P&O Cruises Privacy Notice

Privacy Notice | P&O Cruises (pocruises.com)

Privacy Notice

P&O Cruises is a trading name of Carnival plc. We collect and process data about enquirers and guests to promote, deliver and improve our services. This privacy notice describes what personal data we collect, how we use that personal data, and how to ensure that our processing meets your expectations

Communications preferences

To update your communications preferences, including how you receive emails, calls, mailings and brochures, you can:

• Click on the preferences link at the foot of each email
• Log into (or sign up for) My Account to make changes at https://www.pocruises.com/myaccount/
• Email us at customerservices@pocruises.com
• Call us on 0344 3388003 (local call charges apply)
• Write to Customer Services, P&O Cruises, Carnival House, 100 Harbour Parade, Southampton, SO15 1ST.

Why we process personal data

We process personal data about enquirers and guests before, during and after their cruises to support our business interests, which include:

• Making enquirers and guests aware of news and offers from Carnival plc and our partners and personalising these to your holiday interests, including where these are displayed on third party websites, search engines and social media;
• Providing services to our guests and recording what services we have provided;
• Managing the health, welfare, safety and security of our guests;
• Handling enquiries, complaints and investigations;
• Operating guest loyalty programmes;
• Monitoring and improving the quality of our services;
• Researching and understanding market needs to improve our marketing effectiveness;
• Working with our partners such as on-board boutiques and spas to manage billing and improve the quality of their services.

We also process personal data about job applicants, current and former employees, service providers, travel agents and other groups of individuals in the course of employment and business operations, and this data is subject to our internal privacy policies.

What personal data we collect

Personal data you provide to us

We collect personal data you provide to us when you enquire, book or sail with us, for example:

• Enquiry: Personal details (name, gender, age etc.), contact information (home address, phone number, email address etc.), details of your interests and communications preferences;
• Booking: Personal details, contact information, booking preferences, financial details (credit/debit card, bank details), travel documents (passport number), care needs (medical, dietary, mobility etc.), dining preferences, other travel details (vehicle registration, excursion bookings);
• On-board Activity: Financial details, bookings and billing for on-board services and shore excursions, photographs taken during the cruise;
• Enquiries & Complaints: Personal details, contact information, enquiry or complaint details;
• Loyalty Programme: Personal details, contact information, communications preferences, cruise history;
• Health & Welfare: Medical, dietary and mobility details provided to us before, during or after the cruise;
• Security & Safety: Travel documents, facial photograph, incident reports or witness statements;
• Surveys & Market Research: Responses to post-cruise surveys and market research surveys.

If you purchase services or credits as a gift or surprise booking, we will record your details as needed in relationship to the individual(s) for whom the gift or surprise booking was purchased.

Personal data generated by your interactions with us

Your interactions with us will result in personal data being created and stored by us. Examples include:

• Booking: Booking party details, reference numbers, travel itineraries, flight bookings, manifests, immigration details
• On-board Activity: On-board spending, boutique spending, casino spending, spa/gym specialist interactions, dining records;
• Enquiries & Complaints: Enquiries or complaints and associated investigation and correspondence before, during or after a cruise;
• Loyalty Programme: Nights on board, cumulative spending;
• Health & Welfare: Medical reports, billing data, welfare reports, correspondence;
• Security & Safety: Accident/incident reports, witness statements, embarkation/disembarkation logs, audio/video recordings, police reports.

Personal data we create

We analyse the personal data we hold in order to improve the effectiveness of our direct marketing communications or to deliver our loyalty programmes. This can, in turn, generate personal data; for example, helping us to decide which marketing communications are likely to be of interest to you, or to determine your loyalty status.

Personal data from other organisations

We receive personal data from other individuals or third party organisations. For example, when making a booking we will receive details of all members of the booking party from the guest making the booking. We receive personal data from third party organisations including travel agents processing bookings on a guest’s behalf, from competitions or promotions where personal data has been provided as part of the competition or promotion, or from social media where personal data has been posted on our social media pages. We use publicly accessible data sources such as data brokers to maintain the accuracy of our enquirer and guest records, and from time to time use external sources to help us to resolve disputes or recover unpaid accounts.

Sensitive personal data

We do not process sensitive personal data about you except where there is a legal reason to do so. Sensitive personal data can include:

• Health: We collect personal data about guest health as part of the booking and embarkation processes, or where guests use medical services on board ship. This is retained for subsequent care purposes and to facilitate billing for services provided.
• Biometrics: We use photographs of our guests to maintain security and safety whilst they are on board our ships. These are not retained or used for other purposes.
• Sexual orientation: Enquirers and guests may from time to time choose to provide data to us relating to their sexual orientation or gender identity so that we can maintain their health, welfare and enjoyment of the services we provide (though we will not actively seek to collect such information).

We process personal data about children to provide services when they are guests on our ships, but do not seek to collect personal data about children for any other purpose.

From time to time we are asked to process personal data relating to criminal history of individuals, for example if we receive a request from law enforcement authorities, or when investigating security matters that might relate to criminal or civil offences.

How we process personal data

We use personal data with your consent, or where it is necessary in order to:

• Enter into a contract and deliver services for you;
• Comply with a legal duty
• Protect your vital interests or the vital interests of those around you;
• For our own lawful interests or those of other organisations, provided your rights don’t override these.

We will only use personal data about you for the purpose(s) it was collected for or closely related purposes, and will inform you or seek your consent if we need to use it for other purposes.

Enquiries

If you enquire about our services, or engage in competitions or other promotional activities that we or our partners provide, we will ask your consent to provide you with news and offers about our services that you may find of interest. Depending upon your preferences, our communications with you may include:

• Email: We monitor our email communications, including where emails are undelivered and whether or not they appear to have been read. We will cease sending you email communications should we be unable to deliver email to you.
• Post: We may from time to time send postal communications including brochures, newsletters and offers. Where letters are returned to us, or where external data providers notify us of changes, we take steps to update our records. We may cease sending you postal communications if we believe we are no longer able to contact you at the address on file.
• Calls: Calls made to us, and calls received from us, may be recorded for the purposes of audit, training and the monitoring of services provided by us.
• Web: Visitors to our website may be tracked using analytics methods described in our Cookies Policy, unless web browsers, ad-blockers, privacy tools or other settings prevent this from occurring.

You are free to withdraw or amend your consent to receive news and offers at any time.

Bookings

When you make a booking either directly or through a travel agent, we will collect personal data about you and other travellers in your group to effect the booking, including your names, genders, dates of birth, home addresses, phone, email, details of any medical, care or dietary requirements, specific preferences relating to the booking you have selected, and your payment details. We need this data to enter into a contract with you.

If you provide us with personal data about any other individuals included in a booking, you must have the authority of those individuals to provide their personal data to us for the purposes set out in this Privacy Notice, and will remain accountable for the information provided. It is the responsibility of the booking leader to ensure that personal data about the group members is accurate and up to date.

If you commence a booking through our website and provide your contact details as part of the booking process, but do not complete that booking, we may send you up to three reminder emails to help you to complete the booking. This will not affect any preferences you have registered with us.

Managing your booking

After you book a cruise, you will be invited by email to access our online Cruise Personaliser service where you will need to provide additional personal data about you and your travel party. This additional mandatory personal data including passport, insurance and emergency contact details for you and your booking group is necessary to complete your booking.

You may optionally book or purchase on-board products and services, excursions and other activities. Depending on the product or service selected, you may be required to provide further personal data to provide these to you, and we may have to share your personal data with other companies such as spa operators or travel operators in order to provide these to you.

Within Cruise Personaliser, data about a group of individuals in a booking, including personal data, bookings and purchases, loyalty number and status will be visible to all members of that booking group.

Before your cruise, you will receive information about your booking by post or email.

Flights

If the cruise you book includes flights as part of a package, we will share personal data about you with the contracted airline in order to complete your booking. The contracted airline will be named on the flight confirmation we provide you, and further details of how they will process your personal data may be obtained directly from that airline.

On board our ships

Your security and safety

We will use personal data about you for the purposes of carrying out security checks. Where we are required to do so, personal data about you will be shared with recognised law enforcement agencies prior to boarding, during your cruise, or after disembarkation, for security and immigration purposes. Where we are required to do so, personal data will also be shared with these agencies in order to prevent and detect crime as well as to safeguard children and vulnerable adults. These purposes may involve sending personal data between different countries, including countries outside the European Union where controls on data protection may not be as strong as the legal requirements within the European Union.

For the safety and security of each ship and its guests, and to maintain health and safety, we operate closed circuit television (CCTV) cameras onboard our ships, including at all access points and throughout public areas. These cameras record continually with footage being retained and stored for a set period. Where body-worn cameras are deployed onboard our ships, they are operated by authorised and trained employees to capture video and audio evidence, prevent harm, and deter individuals from committing crime or inappropriate behaviour. Body-worn camera usage will be incident-specific, and reasonable warning of their use will be given where practical. They are not used for sensitive incidents where recording video would be inappropriate. Where necessary, images taken from these cameras will be used internally for identification purposes and to assist with investigation of safety or security related matters. Images will also be shared with law enforcement agencies (in any jurisdiction) in order to detect or prevent criminal activity or to assist in the apprehension and prosecution of offenders.

Enjoyment of your cruise

Please be aware that there are photographers and camera crew on board the ship taking photographs and making films for guests to purchase at the end of your cruise or for our own promotional use. They are happy to take reasonable steps to avoid filming or photographing you where you indicate that this is your preference, but you may be included unless you tell us otherwise and we are unable to guarantee that you will not be included on an incidental basis.

Some on-board products and services, excursions and other activities, are provided by other companies. We may share sufficient personal data with these partners before, during and after your cruise to provide a seamless service to our guests, such as the ability to charge purchases to guests’ onboard accounts.

Casinos on our ships are operated by Ocean Players Club, a division of Carnival Corporation based in the United States of America. Our legal and technical controls safeguarding this relationship are described in ‘Transferring personal data to third countries’. Limited personal data about you is transferred to Ocean Players Club for the purpose of preparing a casino account should you wish to use their facilities, and to prevent and detect fraud. For further information on how Ocean Players Club will process personal data, please view their privacy notice.

Your health and welfare

In the unlikely event that you are involved in an accident or require medical treatment on our ships, we will use personal data already provided to us, or obtained from you, to deliver your treatment. We will share that personal data with third party healthcare providers with your consent, or where it is in your vital interests, or in the public interest to do so, and we will retain a record of treatment provided for billing and obligatory record-keeping purposes.

After your cruise

Feedback

Upon completion of your cruise, we will contact you to seek feedback on your experience to understand your satisfaction level so that we can improve the quality of services we offer, and to assess the performance of our on-board staff and their associated rewards. For UK guests, we may provide your email address to a third party review service for the purpose of managing your feedback.

Loyalty programmes

We operate loyalty programmes that allow you to benefit from your time spent on our ships, through future offers that may include discounts, upgrades, early booking, competitions, gifts and other rewards. For this reason, we retain a basic record of cruises you have taken including your name, contact details, cruise numbers and dates, and any loyalty offers that you have redeemed with us. If you believe we hold incorrect historical cruise details, you can contact us with evidence of those cruises to correct your record.

We will contact you with details of our loyalty programme when you book your first cruise, and if you join you will receive further communications thereafter including details of your loyalty status and subsequent benefits. In order to calculate these benefits we need to profile the time and money you spend with us. You may opt out of the loyalty programme and programme-related communications at any time. We use external data providers to help us to maintain the accuracy of your loyalty programme contact data.

Future cruise credits

When you are on board our ships, you may be offered the opportunity to purchase future cruise credits. If you hold any future cruise credits, we will contact you with offers related to the use of those credits up to their expiry date. If you booked your cruise through a travel agency partner, then we will inform the travel agency of your future cruise credits and they may choose to contact you with offers to ensure the timely use of those credits.

Queries

Should you have queries before, during or after your cruise, then we will use information related to your cruise such as travel details, billing, on-board communications and other information we have on record or which you or third parties may provide to us, to resolve your query.

We may also contact you with information following the cruise you have taken, or if there are queries relating to your payment or the services you have received.

Understanding your needs

The personal data you provide to us or which we obtain through your dealings with us may be analysed for the following purposes:

• To personalise our news, offers and services to your holiday interests, including where these are displayed on third party websites, search engines and social media;
• To track the delivery of and response to our marketing communication;
• To review, develop and improve the services we offer (including market research);
• For statistical analysis.

We also conduct identifiable and anonymous market research to provide longer-term insight into the effectiveness of our services and marketing, and to support our service planning and delivery.

Personal data

Sharing personal data

Enquiries and bookings are processed in the European Union, where our systems may be accessed by Carnival group staff and suppliers from outside of the European Union subject to strict security controls.

We contract other companies and individuals to perform certain activities on our behalf. Examples include:

• Fulfilling requests for brochures and promotional materials: printers, fulfilment service providers;
• Advertising: targeting on third party platforms such as search engines, social media platforms and advertisement brokers
• Processing payments: banks, payment service providers;
• Postal mail and e-mail communications: postal services, couriers, e-mail service providers;
• Maintaining guest records and analysing data: customer insight agencies, credit agencies;
• Providing port services and excursions;
• Providing travel services: airlines, coach operators, travel agents.

These contractors have access to personal information needed to perform their functions, but are not permitted to use it for other purposes.

If you make a booking we may pass your personal information on to other relevant suppliers of your travel arrangements such as airlines, hotels and transport companies. Where necessary, your personal information will also be passed to travel agents, security and credit checking companies, credit and charge card companies. We are required to co-operate with government and law enforcement agencies and the public authorities of any country in your itinerary, including customs and immigration authorities.

Transferring personal data to third countries

We process your personal data worldwide, including on board our ships, depending upon the destinations you travel to with us. For example, we have to provide personal data to immigration authorities, port agents or excursion operators in destination countries. This will involve sending your personal information between different countries, including countries outside the EU where controls on data protection may not be as strong as the legal requirements in the EU.

From time to time personal data must be shared with other Carnival companies outside of the EU, or accessed by Carnival companies from outside of the EU, in order to provide the services you request from us. We use legal mechanisms ('standard contractual clauses') and technical and procedural controls to safeguard personal data.

Your rights concerning your personal data ("Information rights")

You have rights over how we use personal data about you, and can exercise those rights by contacting our Data Protection Officer using the contact details below:

• Data Protection Officer, Privacy & Data Protection Team, Carnival House, 100 Harbour Parade, Southampton, SO15 1ST,
• Or call 0344 338 8650,
• Or email privacy@carnivalukgroup.com. 

Our ability to uphold these rights for you depends upon our obligations to process personal data for security, safety, fraud prevention reasons, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request

Withdrawing consent to processing

Where we have obtained your consent to process personal data about you, you have the right to withdraw your consent at any time. Where we process personal data about you in ways for which your consent is not required, for example to record your cruise history, you may have a limited right to ask us to cease processing of that personal data or restrict the nature of the processing.

Accessing the personal data we hold about you

You may request a copy of the personal data we hold about you, subject to a small number of exemptions set out in law. This includes obtaining personal data about you in electronic form to provide to a third party should you wish to do so.

Ensuring the accuracy of personal data we hold about you

We will update or amend personal data we hold about you if you inform us of inaccuracies. We will use external data sources to maintain the accuracy of our enquirer, guest and loyalty records.

Deleting personal data we hold about you

We retain personal data for the period required for processing, and where we are under an obligation to do so, for example billing data is retained in accordance with anti-money laundering and financial records keeping requirements.

We retain a basic record of guests’ cruise history (name and contact details, booking/cruise number, nights on board, class of travel) indefinitely for the purpose of maintaining our loyalty scheme.

We will delete personal data we hold about you if you ask us to do so, as required by data protection law.

How to complain about our processing of personal data

If you have a concern or complaint about our processing of personal data, please contact our Data Protection Officer using the contact details below:

• Data Protection Officer, Privacy & Data Protection Team at Carnival House, 100 Harbour Parade, Southampton, SO15 1ST, 
• Or call 0344 338 8650,
• Or email privacy@carnivalukgroup.com.

If you are not satisfied with how we have responded to your complaint about the processing of personal data, or following our response you believe our processing of personal data is not in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO) as set out on their website at https://ico.org.uk/concerns/

Securing your personal data

We take the security of your personal data seriously, and use a number of technical and organisational controls and ongoing training to safeguard the personal data we process from improper access, use, alteration, destruction and loss.

Where we share your personal data with other companies as described above, we require those companies to process your personal data to an equivalent level of security.

Websites

You can find out how our websites process personal data about you here.

Cookies

We use cookies and similar tools on our website to improve its performance and enhance your user experience. You can find out more about how we use cookies here.

How to contact us

P&O Cruises is a trading name of Carnival plc. Carnival plc is registered in England & Wales number 04039524, and is registered as a data controller with the Information Commissioner’s Office number Z8383204.

All enquiries relating to data protection, including communications with our Data Protection Officer, should be sent to: Data Protection Officer, Privacy & Data Protection Team, Carnival House, 100 Harbour Parade, Southampton, SO15 1ST, or call 0344 338 8650, or email privacy@carnivalukgroup.com

Changes to this policy

This policy was last updated on 8th April 2019. When changes are made to this notice, we will publish the changed policy on our websites with details of the changes.

TERMS AND CONDITIONS:
P&O CRUISES IN-STORE EVENTS PRIZE DRAW 
June – October 2025
(Prize Draw)

1. The Promoter is Carnival plc trading as P&O Cruises, with its registered office at Carnival House, 100 Harbour Parade, Southampton SO15 1ST (Promoter). 
2. The terms and conditions which apply to this Prize Draw are available at https://pocruisesexperience.co.uk/prize-draw/terms. By entering this Prize Draw, you will be deemed to have read and understood these terms and conditions and to have agreed to be bound by the same.

How to Enter

3. The Prize Draw will run from 00:01 BST on 13^th June 2025 (Opening Date) until 23:59 GMT on 30^th October 2025 (Closing Date) inclusive.
4. To take part in this Prize Draw you must do one of the following during the Promotional Period:
   1. Complete an entry form available at a P&O Cruises either Liverpool, Gunwharf, Bluewater, Cardiff or Leeds in-store event, or
   2. Visit https://pocruisesexperience.co.uk and complete and submit the entry form available there.
5. P&O Cruises’ in-store events will be held between 13 till 15 June 2025 (10:00 GMT - 21:00 GMT Monday – Friday, 09:00 GMT - 21:00 GMT Saturday, 11:00 GMT -17:00 GMT Sunday) at the Liverpool One Shopping Centre, 04 till 06 July 2025 (10:00 GMT - 21:00 GMT Monday – Friday, 09:00 GMT - 21:00 GMT Saturday, 11:00 GMT -17:00 GMT Sunday) at Gunwharf Quays outlet Shopping Centre, 26 till 28 September 2025 (10:00 GMT - 21:00 GMT Monday – Friday, 09:00 GMT - 21:00 GMT Saturday, 11:00 GMT -17:00 GMT Sunday) at the Bluewater Shopping Centre, 3 till 5 October 2025 (10:00 GMT - 21:00 GMT Monday – Friday, 09:00 GMT - 21:00 GMT Saturday, 11:00 GMT -17:00 GMT Sunday) at the Cardiff St Davids Shopping Centre, 24 till 26 October 2025 (10:00 GMT - 21:00 GMT Monday – Friday, 09:00 GMT - 21:00 GMT Saturday, 11:00 GMT -17:00 GMT Sunday) at Leeds Trinity Shopping Centre.
6. All entries must be received by the Promoter no later than 23:59 GMT on the Closing Date. All entries received after the Closing Date are automatically disqualified. 
7. Only one entry to the Prize Draw is permitted per person. If you enter the Prize Draw more than once, any entries you have submitted will be disqualified.
8. No purchase is necessary to enter the draw.

Eligibility 

9. The Prize Draw is only open to all UK residents aged 18 or over except the following persons: 
   1. Employees of the Promoter (or any of their associated or group companies),
   2. Employees or agents of any suppliers to the Promoter, or
   3. members of the immediate family or households of the persons shown at 9 a) 9 b) above.
   4. Any employees or agents of any Travel Agent partners who have a commercial relationship with the Promoter.

   No bulk or third-party entries will be accepted. The Promoter will not accept entries that are automatically generated by computer; illegible, have been altered, reconstructed, forged or tampered with or are incomplete.

The Prizes

10. There is one Prize only. The Prize is one Caribbean cruise holiday for two adults over the age of 18 sharing one GF grade Balcony cabin onboard P&O Cruises ship ‘Arvia’ flying from selected UK airports on 30 January 2026 for 14 nights (cruise number K603) (Cruise Prize). 
11. Details of how to book Cruise Prize will be provided to Cruise Prize winner by email. 
12. Booking of Cruise Prize must be made by winner by 16 November 2025. If Cruise Prize winner fails to book Cruise Prize by this date the Promoter reserves the right to allocate the corresponding Cruise Prize to another winner drawn in accordance with these terms. 
13. Cruise Prize includes economy class return flights to/from Barbados from a P&O Cruises nominated UK airport, accommodation as set out above, onboard main meals (excluding speciality restaurants for which an additional charge will apply), access to entertainment options and use of most facilities onboard.
14. Cruise Prize does not include transportation to and from the winner and/or their guest’s homes to UK airport, travel insurance, drinks, spa treatments, shore excursions, luggage fees, personal expenses, or purchases made on board. 
15. It is the responsibility of Cruise Prize winner to ensure they and their guest have valid passports and travel insurance, meet all required travel requirements, and obtain any vaccinations and visas required to take part in the Cruise Prize. Cruise Prize winner and their guest are required to have adequate travel insurance as a condition of travel.
16. The Promoter’s booking conditions will apply to Cruise Prize. These can be viewed at: https://www.pocruises.com/legal-and-privacy/booking-terms-and-conditions
17. Cruise Prize is non-transferrable, non-exchangeable and no cash alternative is available. 
18. Should Cruise Prize become unavailable a substitute of equal value shall be provided by the Promoter. The Promoter reserves the right, at their discretion, to replace Prize (or part thereof) with an alternative prize of equal or higher value. In respect of a Cruise Prize, such alternative prize may take place on board a different vessel or during different dates if commercial considerations or other events outside the Promoter’s control require, such circumstances and events including but not limited to the cancellation or restriction of any Prize in accordance with any government-issued guidelines.

Winner

19. The Promoter will contact the winner by email or phone within 10 days of the Closing Date using the details provided when entering the Prize Draw. 
20. Should the Promoter be unable to contact the winner within 3 tries of first contact or should the winner be unable to accept the Cruise Prize, the Promoter reserves the right to award the Cruise Prize to an alternative winner, drawn in accordance with these terms and conditions. 

Limitation of liability

21. There are certain things for which the Promoter does not accept any liability to you. The Promoter cannot exclude or limit its liability for death or personal injury caused by its negligence, or loss caused by a false statement where the statement is made fraudulently. Otherwise, the exclusions described at clauses 2 and 23 will apply. References to the “Promoter” in these paragraphs include all of the Promoter’s associated companies, agents or any other third parties involved in the Prize Draw.
22. The Promoter will not be responsible for (and will have no liability in connection with) the following occurrences, to the extent that they occur for reasons beyond the Promoter’s reasonable control:
    1. any postponement or cancellation of the Prize Draw,
    2. any changes to the prize(s) or the way in which they can be used; 
    3. any act or default of any third-party supplier.
23. The Promoter does not accept responsibility for network, computer, hardware or software failure of any kind, which may affect the sending, receipt or processing of your entry.

Personal data

24. The Promoter will use the personal data you provide for the purpose of administering this Prize Draw and to facilitate the redemption of prize. 
25. If you have also elected to receive news, information and other marketing information from the Promoter you agree that the personal data you provide will also be used for this purpose.
26. By entering the Prize Draw you agree to the collection, retention, usage and distribution of your personal information for the purposes shown at clauses 24 and 25, above.
27. Personal data will be processed in accordance with the Promoter’s privacy notice available at www.pocruises.com/privacy.
28. For the purposes of this Prize Draw the Promoter is working with N2O Limited (UK Company registration number 03823730 and their appointed subcontractor Prizeology Limited (UK Company registration number 10584926). N2O and Prizeology will assist the Promoter in running and administering this Prize Draw. 
29. The surname and county of the prize winner will be available from the Promoter by sending an email including the name of the competition to prizes@pocruises.com within 60 days of the Closing Date. If you object to any or all of your surname, county and winning entry being made available, please contact the Promoter at prizes@pocruises.com. In such circumstances, the Promoter must still provide the information and winning entry to the Advertising Standards Authority on request.

General 

30. If the Promoter has grounds to suspect any entrant or third party of cheating, deception or fraudulent or unsportsmanlike conduct of any kind (including, without limitation, manipulating the Prize Draw, choice of prize winner(s) or any entry) the Promoter reserves the right (in its sole discretion) to disqualify any entrant, entry or person it reasonably believes to be responsible for, or associated with, such activity. The Promoter’s decision in such matters shall be final.
31. The Promoter reserves the right at any time and from time to time to modify or discontinue, temporarily or permanently, this Prize Draw with or without prior notice due to reasons outside its reasonable control. 
32. These terms and conditions shall be governed by English law, and the parties submit to the exclusive jurisdiction of the courts of England and Wales.