- Our privacy commitment to you
- Who we are
- What Personal Data do we collect about you?
- Third party Personal Data we collect
- How is your Personal Data collected?
- If you fail to provide Personal Data
- How we use your Personal Data
- Purposes for which we will use your Personal Data
- Keeping your data safe
- When we have to share your details
- International Transfers
- Your personal details when you book through a travel agent
- How long will you use my Personal Data for?
- How is information stored and processed?
- No fee usually required
- What we may need from you
- Time limit to respond
- Analytics and Targeted Advertising
- Third-party links
- Social Media Sites
- Payments and Financial Data/Credit Card Information Security
- Site Security
- Contact details
- Tailoring your communications
- Making a complaint
Our privacy commitment to you
Why you should read this
We are committed to looking after the data you have given us, making sure it's used responsibly, and that it is only shared in the ways you expect. Your personal details are in safe hands: we will only use them for the purposes of providing our travel-related products and services ('services') to you, to improve the services we offer, and to provide you with our latest news and updates. We will never share your personal details with other companies for marketing purposes unless you've given us explicit permission.
Who we are
It's important that you know who actually holds your Personal Data.
The "Globus family of brands" operate in the United States, United Kingdom, Australia, New Zealand, Canada, India and other Globus family of brands offices globally. Cosmos is a trading name of Cosmos Tours Ltd., and Cosmos Tours Ltd ('Cosmos', 'we', 'us' or 'our') comprises the Avalon Waterways, Globus and Cosmos brands. This Website is owned, managed and operated by the Globus family of brands. We hold your Personal Data on behalf of all of our trading entities (and represent the 'data controller' for the purposes of relevant data protection law). Cosmos Tours Ltd is part of the Globus family of brands, an international group of companies providing escorted tours, vacation packages and river cruises to guests around the world.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
"Disclose" means to release, transfer, disseminate, or otherwise communicate all or any part of any record orally, in writing, or by electronic or any other means to any person or entity.
"User" means an individual who has registered or who has provided personal data with the application.
"Minor" means any individual under 18 years of age, or as defined under the laws of their jurisdiction or residence, including the Children’s Online Privacy Protection Act (COPPA) in the US and Article 8 of the GPDR in the EU and UK.
"Personal Data" means any recorded information about a specific individual whose identity may be inferred from the information. This information includes, for example, name, e-mail and mailing address, phone number, account and billing information, and other information provided by a user of the application or incidental to providing products and services to you.
"Application" means CosmosGO, AvalonGO, GlobusGO or MonogramsGO mobile app, and any domestic or internationally-owned or managed Website of the Globus family of brands that may be accessed through it. This includes on-trip service and provided devices.
"We", "Us" or "Our" means “Globus family of brands” in the United States, United Kingdom, Australia, New Zealand, Canada, India or other Globus family of brands operating offices globally.
What Personal Data do we collect about you?
Personal Data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymized data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, and marital status, and title, date of birth, gender and passport information.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes payment card details.
- Employment Data includes information that you may provide on a job application to us.
- Special Categories of Personal Data (or sensitive Personal Data) may include any relevant information about your health, medical conditions and/or disabilities, religious beliefs, dietary or other requirements (if applicable).
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Websites.
- Profile Data includes purchases made by you, your interests, preferences, and feedback and survey responses.
- Usage Data includes information about how you use our Website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not sell or market products to Minors. Minors are not eligible to register with, use or purchase services via the Website. We do not knowingly collect Personal Data from any Minor, and will not deliberately use such information. Generally, if you are under 18, you may use the Website only with the involvement of a parent or guardian. Our policy regarding minors encompasses compliance with particular laws in the United States, United Kingdom, Australia, New Zealand, Canada and India. We respect the privacy of minors, and are committed to complying with COPPPA in the US. We do not intentionally collect Personal Data from children under the age of thirteen (13) and you may not register or transact on the Website if you are under 13. If we learn that a child under 13 has provided Personal Data to us without verification of parental consent, we will take commercially reasonable steps to delete that information. If you are under the age of sixteen (16) and reside in the European Union, you must provide an email address for your parent or legal guardian, and before you can access or use the Website, we must receive your parent’s or legal guardian’s express consent. You will not receive access or the ability to use the Website and we will not collect additional Personal Data from you, until we receive your parent’s or legal guardian’s consent. Your parent or legal guardian may revoke consent at any time and we will take reasonable steps to delete all Personal Data collected from you. We will also provide your parent or legal guardian with the ability to request to review your Personal Data, prohibit further collection of your Personal Data, and delete, or instruct the deletion of your Personal Data.
Third party Personal Data that we collect
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a trip and related services). In this case, we may have to cancel the services you have booked with us (and our standard cancellation terms will apply) but we will notify you if this is the case at the time.
How we use your Personal Data
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in 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 or regulatory obligation;
- In the case of Special Categories of Personal Data, where you have provided your explicit consent to such processing of that data. You have the right to withdraw your consent to such processing at any time, but please be aware that this may mean that we are unable to provide some or all of the services that you have booked with us (and our standard cancellation terms will apply); or
- Where we wish to send direct marketing communications to you via email, text message, telephone or mail/post where you have provided your explicit consent to such processing of your data. You have the right to withdraw consent to such marketing at any time by contacting us.
Purposes for which we will use your Personal Data
Information about our guests is an important part of our business, and we are not in the business of selling it to others. We will only share your Personal Data with our authorized service providers that perform services or functions on our behalf.
We do not sell or market products to Minors. Minors are not eligible to register with, use or purchase services via the Website. We do not knowingly collect Personal Data from any Minor, and will not deliberately use such information. If you are under 18, you may use the Website only with the involvement of a parent or guardian.
We have set out, in a table format (PDF) below, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your Personal Data on the basis of more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data.
Keeping your data safe
We promise we’ll do all we can to keep your data safe. We will store your data securely, encrypt it when we share it, and only hold it for as long as we need to. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
When we have to share your details
So that we can meet our obligations to you, such as send you a brochure you’ve requested, a trip quote, or provide the trip you’ve booked, we will pass your personal details onto our suppliers as we need to. This allows them to meet your requests, ensure you have a hassle-free trip, and that they can get in touch if you need assistance.
Some of these suppliers will be outside the United States, United Kingdom, Australia, New Zealand, Canada, India and European Economic Area (‘EEA’). We require all of our suppliers outside the US, Canada and EEA to work to the same data standards we do, and a full list of our suppliers online can be provided.
In addition, we may also share your Personal Data with the following third parties in the following circumstances:
- With third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy notice.
- If we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request;
- To enforce or apply the Terms and Conditions or to investigate potential breaches; and/or
- To protect the rights, property or safety of Globus family of brands and Cosmos, our guests or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
Many of our external third parties are based outside the United States, United Kingdom, Australia, New Zealand, Canada and India and European Economic Area (EEA), and so their processing of your Personal Data will involve a transfer of data outside the United States, United Kingdom, Australia, New Zealand, Canada and India and EEA. Organizations that are based outside of the United States, United Kingdom, Australia, New Zealand, Canada and India and EEA may not be subject to data protection laws which offer the same rights and protections to you as is the case within the United States, United Kingdom, Australia, New Zealand, Canada and India and the EEA.
Therefore, wherever we transfer your Personal Data out of the United States, United Kingdom, Australia, New Zealand, Canada and India and EEA, we take reasonable steps as required by applicable laws and regulations to safeguard your Personal Data, including using specific contracts and contractual language for service providers. For further details, please see information regarding the CCPA in the United States, Canadian Privacy Laws, Australian Privacy Principles, New Zealand Privacy Act, UK General Data Protection Regulations and the GDPR within the EU..
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the United States, United Kingdom, Australia, New Zealand, Canada and India and EEA.
Your personal details when you book through a reseller
How long will you use my Personal Data for?
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your Personal Data can be provided. For further information, please contact us.
How is information stored and processed?
Personal Data collected on our Website, or received by us from you or third parties, may be stored and processed in the US or any other country where we or our service providers maintain facilities.
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights set out above). 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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). 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 to speed up our response.
Time limit to respond
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 and keep you updated.
Analytics and Targeted Advertising
We, as well as third-party vendors acting on our behalf (such as Google or Facebook), may use first-party cookies (such as the Google Analytics cookies), tracking pixels, and scripting techniques and third-party cookies, tracking pixels, and scripting techniques to gather anonymous analytics and statistics about our services and how they are being used by our visitors so we can improve our services. Our web server storage logs may collect the domain names, internet protocol addresses, the types of web browsers, and certain data of visitors to the Website.
Data about your activities online may be collected for use in providing advertising tailored to your individual interests, either by us, our affiliates, or third parties. We may work with third parties such as network advertisers and ad exchanges to serve advertisements across the internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party Websites and viewing of ads and of our content.
We and these third-party vendors, including Google, may use third-party technologies (such as a Facebook Custom Audience Pixel) together with our own first party technologies in order to analyze ad impressions, your use of ad services, and interactions with these ad impressions and ad services. The information collected may also include information about your visits to our Website, including the pages you have viewed and what content you have seen. These third-party tracking technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the effectiveness of the advertisements that have been delivered to you.
You can opt out of certain advertising by visiting the Network Advertising Initiative consumer opt out page at http://optout.networkadvertising.org/, by using the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout, or by visiting the Digital Advertising Alliance's opt-out page at https://www.aboutads.info/choices. For more information on the privacy practices of Google, please visit Google's Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Please note, at this time we do not respond to browser based “do not track” signals.
Our Website may include links to third-party Websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every Website you visit.
Social Media Sites
When you interact with an account on or through a social media platforms, such as Facebook, YouTube, Pinterest, Instagram, or Travel Blog, we collect the Personal Data that you make available to us on that page or account, including your user ID and/or username, and any information you have made public in connection with that social media service. Please note, however, that we will comply with the privacy policies of the corresponding social media platform and we will only collect and store such Personal Data that we are permitted to collect by these social media platforms.
Our Website includes social media widgets, such as Facebook, YouTube, Pinterest, Instagram, and Travel Blog widgets. These features collect information about your IP address and which page you’re visiting on our Website, and they set a cookie to make sure their features function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with those features are governed by the privacy policies of the companies that provide them.
Payments and Financial Data/Credit Card Information Security
We use 3DES encryption and the https security protocol to communicate with your browser software. This method is the industry standard security protocol, which makes it extremely difficult for anyone else to intercept the credit card information you send to us. Companies we work with to process credit card transactions also use 3DES encryption and security protocols. We collect credit card information solely to complete a single transaction. We do not store complete credit card information.
We utilize email tracking systems that provide us with data such as who opened or forwarded an email, the time it was opened, and whether the reader clicked certain links within the email.
What is a cookie?
A cookie is a small text file, which often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a "device") browser from a website's computer and is stored on your device's hard drive. There are various types of cookies which perform different functions, such as remembering which items you have placed in your shopping basket or recording your browsing habits. The information recorded by the cookie is retrieved on your next visit to our sites. For more information about cookies, visit www.aboutcookies.org
The cookies we use don't detect any information – including personal information such as credit/ debit card details that you may have stored on your computer. Cookies cannot harm your computer or access information saved on your hard drive.
We use a number of cookies on websites for a variety of reasons. Some cookies are essential to be able to provide our services to you, such as purchasing a holiday. Others help us provide a better service to you, such as providing you with relevant prices and offers through our marketing activity, or allowing you to share holidays through social media channels.
We currently use the following types of cookies on our sites.
Strictly necessary cookies: these cookies are essential to allow you to fully use our website and its full features, such as buying a holiday. These cookies do not gather information about you that could be used for marketing.
Performance cookies: these cookies collect information about how our visitors use our website, to help us understand what sections of our site are popular, and help us fix errors on any of our web pages.
Marketing and targeting cookies: these collect information about your browsing habits and are placed by third-party providers and ourselves. The information in these cookies is anonymized but they contain a unique key that is able to distinguish individual browsing habits, or if an individual user has clicked on an advert we have placed. We use these cookies to understand if our marketing is effective, and if our recommendations for you are a good fit. We use the following third-party cookies to do this: Doubleclick, Google Adwords, Facebook, Adalyser, Impact and Bing.
How to manage cookies
Most web browsers will accept cookies, but if you would rather that we did not collect data in this way you can choose to accept all or some or reject cookies in your browser's privacy settings. Rejecting all cookies means that certain features cannot be provided to you - for example, you may not be able to book a holiday on our website. Each browser is different, so check the 'Help' menu of your browser to learn how to change your cookie preferences.
How to check cookies are enabled on a PC
1. Click on 'Tools' at the top of your browser window and select Options
2. Click the 'Under the Hood' tab, locate the 'Privacy' section, and select the 'Content settings' button
3. Now select 'Allow local data to be set'
Microsoft Internet Explorer
1. Click on 'Tools' at the top of your browser window and select 'Internet options', then click on the 'Privacy' tab
2. Ensure that your Privacy level is set to Medium or below, which will enable cookies in your browser
3. Settings above Medium will disable cookies
1. Click on 'Tools' at the top of your browser window and select Options
2. Then select the Privacy icon
3. Click on Cookies, then select 'allow sites to set cookies'
1. Click on the Cog icon at the top of your browser window and select the 'Preferences' option
2. Click on 'Security', check the option that says 'Block third-party and advertising cookies'
3. Click 'Save'
How to check cookies are enabled on a Mac
1. Click on 'Chrome' at the top of your browser window and select 'Preferences' options
2. Click the 'Under the Hood' tab, locate the 'Privacy' section, and select the 'Content settings' button
3. Now select 'Allow local data to be set'
1. Click on 'Safari' at the top of your browser window and select the 'Preferences' option
2. Click on 'Security' then 'Accept cookies'
3. Select the 'Only from site you navigate to'
1. Click on 'Firefox' at the top of your browser window and select 'Preferences' options
2. Then select the Privacy icon
3. Now select 'Accept cookies from sites'
Microsoft Internet Explorer 5.0 on OSX
1. Click on 'Explorer' at the top of your browser window and select 'Preferences' options
2. Scroll down until you see 'Cookies' under Receiving Files
3. Select the 'Never Ask' option
Our website is 100% secure. All of the personal information you give us is protected by a secure server. The secure server software SSL (Secure Socket Layer) encrypts all information you enter before it is sent to us. The information is only de-encrypted when it reaches our server.
We also have a ‘Firewall’ in place to protect our internal information from the Internet. If you make payment on-line all of your personal information is encrypted using SSL ("Secure Sockets Layer"). SSL is an industry-standard protocol for encryption over the internet. This prevents your personal information from being read by anyone else. This security layer is 128bit encrypted and protects your personal information from unauthorized access and malicious attack.
Postal address: Avalon House Lower Mortlake Road, Richmond Surrey TW9 2JY
Email address: email@example.com
Telephone number: 0208 315 4500
Tailoring your communications
We always want our communications to be relevant, useful and inspiring, to help you choose your next dream trip.
That’s why we ask you up-front if and how you’d like to receive marketing information from us. We know you don’t like receiving unwanted mail or emails, and we don’t want to send them either.
We will get your consent before we send you direct marketing by email, text message, post or telephone and before we share your Personal Data with any company outside the Globus family of brands for marketing purposes.
We also use the information you have provided and that we collect about you, such as the destinations you prefer to travel to, where you live and your age, to tailor communications we send you. We do this to ensure you always get a great service fully tailored to your preferences.
We do not sell your Personal Data. This includes our partners and vendors. We only retain your information for the specific purpose of performing specific services offered by us. Please check our Website for check-box link “do not sell my Personal Data. You can also email us at: firstname.lastname@example.org You can opt-out from receiving communications from us via any email sent (look for the unsubscribe option.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions. If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of Personal Data we have shared with third parties, if any, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to email@example.com. You may choose to opt-out of the sharing of your Personal Data with third parties for marketing purposes at any time by submitting a request in writing to the contact information at firstname.lastname@example.org . Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.
Making a complaint
You have the right to tell us you don’t want us to share your personal information with anyone - the Right to Restrict Processing under the GDPR. You should be aware that if you ask us to do this, we will not be able to continue with any booking you hold with us, and our standard cancellation terms will apply. You can ask us to restrict processing by emailing us.
To find out more about data protection and your privacy, the Information Commissioner’s website has information on all current data protection laws and your rights. Find out more at ico.org.uk
We’re always happy to answer any questions as well. If you have any concerns or would like questions answered then get in touch.
If you have any questions about the data we hold on your behalf, we will do our best to answer them.
If you have a specific enquiry about the data we hold, or want to see the data we hold, please call us on 0208 315 4500, or send a request in writing to:
The Data Protection Team
Cosmos Tours Ltd, Avalon House, Lower Mortlake Road, Richmond, Surrey, TW9 2JY
If you are acting on behalf of another person and want to access their data, or have us answer questions about their data, please call us on 0208 315 4500.