Who controls your information
For personal information collected directly through alophim.com, the website operator and initial data controller is:
GleamEdge Ltd
Company number: 19482212
167–169 Great Portland Street
5th Floor
London
W1W 5PF
United Kingdom
Email: [email protected]
Phone: +44 330 335 0950
“Alophim” is the website brand used by GleamEdge Ltd for the promotional cruise information and enquiry-referral service available through alophim.com.
Our role
GleamEdge Ltd operates alophim.com as an independent advertising, enquiry-review and referral service. We collect and review enquiries and may select one suitable participating independent excursion or booking provider based on the visitor's requested date, group size, preferred experience, practical requirements and provider availability.
GleamEdge Ltd does not own or operate vessels, employ captains or crew, confirm excursion bookings, accept customer payments or provide the excursion itself.
The selected provider may contact the visitor directly regarding availability, final pricing, booking conditions and service delivery. Once the provider receives the enquiry and determines how it will use the information for quotations, bookings, payments or excursion delivery, it will normally act as a separate data controller under its own privacy notice.
Scope of this notice
This notice applies to personal information processed by GleamEdge Ltd through:
- alophim.com;
- website enquiry and contact forms;
- telephone and email enquiries;
- customer-service and complaint communications;
- enquiry review and referral records;
- website security, preference and performance technologies.
This notice does not govern independent processing carried out by an excursion operator, booking provider, payment provider, marina or external website after information has been transferred to or collected directly by that organisation.
Before accepting a quotation, making a payment or completing a booking, visitors should read the privacy information and terms provided by the selected independent provider.
Information we collect
Depending on how you use the website, we may collect:
- Identity information: your name and, where voluntarily provided, organisation name.
- Contact information: email address, telephone number and preferred contact method.
- Enquiry information: preferred date, preferred time, group size, cruise type, message content and special requests.
- Communication information: form submissions, emails, call notes and records of our response.
- Lead-transfer information: the date of transfer, the offer concerned and the independent provider to which the enquiry was sent.
- Technical information: IP address, browser and device type, operating system, referring page, requested pages, timestamps and security-event data.
- Preference information: the cookie or privacy choices saved in your browser.
- Complaint information: details needed to review a complaint about the website or the handling of an enquiry.
GleamEdge Ltd does not request or collect payment-card details through the general enquiry form. Do not submit passwords, passport details, payment-card information or other unnecessary confidential information through the form.
Health and accessibility information
Information about health, disability, mobility, pregnancy, allergies or similar matters may be special category personal data under UK data-protection law.
The general website form is not intended for detailed medical information. Visitors should provide only the minimum information needed to indicate that an accessibility or suitability discussion is required.
Where detailed health or accessibility information is necessary, we may ask the visitor to provide it directly to the selected independent provider. If GleamEdge Ltd must collect and transfer specific special category information, we will first request separate explicit consent for the stated purpose.
Explicit consent can be withdrawn by contacting us. Withdrawal does not affect processing that took place lawfully before consent was withdrawn.
How we collect personal information
We collect information:
- directly from you when you submit a form;
- directly from you when you contact us by phone or email;
- automatically from your browser or device when you use the website;
- from website security, hosting and performance providers;
- from an independent cruise provider when it gives us a limited status update about an enquiry, complaint or referral.
We do not purchase general consumer marketing lists for use through alophim.com.
How we use personal information
We use personal information to:
- receive, review and respond to cruise and excursion enquiries;
- clarify requested dates, group size, preferred experience or practical requirements;
- assess which participating independent provider is reasonably suitable for the enquiry;
- transfer the enquiry to one selected independent excursion or booking provider;
- record when and to whom an enquiry was transferred;
- respond to questions about the website or enquiry process;
- manage complaints relating to alophim.com or lead handling;
- prevent spam, misuse, fraud and security incidents;
- operate, troubleshoot and improve website reliability;
- comply with legal obligations and establish or defend legal claims;
- send optional marketing only where appropriate consent or another lawful permission exists.
GleamEdge Ltd does not use enquiry information to confirm an excursion, take payment or manage performance of the final excursion contract.
Lawful bases for processing
We use a lawful basis that is appropriate to each purpose:
| Purpose | Information used | Lawful basis |
|---|---|---|
| Receiving and responding to an enquiry | Identity, contact, enquiry and communication information | Legitimate interests in operating an enquiry service and responding to a request initiated by you |
| Transferring an enquiry to one selected independent provider | Identity, contact and relevant enquiry information | Legitimate interests in connecting you with a suitable participating provider for the enquiry you initiated, where you would reasonably expect that transfer |
| Processing health or accessibility information | Only the minimum information required | Explicit consent, together with the applicable special category condition |
| Website security, spam prevention and technical logs | Technical and security information | Legitimate interests in protecting and maintaining the website |
| Remembering cookie preferences | Preference information | Legitimate interests and, where applicable, necessity for providing the requested website control |
| Compliance with legal requirements | Relevant enquiry, communication and technical records | Legal obligation |
| Complaints, disputes and legal claims | Relevant enquiry, transfer and communication records | Legitimate interests in resolving complaints and establishing, exercising or defending legal claims |
| Optional email, SMS or telephone marketing | Contact details and marketing preference | Consent, unless another permission is lawfully available and clearly explained |
Where we rely on legitimate interests, we consider the purpose, necessity and effect of the processing and whether your interests, rights or freedoms override our interests.
Transfer of enquiries to independent providers
The purpose of the website form is to allow GleamEdge Ltd to review a visitor's requirements and, where appropriate, connect that visitor with one suitable participating independent excursion or booking provider.
The provider is not necessarily known when the form is submitted. GleamEdge Ltd selects a provider after reviewing factors such as the requested date, time, group size, preferred experience, practical requirements, location and provider availability.
We normally transfer an enquiry to one selected provider. We transfer only information reasonably necessary for that provider to understand and respond to the enquiry. This will usually include the visitor's name, contact details, requested date or time, group size and message.
The selected provider will identify itself when it contacts the visitor. GleamEdge Ltd can also confirm, on request, which provider received an enquiry. The provider is responsible for explaining how it uses personal information for quotations, bookings, payments, customer service and excursion delivery.
GleamEdge Ltd and the selected provider normally act as separate controllers for their respective processing. GleamEdge Ltd may receive compensation when an enquiry is referred or when a booking is completed through a participating provider.
If the selected provider cannot respond or cannot meet the request, GleamEdge Ltd will not routinely send the same enquiry to another provider without an additional notice or other appropriate basis.
International transfers
Some hosting, security, email or technical service providers may process or make personal information accessible outside the United Kingdom.
Where this amounts to a restricted transfer under UK data protection law, we use an applicable transfer mechanism, such as:
- UK adequacy regulations;
- the UK International Data Transfer Agreement;
- the UK Addendum to approved EU standard contractual clauses;
- another mechanism permitted under UK data protection law.
Where required, we also assess whether supplementary safeguards are needed for the transfer.
You can contact us for further information about the safeguards relevant to your personal information.
Security
We use technical and organisational measures intended to protect personal information against accidental or unlawful loss, alteration, disclosure or access.
Measures may include:
- HTTPS encryption for website traffic;
- access controls and limited administrative access;
- hosting and network-security controls;
- spam and automated-abuse protection;
- software maintenance and security monitoring;
- appropriate contracts with service providers.
No online transmission or storage system is completely secure. Please do not send unnecessary sensitive information through a general enquiry form.
Retention
We retain personal information only for as long as reasonably necessary for the relevant purpose.
| Record | Typical retention period | Reason |
|---|---|---|
| Enquiries that do not proceed | Up to 90 days after the last communication | Responding to the enquiry and resolving follow-up questions |
| Lead-transfer record | Up to 12 months after transfer | Demonstrating where the enquiry was sent, referral accounting and complaint handling |
| Complaint or dispute records | Up to 6 years after closure where reasonably required | Legal claims, accountability and dispute resolution |
| Health or accessibility information held by GleamEdge Ltd | Deleted after transfer or resolution of the suitability enquiry, normally within 30 days | Data minimisation and limited purpose |
| Technical and security logs | Normally up to 30 days | Security, fraud prevention and error investigation |
| Cookie preference record | Up to 6 months | Remembering the choice made in the cookie banner |
| Marketing consent and suppression records | While consent remains valid and for as long as needed to respect an opt-out | Marketing compliance and preventing unwanted contact |
These periods may be extended where information is required for an active complaint, legal claim, fraud investigation or legal obligation. Information may be anonymised instead of deleted where it can no longer identify an individual.
Children and young people
alophim.com is intended for adults making cruise enquiries. We do not knowingly invite children to submit enquiries or consent to marketing.
Where a child will be part of a cruise group, the adult making the enquiry should provide only the minimum information needed to ask the provider about capacity, safety or suitability.
Marketing communications
Messages sent solely to respond to your cruise enquiry are service-related communications and are not treated as consent to unrelated marketing.
If we ask whether you would like marketing by email, SMS or telephone, the marketing choice will be separate and optional. We will identify the communication method and the organisation that will send the marketing.
You can withdraw marketing consent or object to direct marketing at any time by using the unsubscribe method in the message or by contacting us.
We may retain a minimal suppression record after an opt-out to ensure that your preference continues to be respected.
Automated decision-making and profiling
GleamEdge Ltd does not use enquiry information to make decisions based solely on automated processing that produce legal or similarly significant effects.
Provider selection is based on the enquiry information and available partner criteria and is not intended to produce a legal or similarly significant effect. Security tools may automatically identify suspected spam, bots or malicious activity. These controls protect the website and do not decide whether a person may purchase or participate in an excursion.
Your rights
Depending on the circumstances, UK data protection law may give you the right to:
- be informed about how your information is used;
- request access to your personal information;
- have inaccurate or incomplete information corrected;
- request deletion in certain circumstances;
- request restriction of processing in certain circumstances;
- object to processing based on legitimate interests;
- object to direct marketing at any time;
- receive portable data where the right applies;
- withdraw consent where processing relies on consent;
- complain to the Information Commissioner’s Office.
These rights are not absolute. Whether a right applies can depend on the lawful basis, the purpose of processing and legal obligations.
If your request relates to information held by an independent cruise operator after transfer, we may direct you to that provider or forward the request where appropriate.
How to make a privacy request
To exercise a data-protection right or ask a privacy question, contact:
GleamEdge Ltd
167–169 Great Portland Street, 5th Floor
London, W1W 5PF
United Kingdom
Email: [email protected]
Phone: +44 330 335 0950
Please describe the request clearly. We may ask for information reasonably necessary to confirm identity and locate the relevant records.
We normally respond within one month after receiving a valid request. Where the law permits additional time for a complex or multiple request, we will explain the extension.
Complaints
Please contact GleamEdge Ltd first if you are concerned about our handling of personal information so that we can review the issue.
You also have the right to complain to the UK Information Commissioner's Office:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom
ICO telephone: 0303 123 1113
Website:
ico.org.uk/make-a-complaint
Changes to this Privacy Policy
We may update this policy if the website, enquiry process, recipients, service providers, technologies or legal requirements change.
The current version will be published on this page with a revised “Last updated” date. Where a material change affects an active enquiry or the way information is shared, we may provide an additional notice where appropriate.