My Account The Leader in Enriching Cultural Experiences since 1958 Grand Circle LLC – Privacy Policy Last Updated: October 31, 2018 Grand Circle is constantly striving to provide excellent service to you while building a long-lasting relationship. To achieve these goals, we occasionally need information supplied by you when you visit our website. We value your privacy and protect your personal information as described in greater detail below. Before submitting your personal information to our website, please read this policy carefully to learn about our privacy practices, keeping in mind these two important points about our commitment to you: We do not share your personal information, except in order to provide services and information to you, or as required by law. Grand Circle does not partner with third-party advertisers. Your personal information is shared only with our own affiliated companies and with vendors in order to deliver information and services to you, except in very special circumstances (such as legal proceedings) as described below. We are committed to protecting your personal information. We have put in place procedures designed to keep your information protected, including using encryption technology to process financial information. In order to use Grand Circle's websites, www.gct.com, www.oattravel.com and www.grandcirclefoundation.org you must accept the practices described herein. If you do not agree with these terms, you will not be permitted to explore our website further. What information we collect from you What is Personal Information “Personal information” is information that can be used to identify you, directly or indirectly, alone or together with other information. Personal Information may include, but is not limited to, your name, address, telephone number, email address, company affiliation and title, and payment information (such as credit card numbers), collected on a voluntary basis. For example, we collect personal information through the establishment of a “My Planner” and in connection with payments made through this Website. Personal information does not include data where the identify has been removed (anonymous data). Certain information may not be personally identifiable when standing alone In general. Grand Circle may collect personal information such as names, company names, titles, addresses, telephone numbers, fax numbers, e-mail addresses, and payment information (such as credit card numbers) from users on a voluntary basis. For example, we collect personal information through the establishment of a “My Planner” and in connection with payments made through this Website. Information of a non-personal nature. Grand Circle automatically collects some information about your computer when you visit www.gct.com and www.oattravel.com. In addition to personal information, Grand Circle may also gather non-personally identifiable information, which may be used by Grand Circle. Generally, “non-personally identifiable information” means information that is collected by automatic or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. As you use our website, your browser and devices communicate with servers operated by us, our business partners and service providers to coordinate and record the interactivity and fill your requests for services and information. Our websites actively log and record information of a non-personal nature such as referral websites, visits, length of sessions, domains, browser software and more. We aggregate and use this non-personal data to improve our website experience for you. We also record the IP address of the computers that visit our website. We also may collect information about your online activity, such as content viewed and pages visited. One of our goals in collecting this automatic information is to help us understand the interests of our travelers and customize your user experience. Cookies and other web technologies. Grand Circle uses an email delivery and marketing company to send emails. Pixel tags and cookies are used in those email messages and at our websites to help us maximize the effectiveness of our marketing and our websites. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences and your use of our websites. Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. The data on your use of our site may be linked to the personal Information you have chosen to share with us when you register. We use cookies to store visitor preferences, record session information, record user-specific information on what pages users access or visit, alert visitors to new areas that we think might be of interest to them when they return to our site, or record past activity at a site in order to provide better service when visitors return to our site. Most internet browsers automatically accept cookies. However, you can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the sites you visit. If you decide not to accept our cookies, your ability to use some features on our site may be impaired. Certain visitors to our site may have previously received targeted promotional materials relative to the site. How we use your information Grand Circle does not sell or rent your personal information. Any information that you voluntarily submit may be used by us to provide you with enhanced services such as providing you with products and services that you may have requested. We have the utmost respect for your privacy and security. Grand Circle uses the information we collect about you for the following general purposes: For registration and to manage your account, including to facilitate your access to and use of our site To improve the content of our websites To customize the content and/or layout of our page for each individual visitor To process payments and information requests To communicate with you To enable us to publish your reviews, forum posts, and other content to the Grand Circle community To respond to your questions and comments To measure interest in and improve our products, services, and website To notify you about special offers and products or services available from us that may be of interest to you To solicit information from you, including through surveys To resolve disputes or troubleshoot problems For other administrative and analytical purposes such as information systems management, accounting, billing and audits, marketing, customer-relations correspondence, and/or operation of frequent traveler programs To comply with our legal obligations, including responding to subpoenas or when ordered by a court or other government authority With your consent With whom we share your information Grand Circle may contract with third parties to process payments and information requests, and these parties would have access to personal information in fulfilling their duties. We also may share your personal information with our affiliated companies in connection with delivering services and information to you and with other parties in connection with the arrangement of travel services, such as hotels and providers of transportation. We also may share your personal information with the Grand Circle Foundation. The information we collect is not shared with other organizations for commercial purposes. Your privacy is important to us. Any information that we collect online or via the telephone is done to provide you with the best website experience and service possible. We reserve the right to disclose personal information as we determine may be required by law or governmental authorities. We also reserve the right to sell, license, or otherwise transfer to a third party, personal information in connection with an assignment, sale, joint venture, or other transfer or disposition of a portion or all of the assets or ownership interests of Grand Circle LLC or its affiliated entities. Subject to the foregoing, we do not sell your personal information. When you voluntarily disclose information about yourself in the content that you submit to this website (e.g., personal information such as your name, phone number and personal web address) through a Traveler Review or other public posting on the website, this information will be publicly available, can be collected and used by third parties and may result in unsolicited messages from others. Such activities are beyond our control. Please refrain from disclosing personal information on this website that you intend to keep private. Please also note that by submitting a Traveler Review or other public posting on this website, it becomes the property of Grand Circle LLC, and we may reproduce some or all of it in our promotional materials—either elsewhere on our website, our social media, in an email, or in our catalogs. You also authorize us to disclose your last name, hometown and state, and travel history with us in connection with the review. Social media services. You can choose to access certain third party social media websites and services through our site (such as Facebook). When you do so, you are sharing information with those sites, and the information you share will be governed by their privacy policies. You may also be able to modify your privacy settings with these third party social media websites. Email communications. Grand Circle wants to make it easy for you to take advantage of travel-related opportunities on our websites. One way we do this is by sending you e-mail messages that contain information about your apparent travel-related interests. We believe these email messages will provide you with useful information about travel-related special offers available through our sites. If you do not want to receive email from us in the future, please let us know by sending us email at the below address, calling us at the below telephone number, or writing to us at the below postal address. We reserve the right to send you occasional service-related emails about your account even if you voluntarily opt-out of email notifications. If you supply us with your postal address on-line, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by calling us at the number provided below, emailing us at the below address, or writing to us at the below postal address. To be removed from our mailing list, please provide us with your exact name and address. Third-party advertising. Grand Circle does not partner with or have special relationships with any third-party advertisers or ad server companies. International Data Transfers (EU/EAA, UK and Other Applicable Jurisdictions). Although Grand Circle is headquartered in the United States, it has affiliated entities throughout the world. In the order to perform our contractual obligations with you, if any, as well as for operational and other legitimate interests, we may process, store and transfer Personal Information in a country which may be outside of your own, such as the United States. By providing us with your Personal Information, you acknowledge such transfer of information out of your jurisdiction. By using our services, you also understand that your information may be transferred to our affiliated entities and those third parties with whom we share it as described in this Policy. If you do not wish for certain Personal Information to be so transferred, please do not provide your Personal Information to us and/or take such steps described herein to prevent the collection of your Personal Information. Please note in that if you choose not to share Personal Information with us, we may be unable to provide services to you. If you have any questions, please contact Grand Circle. How we protect your information Although no website can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures appropriate to the risk for our use of Personal Data, taking into account the state of the art, the costs of implementation, the nature, scope, context and purposes of processing in order to help protect the personal information you provide to us from being lost, used or accessed in an unauthorized way, altered or disclosed, and to maintain its accuracy and integrity. For example, we use encryption when transmitting your personal financial information between your system and ours. For Personal Information of EU/EEA and UK Residents, we also take into account the risk of varying likelihood and severity for the rights and freedoms of natural persons. Children's privacy Grand Circle does not knowingly collect personal identifiable information from children under the age of 18. If you are under the age of 18, please do not provide your name and address or other contact details or any other personally identifiable information of any kind whatsoever. If you are a parent or guardian of someone under the age of 18 who has provided us information without your knowledge and consent, you may request that we remove this information by contacting us at the below address or phone number. External links This website contains links to other websites. We are not responsible for the privacy practices of other websites. This privacy policy applies solely to information collected by Grand Circle LLC and its affiliates. We recommend that you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information. Minimization, Retention, And Deletion Of Personal Information To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, the purposes for which you process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your date. At your request, when we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. EU/EEA and UK Specific Clauses Lawful Basis for Processing (EU/EEA; UK) Regardless of your jurisdiction, we will only use your Personal Information when the law allows us to. That said, if you are a resident of the EU/EEA or the United Kingdom, our lawful basis for collecting and using your Personal Information will depend on the Personal Information concerned and the specific context in which we collect it. Generally, we will not collect or access any Personal Information other than under the following circumstances: Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third Party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal, regulatory, or self-regulatory obligation. We may also collect or access Personal Information with your consent. What we mean by legitimate interests is the interest of our business in conducting, managing, and growing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need additional details about the specific legal ground we are relying on to process your personal data. Where we rely upon your consent to process the Personal Information, you have the right to withdraw or decline your consent at any time. You may withdraw consent to marketing at any time by contacting us at address or telephone number below. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal. If you decide not to provide information required by us, your use and our provision of services may be limited or impossible to facilitate. Your Data Subject Rights (EU/EEA and UK) Under certain circumstances you have rights under applicable data protection laws with respect to Personal Information we knowingly collected> Choice Request access to your personal data Request correction of your personal data Request erasure of your personal data Object to processing of your personal data Request restriction of processing your personal data Request transfer of your personal data Right to withdraw consent We will try to comply with any of these requests pertaining to your Personal Information in accordance with applicable law. Please recognize that we may in certain circumstances be unable to provide the access or information sought, or correction or deletion requested. For example, we may be unable to fulfill a request if it requires us to release commercial confidential information, the disclosure of Personal Information relating to another person that is not the requestor or would result in impracticability, excessive redundancy, and/or unique burden or expense to Grand Circle. We may need to verify your identity before acting on your request. 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 also contact you to ask you for further information in relation to your request in order to aid our response. You will not have to pay a fee to access your Personal Information (or to exercise any 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. 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. If you wish to exercise any of the rights set out above, please contact our privacy manager at the address below. Terms and modifications to this privacy statement We will occasionally update this Privacy Policy. When we do, we will revise the “last updated” date at the top of the Privacy Policy. You are responsible for periodically reviewing this Privacy Policy for updates to its terms. How you can contact us If you have questions about this privacy policy, or if you believe that this site is not following its stated Privacy Policy, please contact us at: privacy@oattravel.com Grand Circle LLC 347 Congress Street Boston MA 02210 Reach us by telephone at (800) 321-2835. ©2018 Grand Circle LLC. All rights reserved. Call our Travel Counselors 1-800-221-2610 CONTACT US People & Culture Reservations & Customer Service Frequently Asked Questions About Us Media Inquiries Traveler Photo Contest Career Opportunities GCT Store Overseas Adventure Travel FIND US ON FACEBOOK Grand Circle Cruise Line Grand Circle Travel © 2020 Grand Circle Travel347 Congress St. • Boston, MA 02210 Terms & Conditions Privacy Policy Terms of Use Special Needs