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Privacy Policy

Privacy Notice

Sarnia Yachts understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients, intermediaries and employees, and will only collect and use personal data in ways that are described here, and in a way that is consistent with our ob­li­gations and your rights under the law.

  1. What Does This Notice Cover?

This Privacy Information Notice explains how we use your personal data in line with the requirements of the European Union General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”): how it is collected, how it is held and how it is processed. It also explains your rights under the law relating to your personal data.

This privacy notice does not cover any third party websites reached via links on this website.  You are advised to read the privacy statements on the other websites you visit.

It applies to all personal data collected by any of the Sarnia Yachts associated companies including:

  • Sarnia Yachts Limited
  • Sarnia Yachts (Malta) Limited
  • Sarnia Yachts (Management) Limited
  • Sarnia Yachts Services Limited
  • Sarnia Crew Services Limited
  • Sarnia Yachts (Asia) Limited
  • Sarnia Manning Services Limited
  • Crew Services PCC Limited
  • European Crewing Limited
  1. How Do EU Regulations Apply To Guernsey? 

          Any company dealing with an EU citizen has to comply with the GDPR regulations, regardless of the country from which that company operates.  Also, in order to acquire recognition from the EU that Guernsey has equivalent legislation in place, the Island’s government has adopted the EU law as the basis for its own new data protection regulations.

  1. What Is Personal Data?

Personal data is defined by the GDPR as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identi­fica­tion numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 4, below.

  1. What Are Your Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10.

b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.

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

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

i) The right to withdraw your consent should this be the lawful basis under which your data is being processed.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commis­sioner’­s Office in Malta (www.idpc.org.mt) or Guernsey (www.dataci.gg).

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commis­sioner’­s Office.

  1. What Personal Data Do We Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us): 

 

·         Name

 

·         Date of Birth

·         Residential Address

 

·         Email Address

·         Place of Birth

 

·         Nationality & domicile

·         Photograph

 

·         Mobile number

·         Telephone number

 

·         Marital Status

·         Gender

 

·         Medical details

·         Profession

 

·         Regulatory status

·         Business name

 

·         Tax information

·         Payment information

 

·         Financial Information

·         Corporate information

 

·         Business interests

·         Educational or professional quali­fica­tions

 

·         Previous criminal convictions

·         Employment history

 

·         Education

·         Social media information

 

·         Copy of identi­fica­tion documents

·         Travel arrangements

 

·         Next of Kin details

        All of the personal data that we gather is risk rated according to its sensitivity with additional security measures in place for the most sensitive forms of data such as financial or medical information. 

  1. How Do We Use Your Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This will usually be because the data is necessary for our performance of a contract with you, or because we have an overriding legal obligation with which to comply. Your personal data may be used for one of the following purposes:

  • Performance of contractual terms:
  • Supplying our pro­duc­ts and/­or services to you. Your personal details are required in order for us to enter into a contract with you;
  • Perso­nalising and tailoring our pro­duc­ts and/­or services for you;
    • Commu­nicating with you. This may include responding to emails or calls from you;
    • Paying you or completing transactions on your behalf.
  • Complying with the requirements of various legal obligations:
  • Maritime regulations;
  • Fiduciary regulations;
  • Financial crime laws;
  • Employment laws;
  • Tax legislation.
  • If it is considered by Sarnia that it is in your vital interests:
    • Collating your personal details to enable relevant yacht insurance to be provided;
    • Retaining 3rd party contact details in case of misadventure;
    • To advise relevant parties for safety purposes.
  • In the legitimate interests of Sarnia, provided that those interests do not conflict with your rights under GDPR:
  • Facilitating your marine travel;
  • Safety purposes;
  • As part of the crew recruitment process;
  • Providing you with relevant industry updates.
  1. Do You Give My Data To Third Parties?

Yes, however, Sarnia will never provide your information to a third party without your consent unless that data falls into one of the categories above.  For example we are legally obliged to provide details of maritime qualifications to the yacht registry of the flag state of the vessel on which a crew member is operating.

We may sometimes contract with third parties to supply products and/­or services to you on our behalf. These may include payment processing, delivery, and marine travel. In some cases, those third parties may require access to some or all of your personal data that we hold.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our ob­li­gations, and the third party’s obligations under the law.

In some circum­stances, we may also be legally compelled to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  1. How Long Will We Keep Your Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for no longer than 10 years after the termination of our relationship with you, unless we have been legally compelled to retain the data by a Government Authority.

  1. How And Where Do We Store Or Transfer Your Personal Data?

The security of your personal data is essential to us and to protect your data we will only store your personal data in Guernsey or Malta, either physically or electronically.  We do not currently use cloud based data storage. Should it be necessary under the purposes outlined in section 6 above, your data may be sent outside of the EU. 

In addition, we take a number of important data security measures, including the following:

  • Secure company servers;
  • Password protection;
  • Internal restrictions on access to personal data;
  • Security autho­risa­tions;
  • Hard copies under lock and key;
  • Restricted access to Sarnia premises.
  1. How Can You Access Your Personal Data?

If you want to know what personal data we have about you; you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.  A Subject Access Request Form is available for you to use and is available in Appendix One of this policy document. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our ad­mi­nis­trative costs in responding.

We will respond to your subject access request within not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

  1. How Do You Contact Us?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Postal Address for requests in Guernsey:

The Data Protection Administrator

Sarnia Yachts

PO Box 657

La Plaiderie House

St Peter Port

Guernsey

GY1 3PR

Postal Address for requests in Malta:

The Data Protection Administrator

Sarnia Yachts (Malta) Limited

2/6 Market Street

Floriana

FRN 1082

Malta


Email address:

subjectaccessrequest@sarniayachts.com

  1. Changes To This Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website.