Privacy Policy

BY: TWW

DATE: 5/16/2018

What we do with your personal data

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PRIVACY POLICY



BACKGROUND:

THOMPSON WESTWOOD WHITE YACHTS understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.twwyachts.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

 

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

 

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

 

“Account” means an account required to access and/or use certain areas and features of Our Site;

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;

“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our” means the following three companies: THOMPSON WESTWOOD WHITE YACHTS SARL registered in Monaco under RCI 14S06326, whose registered address is 57 Rue Grimaldi, MC 98000 Monaco, and THOMPSON WESTWOOD WHITE YACHTS LIMITED, a limited company registered in England under company number 10788116, whose registered address is 10 John Street, London, UK WC1N 2EB and TWW YACHT MANAGEMENT LIMITED, a limited company registered in England under company number 11046191, whose registered address is 10 John Street, London, UK, WC1N 2EB.

 

2. Information About Us

2.1 Our Site is owned and operated by Us.

2.2 Our Data Protection Officer is Pauline Mackie, and can be contacted by email at pauline@twwyachts.com, by telephone on +377 97 77 67 57, or by post at 57 Rue Grimaldi, 98000 Monaco.

 

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

 

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;

4.1.2 The right of access to the personal data We hold about you (see section 12);

4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to Us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with either Monaco’s or the UK’s supervisory authority.

 

5. What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal data (please also see section 12 on Our use of Cookies and similar technologies):

5.1 name;

5.2 contact information such as email addresses and telephone numbers;

5.3 IP address

5.4 web browser type and version;

5.5 operating system;

5.6 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

 

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 Personalising and tailoring your experience on Our Site;

6.2.2 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);

6.2.3 Personalising and tailoring Our products and services for you;

6.2.4 Replying to emails from you;

6.2.5 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time.

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone or post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

6.5.1 Inactivity or no communication between the data subject and Us, with who we do not have a contractual relationship, for a period of two years will result in the personal data to be deleted.

 

7. How and Where Do We Store Your Data?

7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR and the EU-US Privacy Shield.

7.2 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.


8. Do We Share Your Data?

8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.

8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

 

9. How Can You Control Your Data?

9.1 When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.

 

10. Your Right to Withhold Information

10.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

10.2 You may restrict Our use of Cookies. For more information, see section 12 and Our Cookie Policy.

 

11. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable, and We will provide any and all information in response to your request free of charge. Please contact Us for more details at pauline@twwyachts.com, or using the contact details below in section 13.

 

12. Our Use of Cookies

Our Site uses cookies which allow us to monitor the use of our website. This is for analytical purposes only and the information we gather cannot be used to identify you as an individual. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services.

12.1 What are cookies?

Cookies are a small text file sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognise you and make your next visit easier and the service more useful to you.

12.2 How we use cookies

When you use and access our website, we may place a number of cookies files in your web browser. We use cookies for the following purposes: to improve your experience, to provide analytics and to store your preferences.

12.3 Your choices regarding cookies

If you would like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

 

13. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at pauline@twwyachts.com, by telephone on +377 97 77 67 57, or by post at 57 Rue Grimaldi, MC 98000 Monaco. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

 

14. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

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