Privacy policy
SUPERYACHT PARTNERS respects your privacy and is committed to protecting
your personal data. This privacy policy will inform you as to how we look after your
personal data when you visit our website (regardless of where you visit it from) or
deal with us and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how SUPERYACHT PARTNERS
collects and processes your personal data through your use of this website, including
any data you may provide through this website or through your dealings with us.
This website is not intended for children and we do not knowingly collect data
relating to children.
It is important that you read this privacy policy together with any other privacy policy
or fair processing policy we may provide on specific occasions when we are
collecting or processing personal data about you so that you are fully aware of how
and why we are using your data. This privacy policy supplements other notices and
privacy policies and is not intended to override them.
Controller
SUPERYACHT PARTNERS is the controller and responsible for your personal data
(collectively referred to as the Company, “we”, “us” or “our” in this privacy policy).
We have appointed a data privacy manager 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
data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please
contact our data privacy manager in the following ways:
Full name of legal entity: SUPERYACHT PARTNERS
You have the right to make a complaint at any time. We would, however, appreciate
the chance to deal with your concerns before, so please contact us in the first
instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated 28th
May 2019. 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.
Third-party links
This 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 policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual
from which that person can be identified. It does not include data where the identity
has been removed (anonymous 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, last name, username or similar identifier, marital
status, title, date of birth and gender
Contact Data includes billing address, delivery address, email address and
telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details
of products and 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 this website.
Profile Data includes your username and password, your interests, preferences,
feedback and survey responses.
Usage Data includes information about how you use our website, products and
services
Marketing and Communications Data includes your references in receiving
marketing from us and our third parties and your communications preferences.
We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your
health, and genetic and biometric data). Nor do we collect any information about
criminal convictions and offences.
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 goods or services). In this case, we may have to cancel a product
or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity (contact details) by filling in forms
or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you
– apply for our products or services;
– request marketing to be sent to you; or
– give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will
automatically collect Technical Data about your equipment, browsing actions and
patterns. We collect this personal data by using cookies, server logs and other
similar technologies. We may also receive Technical Data about you if you visit other
websites employing our cookies. Please see our cookie policy on the website for
further details.
Third parties or publicly available sources. We will receive personal data about you
from third parties as set out below:
Identify and Contact Data from publicly available sources such as Companies House
and the Electoral Register based inside the EU.
4. 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 obligation.
The Glossary – Lawful Basis lists the types of lawful basis that we will rely on to
process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal
data although we will get your consent before sending third party direct marketing
communications to you via email or text message. You have the right to withdraw
consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, 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 for 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.
Purpose/Activity Type of data
Lawful basis for processing
including basis of legitimate
interest
To register you as a new
customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver any
services under your contract:
(a) Manage payments, fees
and charges
(b) Collect and recover money
owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
(a) Performance of a contract with
you
(b) Necessary for our legitimate
interests (to recover debts due to
us)
Communications
To manage our relationship
with you which will include:
(a) Notifying you about
changes to our terms or
privacy policy
(b) Asking you to leave a
review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance of a contract with
you
(b) Necessary to comply with a
legal obligation
(c) Necessary for our legitimate
interests (to keep our records
updated and to study how
customers use our
products/services)
To administer and protect our
business and this website
(including troubleshooting,
data analysis, testing, system
maintenance, support,
reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate
interests (for running our business,
provision of administration and IT
services, network security, to
prevent fraud and in the context of
a business reorganisation or group
restructuring exercise)
(b) Necessary to comply with a
legal obligation
To deliver relevant website
content and advertisements to
you and measure or
understand the effectiveness
of the advertising we serve to
you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our legitimate
interests (to study how customers
use our products/services, to
develop them, to grow our business
and to inform our marketing
strategy)
To use data analytics to
improve our website,
products/services, marketing,
customer relationships and
experiences
(a) Technical
(b) Usage
Necessary for our legitimate
interests (to define types of
customers for our products and
services, to keep our website
updated and relevant, to develop
our business and to inform our
marketing strategy)
To make suggestions and
recommendations to you
about goods or services that
may be of interest to you
(a) Identity
(b) Contact
(c) Technical
Necessary for our legitimate
interests (to develop our
products/services and grow our
business)
(d) Usage
(e) Profile
(f) Marketing and
Communications
Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising. We have established the following
personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view
on what we think you may want or need, or what may be of interest to you. This is
how we decide which products, services and offers may be relevant for you (we call
this marketing).
You will receive marketing communications from us if you have requested
information from us or purchased goods or services from us and you have not opted
out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any
third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time
by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a product/service purchase,
product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies. If you disable or refuse cookies, please note that
some parts of this website may become inaccessible or not function properly. For
more information about the cookies we use, please see cookie policy on the website
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please
contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and
we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required or permitted by
law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set
out in the table Purposes for which we will use your personal data above.
Internal Third Parties – any of our employees or officers insofar as reasonably
necessary for the purposes set out in the privacy policy
External Third Parties :
SUPERYACHT PARTNERS which provides operational/service coverage throughout
the United Kingdom
Professional advisors including lawyers, bankers, auditors and insurance services
based in the United Kingdom who provide legal, banking, accountancy and
insurance services.
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 policy.
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.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered or
disclosed. 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying any legal,
regulatory, tax, accounting or reporting requirements. We may retain your personal
data for a longer period in the event of a complaint or if we reasonably believe there
is a prospect of litigation in respect to our relationship with you.
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
unauthorised 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, regulatory, tax, accounting or other
requirements.
By law we have to keep basic information about our customers (including Contact,
Identity, Financial and Transaction Data) for six years after they cease being
customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights
below for further information.
In some circumstances we will anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes, in which case we
may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation
to your personal data.
You have the right to :
Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold about you
and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to
have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process it.
You also have the right to ask us to delete or remove your personal data where you
have successfully exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are required to erase
your personal data to comply with local law. Note, however, that we may not always
be able to comply with your request of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your particular
situation which makes you want to object to processing on this ground as you feel it
impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to process
your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us
to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we
have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, your personal data in a structured,
commonly used, machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us to use or where we
used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing carried
out before you withdraw your consent. If you withdraw your consent, we may not be
able to provide certain products or services to you. We will advise you if this is the
case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
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). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we could 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 could
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.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing
our business to enable us to give you the best service/product and the best and most
secure experience. We make sure we consider and balance any potential impact on
you (both positive and negative) and your rights before we process your personal
data for our legitimate interests. We do not use your personal data for activities
where our interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request
before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is
necessary for compliance with a legal obligation that we are subject to.