Introduction
Welcome to the Salamander Voyages Ltd’s privacy policy.
Salamander Voyages Ltd respects your privacy and is committed to protecting your personal data. Salamander Voyages Ltd is a “data controller”, which means that we are responsible for deciding how we hold and use your personal data.
This privacy policy has been issued to you because you are a customer or prospective customer of Salamander Voyages Ltd. The purpose of this privacy policy is to make you aware of how and why your personal data will be used, namely for the purposes of providing charter services by the Company for the chartering of vessels and further to advise how long your personal data will typically be retained for.
This privacy policy provides you with certain information that must be provided under the General Data Protection Regulation ((EU 2016/679) (GDPR) as retained by EU Withdrawal Act (2018) (EUWA) and as amended pursuant to shall then be amended pursuant to the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 (DP Brexit Regulations).
It is important that you read this notice, together with any other privacy notices we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Definitions
Here are some key terms that are used in this privacy policy:
We, us, our: Salamander Voyages Ltd (Company Number NI667527)
Data privacy manager: Tess Wills
Personal data: any information about an individual from which that person can be identified
Special category personal data: Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, data concerning health, sex life or sexual orientation
Legislation: any reference to a statute or statutory provision is a reference to it as it is in force for the time being, taking account of any amendment, extension, or re-enactment and includes any subordinate legislation for the time being in force made under it
1. THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you in connection with the charter services we provide, which we have grouped together as follows:
· Initial Data: includes the information you have provided to us within your quotation request or enquiry
· Identity Data: includes first name, maiden name, last name, marital status, title, date of birth and gender together with the information required so that we may verify your data and place your booking, primarily your passport details
· Contact Data: includes billing address, email address and telephone numbers
· Financial Data: includes bank account and payment card details
· Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences
We may also collect store and use the following “special categories” of more sensitive personal information so as to inform the crew on the vessel of any health and safety requirements, subject to your health condition:
· Health: information about your health, including any medical conditions, health and sickness records, allergy information (including food allergies or intolerances) or physical disability or specific physical needs for access and egress from the vessel
· Nationality
2. HOW IS YOUR PERSONAL DATA COLLECTED?
We collect personal data in relation to you from the following sources:
• You
• Your party member that is making a booking on your behalf
• Your bank or building society
• Where relevant, your doctor, medical and occupational health professionals
3. 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
· To take steps at your request before entering into a contract
· 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 or regulatory obligation
· Where you have given consent (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 in the table below a description of all the ways we plan to use your personal data and our reasons for doing so
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.
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 will not be able to perform the contract we have or are trying to enter into with you.
How we use special category data
We will use your particularly sensitive personal information only in ways that are necessary for us to deal with your booking so as to ensure your safety aboard the vessel.
4. 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 and Contact 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 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 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 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 service.
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.
· External Third Parties as set out in the Glossary
· Specific third parties as set out in the Glossary
· 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
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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 Secretary of State.
· Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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:
• 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:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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; or
(d) 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 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 at [email protected]
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
10.1 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.
10.2 THIRD PARTIES
External Third Parties
· Service providers acting as processors based in the EU, Turkey, Montenegro and the Caribbean States who provide IT and system administration services.
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Turkey, Greece, Montenegro and Croatia who provide consultancy, banking, legal, insurance and accounting services.
· HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and Turjeywho require reporting of processing activities in certain circumstances.
Specific Third Parties
Shall include the following companies and organisations, being organisations with whom we charter vessels and require your personal data for the purposes of fulfilling our contract with you.
• DM Yachting Montenegro
• Songbird Yachting UK
• Aganlar Tersanesi Bodrum, Turkey
• Salamander Gulet Bodrum Turkey
• Bodrum Tour Travel & Yachting
• Oncu Yachting Bodrum Turkey
• Nautilus Yachting
There may be other companies or organisations not listed with whom we charter vessels from on a one off basis. In such circumstances we shall advise you of said company or organisations’ identity
