This privacy notice applies to the personal data we will have received from you if you are a person who has had a treatment or service onboard a cruise ship in a spa operated by us, One Spa World.
This privacy notice will tell you how we look after the personal data you have provided to us and tell you about your privacy rights and how the law protects you.
Residents of certain countries and jurisdictions or whose personal data was collected in the EU may have additional rights. Please look at our section headed "Notices to Residents of Certain Jurisdictions" to see if this applies to you.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. DATA SECURITY
7. DATA RETENTION
9. NOTICE TO RESIDENTS OF CERTAIN JURISDICTIONS
Residents of EU/UK
9.1 Your Legal Rights
9.2 International Transfers
Purpose of this privacy notice
This privacy notice aims to give you information on how One Spa World (referred to in this policy as "OSW", "we", "us" and "our") collects and processes your personal data including the information you provide to us on our consultation form and health questionnaire prior to your treatment.
OSW is the controller in respect of your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the DPO using the details set out below.
|Full name of legal entities:||
OneSpaWorld (Bahamas) (fka Steiner Transocean Limited)
STO Italy S.R.L.
Steiner Transocean (II) Limited
|DPO Email address:||[email protected]|
Changes to the privacy notice
This version was last updated on May 24, 2018.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The data we collect about you when you have an onboard service from us comprises of the data provided by you in the consultation form you fill out for us and any information you provide to your service provider. This data includes your name, occupation, gender, age, voyage related info (vessel name, stateroom, date), type of service being purchased, and health related data including information about your health history. Some forms may also include date of birth, address, country of residence, telephone, and email. Medispa doctors may take additional notes and photos before, during, and after the service. Your photo may be taken in the course of other services or promotion activity. Case detail in the event you were involved with an incident that required documentation.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide the service you have requested as we need certain information particularly in respect of your health to ensure the requested service is suitable for you.
Data we collect from and about you comes from (i) the forms we request you to complete prior to your service, (ii) any information you may give to your service provider when you speak to them. (iii) if participating in our home delivery program, the information you provide us to fulfil your order (iv) the cruise line which provides us with data that can include voyage info (including bookingID, stateroom number, folio, etc), guest/crew data (including but not limited to name, gender, data of birth, nationality, in some cases, celebration event info and guest photos, etc).
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to fulfil our obligations to you and the cruise line in order to provide the service you have requested. Other legitimate purposes for which we may also use your personal data include to determine whether the service you have requested is suitable for you or to suggest suitable alternatives to you. We may also use your data if you have an adverse reaction to our service to analyse whether the service may have caused the reaction and to deal with any claim by you.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
The data retention period in respect to the consultation forms is in part influenced by the rules and regulations governing the vessel's operations. The data retention period could range from a few days (depending on voyage schedule) to about 36 months.
The information we hold in respect of you in connection with your service will be held by us for a period of about 36 months.
If you have any complaints concerning OSW's processing of your personal data please contact us at [email protected].
You have the right to lodge a complaint with the supervisory authority which is responsible for the protection of personal data in the country where you live or work, or in which you think a breach of data protection laws might have taken place.
We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance on [email protected].
If you are a resident of the European Union ("EU") or the United Kingdom ("UK") you may have certain addition rights as detailed below.
For the purposes of this notice "personal data" shall have the meaning given to that term in the EU General Data Protection Regulation ("GDPR").
Under certain circumstances, you have rights under data protection laws in relation to your personal data including those outlined below. If you wish to exercise any of the rights set out above, please contact our DPO at [email protected].
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdrawal consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually requiredYou will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may share your request with the cruise line on which your service was performed and may share with them any data related to responding to your request. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We share your personal data within our corporate group. This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: