Privacy Policy

Compagnie du Ponant whose registered office is at 408 Avenue du Prado 13008 Marseille, France (hereinafter referred to as the “Compagnie”, “we”, “us” and “our”), operates cruises in Australia. Paspaley Pearl By Ponant is being operated for Compagnie and all information provided to Paspaley Pearl By Ponant is for the benefit of Compagnie.

Compagnie is committed to complying with its obligations under the Privacy Act 1988 (Cth) (the Act).

In this Privacy Policy, we set out how we manage your personal information. You should also refer to Compagnie‘s passage terms and conditions for further details on some of the personal information we may need to collect, use or disclose as part of your cruise.

By providing your personal information to us, you consent to our collection, holding, use, and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that may apply between us.

1. Information collected and held

In the process of conducting its operations and its business, Compagnie will collect and hold a range of personal information. The type of information we collect and hold includes (but not limited to):

1. Name;
2. Address;
3. Email address;
4. Phone numbers;
5. Birth date;
6. Nationality;
7. Identification documents (Passport and Drivers Licence);
8. Emergency contact information;
9. Payment information;
10. Information relating to your health and dietary requirements;
11. Proposed travel and tour arrangement, including cruise preference;
12. Photographs and CCTV footage from public areas.

You have the option of not identifying yourself or using a pseudonym when dealing with us in relation to a particular matter. However, if you do this or if you do not provide, or if we do not collect, your personal information then we may not be able to provide you with our services.

We take all reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, unauthorised modification or unauthorised disclosure. We will keep your personal information secure and it will be held by us in our customer database in accordance with the Act. We will only release your personal information if you authorise us to do this or if we are legally required to do so.

2. Method of collecting information

We may collect personal information about you in a variety of ways including when you:

1. Deal with us in person;
2. Contact us over the phone;
3. Send us correspondence (by letter, email or fax);
4. Visit our web sites.

As far as it is reasonable or practicable, we will collect your personal information directly from you. If it is not reasonable or practicable and personal information is collected from someone else (e.g. a travel agent or another person booking on your behalf), we will take reasonable steps to ensure that you are made aware of the collection of your personal information, unless specific exemptions apply. Sensitive information will only be collected with your consent, unless specific legislative exemptions apply.

If we receive personal information which we did not solicit and we determine within a reasonable period of time that we could not have otherwise collected the personal information, where lawful or reasonable to do so, we will destroy the information or ensure that the information is de-identified as soon as practicable.

3. Use of information

We will not collect personal information or sensitive information unless it is reasonably necessary for one or more of our core business functions or a related activity or it is permitted under Australian law.

Compagnie will collect, hold, use and disclose your personal information for the following purposes:

1. To facilitate the booking and ticket purchase and provision of services on board our vessels;
2. For the conclusion, administration and performance of the contractual relations between you and Compagnie;
3. Respond to an individual’s enquiry or request for information or resolve a compliant
4. Improve and personalise your experience with us, such as customised offers, customer loyalty and commercial information campaigns, satisfaction surveys, contests, new services and products to improve your customer experience;
5. Subscribing or unsubscribing to newsletters, media releases or other communication;
6. Advertising targeting purposes on our website or third-party website;
7. Promotional activities by the Compagnie (for instance email, sms, phone call, etc.)
8. Provide you with the necessary medical assistance during the cruise;
9. Enforce legal and regulatory obligations, and national, community and international standards arising from the provisions established by authorities duly authorised for these purposes by law;
10. Warrant the protection of goods and persons;
11. Obey the requirements of CLIA organisms, (ISPS ISM code), SNEAS (domestic security code).
12. Assessing an applicant’s suitability for employment with us;
13. Investigate a breach of any of our terms and conditions or any suspected unlawful activity.

Direct marketing communications will contain an ‘unsubscribe’ link that provides individuals with the opportunity to opt out of direct marketing communications. In other circumstances, individuals who do not wish to receive direct marketing communications from Compagnie may contact us to opt out (see our contact details below).

4. Disclosure of information

Compagnie may disclose personal information for the purposes described in this Privacy Policy to:

1. Compagnie‘s employees, officers, directors, agents, contractors
2. Third party suppliers or service providers
3. Our professional advisers (including our accountants, legal advisers and auditors)
4. Our insurers
5. Payment systems operators (e.g. banks or merchants receiving card payments)
6. Any person to whom we are required or permitted by law to disclose personal information. This may include the Australian Police or Government departments or regulators within Australia in connection with law enforcement activities and emergency services.

When you provide your personal information to us, you consent to the disclosure of your personal information outside of Australia and acknowledge that, in doing so, we will not be accountable under the Act for the treatment of that personal information by the overseas recipients. Any party to whom we disclose information may not be subject to regulation which has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the Australian Privacy Principles protect the information and you may have no or no similar privacy protection in the country where the overseas entity is located.

However, we will take reasonable steps that are reasonable in the circumstances to ensure that any overseas recipient will deal with such personal information in a way that is substantially similar to or consistent with the way in which the relevant Australian Privacy Principles in the Act protects such personal information.

Our website (https://paspaleypearlbyponant.com.au/) may contain links to other websites. We recommend that you review the privacy policies of those websites so that you can understand their privacy practices. Compagnie is not responsible for the privacy practices of, or the content on, those websites. This Privacy Policy does not extend to those websites.

5. Access to and correct of information

Individuals have the right to request access to and correct personal information we hold about them, subject to exceptions listed in the Act. Upon request, and within the parameters of the legislation, we will provide individuals with access to this information.

To protect the integrity and security of the information we hold, we may ask that  you follow a defined access procedure, which may include steps to verify your identity. In certain cases we may charge you an administration fee for providing you with access to the information you have asked for, but we will inform you of this before proceeding.

There may  be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases we will let you know why we cannot comply with your request.

We will take reasonable steps to update the personal information we hold if the information is accurate, up-to-date and complete. You may contact us to update or correct your personal information or if you believe that any information we hold on you is irrelevant or misleading, (see contact details below). Please include your name, address and/or email address when you contact us. You will not be charged for a correction request. We rely in part upon customers advising us when their personal information changes. We will respond to any request within a reasonable time. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date.

6. Complaints

If you have a question about this Privacy Policy or wish to make a complaint about the way we have collected, used, held or disclosed your personal information, please contact us at the address below. We may need to contact you for further details.

Our Privacy Officer will deal with the matter within a reasonable time, and will keep you informed of the progress of our investigation. If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns.

You are also entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC). You can obtain further general information about your privacy rights and privacy law from the OAIC by:

• calling their Privacy Hotline on 1300 363 992
• visiting their web site at http://www.oaic.gov.au
• writing to:

The Australian Information Commissioner
GPO Box 5218
Sydney NSW 1042

7. Contact us

Compagnie du Ponant Pty Ltd
Att: Privacy Officer
Address: Lower ground floor, 165 Walker Street, North Sydney, 2060 Australia

Email: vieprivee@ponant.com

8. Changes to this Privacy Policy

Compagnie may revise this Privacy Policy from time to time either by posting the revised Privacy Policy on the Paspaley Pearl By Ponant website or by other written notification to you. Any changes to this Privacy Policy takes effect upon the earlier of the revised Privacy Policy being posted on the website.

9. For Customers in the EU

If you are located in the EU, please see our EU Personal Data Protection policy: https://www.calameo.com/read/00013242389943daa197a?authid=Iff8CnoCVGF6