INTRODUCTION

This privacy policy sets out how Blue 7 Trading Ltd, T/A Seven Superyachts handles your personal data under the Data Protection Act (“DPA”) and the General Data Protection Regulations (“GDPR”).

For simplicity throughout this notice, ‘we’, ‘us’, and ‘our’ means Seven Superyachts.

This document sets out to explain:

• The types of personal data we may collect about you when you interact with us.

• How we may collect, use, and share your personal data.

• Our legal bases for using your personal data.

• How long we keep your personal data.

• How we protect your personal data.

• The countries to which we may transfer your personal data.

• Your rights regarding your personal data.

It is likely that we will need to update this privacy policy from time to time. The most current version will be available on our website.

WHEN WE MAY COLLECT YOUR PERSONAL DATA?

Circumstances in which we may collect your personal data include but are not limited to:

• When you wish to do business with us or to work for us.

• When you visit our website/app or submit your information via the website/app.

• When you ask us to provide you information about our services.

• When you ask us to provide you with information regarding a vessel or company that we represent.

• When you contact us by any means with queries, complaints etc.

• When you book any kind of appointment or meeting with us.

• When you engage with us on social media.

• When you download or install one of our apps.

• When you comment on or review our services.

• When you fill in any forms be they digital or hard copy.

• When you have given a third-party permission to share with us the information they hold about you.

• When we collect data from publicly available sources where the data is made public.

WHAT PERSONAL DATA DO WE COLLECT?

The types of personal data we collect about you depends on your relationship with us. For example, you may be a retail client, a business client or someone seeking employment with us.

The personal data may include, but is not limited to:

• Your contact details such as full name, title, postal addresses, email addresses, and telephone numbers.

• Personal data such as date of birth, nationality, gender, and facial image.

• Physical information such as dietary preferences, allergies, disabilities, and requirements related to those.

• Your current employer, position within that employment, and employment history.

• Proof of identity and background information in support of procedures relating to Know Your Client (KYC), recruitment, and internal commercial requirements.

• Financial information, such as bank account details, payment card details (without verification No.).

• Transactional data such as details of payments to and from your account with us; invoices, statements, and associated payments.

• Digital usage data regarding how you interact with us for the purposes of improving our services and helping to improve our business. For example:

  • Monitoring your views on our website. This may include collating details such as your IP address, your device data, and your general location.

  • Monitoring your interactions with us via social media, including your username(s).

  • Monitoring which third party websites and apps directed you to us.

  • Monitoring your receipt and opening of our email correspondence to you.

• Your communication preferences regarding marketing materials.

• Details of your yachting preferences.

HOW DO WE USE YOUR PERSONAL DATA?

For whatever reason you interact with us, we aspire to making it the best possible experience for you. Central to achieving that aim is making sure that we have all the relevant information. In such circumstances, privacy law sees it as in keeping with our ‘legitimate interest’ to handle your personal data in the pursuit of our commercial endeavours.

Ways in which we may use your personal data in alignment with our legitimate interest include, but are not limited to:

• As required in the sale or purchase process of a new or second hand vessel including but not limited to as may be required in relation to vessel title, VAT, legal documentation with future owners, vessel registration, lawyers, banks, and insurers.

• As required in the provision of any consultancy or other services for which we have been contracted be the contract in writing, verbal or howsoever agreed.

• As required for warranty purposes with the manufacturers of the vessel, engines, electronics, and component parts for the purposes of providing a warranty to you.

• In the course of our commercial endeavours to manage, administer and improve our provision of services and to administer any service or support which you have requested.

• To provide information requested by you. We may also keep a record of your requests to inform any future communication and to demonstrate how we communicated with you previously.

• To protect our business and you from fraud and other illegal activities.

• • To keep you informed about relevant products, services, and events that you may be interested in.

• To send you communications required by law. For example, legally required information relating to any service we have agreed to provide. These messages will not include any promotional content and do not require prior consent.

• To display relevant content to you on our website/app or via your browser, based on your consent to receive notifications and/or for our website to place cookies or similar technology on your device.

• As required, we may share your data with medical personnel should the need arise to protect your life.

• To comply with our contractual or legal obligations to share or store data, for example, where we are required to keep and maintain records, including invoice documentation, for the purposes of audit and review by HMRC.

• To process your application for a job and to follow up accordingly.

WHO DO WE SHARE YOU DATA WITH?

We sometimes share your personal data with partner companies and with trusted third parties.

The policy we apply to those organisations to keep your data safe and protect your privacy is as follows:

• We provide only the information they need to perform their specific services.

• They may only use your data for the exact purposes we specify in our contract with them.

• We work closely with them to ensure that your privacy is respected and always protected.

• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

• IT companies who support our website, app, and other business systems.

• Operational companies such as delivery couriers.

• Direct marketing companies who help us manage our electronic and printed communications with you.

• Data insight companies to ensure your details are up to date and accurate.

In very specific circumstances we may be required share your data with a third party for their own purposes. All such requests are assessed on a case-by-case basis and take your privacy into consideration. Examples include:

• For fraud management, we may share information about fraudulent or potentially fraudulent activity. This may include sharing data about individuals with law enforcement bodies.

• We may also be required to disclose your personal data to the police or other enforcement, regulatory or government body, in your country of origin or elsewhere, upon a valid request to do so.

WHERE YOUR PERSONAL DATA MAY BE PROCESSED

We may be obliged to transfer your personal data to locations outside the jurisdiction in which you provide it or in which you are resident. If we do this, our contract with the receiving party will state that they must follow the standards described in this privacy policy.

YOUR RIGHT TO ACCESS YOUR PERSONAL DATA

You have the right to request sight of personal data that we hold about you. Should you wish to proceed with a Data Subject Access Request (DSAR) please contact the Data Protection Officer by email at legal@sevensuperyachts.com. You will need to provide two forms of confirmation of your identity with this request which can include:

• Valid Passport.

• Driving license.

• Utility Bill or bank statement dated within the last 6 months.

YOUR RIGHT TO RESTRICT, OBJECT TO & WITHDRAW CONSENT

You are entitled to object to, restrict or completely withdraw your consent for us to use or hold your personal data at any time. Please be advised that where we are required by law to hold your data, we may not be able to remove it in line with your request.

HOW LONG DO WE KEEP YOU INFORMATION?

Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected.

We will delete your personal data from our systems unless we believe in good faith that we need to retain some information to place you on a ‘do not contact’ list or where the law or other regulation requires us to preserve it (for example, because of our obligations to tax or regulatory authorities).

CONTACTING THE REGULATOR

If you feel that your personal data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

You can contact the ICO by calling +44 (0)303 123 1113.

Or visit the ICO website at www.ico.org.uk/make-a-complaint. (Please note we cannot be responsible for the content of external websites).

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

ANY QUESTIONS

If you have any questions or if you are dissatisfied with any aspect of this privacy policy, please contact:

The Data Protection Officer, Seven Superyachts, Bank Chambers, Brook Street, Bishops Waltham, SO32 1AX, United Kingdom, or email the Data Protection Officer at legal@sevensuperyachts.com.