Carnival plc – Shine Rewards Scheme Privacy Notice
Cunard and P&O Cruises are trading names of Carnival plc. We collect and process data about travel agents in connection with the promotion, delivery and improvement of our travel agency loyalty scheme ‘Shine’ (the “Scheme”). This privacy notice describes what personal data we collect in connection with the Scheme, how we use that personal data, and how to ensure that our processing meets your expectations.
Why we process personal data
We process personal data about our travel agent partners in connection with the Scheme in order to promote the Scheme and to administer and fulfil the Scheme. We may process personal data related to members of the Scheme in order to support our legitimate interests, which include:
- Inviting travel agent partners to participate in the Scheme;
- Making our travel agent partners aware of news, offers and loyalty benefits;
- Monitoring and improving the quality of our services;
- Working with our travel agent partners to manage and improve employee reward opportunities.
What personal data we will collect
We collect personal data from you when you provide it to us, and with your consent use it to register you in the Scheme and better tailor the Scheme and our communication to you including:
- Contact details including your name and email address;
- Employment data including personal title, job title, length of service in industry, work address, phone number, ABTA number (so we can confirm that you are a travel agency employee);
- Other personal data including home address (so we can deliver rewards to you), date of birth, interests and hobbies (so we can personalise rewards and promotions);
- Other reference numbers to record your participation in training and other Carnival plc programmes.
In addition we may generate personal data about you through your activities while you use the Scheme including:
- Transactional information (orders, delivery tracking, points accrual and redemption, prize wins etc.);
- Reward activity including the use of e-codes, gift cards and vouchers;
- Customer service enquiries;
- Website usage including cookies and analytics data.
How we process personal data
The personal data you provide to us or which we obtain through your dealings with us in connection with the Scheme may be used for the following purposes:
- To administer your membership of the Scheme;
- To keep you up to date with our latest news, offers and services;
- To track the response to our travel agent communications;
- To review, develop and improve the Scheme and the services we offer to our travel agent partners;
- For statistical analysis.
We will send information about news, offers and services to you by email whilst you remain a member of the scheme, and you may from time to time receive written communications, rewards or gifts to your registered postal address. Should you wish to discontinue these communications then you will need to close your account which you can do on your ‘My Account’ page.
We also use anonymised personal data related to the Scheme to provide longer-term insight into the effectiveness of our travel agent partner services and communications and to support our service planning and delivery.
Sharing personal data
We contract a third party, Sodexo Motivation Solutions U.K. Limited to perform certain activities on our behalf in connection with the Scheme. Examples include maintaining the database of Scheme participants, supplying and operating the Scheme website, fulfilling Scheme benefits, sending certain communications in relation to the Scheme, analysing data and providing reports. Sodexo Motivation Solutions U.K. Limited is a processor acting on behalf of Carnival plc and has access to personal information needed to perform its functions, but is not permitted to use it for other purposes. We may use third parties to deliver aspects of the service, for example sending emails and other communications. When we do so, they will act as processors on behalf of Carnival plc and will be subject to appropriate legal and technical controls.
If you claim a Scheme benefit we (or Sodexo Motivation Solutions U.K. Limited on our behalf) may pass personal data about you on to the relevant supplier(s) of your Scheme benefit. This may involve sending personal data about you between different countries within the European Union.
You may from time to time be offered discounts and other benefits through the Scheme website which are offered by Sodexo Motivation Solutions U.K. Limited or other partners. When you click on these links you will be asked to consent to the transfer of your details to those third parties, and your use of their services will be subject to their privacy notices.
We will share aggregated data related to Scheme membership and participation with your employing travel agency. This may include the number of individual travel agency employees who are members of the Scheme, how many points have been earned by travel agency employees who are members of the Scheme and information about how travel agency employees are utilising points awarded under the Scheme. This data will not identify you personally, although in certain circumstances it might be possible for a travel agency to identify individual employees from this data.
Your rights concerning your personal data
You have rights over how we use personal data about you, and can exercise those rights by contacting our Privacy & Data Protection Team at the address below. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, 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.
Withdrawing consent to processing
Where we have obtained your consent for processing of personal data about you, you have the right to withdraw your consent at any time. Where we process personal data about you in ways for which your consent is not required, you may ask us to cease processing, or restrict the nature of the processing if you wish. Should you wish to withdraw your consent to processing then you can close your account on your ‘My Account’ page or by contacting us at the address below.
Accessing the personal data we hold about you
You may request a copy of the personal data we hold about you. This includes obtaining personal data about you in electronic form to provide to a third party should you wish to do so.
Ensuring the accuracy of personal data we hold about you
You can update your details on the ‘My Account’ section of the website. We will update or amend personal data we hold about you if you inform us of inaccuracies.
Deleting personal data we hold about you
We will delete personal data we hold about you if you ask us to do so, except where certain exemptions apply.
How to complain about our processing of personal data
If you have a concern or complaint about our processing of personal data, please contact our Privacy & Data Protection Team at the address below.
If you are not satisfied with our processing of personal data, how we have responded to your complaint about the processing of personal data, or you believe our processing of personal data is not in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO) by calling +44 (0)303 123 1113, or visiting https://ico.org.uk/concerns/
Securing your personal data
We take the security of your personal data seriously, and use security policies, standards, technologies and ongoing training to protect the personal data we process from improper access, use, alteration, destruction and loss.
Where we share your personal data with other companies as described above, we require those companies to process your personal data to an equivalent level of security.
How to contact us
Cunard and P&O Cruises are trading names of Carnival plc. Carnival plc is registered in England & Wales number 04039524, and is registered as a data controller with the Information Commissioner’s Office number Z8383204. All enquiries relating to data protection, including communications with our Data Protection Officer, should be sent to our Data Privacy Team at Carnival House, 100 Harbour Parade, Southampton, SO15 1ST, or by calling 0344 338 8650, or by email to firstname.lastname@example.org.
Changes to this policy
This policy was last updated on 1st November 2018. When changes are made to this policy, we will publish the changed policy on our websites with details of the changes.