Smart Yachts International Limited (
we,
us or
our) understand the importance of keeping your data secure, which is why we are committed to protecting and respecting your privacy at all times.
This Privacy Policy, along with any other documents referred to in it, sets out the basis for the personal data we collect from you, how we process it and how you can ammend it.
Please read the following information carefully to ensure you understand all the ways in which your personal information is processed. This privacy notice supplements any other notices we may issue from time to time and is not intended to override them.
If you are unhappy with anything in this Privacy Policy please either contact our data privacy manager or navigate to an alternative website. By browsing or interacting with www.smartyachtsinternational.com you are consenting to the practices described in this policy.
1. Controller
1.1 Smart Yachts international is the controller responsible for your personal data.
1.2 We have appointed a data privacy manager who is responsible for overseeing any questions that arise from this Privacy Policy. If you need to contact this person, including any requests to exercise your legal rights, please do so using the details set out in section
2. Contact Details
Legal Entity: Smart Yachts International Limited
Email address: gdpr@smartyachtsinternational.com
Postal address: The Maltings, Allendale, NE47 9EE, UK
2.1 You have a legal right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. What data do we collect about you?
3.1 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).
3.2 We may collect, use, store and transfer different kinds of personal data about you:
3.2.1 Identity Data: including first name, last name, job title, username or similar identifier, your signature, title, date of birth and gender.
3.2.2 Contact Data: including billing address, email address and telephone numbers.
3.2.3 Technical Data: including 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 our website.
3.2.4 Profile Data: including your username and password, your interests, preferences, feedback, survey responses, and correspondence.
3.2.5 Usage Data: including information about how you use our website, products and services.
3.2.6 Marketing and Communications Data: including your preferences in receiving marketing from us and your communication preferences.
3.3 We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3.4 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).
4. How do we collect your data?
4.1 There are various ways you can provide us with information, including, identity, contact, financial and profile data when browsing our website. This data is most likely provided when you:
4.1.1 Enquire about a product or service;
4.1.2 Create an account on our website;
4.1.3 Request marketing information; or
4.1.4 Fill in an online form or survey on our website.
4.2 When you interact with our website we may automatically collect technical information about your equipment and browsing patterns. We collect this data by using cookies and similar technologies. Please refer to section 6 for more information on cookies.
4.2.1 Much of this technical information is collected automatically by Google Analytics, their privacy policy can be found here:
https://policies.google.com/privacy
4.3 We may also receive information about you from various third parties, including social media sites, credit reference agencies and analytics providers.
5. How we use your information
5.1 We only use your personal data to the extent permitted by law. Most commonly it is used in the following circumstances:
5.1.1 To complete obligations that arise from contracts entered in to between you and Smart Yachts International. Information is used to deliver the service that you request from us.
5.1.2 To comply with a legal or regulatory obligation.
5.1.3 To offer information about alternative services that are similar to those you have enquired about, provided consent is given.
5.1.4 To provide you with information regarding promotions, new software lines and news about our company, provided consent is given.
5.1.5 To improve our website and ensure content is presented in a suitable way for your computer/device.
5.1.6 To administer our website, including trouble shooting, data analysis, testing and research. Historical data collected by Google Analytics is preserved in order that we can segment effectively for marketing analysis.
5.1.7 To assist in keeping our website safe and secure.
5.2 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us or clicking the Unsubscribe link within any marketing email we send.
5.3 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.
5.4 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 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.
6. Cookies
6.1 In common with many other websites, we make use of cookies. Cookies assist us in ensuring our website looks as good as possible and is easy to use.
6.2 A cookie is a small file of letters and numbers that a website puts on your computer (if you agree) so that it can remember something about you at a later time. Cookies allow us to recognise if you have visited our website before and remember your preferences. Cookies also help us to collect information on how you are using our website so we can deliver an improved service and ensure relevant information is provided to you.
6.3 You can block cookies at any time by activating the setting on your internet browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts or all of our website. Some of the cookies we use improve the functionality of our website, so if you choose to disable cookies on your browser, you might find that you can’t access some aspects of our website, or that parts of the website don’t function in the way that you might expect them to.
6.4 We are required by law to provide you with a clear and comprehensive statement on how we use cookies, if the information provided here does not answer all of your queries please contact us at gdpr@smartyachtsinternational.com.
6.5 We use cookies to help us distinguish you from other website users and log in to secure areas of our site. Our cookies do not store information that could be used to identify you personally, such as your contact details or financial information.
6.6 We use the following cookies:
6.6.1 Strictly Necessary Cookies:These are necessary for the correct operation of our website. These include cookies to enable you to login to secure areas.
6.6.2 Analytical Cookies:These allow us to recognise and count the number of visitors to our site and assess how these visitors interact with and navigate the pages. They help us improve the user experience and help us ensure you can find what you’re looking for.
6.6.3 Functionality Cookies:These allow us to recognise you when you return to our website. We can then offer personalised content and remember your preferences.
6.6.4 Targeting Cookies:These log your visit to our website, the pages you have visited and the links you’ve followed. This is used to make our website and subsequent advertising more relevant to you and may be shared with third parties for the purpose of targeted advertising.
7. Disclosure of your information
7.1 In some circumstances we may have to share your information with third parties:
7.1.1 To assist in the provision of our website, including analytics and search engine providers, review collectors and software providers.
7.1.2 With 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 only use your personal data in the same way as set out in this privacy notice.
7.2 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.
7.3 Unless we are required to share your personal data by law, we will not otherwise share, sell or distribute any of the information you provide to us. In some circumstances we may have a duty to disclose personal data in order to enforce our Terms and Conditions, or to protect our rights, property, customers or staff. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.
7.4 We will get your express opt-in consent before we share your personal data with any company outside of Smart Yachts International for marketing purposes.
8. Where we store your data
8.1 All our data is stored on industry leading external secure servers.
8.2 We have put in place all reasonable and 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.
8.3 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements
8.4 Smart Yachts International Limited is registered and operates from the UK within the European Economic Area (EEA). Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
8.4.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
8.4.2 Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
8.4.3 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
8.5 You are responsible for keeping your account password secure, we ask you not to share this with anyone and to keep it confidential. Passwords can be changed by logging in to your account. We take no responsibility for unauthorized use of your account.
9. Your rights
9.1 This Privacy Policy is written in accordance with the Data Protection Act (UK) and the General Data Protection Regulation (EU).
9.2 You have the right to interact with our website without opting in to marketing from Smart Yachts International. If you do choose to opt in to marketing you can withdraw consent at any time either by managing your preferences in your account or by utilising the unsubscribe option on any marketing email.
9.3 You can check the data we hold about you either by logging in to your online account, or by emailing gdpr@smartyachtsinternational.com. The easiest way to make changes to your personal information is by logging in to your account. You can also email changes to us and these will be processed within 28 days.
9.4 Right to erasure:
9.4.1 Under the General Data Protection Regulation (GDPR) you have the right to have personal data erased
9.4.2 If you wish to have your information removed please contact our Data Protection Officer by email at gdpr@smartyachtsinternational.com. Requests will be dealt with in a timely fashion but we reserve the right to take up to one month to respond to requests. Requests will be denied if we have a legal obligation to hold the data.
9.5 You have a right to complain to a supervisory authority if you believe we have handled your information incorrectly. Please visit the Information Commissioner’s Office (ICO) website here
https://ico.org.uk/ for more information. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
10. Third party websites
10.1 You may have arrived at our website through a referring website. We have no control over the personal data these websites collect and advise you to read their terms of service and privacy policy to ensure you are aware what data they collect from you.
10.2 Our site may contain links to other websites or applications. If you follow a link from our site to any other website it may allow third parties to collect or share data about you. Please note that these sites have their own privacy policies and we recommend you read these before using the website or service. We do not accept any responsibility or liability for the content of third party privacy notices.
11. Updates to our Privacy Policy
11.1 This Privacy Policy was last updated on 24
th March 2020.
11.2 We reserve the right to amend this Privacy Policy. Please check back frequently to ensure you are aware of any updates or changes made.
11.3 It is important that the personal data we hold about you is accurate and correct. Please keep us informed of any changes during your relationship with us.
