Privacy Policy
1. Who is responsible
The controller is CruiseTalentNetwork (in formation), Herengracht 999, 1017BR Amsterdam, Netherlands, Chamber of Commerce number CHofCom in formation. For all privacy questions and requests: info@cruisetalentnetwork.com.
CTN is a business-to-business platform. We process personal data of the people who work for cruise companies, of entertainers (often sole traders) and of the performers in their acts.
2. Which data, why, and on what legal basis
| Data | Purpose | Legal basis (GDPR art. 6) |
|---|---|---|
| Name, business e-mail address, role, password (stored only as a secure hash) | Creating and securing your account | Performance of the contract (b) |
| Company and business details: name, address, VAT number, IBAN, invoice e-mail | Agreements, invoices and payments | Contract (b); legal obligation for tax records (c) |
| Portfolio: act name, texts, photos, video link, base city, languages, rivers, show types and fees | Showing the act to approved cruise companies | Contract (b) |
| Itineraries, bookings, agreements, signatures (name, place, time), cancellations, invoices | Running the booking process and the administration | Contract (b); legal obligation (c) |
| Long-term residencies: the residency offer (monthly fee, availability, rivers), proposals, the Residency Agreement with signatures, and the monthly invoices | Arranging and administering residencies on board | Contract (b); legal obligation for invoices (c) |
| Messages between users | Communication about bookings | Contract (b) |
| Cruise manager on board: name, function and work e-mail address of the cruise manager or cruise director of a cruise, entered by the cruise company; the messages, status messages and check-ins they make on their on-board page | Sending the personal on-board link and notices of new messages; letting the cruise manager and the entertainers of the cruise communicate through the platform. Entertainers see only the name and function, from 7 days before their show until the day after; the e-mail address is never shown | Legitimate interest (f) of the cruise company and the entertainer in a show that goes ahead smoothly. The cruise company informs its cruise manager |
| Notifications and e-mails sent to you | Informing you about requests, decisions and invoices | Contract (b) |
| Security log: sign-ins, failed attempts, important actions, IP address, time | Security, fraud prevention, tracing errors and disputes | Legitimate interest (f) |
| App notifications: the notification address of each device on which you switch them on, the type of device, and which kinds of notifications you want | Sending notifications about requests, cancellations and messages to your phone | Consent (a): you switch notifications on per device and can switch them off at any time |
| Questions to the assistant (cruise companies) | Answering questions about the platform | Legitimate interest (f); questions are not stored. The assistant uses artificial intelligence: the question and the relevant handbook passages may be processed by Anthropic as our processor to write the answer. Answers can contain mistakes (Terms, section 14) |
| Reports and complaints, including your name and e-mail address if you give them | Handling reports of illegal content and complaints | Legal obligation under the Digital Services Act (c) |
Documents: since 30 October 2026 CTN no longer collects identity documents, insurance or A1 certificates, VAT registration extracts or health certificates. Entertainers show them directly to the cruise operator on request before boarding. Documents that were uploaded before that date are erased automatically.
Automated processing: phone numbers and e-mail addresses are automatically removed from texts and messages before they are stored. We do not use profiling and we do not take decisions about you based solely on automated processing.
3. Who can see your data
- Cruise companies (approved, and only their own users) see entertainers’ portfolios, fees, availability and verification status — not their documents, address or bank details. On an agreement and on invoices they see the business details needed for those documents.
- Entertainers see the name of the cruise company, the ship, the itinerary details of their booking and the names of the people they communicate with.
- Other entertainers never see your portfolio, fees or availability.
- Processors working for us under a data processing agreement: our hosting provider (STRATO AG) and our e-mail provider (STRATO AG). They may use the data only on our instructions.
- Authorities, only if we are legally obliged to provide data.
We do not sell personal data and do not use it for advertising. We store data within the European Economic Area. Videos are loaded from YouTube (Google) only after you click Play; see Cookies and external media. App notifications are delivered through the push service of your phone or browser (Apple, Google or Mozilla); they receive only the encrypted notification and the device address.
4. How long we keep data
| Data | Retention |
|---|---|
| Account, profile and portfolio | As long as the account exists; removed within 3 months after the account is closed |
| Bookings, agreements, invoices and the business details on them | 7 years after the end of the year concerned (Dutch tax retention obligation) |
| Messages | As long as the account exists; removed within 3 months after closure, unless needed for an ongoing dispute |
| Name and e-mail address of the cruise manager on board, and the on-board link | Removed 30 days after the cruise (the messages stay with the booking, like other messages) |
| Security log | 12 months (removed automatically) |
| E-mails sent by the platform | 90 days after sending (removed automatically) |
| Reports and complaints | 2 years after the decision |
| Notification addresses of devices | Until you switch notifications off on that device or close your account; removed automatically when the device no longer accepts them |
| Session cookie | Until you sign out, or after 8 hours without activity |
5. Security
We protect data with, among other things: encrypted connections (HTTPS), passwords stored as secure hashes, account lock-out after repeated wrong passwords, protection against forged requests, access checks on every page and file, uploaded files stored outside the website and checked for their real type, daily backups, and a security log. Access to documents is limited to CTN administrators.
6. Your rights
You can close your account yourself under Your account → Close your account; your personal data is then erased within 3 months, except what must be kept by law (section 4).
You have the right to access your data, to have it corrected or erased, to restrict or object to its processing, and to receive your data in a structured format (data portability). Send your request to info@cruisetalentnetwork.com. We respond within one month and may ask you to confirm your identity. Some data must be kept for legal reasons (see section 4); we will tell you if that applies.
If you believe we do not handle your data correctly, please contact us first. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl) or the supervisory authority in your country.
7. Changes
We may update this policy. We announce material changes by e-mail and on the platform. The version date is at the top.