Privacy Notice
Yacht Intelligence Limited
 April 2024

Introduction

Yacht Intelligence Limited respects your privacy and is committed to protecting your personal data.  This privacy notice
is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. THIRD-PARTY LINKS
11. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
12. COMPLAINTS

Important information and who we are

Purpose of this privacy notice

This privacy notice gives you information about who we are and how we collect and use your personal data and about the
rights you have in connection with your personal data.

When we refer to website in this privacy notice we mean the website at this address: yacht-intelligence.com.

Who we are

Yacht Intelligence Limited is the controller and responsible for your personal data (referred to as Yacht Intelligence
Limited, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the
details set out below.

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact the data privacy manager in
the following ways:

Full name of legal entity: Yacht Intelligence Limited

Email address: sales@yacht-intelligence.com

Postal address: Unit C Belmore Hill Court Owslebury Hampshire SO21 1JW

Telephone number: +44(0) 23 8076 8555

The types of personal data we collect about you and your responsibilities

Personal data means any information about an individual from which that person can be identified.

The type of personal data we may collect, use, store and transfer depends on our relationship with you and the context
in which we obtain and use it.

We have grouped together the different kinds of personal data we may collect as follows:

• Identity Dataincludes your first name, last name, any previous names,
  title, date of birth and gender. 
• Professional Information Data includes, details of your
  professional online presence e.g. LinkedIn profile, your occupation and interests and professional information
  (such as job title, previous positions and professional experience).
• Contact Dataincludes billing address, delivery address, email address
  and telephone numbers.
• Financial Dataincludes bank account details.
• Transaction Dataincludes information relating to the matter in which
  you are seeking our services or purchasing our products.  As well as details about payments to and from you and
  other details of products and services you or your customers or other third parties have purchased from us.
• Technical Datadetails of your visits to our website including your
  internet protocol (IP) address, 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.
• Profile Dataincludes purchases or orders made
  by you or other third parties on your behalf, your interests, preferences, feedback and survey responses.
• Usage Dataincludes information about how you use our website,
  products and services, IT, communication and other systems, and other monitoring information e.g. if you leave a
  voicemail message.
• Marketing and Communications Dataincludes
  your preferences in receiving marketing from us and our third parties, details of the services you have
  specifically requested or that have been requested by third parties on your behalf and your communication
  preferences.

We also collect, use and share aggregated data such as statistical or demographic data
which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate
individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse
general trends in how users are interacting with our website to help improve the website and our service offering.

We do not collect any Special Categories of Personal Data about you (this would include
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any
information about criminal convictions and offences.

When we provide our services to you or have a business relationship with you, we may hold and use personal data about
you, your officers and/or your employees or other third parties.  When you provide personal data to us
relating to a third party you confirm that you have any necessary permission or authority to do
so.  You are also responsible for ensuring that the provision of that personal data complies with
data protection and other applicable law.

Our website is not intended for children and we do not knowingly collect data relating to children.

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 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). In this case, we may have to cancel a product or service you
have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us.You may give us your
  personal data by filling in forms including on our website or by corresponding with us by post, phone, email or
  otherwise. This includes personal data you provide when you:
• apply for or use our products or services;
• register a warranty;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions.As you interact with our
  website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We
  collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for
  further details.
• Third parties or publicly available sources.We will receive personal
  data about you from various third parties and public sources as set out below:
  • Identity, Contact and Transaction Data from third parties who have purchased our goods
    and/or services (e.g. where you require service support in respect of those goods and/or services).
  • Technical and Usage Data from analytics providers such as Google Analytics.
  • Contact and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from publicly available sources.

How we use your personal data

LEGAL BASIS

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the
following legal bases:

• Performance of a contract with you:Where we need to perform the
  contract we are about to enter into or have entered into with you.
• Legitimate interests:We may use your personal data where it is
  necessary to conduct our business and pursue our legitimate interests (e.g. provision of our services that we
  have agreed with a third party such as your employer or our customer; or to prevent fraud; or to enable us to
  give you the best and most secure customer experience).  We make sure we consider and balance any potential
  impact on you and your rights (both positive and negative) 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)
• Legal obligation:We may use your personal data where it is necessary
  for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation
  when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active
  agreement to use your personal data for a specified purpose, for example if you subscribe to an email
  newsletter.

Purposes for which we will use your personal data

We use personal data for a number of legitimate interests, including to provide and improve our services, administer our
relationship with you and our business or third party providers, for marketing and in order to exercise our rights and
responsibilities.  More detailed information about these legitimate interests is set out below.

• To register you as a new customer or register your warranty
• To provide products and/or services including:
  • Processing and delivering orders and customer management
  • Maintain and enhance our products and services
  • Manage payments, fees and charges
  • Collect and recover money owed to us
• To manage our relationship with you which will include:
  • Notifying you about changes to our terms or privacy notice
  • Asking you to leave a review or take a survey
  • Updating and enhancing customer records
• To enable you to partake in a prize draw, competition or complete a survey
• To administer and protect our business and our website (including troubleshooting, data analysis,
  testing, system maintenance, support, reporting and hosting of data)
• To deliver relevant website content and advertisements to you and measure or understand the
  effectiveness of the advertising we serve to you
• To use data analytics to improve our website, products/services, marketing, customer relationships
  and experiences
• To develop our business and the products or services we provide whether we are providing products
  or services to you or your employer or the organisation you represent or we have a business relationship with
  you
• To send you relevant marketing communications and make personalised suggestions and recommendations
  to you about goods or services that may be of interest to you or your employer or the organisation you represent
• Ensuring safe working practices, staff administration and assessments and to enforce or protect any
  of our rights, property or safety (or those of employees, customers or other third parties)

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which
we are using your data.

We do not use your personal data for automated decision making.

Direct Marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or
services from us and you have not opted out of receiving that marketing.

We may also analyse your Identity, Professional Information, Contact, Technical, Usage and Profile Data to form a view
on which products, services and offers may be of interest to you so that we can send you relevant marketing
communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any
marketing communications sent to you or by contacting us at any time.

If you opt out of receiving marketing communications you will still receive service-related communications that are
essential for administrative or customer service purposes for example relating to order confirmations, product/service
purchase, warranty registration, appointment reminders, updates to our Terms and Conditions, checking your contact
details are correct.

 

Cookies

For more information about the cookies we use, please see our Cookie Policy.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the list Purposes for which we will use your personal data above.

• Internal Third Partiesmeans entities in our group or who are
  affiliated to us.
• External Third Partiesmeans:
  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers,
    auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint
    controllers who require reporting of processing activities in certain circumstances.
  • Consultants and sub-contractors, acting as processors or joint controllers.
• 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 notice.

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.

International transfers

To deliver services to you, it is sometimes necessary for us to transfer your personal data outside the UK or the
European Economic Area (EEA) e.g.:

• With your and our service providers located outside the UK or the EEA;
• If you are based outside the UK or the EEA;
• If one of our External Third Partiesis based
  outside the UK or the EEA so their processing of your personal data will involve a transfer of data outside the
  UK or the EEA;
• If one of our members of staff needs to access it remotely while they are travelling outside the UK
  or the EEA.

These transfers are subject to special rules under European and UK data protection law. Whenever we transfer your
personal data out of the UK or EEA we will do so on the basis that one of the following conditions applies:

1. the country to which we transfer your data has been deemed to provide an adequate level of
   protection for personal data by the European Commission or the UK;
2. the transfer is necessary for the performance of the contract between us (or one of the other
   exceptions set out in the UK or EU General Data Protection Regulations);
3. a similar degree of protection is afforded to it which may include using specific data protection
   clauses which have been approved by the European Commission or the ICO; or
4. you have provided Explicit Consent (meaning consent which requires a very clear and specific
   statement (that is, not just action)) to the proposed transfer.

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.

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.

Your legal rights

You have rights under UK and EU data protection laws in relation to your personal data.

You have the right to:

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 in certain
circumstances. 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) as the legal basis for that particular use of your
data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we
have compelling legitimate grounds to process your information which override your right to object.

Direct marketing. You also have the absolute right to object any time to the
processing of your personal data for direct marketing purposes (see OPTING OUT OF
MARKETING ABOVE).

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:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• 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 products or
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.

No fee usually required

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.

Third-party links

Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling
those connections may allow third parties to collect or share data about you. We do not control these third party
websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the
privacy notice/policy of every website you visit.

Changes to the Privacy Notice and your duty to inform us of changes

We keep our privacy notice under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us, for example a new address or email address.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for
data protection issues (www.ico.org.uk). The EU General Data Protection Regulation also gives you the right to lodge a
complaint with a supervisory authority, in particular in the European Union (or EEA) State where you work, normally live
or where the alleged infringement of data protection laws occurred.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO or other supervisory
authority so please contact us in the first instance.