Privacy Policy

What we use your personal
data for
Our reasons
If you are the Winner of a
Competition
• To perform our contract with you including to notify you by
contacting you and publishing your name and suburb on our
Website; and
• to comply with our legal and regulatory obligations including
to notify any person who enquires about the Winner of a
Competition
Providing the Website to you To perform our contract with you or to take steps at your request
before entering into a contract (being the Website Terms of Use)
To enforce legal rights or defend
or undertake legal proceedings
Depending on the circumstances:
• to comply with our legal and regulatory obligations
• in other cases, for our legitimate interests or those of a third
party, i.e. to protect our business, interests and rights or
those of others
Communications with you not
related to marketing, including
about changes to our terms or
policies or changes to the
Services or service or other
important notices
Depending on the circumstances:
• to comply with our legal and regulatory obligations
• in other cases, for our legitimate interests or those of a third
party, i.e., to provide the best service to you
Protect the security of systems
and data
To comply with our legal and regulatory obligations we may also
use your personal data to ensure the security of systems and data
to a standard that goes beyond our legal obligations, and in those
cases our reasons are for our legitimate interests or those of a
third party, i.e., to protect systems and data and to prevent and
detect criminal activity that could be damaging for you and/or us
Operational reasons, such as
improving efficiency, training,
and quality control or to provide
support to you
For our legitimate interests or those of a third party, i.e., to be as
efficient as we can so we can deliver the best service to you
Statistical analysis to help us
manage our business, e.g., in
relation to our performance,
customer base, app and
functionalities and offerings or
other efficiency measures
For our legitimate interests or those of a third party, i.e. to be as
efficient as we can so we can deliver the best service to you and
improve and develop our Services
Updating and enhancing user
records
Depending on the circumstances:
• to perform our contract with you or to take steps at your
request before entering into a contract (in this case, the
contract means the Terms and Conditions of Use which apply
to the Services)
• to comply with our legal and regulatory obligations
• where neither of the above apply, for our legitimate interests
or those of a third party, eg making sure that we can keep in
touch with our customers about their accounts and new
products or functionalities related to the Services and our
services

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What we use your personal
data for
Our reasons
To comply with our legal and
regulatory obligations
Depending on the circumstances:
• to perform our contract with you or to take steps at your
request before entering into a contract (in this case, the
contract means the Terms and Conditions of Use which apply
to the Services)
• to comply with our legal and regulatory obligations
where neither of the above apply, for our legitimate interests or
those of a third party, e.g. making sure that we can keep in touch
with our customers about their accounts and new products or
functionalities related to the Services and our services
To share your personal data
with members of our group and
third parties in connection with a
significant corporate transaction
or restructuring, including a
merger, acquisition, asset sale,
initial public offering or in the
event of our insolvency.
In such cases information will be
anonymised where possible and
only shared where necessary
Depending on the circumstances:
• to comply with our legal and regulatory obligations
• in other cases, for our legitimate interests or those of a third
party, i.e., to protect, realise or grow the value in our
business and assets
See ‘Who we share your personal data with’ for further information on the steps we will take to
protect your personal data where we need to share it with others.
7 MARKETING
We intend to send you email marketing to inform you of our services such as promotions.
We will always ask you for your consent before doing sending you marketing communications,
except where you have explicitly opted–in to receiving email marketing from us in the past or except
where you were given the option to opt–out of email marketing when you initially signed up for your
account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:
o contacting us at cruisecashcompetitions@outlook.com.
o using the ‘unsubscribe’ link included in all marketing emails you may received from us
We will always treat your personal data with the utmost respect and never sell or share it with other
organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for
marketing purposes, see ‘Your rights’ below.
8 WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with service providers we use to help us run our business or
provide the services or functionalities in the Services, including developers and cloud storage
providers.
We only allow service providers to handle your personal data if we are satisfied they take
appropriate measures to protect your personal data. We also impose contractual obligations on
service providers to ensure they can only use your personal data to provide services to us and to
you.
We or the third parties mentioned above may occasionally also need to share your personal data
with:

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▪ external auditors, e.g. in relation to the audit of our accounts and our company —the
recipient of the information will be bound by confidentiality obligations
▪ professional advisors (such as lawyers and other advisors)—the recipient of the
information will be bound by confidentiality obligations
▪ law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal
and regulatory obligations
▪ other parties in connection with a significant corporate transaction or restructuring,
including a merger, acquisition, asset sale, initial public offering or in the event of our
insolvency—usually, information will be anonymised but this may not always be possible,
however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us
(see ‘How to contact us’ below).
We will not share your personal data with any other third party.
9 HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will keep your personal data for as long as you have an active account with us and for a period
of up to 6 years thereafter to comply with any accounting or legal obligations including in the event
of the pursuit or defence of legal claims. Once you have closed your account with us, we will move
your personal data to a separate database so that only key stakeholders in our business on a ‘need
to know basis’ have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your
personal data.
10 TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
At this point in time, we do not transfer your personal data outside of the UK. If this changes, we
would comply with applicable UK laws designed to ensure the continued protection and privacy of
your personal data. Any updated destinations to which we send your personal data, would be
indicated in the present section and notified to you in accordance with the section on ‘Change to
this privacy policy’ below.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country
outside the UK where: the UK government has decided the particular country ensures an adequate
level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the
UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective
legal remedies for you; or a specific exception applies under relevant data protection law.
Accordingly, if we were to start transferring your personal data from the UK to:
▪ The EEA: we would rely on the adequacy finding granted by the UK to the EU under the
Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on
the adequacy regulation granted to the UK under the Adequacy Decision.
▪ Any country located outside the UK/EEA: we would rely an appropriate safeguards under
the UK GDPR, such as by including the relevant Standard Contractual Clauses in our
data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any
time we would not transfer your personal data outside the UK unless we could do so on the basis
of an alternative mechanism or exception provided by UK data protection law.
11 YOUR RIGHTS
You generally have the following rights, which you can usually exercise free of charge. For more
information regarding these rights, please visit the ICO website here.
Access to a copy of your personal data The right to be provided with a copy of your
personal data.
Correction (also known as rectification) The right to require us to correct any mistakes in
your personal data.

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Erasure (also known as the right to be
forgotten)
The right to require us to delete your personal
data—in certain situations.
Restriction of useThe right to require us to restrict use of your
personal data in certain circumstances, e.g. if you
contest the accuracy of the data.
Data portabilityThe right to receive the personal data you provided
to us, in a structured, commonly used and machine–
readable format and/or transmit that data to a third
party—in certain situations.
To object to useThe right to object:
• at any time to your personal data being used
for direct marketing (including profiling)
• in certain other situations to our continued use
of your personal data, e.g. where we use you
personal data for our legitimate interests.
Not to be subject to decisions without
human involvement
The right not to be subject to a decision based
solely on automated processing (including profiling)
that produces legal effects concerning you or
similarly significantly affects you
We do not make any such decisions based on data
collected by the Services.
For further information on each of those rights, including the circumstances in which they do and do
not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to
the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email or write to us—see below: ‘How to
contact us’. When contacting us please:
o provide enough information to identify yourself (e.g., your full name and username) and
any additional identity information we may reasonably request from you, and
o let us know which right(s) you want to exercise and the information to which your request
relates
12 KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost, or
used or accessed unlawfully. We limit access to your personal data to those who have a genuine
business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify
you and any applicable regulator of a suspected data security breach where we are legally required
to do so.
If you want detailed information from Get Safe Online on how to protect your information and your
computers and devices against fraud, identity theft, viruses and many other online problems,
please visitwww.getsafeonline.org. Get Safe Online is supported by HM Government and leading
businesses.
13 HOW TO COMPLAIN
Please contact us if you have any queries or concerns about our use of your information (see
below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.