This Policy was last updated on 24 May 2018 to take into account new requirements under the General Data Protection Regulation regarding how we inform you about the ways in which we use your personal data, and your rights in relation to that data. Any changes we make to this Policy in the future will be posted on this page. You can also obtain an up to date copy of this Policy from any of our locations or by contacting us using the details set out in section 1 below.
About us and how to contact us
In this Policy “Princess Motor Yacht Sales”, “we” or “us” refers to each of Orca Marine Leisure Limited and its subsidiary companies Argo Nautical Limited, Argo Nautical Yachting S.L.U and Argo Nautical GmbH. We are authorised distributors of the Princess and Chris Craft brands.
You can contact us on any matters relating to your personal data by emailing email@example.com or by writing to Data Compliance, Argo Nautical Limited, 6 Athena Court, Athena Drive, Tachbrook Park, Warwick, CV34 6RT.
What personal data do we collect and why
We collect information from you when you visit our websites or premises, attend boat shows and other marketing events, purchase something from us, enquire in person about our products (motor yachts, luxury boats, parts and accessories) or services, contact us by telephone, email or other means, or respond to a communication from us. We may also receive information about you from the relevant vessel manufacturer. The provision of information to us is largely voluntary; however, if you do not provide us with Transaction information or Preference information, we may not be able to fulfil your order or provide you with updates.
|Category of personal data||Examples of your personal data|
|Contact information||Name, Address, Email Address, Telephone Number.|
|Vessel information||Details of your new and/or existing vessel.|
|Transaction information||Contact information, together with purchase details, delivery details, payment details, any communications we have about your purchase. In the case of charter services this may include specific additional information such as passport details, relevant medical conditions and emergency contacts.|
|Legal information||Fraud checks or flags raised about your transactions, payment card refusals, complaints, copies of documents you provide to prove your identity where the law requires this.|
|Preference information||Your marketing preferences, your account settings including any default preferences, any preferences we have observed, such as the types of offers that interest you, or the areas of our website that you visit.|
|Communications||Communications we may have with you, whether relating to a transaction or not.|
|Voluntary information||Any voluntary information you provide us with, such as hobbies and interests, and responses to surveys.|
|Observed information||Details of your online browsing activities on our website, such as the pages, products or areas of our website that you visit, or which link has brought you to our website from our email communications or third-party websites.
This information may be identifiable to you because you are logged in to your account, or because we have collected details of your IP address or the device that you have used to access the website. This may also give us the geographic region which your device reports that you are located in.
CCTV footage at our premises.
We use the data we collect about you for various purposes. European data protection legislation sets out specific “lawful bases” for processing personal data. The basis on which we process different information about you and the purpose of that processing are explained below.
|Lawful basis and purpose||What personal data do we use?|
|Consent: To send you direct marketing in accordance with the preferences you select when you sign up to receive updates, purchase products, or via our preferences centre.||Contact information, Preference information, Communications, Voluntary information|
|Entering into and performance of our contract with you: To discuss and negotiate a transaction, fulfil your order, take payment and deliver your products or services to you, register a vessel with the marine authorities (where applicable), to deal with any complaints or any after sales services, including for warranty purposes.||Vessel information, Transaction information Preference information Communications, Voluntary information|
|Complying with legal obligations: To confirm your identity, keep records required by law or to evidence our compliance with laws, including tax laws, consumer protection laws and data protection laws. To provide information to law enforcement agencies or other authorities where we are required to do so.||Potentially any category (where relevant)|
|Our legitimate interests: For our internal business administration, to manage customer accounts, including keeping general records of customers, sales, customer care and other interactions, and to protect genuine customers and our business from fraud. This is necessary in order for us to operate efficiently, deal with any issues which may arise and to protect ourselves against any future legal claims and ourselves and others against fraudulent transactions.||Vessel information, Transaction information, Legal information, Preference information, Communications|
|Where you are an existing customer or have been in discussions to purchase products, to provide you with updates and promotional offers about our products and/or services, and invitations to events, where you have not opted out of receiving such communications from us. This is necessary to support our commercial objectives. We will ensure that we are providing you with relevant details of our products and services where these are of interest to you. They will only ever be sent in line with your stated preferences and interests and you can update your preferences at any time.||Contact information, Preference information, Communications, Voluntary information|
|Similarly, if you are not an existing customer but have previously enquired about our products or services, to market to you by post or telephone unless you have asked us not to do so.||Contact information, Preference information, Communications, Voluntary information|
|To manage any promotions that you have chosen to participate in.||Contact information, Preference information, Communications, Voluntary information|
|To improve our marketing activity more generally: This means we use information about you and about our other customers to work out what is working and what is not in terms of our marketing activity or our sales performance, so that we can develop our websites and offers to be more relevant to our customers generally, to improve your online experience and the services we offer. We will also use information provided by your device to recommend the intended geographic website for the location it reports you as being in. Where possible, we will use statistical or pseudonymised data for these purposes.||Transaction information, Preference information, Communications, Voluntary information, Observed information|
|Observed information (including CCTV footage)|
|Your vital interest: To contact you if there are urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information may prevent or reduce any potential harm to you.||Contact information|
What are your rights?
You have certain legal rights, which are briefly summarised below, in relation to any personal data about you which we hold.
Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose. Your withdrawal of your consent won’t impact any of our processing up to that point.
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue to process your personal data.
|Your right||What does it mean?||Limitations and conditions of your right|
|Right of access||Subject to certain conditions, you are entitled to have access to your personal data (this is more commonly known as submitting a “data subject access request”).||If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
We must be able to verify your identity. Your request may not impact the rights and freedoms of other people, eg privacy and confidentiality rights of other individuals.
|Right to data portability||Subject to certain conditions, you are entitled to receive the personal data which you have provided to us and which is processed by us by automated means, in a structured, commonly-used machine readable format.||If you exercise this right, you should specify the type of information you would like to receive (and where we should send it) where possible to ensure that our disclosure is meeting your expectations.
This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (ie not for paper records). It covers only the personal data that has been provided to us by you.
|Rights in relation to inaccurate personal or incomplete data||You may challenge the accuracy or completeness of your personal data and have it corrected or completed, as applicable.
We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details, telephone number.
|This right only applies to your own personal data. When exercising this right, please be as specific as possible.|
|Right to object to or restrict our data processing||Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data.||As stated above, this right applies where our processing of your personal data is necessary for our legitimate interests. You can also object to our processing of your personal data for direct marketing purposes.|
|Right to erasure||Subject to certain conditions, you are entitled to have your personal data erased (also known as the “right to be forgotten”), eg where your personal data is no longer needed for the purposes it was collected for, or where the relevant processing is unlawful.||We may not be in a position to erase your personal data, if for example, we need it to (i) comply with a legal obligation, or (ii) exercise or defend legal claims.|
|Right to withdrawal of consent||As stated above, where our processing of your personal data is based on your consent you have the right to withdraw your consent at any time.||If you withdraw your consent, this will only take effect for future processing.|
If you wish to exercise any of your rights please contact firstname.lastname@example.org.
Please contact us if you have any concern about how your personal information is processed and we will try to resolve your concerns. If you are not satisfied with our response or you consider that we are in breach of our obligations under data protection laws you may make a complaint to the Information Commissioner’s office. Please see the Information Commissioner’s website (www.ico.org.uk) for more information.
Who do we share personal information with and where are they?
When you provide personal information to one Princess Motor Yacht Sales company it may be shared with other Princess Motor Yacht Sales companies. This enables us to run our business effectively and to provide you with an efficient service.
If your geographic needs would be better served by one of our authorised sub-dealers, with your permission we will pass on your information to that sub-dealer.
In order to make certain services available to you we sometimes share your data with trusted third parties.
If your enquiry leads to the purchase of a new vessel, your information will be shared with the relevant manufacturer/component supplier for warranty registration and safety recall purposes. If you purchase a used vessel with an insurance backed warranty your information will be registered with the insurer.
To ensure that the data that we hold remains up to date, we periodically cleanse our databases using consumer credit reporting agencies to check our contact information.
We may use third party service providers such as events management companies, call centres and mailing houses to support our marketing activities. We may also use service providers in less direct ways, such as in the provision of our payment and finance systems, or fraud verification.
We have agreements with our service providers which restrict how they are able to process your personal information and require them to keep it secure. If any service provider is based outside of the European Economic Area, we will ensure that the provider is either a current subscriber to the EU/US Privacy Shield, or we have an appropriate contract for the international transfer of personal information with them.
We may share any of your personal data with a prospective purchaser of all or any part of our business, on the basis of our legitimate interests and the interests of our purchaser, so that they can appropriately value the business and assess any risks and continue doing business with you after the acquisition.
How long do we keep your information for?
We will only retain your personal information for the purposes set out in this Policy and for as long as we have a legal or business requirement to do so. By law, different retention periods apply to different types of records and data, however the longest we will normally hold any personal data is 7 years from the date of your last transaction, for taxation, accounting and risk management purposes. This may be extended in the event of a query, investigation or dispute until fully resolved.