Please read the entire policy carefully.
The following describes how we process data relating to identified or identifiable individuals and households (“Personal Data”), including the categories of Personal Data, its sources, and the purposes for which we process that data.
1. Collection Of Information
1.1 Information You Provide to Us
We collect information that you provide directly to us. For example, we collect information that you provide when you create an account; post information about yourself, photos, videos and other files; fill out a form; messages or communicate with us or users; create, propose or share cruise itineraries, activities and other content; join teams; vote, rate; express interest in ads; play game; score bonuses; exchange bonuses for discounts; apply for data transfer to shipowners; donate; enter a contest, other promotion, or survey; give feedback; or when you otherwise use our Services and Products.
The types of information that we may collect include:
- Identifiers and contact data, such as your name, username, password, email address, postal address, telephone number, gender, date of birth, age and/or age range; or other account-related information; your identity, public profile, and similar information from social networks such as Facebook; interests, opinions; demographic information and any other personal information that you choose to provide, such as photos, videos, story about yourself, preferred teams, and professional or employment-related information. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. Certain information about yourself is optional to provide.
On occasion, the information that you give us when you join a team may imply information about your beliefs, political views, health conditions, or your sexual identity. This, and other kinds of sensitive information, is given special protection in accordance with applicable law. Posting personal or sensitive information about others without their permission is against our Community Principals.
- Networks and connections
We collect information about the people, accounts, hashtags and teams you are connected to and how you interact with them across EmbarQ, such as people you communicate with the most or teams you are part of. We also collect contact information if you choose to upload, sync or import it from a device . Your choice to create or join teams is also optional, but we are required to process this information in order to administer your account, and to indicate that you are a member of the teams that you join
- Your usage
We collect information about how you use our EmbarQ, such as the types of content you view or engage with; the features you use; the actions you take; the people, accounts or teams you interact with; the games you play, your game scores; your donations; and the time, frequency and duration of your activities.
- Information about transactions made on EmbarQ.
If you use our Products for purchases or other financial transactions (such as when you make a purchase from our Partners or make a donation), we collect information about the purchase or transaction. This includes payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing, shipping and contact details.
1.2 Information We Collect Automatically When You Use the Platform
When you use our Platform, we automatically collect internet and other electronic network activity information about you and other information, including:
- Log Information: We collect log information about your use of the Platform, including the type of browser that you use; the time, duration, and frequency of your access; Platform pages viewed; your IP address; and the page you visited before visiting our Platform.
- Device Information: We collect information about the computer or mobile device that you use to access our Platform, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
- Geolocation Information: We may collect information about the location of your device each time you use our Platform based on your consent to the collection of this information, such as when you enable location services. For further information see Section 5.2. We may also collect information, such as your IP address, that can sometimes be used to approximate your location based on your device settings.
- Other Information: Based on your consent, we may collect other information from your device, such as photos from your camera roll or calendar information you want to manage via the Platform.
1.3 Information We Collect From Other Sources
We may collect information about you from other sources, such as through certain features on the Platform you elect to use. We rely on these third parties to either have your consent or ensure that they are otherwise legally permitted or required to disclose your information to us. Examples include:
- Social Media Services. If you register or log into your account through a third-party social media service, we will have access to some of your third-party account information from that service, including identifiers, such as your name and other information in that account, and used for purposes such as improving your EmbarQ recommendations. We may also have access to third-party account information if you use the Platform feature to share a link. You can enable or disable the connection between our Platform and your third-party account. Facebook and other social media companies may transfer information about you to us when you register for one of our Services or interact with that social media company on or in connection with our services.
- Things others do and information they provide about you. We may also receive and analyze content, communications and information that other people provide when they use our Products or Services. This can include information about you. For further details about the rights over this information available to individuals, see Section 6.
- Current or Future Corporate Affiliates. We may receive information about you from our current or future corporate parents, subsidiaries, or affiliates.
- Information From Other Third-Party Sources. In order to provide you with more tailored recommendations, we may obtain information about you from publicly and commercially available sources, such as third-party publishers, advertising networks, and service providers that we use to manage our ads on other sites, and other third parties as permitted by law. Advertisers, app developers, publishers, behavioral advertising vendors, market research, and social media companies or similar companies can send us information about you, for example a business could tell us about a purchase you made in its store and your use of bonuses. For more information about the data that we obtain from these providers, please contact us at firstname.lastname@example.org.
We may analyze and make inferences from the information we collect.
See Section 2 to learn how we will use the information that you provide to personalize our recommendations and other content to you.
2. Use Of Information
2.1 Operating our Platform
We may use information about you described above for various business purposes related to operating EMBARQ, including to:
- Provide, maintain, and improve EMBARQ, including to process transactions, develop new products and services (for example, including you in tests or pilots of new or revised EMBARQ functions), and manage the performance of EMBARQ;
- Display information about you, for instance, your list of interests, itineraries and teams, which will be visible on your profile, according to your privacy settings.
- Personalize EMBARQ, for example, to suggest itineraries, teams, games, ads and other sponsored content in which we think you may be interested. In order to understand our customers’ preferences, and better recommend products and services we may create a Consumer Profile by linking together and analyzing collected Personal Data. We may also augment Consumer Profiles with Personal Data that we create (such as Inference Data) or that we receive from our subsidiary companies, third parties, and may include Personal Consumer Profiles for our legitimate interests in market research and statistical analysis in connection with the improvement of our Services.
- Allow you to share information about your use of the EMBARQ through a third-party social media service, if you connect your account through that service (which you can turn off at any time) and to provide you with better recommendations;
- Monitor and analyze trends, usage, and activities in connection with EMBARQ; and
- Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; to protect the rights, property, or safety of EMBARQ and others; to enforce compliance with our policies; and to comply with applicable law and government requests; and
- Perform accounting and administrative tasks, and enforce or manage legal claims.
- We use location-related information-such as your current location, where you live, the places you like to go, and the businesses and people you're near-to provide, personalize and improve Embarq, including ads, for you and others. Location-related information can be based on things like precise device location (if you've allowed us to collect it), IP addresses, and information from your and others' use of EmbarQ.
2.2 Communicating With You
We may use information about you for various business purposes related to communicating with you, including to:
- Respond to your comments, questions, and requests, and provide customer service;
- Communicate with you, in accordance with your account settings, about products and services, offered by us and others, to provide news and information that we think will be of interest to you, to conduct online surveys, and to otherwise communicate with you in accordance with Section 2.3;
- Notify you about events with your itinerary, team, invitations, status, score, rating and other things, connected with your usage of EmbarQ; and
- Send you technical notices, updates, security alerts and support, and administrative messages.
2.3 Advertising And Other Uses
We may use information about you for various other business purposes, including to:
- Provide content, features, or sponsorships that match your profile or interests;
- Facilitate contests and other promotions;
- Send you marketing communications, subject to applicable law. These communications may be personalized or customized based on your user profile. Similarly, we may also collect Device/Network Data and contact data so that we can determine whether you have opened an email or otherwise interacted with our communications, and we may generate Inference Data based on these interactions.
- Provide measurement, analytics, and other business services. We use the information we have (including your activity off our Products, such as the websites you visit and ads you see) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps, and services.
- Carry out any other purposes described to you at the time that we collected the information.
- EmbarQ, and certain third parties operating on or through our Services, may engage in targeted advertising. This form of advertising includes various parties and services providers, including third party data controllers, engaged in the processing of Personal Data in connection with advertising. These parties may be able to identify you across sites, devices, and over time.The parties that control the processing of Personal Data for behavioral advertising purposes may create or leverage information derived from personalization and profiling. In some cases, these parties may also develop and assess aspects of a profile about you to determine whether you are a type of person a company wants to advertise to, and determine whether and how ads you see are effective. These third parties may augment your profile with demographic and other Inference Data derived from these observations, and may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a purchase for a good or services you were shown in an advertisement.
We generally use targeted advertising for the purpose of marketing our Services, Products and third-party goods and services, to send marketing communications, including by creating custom marketing audiences on third-party websites (such as Facebook).
2.4 Legal Basis for Processing
If you are in a jurisdiction that requires a specific legal basis for processing personal data, our legal basis for collecting and using the information described above will depend on the type of information and the specific context in which we collect it.
- We process information about you in order to provide our services in accordance with our Terms and Conditions, for example, to allow you to join teams or to display your profile to other users; to allow us to send you important service updates.
- We also process information about you where it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Platform).
- Sometimes you provide us with sensitive information about you; for instance, the mere fact of joining a certain team may indicate information about your health, religion, political views, or sexual identity. Joining such groups or posting information on the Platform about these topics is entirely voluntary and, depending on the settings of the group and your profile (e.g., public or private), our legal basis for processing any sensitive information is either that you manifestly make it public or your explicit consent.
- In some cases, we may also have a legal obligation to process information about you, or may otherwise need the information to protect your vital interests or those of another person. For example, we may process information, if we believe doing so is required by, or in accordance with, applicable law, regulation, legal process, or audits.
3. Sharing Of Information
3.1 Through Our Platform
1) We share some of the information that we collect by displaying it on our Platform according to your member profile and account settings. You can choose the following Profile visibility types: Nobody/ Your team members only/Embarq users only/Everyone.
- Content about you can be shared or reshared by others.
You should consider who you choose to share with, because people who can see your activity on our Products can choose to share it with others on and off our Products, including people and businesses outside the audience you shared with.
- Information about your active status or presence on our Products.
Users may see signals telling them whether you are active on our Products, or when you last used our Products.
Information that is public on our Platform is visible to others on and off the Platform.
3.2 Within our family of companies.
In order to streamline certain business operations, improve EMBARQ, Service personalization and behavioral marketing, develop products and services that better meet the interests and needs of our customers, and promote information we believe will be of interest to you, we will share your Personal Data internally within our family of companies, as well as any other current or future affiliated entities, subsidiaries, and parent companies of RUNNING ON WAVES LTD.
3.3 With Our Service Providers
We may use service providers in connection with operating and improving the Platform to assist with certain business purposes, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, and some aspects of our technical and customer support. These service providers, which include data analytics providers, may access, process, and store information about you on our behalf for the purposes we authorize, subject to confidentiality obligations. In order to improve personalization, deliver more relevant advertisements, and develop better products and services, we may share some information about you with current or future affiliated entities and trusted third parties for marketing, advertising, or other commercial purposes, and we may allow third parties (such as Facebook and social media advertisers, ad exchanges, data management platforms, or ad servers) to operate on our Services and process data for targeted advertising.
3.4 Data aggregators
In connection with our marketing operations, and subject to Users’ rights and choices, we may share certain information about you with data aggregators for Commercial Purposes and in connection with Data Sales. These disclosures/sales can help better personalize our Services, the services of third parties, enrich Consumer Profiles and help ensure that you see advertisements that are more relevant to your interests.
3.5 Following The Law And Protecting EmbarQ
We may access, preserve, and disclose information about you to government entities and other third parties, including the content of messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms and Conditions or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, EmbarQ or others.
3.6 Social Sharing And Other Tools
The Platform may offer social sharing features and other integrated tools which let you share actions that you take on our Platform with third-party services, and vice versa. Such features let you share information with your friends or the public, depending on the settings you have chosen with the service. The third-party services' use of the information will be governed by the third-parties’ privacy policies, and we do not control the third parties’ use of the shared data. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please review the privacy policies of the services that provide these features.
3.7 Affiliate Sharing And Merger, Sale, Or Other Asset Transfers
If EmbarQ is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, information about you may be shared, sold, or transferred as part of that transaction. We may also share information about you with current or future corporate parents, subsidiaries, or affiliates.
3.8 Other Situations
We may also share information about you with your consent or at your direction or where we are legally entitled to do so. For example, your information may be shared with a shipowner when you apply for it having got ready for the cruise purchase.
4. Additional Details
4.1 Analytics and Advertising Services Provided by Others
4.2 International transfers of your Personal Data as part of our global services
We share information globally, both internally within EmbarQ, and externally with our partners and with those you connect and share with around the world in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in countries outside of where you live for the purposes as described in this policy. These data transfers are necessary to provide the services to you and to globally operate and provide our Products to you. We utilize standard contract clauses, rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to other countries.
You can obtain more information about the safeguards we put in place by contacting us.
We employ technical and organizational measures designed to protect your Personal information that is under our control and that we process on your behalf from unauthorized access, collection, use, disclosure, copying, modification, or disposal, both during transmission and once we receive it. For example, we store all information that you provide to us on servers on which security controls are used. We train employees regarding our data privacy policies and procedures, and authorize employees to access personal information as required for their role. We use firewalls designed to protect against intruders and test for network vulnerabilities. However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the security of your Personal Data when you transmit it to us, and any such transmission is at your own risk.
Where you have a password, which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential. You can update or change your password in your personal account.
4.4 Data Retention
We retain Personal Data for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.
4.5 Policy Scope
Users, including team captains are directly responsible for complying with all requirements of applicable privacy laws in connection with the information that they obtain and process.
4.6 Revisions To This Policy
Our Services are neither directed at nor intended for use by children under the age of 18. We do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it. Do not access or use the Services if you under the age of 18.
5. Your Choices
5.1 Your Choices: Account Information
You may update or correct your account information by editing your account settings or by sending a request to email@example.com as described in Section 6. You may delete your account in your Profile or by sending an email to firstname.lastname@example.org. Deleting will result in permanent erasure of your Profile without possibility of recovery. You will also be able to choose what information others see about you (including nobody) and who may contact you by using the Privacy Settings section in your Account.
5.2 Your Choices: Location Information
When you first access the Platform, depending on your device settings, we will collect information about your location, which we use to make better recommendations for groups and events in your area, and to improve our Platform. If you do not want us to collect information about your location, then you can prevent this by taking the following steps:
- If using a mobile app, by changing the settings on your device.
Note that our Platform or its features may no longer function properly if you change your settings.
Your mobile device settings may also give you the option to choose whether to allow us to view your geolocation on a continuous basis, only when using the app, or never. Allowing us to view your geolocation when you are not using the app allows us to provide you with recommendations on a regular basis. Please refer to your device’s guide for additional information on how to adjust location services.
5.3 Your Choices: Cookies
5.4 Your Choices: Promotional Communications
You can control some of the messages that you receive from EmbarQ by selecting the unsubscribe link in the message that you receive, or by adjusting the communication preferences in your account settings. If you opt out, we may still send you non-promotional messages, such as those about your account or our ongoing business relations.
5.5 Your Choices: Do-not-Track
5.6 Your Choices: Advertising
6. Data Rights
We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us with your request by sending an email to email@example.com
Rights that you may have, depending on the jurisdiction in which you live, may include:
- Accessing, correcting, updating, or requesting deletion of your information.
- Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.
- Opting out from receiving marketing communications that we send you at any time. You can exercise this right by selecting the “unsubscribe” or “opt-out” link in the marketing emails we send you. Additionally, you may update your email preferences by changing the settings in your account.
- Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
- Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority.
Note that EmbarQ is a controller of your information. Other members, such as team captains, may also act as controllers of your information. You should contact these members if you have any questions about how they use information that you have provided to them.
7. California Privacy Rights
California residents have certain rights to access and delete their personal information and to request transparency about our privacy practices. If you would like to access or delete your information, or otherwise exercise your rights under the CCPA, please see Section 6. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you for additional information. Consistent with California law, if you choose to exercise your rights, we will not charge you different prices or provide different quality of services for exercising your rights unless those differences are permitted by law. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
What Cookies Are. Cookies are small data files which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow us to recognize your device.
- EMBARQ ads: We partner with third party publishers, advertising networks and service providers to manage our ads on other sites. Our third party partners may set cookies on your device or use the technologies described below to gather information about your activities on the Platform and other sites and online services you use, in order to provide you with EMBARQ ads that match member profiles or interests. For example, if you visit our Platform and also use a social media platform, you may see an EMBARQ ad on those social media platforms.
- Third-party websites and apps: Our business partners may also choose to share information with EMBARQ from cookies set in their own websites' domains, whether or not you have an EMBARQ account or are logged in.
Duration of Cookies. Some cookies, known as "session cookies", will stay on your device only for as long as you are accessing our Platform. Others, known as "persistent cookies", are stored on your device for longer periods.
We may place cookies on your computer or device, and receive information stored in cookies, when you use or visit:
- EMBARQ sites and apps,
Cookies used by other parties in connection with EMBARQ
Use of Other Technologies. We may allow others to provide analytics services and serve advertisements on our behalf. In addition to the uses of cookies described above, these entities may use other methods, such as the technologies described below, to collect information about your use of the Platform and other websites and online services.
Pixels tags. Pixel tags (which are also called clear GIFs, web beacons, or pixels), are small pieces of code that can be embedded on websites and emails. Pixels tags may be used to learn how you interact with our site pages and emails, and this information helps us and our partners provide you with a more tailored experience.
Device Identifiers. A device identifier is a unique label can be used to identify a mobile device. Device identifiers may be used to track, analyze and improve the performance of the Platform and ads delivered.
Local storage. Local storage is an industry-standard technology that enables the storage and retrieval of data on a computer, mobile phone or other device. Local storage may be used to store member preferences on devices.
Cookies. Most devices and web browsers are set to accept cookies by default. If you prefer, you may be able to remove or reject cookies. You can learn more about how to block cookies by visiting allaboutcookies.org. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Platform.
Revisions to this Policy