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.
This Privacy Policy will inform you as to how we look after the Personal Data that you provide to us or we collect from you when you visit our Website, make an enquiry and/or purchase services from us. This Privacy Policy tells you about your privacy rights and how the law protects you.
This is the full version of our Privacy Policy and forms part of your terms and conditions of reservation with us.
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 of the Avalon Waterways, Globus and Cosmos brands. This Website is owned, managed and operated by the Globus family of brand . 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.
United States - Globus family of brands
Postal address: 4695 S. Monaco, Suite 200 Denver, CO 80237
Email address: consumervacation@globusfamily.com
Telephone number: 1-800-276-1241
Canada - Globus family of brands
Postal address: 3280 Bloor St W. Centre Tower, Suite 400 Toronto, ON M8X 2X3
Email address: consumervacation@globusfamily.ca
United Kingdom - Cosmos Tours Limited, a company registered in England and Wales
Company registration number: 01175122
Email address: admin@cosmos.co.uk
Postal address: Cosmos Tours LTD, Ground Floor, Avalon House, Lower Mortlake Road, Richmond TW9 2JY
Telephone number: 0844 573 0668
Australia/New Zealand - Globus family of brands
Postal address: Australia - Level 6, 68 Pitt Street, Sydney 2000; New Zealand - Level 9, 55 Shortland Street, Auckland City
Email address: enquiries@globusfamily.com.au
Telephone number: 1300 230 234
This is the current version of our Privacy Policy updated on 18 November 2021.
We may make changes to this Privacy Policy from time to time to time. We reserve the right to make any revised policy effective for Personal Data we already hold about you as well as any information that we receive in the future. Your continued use of the Website and/or services following any changes to the Privacy Policy (which will be notified to you as described above) signifies your acceptance of those changes.
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.
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:
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 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.
We routinely collect, use and share Aggregated Data such as statistical or demographic data for mulitple purposes. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal an individual's identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
When you book a trip with us, we will need to ask for Personal Data (including Identity Data, Contact Data and Special Categories of Personal Data) of the people you are travelling with and also Personal Data (including Identity Data and Contact Data) for your emergency / next of kin contacts for while you are on your trip. We need this information to comply with our obligations in providing the trip you've booked. It is your obligation to ensure that you make such third parties aware of this Privacy Policy.
We use different methods to collect data from and about you including through:
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.
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:
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 below, in a table format 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 where more than one ground has been set out in the table below.
Data subject |
Purpose of processing / activity |
Type of data |
Legal basis for processing the data |
Retention period |
Prospective guest |
Providing a quote and/or requested information |
(a) Identity (b) Contact |
Necessary in order to take steps at the request of the prospective guest prior to entering into a contract with them. |
5 years from quote unless prospective guest still wants to hear from us. |
Guest who books trip with us direct |
Making the reservation and performance of contract for services, including:
|
|
|
7 years after return from trip unless the guest still wants to hear from us. |
Guest who books trip via a travel agent |
Making the reservation and performance of contract for services, including making arrangements for the trip. |
|
|
7 years after return from trip unless the guest still wants to hear from us. |
Other traveler(s) on a trip |
Performance of contract for services, including making arrangements for the trip. |
|
|
7 years after return from trip unless traveler still wants to hear from us. |
Guest and other traveler(s) emergency contact / next of kin |
Processing of emergency contact / next of kin information |
|
|
Destroyed after return from trip |
Guest |
To manage our relationship with you which will include:
|
|
|
7 years after return from trip unless guest still wants to hear from us. |
Guest |
To enable you to partake in a prize draw, competition or complete a survey |
|
|
7 years after return from trip unless guest still wants to hear from us. |
Prospective Guests |
Sending direct marketing communications about products and services which may be of interest to you |
|
Prospective Guest's consent |
5 years after first contact unless prospective guest still wants to hear from us. |
Guests |
Sending direct marketing communications about products and services which may be of interest to you
|
|
Guest's consent |
7 years after latest purchase unless guest still wants to hear from us. |
Visitor to our Website |
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
|
3 years after your last visit of our Website |
Visitors to our Website / Guests |
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to effectiveness of the advertising we serve to you |
Communications
|
Necessary for our legitimate interests (to study how guests use our services, to develop them, to grow our business and to inform our marketing strategy) |
3 years after your last visit of our Website |
Visitors to our Website/Guests or prospects |
To use data analytics (including segmentation and propensity score modelling) to improve our Website, services, marketing, guest relationships and experiences |
|
Necessary for our legitimate interests (to define types of guests for our services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) |
3 years after your last visit of our website |
Visitors to our Website/Guests or prospects |
Complete a sales inquiry form; request a quote, expert request etc. |
|
Guest's and prospective guest's consent |
5 years after first contact unless guest or prospective guest still wants to hear from us. |
Job Applicants via our Website |
To enable us to make employment and hiring decisions (job applications, resumes) |
(c) Employment |
Necessary for our legitimate interests (so that we can make an informed decisions pertaining to employment and hiring) |
1 year from the hiring date or rejection date |
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: consumervacation@globusfamily.com 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 consumervacation@globusfamily.com. California law also permits residents of California to opt-out of our disclosures of Personal Data to third parties for their direct marketing purposes. 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 consurmervacation@globusfamily.com Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.
Same as US 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: consumertravel@globusfamily.ca you can opt-out from receiving communications from us via any email sent (look for the unsubscribe option.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by calling us on (UK) 0330 0588 237 or emailing us at: admin@cosmos.co.uk
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to, or collected by, us as a result of the purchase or provision of any services.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO.
United Kingdom Data Protection Officer
Samuel Parker
First Floor, Wells House, 15 Elmfield Road, Bromley, BR1 1LT
0844 573 0668 sparker@cosmos.co.uk
Individuals have the right to request AU and NZ Globus family of brands to stop using their Personal Data to carry out direct marketing of the products, services and promotional activity. To opt out, a written request is to be sent to the Privacy Officer at privacy@globusfamily.com.au Once the request is received, Globus family of brands will respond within 48 hours.
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.
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 you can see a full list of our suppliers online
In addition to the above, we may also share your Personal Data with the following third parties in the following circumstances:
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 https://www.gov.uk/data-protection and GDPR in the EU: https://oag.ca.gov/privacy/ccpa , https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/, https://ec.europa.eu/info/law/law-topic/data-protection/datatransfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en; https://www.oaic.gov.au/privacy/australian-privacy-principles-guidelines/chapter-8-app-8-cross-border-disclosure-of-personal-information/; https://privacy.org.nz/blog/privacy-2-0/
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.
If you have booked through a travel agent or reseller, they may have separately asked for your permission for them to contact you or send you marketing information. Please refer to the resellers own privacy policy to understand how they process your Personal Data. If you believe a reseller is using your data in a way you have not consented to, you should contact them directly.
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 are set out in the table above. For further information, please contact us.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.
The servers and databases in which information is be stored may be located outside the country from which you accessed the Website, and in a country that does not have the same privacy laws as your country of residence. The Personal Data you provide us may be transmitted abroad for the purpose described in this Privacy Policy, but we will collect, process and use Personal Data only in accordance with this Privacy Policy.
If you reside in the European Union, you have certain rights under the General Data Protection Regulation ("GDPR"), including:
You should be aware that, in some cases, if you ask us to delete or transfer your Personal Data, or if you withdraw your consent to processing (other than in respect of direct marketing), this may mean that we will not able to continue with any reservation you hold with us, and our standard cancellation terms will apply.
To find out more about data protection and your privacy, the below Websites have information on all current data protection laws and your rights.
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.
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.
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.
We share your concerns over privacy disputes. Your visit and any dispute over privacy is subject to this Notice and Our Travel Terms and Conditions, including any limitations on damages, resolution of disputes, and application of the law of the state of Colorado. If you have questions or concerns regarding our privacy practices, you can contact us. We will investigate and attempt to resolve complaints regarding violations of its published Privacy Policy directly with the complainant. In the event that the complaint cannot be resolved internally, the complainant shall submit the matter to binding arbitration before the American Arbitration Association in Denver, Colorado.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Globus family of brands is committed to the adoption of the Australian Privacy Principles (APP). Procedures are in place for dealing with complaints relating to our privacy practices. Any complaint is made by contacting the Privacy Officer at privacy@globusfamily.com.au.
Any complaints made will be investigated as soon as they are lodged and all reasonable efforts will be made to resolve the complaint as soon as possible. The laws Globus family of brands comply with are regulated by the Australian Information Commissioner.
Under California Consumer Privacy Act ("CCPA"), California residents have the right to request in writing from a business, (a) a list of the categories of Personal Information, as that term is defined under the CCPA, such as name, address, e-mail address, and the type of services provided to the guest, that a business has disclosed to third parties (including Independent Affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us by contacting our Guest Care department at consumervacation@globusfamily.com.
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.
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.
We may use third-party services for payment processing (e.g., payment processors). We will not store or collect your complete payment card or banking details. Information may be provided directly to our third-party payment processors whose use of your personal information is governed by their respective Privacy Policy.
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.