The Ritz-Carlton Yacht Collection Global Privacy Policy (incl. EU)

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Last Updated: July 2, 2020

Thank you for visiting The Ritz-Carlton Yacht Collection website located at www.ritzcarltonyachtcollection.com (the “Site”).  The Site is an Internet property of Cruise Yacht OpCo Ltd, d/b/a The Ritz-Carlton Yacht Collection (“RCYC,” “we,” “our” or “us”). This Privacy Policy (“Privacy Policy”) covers our treatment of personal information and other information that we collect when end-users (“User,” “you” or “your”): (a) access or use the Site; (b) access and/or view any of the: (i) links to various featured websites, products and/or services (“Links”), including Links to web venues owned and/or operated by Marriott International, Inc., and its subsidiaries, including The Ritz-Carlton Hotel L.L.C. (collectively, the “Marriott Group”), as featured on the Site; and/or (ii) 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”); (c) access software applications made available on mobile devices and through computers (the “Apps”); (d) access links to RCYC’s social media pages/accounts featured on third-party social media websites, such as Facebook®, Instagram®, LinkedIn®, Twitter® and YouTube® (collectively, “Social Media Pages”); (e) utilize the various contact forms and/or contact information made available on the Site as a means to contact directly, or request to be contacted by RCYC and/or featured members of the Marriott Group (collectively, the “Contact Services,” and together with the Site, Links, Apps and Content, the “Site Offerings”); (f) apply for employment via the Site or linked websites RCYC may use for the purposes of employment; (g) provide your information for inclusion in our guest, prospective guest, or travel professional partner database via phone, email or any other method; and/or (h) make a reservation.

Capitalized terms not defined herein shall have the meanings set forth in The Ritz-Carlton Yacht Collection Website Terms and Conditions (“Terms of Use”).  IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE OFFERINGS.

Personal Information Collected

For the purposes of this Privacy Policy, “personal information” shall mean individually identifiable information from or about an individual.  We collect personal information when you access certain of the Site Offerings and complete the required information request form(s) and/or otherwise provide such information to us and when you make a cruise booking with us (the “Cruise Booking(s)”).  The information that you must supply on the form(s) may include, without limitation: (a) your e-mail address; (b) your full name; (c) credit card number or other payment account information; (d) your telephone number; (e) your zip code and country/geographical region of residence; (f) your Marriott Bonvoy number; (g) nationality and passport number; (h) professional information including job title; and (h) any other information collected via the applicable form (the “Contact Data”). 

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 the Marriott Group 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.

Use of Personal Information

Other than as set forth in this 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 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 in order 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 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 the 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 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. 

How, Where and Purposes for Collecting your Personal and Non-Personal Information

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 and other Marketing Lists

When you sign up for one of our phone,  mail, email 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 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 Pages, you should be aware that: (a) the personal information that you submit by and through such Social Media Pages 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 Pages, 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

This Site may contain links to third-party owned and/or operated websites including, without limitation, Social Media Websites and Links to Marriott Group member websites, as well as the websites of other third parties.  RCYC is not responsible for the privacy practices or the content of such websites.  In some cases, you may be able to make a purchase through one of these third-party websites.  In these instances, you may be required to provide certain information, such as a credit card number or other payment information, to register or complete a transaction at such website.  These third-party websites have separate privacy and data collection practices and RCYC has no responsibility or liability relating to them.

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-carltonyachtcollection.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 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 of 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.

A. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law provides you with the following rights with respect to your personal information:

  • The right to know what personal information we have collected, used, disclosed and sold about you.
  • The right to request that we delete any personal information we have collected about you in accordance with applicable law.
  • The right to opt-out of the sale of any personal information we have collected about you, where applicable.

When you exercise these rights and submit a request to us, we will verify your identity by asking you to log in to your account if you have one with us. Or if you do not, we may ask for your email address, order numbers of previous orders, or other information we think would allow us to verify your request. RCYC also may use a third-party verification provider to verify your identity.

To submit a request to know or a request for deletion, you may send an email to privacy@ritz-carltonyachtcollection.com or submit a request form. You also may designate an authorized agent in writing to make a request on your behalf.  Please include sufficient information for us to identify you in your email, such as information about previous voyages, or, if applicable, your portal account information. Please note we will take reasonable steps to verify your identity and the authenticity of the request.

When you exercise these rights and submit a request to us, and depending on the nature of your request, we will verify your identity by asking you for the email address attached to your member account, your billing address and the last four digits of a credit or debit card on file.  We also may use a third-party verification provider to verify your identity.

RCYC will not discriminate against you because you exercised any of these rights.

B. NEVADA PRIVACY RIGHTS

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. If you are a Nevada resident, you may submit a request to opt out of potential future sales under Nevada law by emailing us at privacy@ritz-carltonyachtcollection.com.  Please include sufficient information for us to identify you in your email, such as information about previous voyages, or, if applicable, your My Yacht Account portal information. Please note we will take reasonable steps to verify your identity and the authenticity of the request.

C. EUROPEAN PRIVACY RIGHTS

If you reside in the EU, you are entitled to the following rights in respect of personal information that RCYC holds:

  • 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").
  • 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 endeavours 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.
  • 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.
  • 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.
  • 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.
  • 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
  • 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.
  • 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 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 of 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 firm 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 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 Site 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 in the event that 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 in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

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. 

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 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

Your personal data is retained for as long as necessary in order for us to comply with any legal requirement which may be in force or otherwise for us to defend a claim in respect of any service provided to you. If you have granted permission for us to retain all or some of your data, it will be held in perpetuity until such time as you rescind this permission, or we determine that your data is no longer useful for our legitimate business interests.   

Changes to this Privacy Policy

RCYC reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our 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 or not 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 us mail to 2601 S. Bayshore Drive, Suite 900, Miami, FL 33133 to the attention of the General Counsel.

Filing a Complaint with the Federal Trade Commission

To file a complaint regarding our privacy practices, please Click Here.

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