Tropical Cruise Privacy Statement

Effective Date: January 1, 2006

Introduction

This privacy statement describes how Tropical Cruise Maldives collects and uses the personal information you provide on our Websites: www.tropicalcruise.co.uk. It also describes the choices available to you regarding the use of your personal information and the steps you can take to access this information and to request that we correct or delete it.

Tropical Cruise Maldives abides by the safe harbour framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union.

If you have questions about this privacy statement, please send them to us by email to info@tropicalcruise.co.uk.

If you have technical difficulty using our Web Website, please contact our Webmaster at info@tropicalcruise.co.uk.

Your privacy is very important to Tropical Cruise Maldives ("we" or "us"). This Privacy Policy describes the principles and practices that apply to Personal Information (defined below) collected from users of our services ("you") on our Website, in telephone or e-mail communications, interviews and surveys.

In summary:

• We will not collect Personal Information without your knowledge and permission;
• We will not knowingly disclose your Personal Information to third parties, except as provided in this Privacy Policy;
• We will allow you to view, correct or remove your Personal Information; and
• We will take reasonable steps to protect the security of the Personal Information we collect from you.
• The remainder of this policy describes our Personal Information handling practices in detail.

1. Definitions

In this Privacy Policy, terms that commence with a capital letter are defined in this Section or in the preamble.

"Guest" means an individual who can search and purchase Products or Services on the Website without being a Member.

"Member" means an individual who has registered with the Website. Members choose a Member ID and a password.

"Member ID" means the e-mail address or user name you use (with your password) to login to our Website.

"Personal Information" means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred from the information. This includes, for example, name, e-mail and mailing address and telephone number, billing and account information, and other information incidental to providing Products or Services (including information about individuals travelling with you).

"Products or Services" means the live-aboard accommodation, resort accommodation, airline travel, hotel accommodation, ground transportation, tours, attractions, travel insurance, and other items available from the Website.

To "Purchase" means to book, reserve or purchase.

"Session Data" means usage information, such as the type of Internet browser and operating system an individual use, the domain name of the Website from which the individual came, the date, time and duration of the visit, number of visits, average time spent on the individual's Website, pages viewed, domain name of the individual, and number of cookies accumulated.

"Website" means the www.tropicalcruise.co.uk Website together with the respective content, Products and Services available from these Websites and sub Websites.

"Subscriber" means an individual who elects to receive offers or promotions from Tropical Cruise Maldives without becoming a Member or a Guest.

2. Consent

BY SUBMITTING PERSONAL INFORMATION TO US, AND/OR BY USING OUR WEBSITE, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW.

If you do not agree with these terms, do not provide any Personal Information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Information, we may not be able to provide you with Products or Services that can be offered on our Website only if we have access to certain Personal Information.

Minors

Minors (as defined under the laws of their jurisdiction or residence) are not eligible to register for, use, or Purchase the Products or Services available on our Website. We do not knowingly collect Personal Information from any Minor, and will not use this information if we discover that it has been provided by a Minor.

Other Travellers or Contacts

If you Purchase Products or Services for other travellers using your Member ID and password, or if you provide us with contact information of a third party, you must make sure that you have the right to do so. By providing the Personal Information of another traveller, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose his or her Personal Information as set forth in this Privacy Policy.

3. What Personal Information do we collect?

We collect only such information as necessary to provide Products and Services to you.

When you are just visiting

You can visit certain areas of our Website without revealing who you are or signing-in.

When you register as a Member

If you register with us as a Member, we collect Personal Information that is necessary to provide the Products and Services offered on our Website. We require that you provide your name and e-mail address. You also need to choose a password, which will be required to gain access to portions of our Website reserved for Member use. We might also request your home Post/zip code.

You may also elect to indicate your preferences for accommodation selection or meal requests, or provide details about your participation in loyalty or awards programs and applicable membership numbers, and other ticketing options.

When you Purchase Products or Services as a Member

When you Purchase Products or Services from our Website, you must provide payment or other necessary information. This includes, for example, billing information, driver information, or similar information as required by the accommodation service provider(s).

When you Purchase Products or Services for a third party

When you Purchase Products or Services for a third party, we will collect that third party's name and contact information, and other information as required by the travel service provider(s), so that we can complete the booking.

When you use the Website as a "Guest"

If you are not a Member, you may elect to use our Website as a Guest.

If you Purchase Products or Services as a Guest, you must provide Personal Information to complete the booking (for example, name, phone number, billing information), as required by the accommodation service provider(s). You must also provide an e-mail address, so that we can send you our welcome e-mail and a confirmation of the Purchase.

When you use "Subscribe"

When you become a Subscriber, we collect your name and email address, so that you may receive offers or promotions from Tropical Cruise Maldives without becoming a Member or Guest.

When you call or write to our Customer Service

When you call or write to our Customer Service, we collect contact information (name, phone number, mailing address or e-mail address) and information about the relevant Purchase as necessary to assist you. For example, if you call for assistance with a pre-existing Purchase, or to make a Purchase, we may request your contact and billing information.

When we send e-mails or e-newsletters

When we send e-mails, e-newsletters, we may insert a pixel tag in the e-mail.

4. How we use the information we collect

We use Personal Information in order to provide and enhance the Products or Services offered on our Website:

• To record your travel preferences, to make reservations or acquire travel insurance on your behalf, or to communicate with you about your travel plans;
• To issue invoices, administer accounts, collect and process payments;
• To provide tips or guidance on how to use our Website, inform you of new features on our Website, or provide other information that may be of interest to users;
• To personalize the service we provide to you, tailor your experience at our Website to your interests and make more appropriate travel recommendations;
• To send you e-mails, e-newsletters, personalized offers via direct messaging or other communications about our services, if you have subscribed to receive this information;
• To manage our Website, diagnose technical problems, improve content, and allocate the resources of our systems so that your experience with our Website is as efficient as possible;
• To process and track your transactions and to send you information about our and our affiliates' and business partners' products and services and other information and materials that may be of interest to you;
• To develop, enhance, market, sell or provide Tropical Cruise Maldives's Products or Services, or those of companies with which we have a commercial relationship, but only if you have granted us permission to do so;
• To evaluate credit standing and to match credit bureau or credit reporting agency information; to investigate, detect and protect Tropical Cruise Maldives and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activities;
• To effect a corporate transaction, in connection with the sale, merger, spin-off, or other corporate reorganization of our corporation, where the information is provided to the new controlling entity in regular course of business;
• To audit compliance with our policies and contractual obligations;
• As permitted by, and to comply with, any legal or regulatory requirements or provisions; or
• For any other purpose to which you consent.

Session Data

We use Session Data, collected through cookies , to better understand how our Website is navigated, how many visitors arrive at specific pages, the length and frequency of stays at our Website, the variety of searches of our Website's database, the types of browsers and computer operating systems used by our visitors and the Internet Protocol addresses from which visitors connect to our Website

We also use this information to improve our Website content and ease of use, to personalize and improve your individual viewing experiences on our Website, and provide information that may be of interest to you.

What we DON'T do

We do not and will not, at any time, request your credit card information, Member ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.

5. To whom we disclose Personal Information

From time to time, we may disclose your Personal Information as follows:

To those travel service providers with which you make arrangements through our Website, for example, airlines, hotel, resorts, live-aboards, ground transportation, attraction, or travel insurance. We provide them with the Personal Information needed to make and complete the purchase, booking, or reservation.

To organizations that perform services for or on behalf of Tropical Cruise Maldives, for example to provide customer service, deliver tickets, ship items, process credit cards, for research, marketing, data processing, to measure the use of our Website, to facilitate usage by a Visitor, or to offer credit card services or evaluate your creditworthiness. We will share with these companies only that Personal Information which they need to work on our behalf. Some of these service providers may be located in other countries. Your Personal Information will be provided to these organizations only if they agree to use such information solely for the purpose of providing services to Tropical Cruise Maldives, and under the instructions of Tropical Cruise Maldives, and with respect to that information, to act in a manner consistent with the relevant principles articulated in this Policy.

To protect our Website and our rights under our Terms and Conditions of Use; to protect ourselves against liability or prevent fraudulent activity; or where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain.

Where the information is public.

To our insurers and to regulatory agencies.

Disclosure without consent

Please note that there are circumstances where the use or disclosure of Personal Information may be justified or permitted, or where Tropical Cruise Maldives may be obligated to disclose information without consent. Such circumstances may include:

If required to comply with a subpoena or warrant issued or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with the rules or court relating to the production of records.

If we receive a formal request to disclose your Personal Information in connection with a legal action, we will attempt to contact you about it, if permitted by law, via the e-mail address you provided during registration, before we respond to that request.

If we believe in good faith that a law, regulation, rule or guideline requires it.

To a person who needs the information because of an emergency that threatens the life, health, or security of an identifiable person or group.

Where it is necessary to collect monies owing to us.

Corporate Travel - Tropical Cruise Maldives for Business Customers

If we have entered into an agreement with your employer to provide data on the Purchase of Products or Services by its personnel, and if you, or someone acting on your behalf, Purchase(s) Products or Services through our Website and indicate(s) that your purchase is for corporate travel purposes either (a) by indicating in the booking path that the Purchase is for business travel or (b) by using a corporate credit card, we will provide your employer with the Personal Information necessary so that it can track your corporate travel purchased on our Website.

6. How we retain and store Personal information

Retention and storage

We will retain your Personal Information in our databases in accordance with our document management, retention and destruction policy and applicable laws. This period may extend beyond the end of your relationship with us, but it will be only as long as it is necessary for us to have sufficient information to respond to any issues that may arise later. For example, we may need or be required to retain information to allow you to obtain credit for trip your Purchased but had to cancel. We may also need the retain certain information to prevent fraudulent activity; to protect ourselves against liability, permit us to pursue available remedies or limit any damages that we may sustain; or if we believe in good faith that a law, regulation, rule or guideline requires it.

Your Personal Information will be stored in secured locations, and on servers controlled by Tropical Cruise Maldives, located either at our offices, or at the offices of our service providers, as described in How we protect Personal Information .

7. How we protect Personal Information

Tropical Cruise Maldives employs physical, administrative and technical safeguards to help protect the confidentiality and integrity of Personal Information and to reduce the risk of loss, misuse, unauthorized access disclosure or modification of Personal Information. When Personal Information is sent to our service providers, we require, in our contracts with them, that they protect all Personal Information in a manner consistent with the principles articulated in this Privacy Policy.

If you choose to contact Tropical Cruise Maldives through the Website, you should be aware that any information transmitted electronically via the World Wide Web might not be secure. Tropical Cruise Maldives assumes no liability for the loss of any information that you transmit to us via the World Wide Web. However, should you choose to pay by credit card when making a booking, reservation or purchase on the Website, your card details will be encrypted for the transaction.

In communicating with you, we may send e-mail as unencrypted plain text because we are aware that most Members, Guests, or Subscribers cannot readily process encrypted e-mail. This is done for your convenience, but with the security concern that, if misrouted or intercepted, it could be read more easily than encrypted e-mail.

9. Privacy

Third Party Advertisers

Third parties advertise on our Website. We do not share any Personal Information about you with these advertisers unless you give us permission to do so, separate from any permission you provide during the Member registration process. These advertisers may seek to use cookies and pixel tags to track Session Data about the ads you have seen and types of things in which you appear interested. These advertisers may also use combined information about your visits to our Website and other Websites in order to provide advertisements about related goods and services that may be of interest to you.

When you click on one of these advertisers' links, you are leaving our Website and entering another Website. We are not responsible for such third party's Websites. You should carefully review the privacy statements of any other Website you visit, because those privacy statements will apply to your visit to that Website, and may be very different from our policy.

Opting-Out

As part of the registration process, we give you the ability to receive via e-mail or direct messaging information about our Products and Services, updates to our Website, customized advertisements and promotions that are targeted to your specific interest, such as flight specials, promotions, and other travel opportunities available on our Website and/or sponsored by our accommodation and travel service providers and advertisers. We send this information directly ourselves, or via third party service providers.

If you do not opt-out from receiving these communications about our Website, we will send them to you.

At any time, you may change which of the communications you wish to receive or not, by changing your preferences, as described in How to access, modify or delete Personal Information .

In addition, in our e-mails and other communications, we will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional e-mails from us.

Links

For your convenience, our Website provides links to other Websites. When you click on one of these links, you are leaving our Website and entering another Website. We are not responsible for such third party Websites. You should carefully review the privacy statements of any other Websites you visit, because those privacy statements will apply to your visit to such other Websites.

10. Provisions of this Privacy Policy

Changes to the Privacy Policy and Changes in Ownership

We may change or supplement this Privacy Policy from time to time. We may also undergo a change of ownership. We will post an appropriate notice of changes to the Privacy Policy and changes or ownership on our Website. Privacy Policy changes will apply to the information collected from the date we post the revised Privacy Policy to the Website, as well as to existing information held by us.

If we decide to change this policy in a material way, we will obtain the necessary consents required under applicable privacy laws if we seek to collect, use or disclose Personal Information for purposes other than those to which consent has been obtained, unless otherwise required or permitted by law. If any proposed change is unacceptable to you, you may request that we remove your Personal Information from our records, as described in How to access, modify or delete your Personal Information .

11. Disputes

If you have questions or concerns regarding Tropical Cruise Maldives privacy practices, you should first contact the Tropical Cruise Maldives sales department by writing to us at info@tropicalcruise.co.uk