PRIVACY POLICIES

BACKGROUND:

TWW 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 the information you provide to us and We collect in the course of operating our business.

This Privacy Policy explains how TWW YACHTS, as a data controller, may collect, use, share and protect information that We obtain about you directly or indirectly 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 continued use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site and services immediately.

From time to time, there may be more than one data controller of your information within our group where you have engaged different parts of our broader organisation to provide different or jointly delivered services.

This Privacy Policy does not apply to, and TWW YACHTS is not responsible for, any third-party websites which may be accessible through links from this website (please see Section 14 (Online services – Links to third party sites, services and content) below for more information).

1. Scope of Privacy Policy

This Privacy Policy explains and describes:

1. Definitions and Interpretation.

2. Definitions and Interpretations.

3. Information About Us

4. Your Rights.

5. What Data Do We Collect?

6. Legal basis for usage of personal data.

7. How Do We Use Your Data?

8. International Transfers

9. Retention of your data

10. Security

11. Do We Share Your Data?

12. How Can You Control Your Data?

13. Our Use of Cookies

14. Online Services – Links to third party sites, services and content

15. Status of this policy

2. 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;

“Applicable Data Privacy Laws”

means the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and the UK’s Data Protection Act 2018;

“Online Services”

Means Our Site and any other website, mobile app or other online service created or hosted by us from time to time on which this Privacy Policy appears;

“Our Site”

https://www.twwyachts.com/, www.twwcrew.com

“personal data”

means any information that can be used to identify you or that we can link to you; and

“We/Us/Our”

means the following three companies: TWW YACHTS SARL registered in Monaco under RCI 14S06326, whose registered address is Le Panorama, 57 Rue Grimaldi, MC 98000 Monaco, and TWW 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 and TWW YACHTS (CM) LIMITED, a limited liability company registered in in England under company number 12827171, whose registered address is 10 John Street, London, UK, WC1N 2EB, and TWW CREW SARL, a limited liability company registered in France under company number 852 901 099, whose registered address Galerie du Port 26 Rue Lacan, 06600 Antibes.

3. Information About Us

If you have any questions, concerns or comments about this Privacy Policy, or want to submit a written complaint about how we handle your personal data, please contact us below.

Our Site is owned and operated by Us.

Our Data Privacy 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.

4. Your Rights

4.1 Under applicable data protection legislation, we have a duty of care to ensure that your personal data is accurate and up to date. Therefore, please contact us to update or correct your information if this changes or if you believe that any information that we have collected about you is inaccurate at info@twwyachts.com.

4.2 Where you have consented to our processing of certain personal data, you can at any time withdraw such consent and/or tell us not to contact you with updates and information regarding our products and services (or part of them) either at the point such information is collected (by leaving the relevant box unticked) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. Please note that where you withdraw your consent, we will no longer be able to provide you with the products or services that rely on having your consent. You can also exercise this right at any time by contacting us using the contact details at the end of this Privacy Policy.

4.3 You can request:

4.3.1 access to the personal data we hold about you;

4.3.2 corrections or updates to your details;

4.3.3 the erasure of your personal data;

4.3.4 the portability of personal data that you have provided to us in a structured, commonly used and machine-readable format.

4.4 If you would like to exercise any of the rights set out in this section, please contact us using the details set out in Section 3 above. We may refuse to provide access where we have legitimate reasons for doing so under applicable data privacy laws, and in exceptional circumstances may charge a fee for access if the relevant legislation allows us to do so, in which case we will provide reasons for our decision.

4.5 If you have any cause for complaint about Our use of your personal data, please contact Us in the first instance using the details provided in Section 3 and We will do Our best to solve the problem for you.

4.6 If We are unable to help, you also have the right to lodge a complaint with either Monaco’s, France’s or the UK’s supervisory authority, as applicable.

5. What Data Do We Collect?

5.1 Depending upon your use of Our Site, We may collect some or all of the following personal data (please also see Section 13 on Our use of Cookies):

5.1.1 name;

5.1.2 contact information such as email addresses, telephone numbers and residential address;

5.1.3 IP address;

5.1.4 employment;

5.1.5 web browser type and version;

5.1.6 operating system;

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

5.2 We collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you sign up for or request that we send you newsletters, alerts, or other materials; when you sign up for a webinar or event; and when you respond to our communications or requests for information.

5.3 We may also collect personal data from third parties such as your employing organisation, regulatory authorities, recruitment agencies, credit reporting agencies, information or service providers, publicly available records, and the third parties described in Section 11 (Do we share your data?) below.

5.4 We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review.

5.5 We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so.

5.6 If you apply for a job or work placement with TWW YACHTS then you may need to provide information about your education, employment, racial background and state of health. As part of your application, you will be asked to provide your express consent to our use of this information to assess your application and to allow us to carry out both recruitment analytics and any monitoring activities which may be required of us under applicable law as an employer. We may also carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions.

5.7 We may exchange your personal data with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics providers, referees and your current and previous employers. We may also gather additional information about you from publicly available resources such as LinkedIn or other social or professional media platforms and collate this with the information that you provide to us. Without your personal data, we may not be able to progress considering you for positions with us.

6. Legal basis for usage of personal data

Where we intend to use your personal data, we rely on the following legal grounds:

6.1 Performance of a contract: We may need to collect and use your personal data to enter into a contract with you or to perform a contract that you have with us.

6.2 Legitimate interests: Where we consider use of your information as being (a) non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own, or a third party’s legitimate, we may use your personal data, which may include:

6.2.1 for our own direct marketing or continued communication;

6.2.2 the prevention of fraud;

6.2.3 our own internal administrative purposes;

6.2.4 personalisation of the service(s) we provide to you;

6.2.5 ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems; and/or

6.2.6 reporting possible criminal acts or threats to public security to a competent authority.

6.3 Compliance with a legal obligation: We may be required to process your information due to legal requirements, including employment laws, tax laws and other regulatory provisions applicable to TWW YACHTS as a provider of Maritime services.

6.4 Consent: You may be asked to provide your consent in connection with certain services that we offer, for example in respect of any processing of your personal data for our marketing purposes where you or your employing organisation is not a client of TWW YACHTS, or in respect of certain special categories of personal data such as your health or racial background for which we are legally obliged to gain your consent due to the sensitive nature of such information and the circumstances in which it is gathered or transferred. Where we are reliant upon your consent, you may withdraw this at any time by contacting us in accordance with Section 3 (Information About Us) below, however please note that we will no longer be able to provide you with the products or services that rely on having your consent.

7. How Do We Use Your Data?

7.1 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 and in accordance with the legal basis set out above in Section 6 (Legal basis for usage of personal data).

7.2 Specifically, We may use your data for the following purposes:

7.2.1 Personalising and tailoring your experience on Our Site;

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

7.2.3 Personalising and tailoring Our products and services for you;

7.2.4 to carry out our obligations arising from any contracts entered into between you and us;

7.2.5 to facilitate our internal business operations, including to fulfil our legal or regulatory requirements;

7.2.6 for business purposes, including data analysis, submitting invoices, detecting, preventing and responding to actual or potential fraud, illegal activities, or intellectual property infringement;

7.2.7 to maintain and update our records including out database of contacts;

7.2.8 Replying to emails and enquiries from you;

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

7.2.10 To evaluate, recruit and hire personnel;

7.2.11 To ensure that content from our online services is presented in the most effective and secure manner for you and the device on which you are accessing our services, and to troubleshoot, and improve such online services;

7.2.12 For research, planning, service development, security or risk management; and

7.2.13 As we believe reasonably necessary or appropriate to comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protect your, our, or others’ rights.

7.3 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.

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

7.5 We may not be able to do some or all of our services without your personal data.

7.6 If at any time we intend to change the purpose for which we hold your personal data, for example to offer you with a complimentary service that we may provide in the future, we will give you prior information of that new purpose, so you are aware of this.

8. International Transfers

8.2 Where you are submitting personal data from within the European Economic Area (“EEA”), such information may be transferred to countries outside the EEA.

8.3 By way of example, this may happen if one or more of our third-party service providers with whom we share personal data in accordance with Section 11 (Do we share your data) are located, or have their servers located, outside your country or the country from which the data were provided.

8.4 If we transfer your information outside the EEA in this way, 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.

9. Retention of your data

We retain the information we collect for no longer than is reasonably necessary to fulfil the purposes that such data was originally collected in accordance with our internal data retention polices or to comply with our legal and regulatory obligations.

10. Security

10.1 We take steps to hold information securely in electronic or physical form.

10.2 Our information security policy is supported by a variety of processes and procedures, and we store information in access-controlled premises or electronic databases requiring logins and passwords. All employees, officers or contractors of TWW YACHTS and third-party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards.

10.3 Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services which is at your own risk.

10.4 If you communicate with us using non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.

10.5 Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.

11. Do We Share Your Data?

11.1 We may exchange your personal data with third-party service providers contracted to TWW YACHTS where any of the following apply:

11.1.1 You have consented to us sharing your personal data in this way.

11.1.2 We deem it reasonably necessary to provide you with the services that you have required at any particular time.

11.1.3 Such sharing is provided for under contract, including our terms and conditions for any particular service that we may provide to you.

11.1.4 Such sharing is to law enforcement bodies or other government authority.

11.1.5 We need to enforce or apply our terms and conditions to which you have agreed (or other terms that have been agreed to apply to our relationship with you or your employing organisation).

11.1.6 It is necessary to protect the rights and interests, property, or safety of TWW YACHTS, our clients or others.

11.1.7 It is relevant in the circumstances to disclose the information to parties with whom we have co-promotional arrangements (such as jointly sponsored events, external venues, or caterers).

11.1.8 Our agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.

11.1.9 We use third party service providers to provide services that involve data processing, for example archival, web-hosting, analytics providers in connection with the operation of our online services, event hosting, information technology providers, auditing, reference checking, professional advisory (including legal, accounting, financial and business consulting), mailing vendor, delivery, technology, website, research, banking, payment, client contact, data processing, insurance, forensic, litigation support, marketing and security services.

11.1.10 All, or most, of the assets of TWW YACHTS or any single business unit within TWW YACHTS are merged with or acquired by a third party, or we expand or re-organise our business, in which case your personal data may form part of the transferred or merged assets.

11.1.11 We are under a legal, regulatory or professional obligation to do so (for example, in order to comply with a Court Order).

11.2 Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on TWW YACHTS’ behalf. When such third parties no longer need your personal data to fulfil this service, they will dispose of such details in line with TWW YACHTS’ procedures unless they are themselves under a legal obligation to retain information (provided that this will be in accordance with applicable data privacy laws). If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

11.3 We also provide anonymous statistical information about users of our websites and related usage information to reputable third parties, including analytics and search engine providers.

11.4 We own the database rights in the information collected via our online services. We do not sell, rent, or otherwise share information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Privacy Policy or with your express prior permission.

11.5 We may disclose your data to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger, acquisition, restructuring or insolvency of any part of our business, provided that we inform any recipient that it must use your personal information only for the purposes disclosed in this Privacy Policy.

11.6 We may share information that does not reasonably identify you or your organisation as permitted by applicable law.

12. How Can You Control Your Data?

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.

13. 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.

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.

How do 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.

We may, for example, collect information about the type of device you use to access our online services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on our online services, the web pages you view immediately before and after you access our online services, whether and how you interact with content available on our online services, and the search terms you enter on our online services.

TWW YACHTS website sets cookies which remain on your computer for differing times. Some expire at the end of each session and some remain for longer so that when you return to our website, you will have a better user experience.

Your choices regarding cookies

Web browsers allow you to exercise some control of cookies through the browser settings. Most browsers enable you to block cookies or to block cookies from particular sites. Browsers can also help you to delete cookies when you close your browser. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org which includes information on how to manage your settings for the major browser providers 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.

14. Online Services – Links to third party sites, services and content

14.1 In addition to our online services, which we control directly, we also use and provide links to websites which are controlled by third parties, which may include:

14.1.1 Twitter, LinkedIn and YouTube, where we have certain TWW YACHTS accounts and profiles.

14.1.2 Facebook, where we have a social page.

14.1.3 Instagram.

14.2 If you use or follow a link to any of these third-party websites, please be aware that these websites have their own privacy policies and that we cannot accept any responsibility for their use of information about you.

14.3 Our online services may include integrated content or links to content provided by third parties (such as video materials). This Privacy Policy does not address the privacy, security, or other practices of the third parties that provide such content.

14.4 We engage third parties that support the operation of our online services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms. Please see Section 13 (Our Use of Cookies) above for more information.

15. Status of this Policy

15.1 Your provision of personal data to us or use of our online services constitutes your acceptance of the terms of this Privacy Policy.

15.2 As technologies and information governance practices develop, and data privacy laws (and surrounding guidance) evolve, we may need to revise this Privacy Policy. You should therefore review this page regularly to ensure that you are aware of any changes to its terms.

15.3 We will post any Privacy Policy changes on this page and, if the changes are significant or may materially impact upon your rights, we will provide a more prominent notice or contact you by other means (including, for certain services, email notification of Privacy Policy changes).

Date of last update: April 2021