Privacy Policy

1. Introduction

Welcome to EZCruising.com ("the Website"), operated by Distribute Digital Ltd ("we", "us", "our"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at ezcruising.com, including any other media form, media channel, mobile website, or mobile application related or connected thereto.

This policy has been prepared in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR), and all other applicable UK data protection legislation. Please read this Privacy Policy carefully. If you disagree with its terms, please discontinue use of our site.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last updated" date at the top of this policy. You are encouraged to review this Privacy Policy periodically to stay informed of updates.

2. Who We Are

Distribute Digital Ltd is the data controller responsible for your personal data collected through this website. Our registered address is Grosvenor House, 11 St Paul's Square, Birmingham, England, B3 1RB. You can contact our data protection team at privacy@ezcruising.com.

3. Information We Collect

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

3.1 Personal Data You Provide Voluntarily

When you subscribe to our newsletter, register an account, contact us, or fill in any form on the Website, you may provide us with:

• Name and email address (when subscribing to our newsletter)
• Contact information including name, email address, phone number, and message content (when contacting us)
• Subscription tier preference (Free, Standard, or Premium)
• Payment information (processed securely by our third-party payment processor; we do not store card details)
• Any other information you choose to provide in correspondence with us

3.2 Data Collected Automatically

When you visit the Website, certain information is collected automatically by our systems and third-party services:

• Log data: IP address, browser type and version, time zone, browser plug-in types, operating system and platform, and other technology on devices you use to access this website.
• Usage data: Information about how you use our website, including the pages you visit, the links you click, the time spent on pages, referral URLs, and navigation patterns.
• Device data: Information about the device you use to access the website, including device identifiers, hardware model, and operating system.
• Cookie data: Information stored via cookies and similar tracking technologies. See our Cookie Policy for full details.

3.3 Data from Third Parties

We may receive information about you from third parties, including:

• Google Analytics: We use Google Analytics to analyse website traffic and user behaviour. Google Analytics collects anonymised data about your use of our website. Google's privacy policy can be found at policies.google.com/privacy.
• Google AdSense: We use Google AdSense to display advertisements on our website. Google AdSense may use cookies and similar technologies to serve ads based on your prior visits to our website and other websites. Google's use of advertising cookies enables it and its partners to serve ads based on your visit to our site and/or other sites on the internet. You may opt out of personalised advertising by visiting Google Ad Settings. Alternatively, you can opt out at www.aboutads.info/choices/.
• Social media platforms: If you interact with our social media features or follow links to our social media pages, those platforms may provide us with information in accordance with their own privacy policies.

4. How We Use Your Information

Having accurate information permits us to provide you with a smooth, efficient, and customised experience. Specifically, we may use information collected about you to:

• Send you our newsletter, editorial updates, and content relevant to your subscription
• Process and manage your subscription, including billing and account management
• Respond to your enquiries, comments, and requests
• Analyse and improve our website, content, and services
• Personalise your experience on the website, including displaying relevant content and advertisements
• Serve personalised and non-personalised advertisements through Google AdSense and other advertising partners
• Monitor and analyse usage and trends to improve your experience with the website
• Detect, prevent, and address technical issues and fraudulent activity
• Comply with our legal obligations under UK and EU law
• Enforce our Terms of Use and other agreements
• Send administrative communications such as confirmations and updates to our policies

5. Legal Bases for Processing

Under UK GDPR, we must have a lawful basis for processing your personal data. We rely on the following legal bases:

• Consent (Article 6(1)(a)): Where you have given clear consent for us to process your data for a specific purpose, such as subscribing to our newsletter or accepting non-essential cookies.
• Contract (Article 6(1)(b)): Where processing is necessary for the performance of a contract with you, such as managing your subscription.
• Legitimate interests (Article 6(1)(f)): Where processing is necessary for our legitimate business interests, such as improving our website, preventing fraud, and direct marketing to existing customers, provided these interests are not overridden by your rights and interests.
• Legal obligation (Article 6(1)(c)): Where processing is necessary to comply with our legal obligations under UK law.

6. Google Services and Advertising

We participate in Google's advertising programmes. Specifically:

6.1 Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC, to help us understand how visitors use our site. Google Analytics uses cookies to collect information such as how often users visit the site, what pages they visit, and what other sites they used prior to coming to this site. We use this information to improve our website. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information.

Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. You can prevent Google Analytics from recognising you on return visits to this site by disabling cookies on your browser or by installing the Google Analytics Opt-out Browser Add-on.

6.2 Google AdSense

We use Google AdSense to display advertisements on our website. Google AdSense is an advertising service provided by Google LLC. Google AdSense uses "DART" cookies to serve ads to site visitors based upon their visit to ezcruising.com and other sites on the internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network Privacy Policy at policies.google.com/technologies/ads.

Third-party vendors, including Google, use cookies to serve ads based on a user's prior visits to our website or other websites. Google's use of advertising cookies enables it and its partners to serve ads to our users based on their visit to our sites and/or other sites on the internet. Users may opt out of personalised advertising by visiting Google Ad Settings.

7. Sharing of Your Information

We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties except as described below. We may share your information with:

• Service providers: Third-party companies who assist us in operating our website and providing our services (e.g. email service providers, hosting companies, analytics providers). These parties are contractually bound to keep your information confidential and secure.
• Advertising partners: Including Google AdSense, which may use cookies and web beacons to collect information about your browsing activities to provide targeted advertising.
• Legal authorities: If required to do so by law or in response to valid requests by public authorities (e.g. a court or government agency).
• Business transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

8. Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar tracking technologies on our website. For a full explanation of the types of cookies we use, how long they persist, and how to manage your preferences, please see our Cookie Policy.

In summary, we use the following categories of cookies:

• Strictly Necessary: Essential for the website to function correctly.
• Analytics & Performance: Help us understand how you use the website (e.g. Google Analytics).
• Marketing & Advertising: Used by us and our advertising partners (including Google AdSense) to show you relevant advertisements.
• Preferences: Remember your settings and choices to personalise your experience.

You can manage your cookie preferences at any time using our Cookie Preference Centre or by adjusting your browser settings.

9. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements. When determining the appropriate retention period, we consider:

• The amount, nature, and sensitivity of the personal data
• The potential risk of harm from unauthorised use or disclosure
• The purposes for which we process the data
• Whether we can achieve those purposes through other means
• The applicable legal requirements

Newsletter subscriber data is retained for the duration of your subscription plus 12 months following unsubscription. Contact form submissions are retained for 24 months. Analytics data is retained for 26 months. After the relevant period, data is securely deleted or anonymised.

10. International Data Transfers

Some of our service providers are based outside the UK or the European Economic Area (EEA). Where we transfer your personal data to a country that does not offer an equivalent level of data protection to the UK, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the Information Commissioner's Office (ICO) or the European Commission.

Google LLC is certified under the EU-US Data Privacy Framework and transfers data to the United States under appropriate legal mechanisms. For more information, see Google's privacy policy.

11. Your Rights Under UK GDPR

Under UK data protection law, you have the following rights regarding your personal data:

• Right of access: You have the right to request a copy of the personal data we hold about you (a Subject Access Request).
• Right to rectification: You have the right to ask us to correct inaccurate or incomplete data.
• Right to erasure ("right to be forgotten"): You can ask us to delete your personal data in certain circumstances.
• Right to restrict processing: You have the right to ask us to restrict how we process your data in certain circumstances.
• Right to data portability: You have the right to receive your data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to certain types of processing, including direct marketing and processing based on legitimate interests.
• Rights related to automated decision-making: You have the right not to be subject to decisions made solely by automated processes, where such decisions have legal or similarly significant effects on you.
• Right to withdraw consent: Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of processing based on consent before withdrawal.

To exercise any of these rights, please contact us at privacy@ezcruising.com. We will respond within one calendar month. We may need to verify your identity before processing your request.

12. Right to Complain

If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Helpline: 0303 123 1113
• Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We would, however, appreciate the opportunity to address your concerns before you contact the ICO, so please contact us first.

13. Security of Your Information

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

Any information disclosed online is vulnerable to interception and misuse by unauthorised parties. Therefore, we cannot guarantee complete security if you provide personal information.

14. Children's Privacy

Our website is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe that your child has provided us with personal data, please contact us at privacy@ezcruising.com and we will delete such information from our records.

15. Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies before providing any personal data. This Privacy Policy applies only to information collected by our website.

16. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by a revised "Last updated" date. If we make material changes to this policy, we may notify you either through the email address you provided or by prominently posting a notice on our website. We encourage you to review this Privacy Policy regularly.

17. Contact Us

If you have questions or comments about this Privacy Policy, or if you wish to exercise your data protection rights, please contact us:

• Email: privacy@ezcruising.com
• General enquiries: info@ezcruising.com
• Post: Data Protection Officer, Distribute Digital Ltd, Grosvenor House, 11 St Paul's Square, Birmingham, England, B3 1RB