for the accuracy or correctness of any data provided if changes are not communicated to us.
3.    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. Where processing is based on consent and in other specific circumstances You may request to have any or all of your details erased. You can ask us for further information on these specific circumstances by contacting us using the details below. We will pass your request onto other recipients of your Personal Information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are using the contact details below.
4.    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. You may, at any time, submit a request to restrict the processing of your data. You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details below. We will pass your request onto other recipients of your Personal Information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are using the contact details below.
5.    Right to Object. The right to object to us processing Personal Information relating to you where processing is based on the performance of a task in the public interest or based on our legitimate interests, You may object to the processing, however, this is subject to any of our overriding interests including in particular compliance with legal requirement on our part. In such case we will aim for a result that is mutually satisfactory such as taking your personal information off the live environment and archiving it for the necessary period to enable us to comply with our legal requirements.
6.    Right to Object to Direct Marketing.  You may object to the processing of your personal data for the purpose of direct marketing. In the event of such an objection, we will no longer be able to provide you with updates regarding our products and services.  We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain Personal Information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.  If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make
7.    Right to Port. The right to obtain certain personal information from us in a format that can be transferred electronically to a third party. You may request to receive your personal information in a structure commonly used and machine-readable format, and have it transferred to another controller. This right only applies where we use your personal information on the basis of your consent or performance of a contract and where our use of your information is carried out by automated means.
8.    Right to be Informed. The right to be informed about the Personal Information being processed.

In some cases, RCYC’s ability to uphold these rights for you may depend upon its 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.
 

IMPORTANT CONDITIONS

Transfer of Personal Information Internationally
If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers.  Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Global Privacy Policy.

Security
We endeavor to safeguard and protect our Users’ Personal Information.  When Users make Personal Information available to us, their Personal Information is protected both online and offline (to the extent that we maintain any Personal Information offline).  Where our registration/application process prompts Users to enter sensitive information (such as credit card information), and when we store and transmit such sensitive information, that information is encrypted with advanced TLS (Transport Layer Security).

Access to your Personal Information is strictly limited, and we take reasonable security measures to ensure that your Personal Information is not accessible to the public.  All our Users’ Personal Information is restricted in our offices, as well as the offices of our third-party service providers.  Only employees or third-party agents who need User Personal Information to perform a specific job are granted access to User Personal Information.  Our employees are dedicated to ensuring the security and privacy of all User Personal Information.  Employees not adhering to our policies are subject to disciplinary action.  The servers that we store User Personal Information on are kept in a secure physical environment.  We also have security measures in place to protect the loss, misuse, and alteration of Personal Information under our control.

Please be advised, however, that while we take every reasonable precaution available to protect your Personal Information and data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure.  Computer hackers that circumvent our security measures may gain access to certain portions of your Personal Information, and technological bugs, errors and glitches may cause inadvertent disclosures of your Personal Information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law.  For the reasons mentioned above, we cannot warrant that your Personal Information will be absolutely secure.  Any transmission of data at or through the Site, other Online Offerings or otherwise via the Internet or wireless networks, is done at your own risk.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies if we learn of an information security breach with respect to your Personal Information.  You will be notified via e-mail in the event of such a breach.  Please be advised that notice may be delayed to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Minors
RCYC feels strongly about protecting the privacy of children. RCYC’s websites are not targeted for use by minors under the age of 18 (“minors”). Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site.  RCYC does not knowingly solicit or collect information from visitors under eighteen (18) years of age. Upon notification that a minor has accessed our website and provided us with personally identifiable information, we will delete the minor’s personally identifiable information from our records. If you believe we might have any information from a child, please email us at privacy@ritz-carltonyachtcollection.com or + (833) 999-7292.
 

Others
It may be necessary, by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence, for RCYC to disclose your Personal Information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our Website Terms of Use or protect our operations.  This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
 

Data Retention
We retain your personal data for as long as we have a relationship with you or in accordance with applicable law, and such relationship includes any request to receive marketing or other promotional materials from us or membership in our loyalty programs. When deciding how long to keep your personal data after our relationship with you has ended, we consider our legal obligations, including requirements of regulators and governmental agencies that have authority over us. We may also retain records to investigate or defend against potential legal claims. We will delete or anonymize your personal data at the end of the retention period. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

Changes to this Privacy Policy
RCYC reserves the right to change or update this Global Privacy Policy at any time by posting a notice on the Site that we are changing our Global Privacy Policy.  If the manner in which we use Personal Information changes, RCYC will notify Users by: (a) sending the modified policy to our Users via e-mail; and/or (b) by any other reasonable means acceptable under applicable state and federal law.  You will have a choice as to whether we use your information in this different manner, and we will only use your information in this different manner where you opt-in to such use.

Contact Us
If you have any questions about this Privacy Policy or our privacy practices in general you may e-mail us as at privacy@ritz-carltonyachtcollection.com or send mail to The Ritz Carlton Yacht Collection, 100 NE Third Ave., Suite 1100, Fort Lauderdale, FL 33301 to the attention of the Legal Department.

Filing a Complaint with the Federal Trade Commission
To file a complaint regarding our privacy practices:
https://reportfraud.ftc.gov/#/ or call 1-877-FTC-HELP (1-877-382-4357).