CUSTOMER PRIVACY & COOKIES POLICY
At Simpson Marine Limited we collect different types of information about our users for the following main reasons:
To provide subscription services;
To help us to monitor and improve the services we offer;
To promote our business on the site;
If we have permission from the user, or where otherwise allowed by law, to market services to them.
There may be other privacy policies that apply to certain services we provide. Please read these when you register or subscribe for these services on these sites.
By visiting this website, you consent to the collection and use of your personal data as described herein. If you do not agree with the terms set out herein, please do not visit this website. If required by applicable law, we will seek your explicit consent to process personal data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your personal data, the use of this website may not be possible.
OUR PRINCIPLES
We do our very best to protect your privacy by using security technology appropriately. This means:
We make sure that we have appropriate security measures to protect your information; and
We make sure that when we ask another organisation to provide a service for us, they have appropriate security measures.
We will respect your privacy. You should receive marketing (whether by email, post, SMS or telephone) only from us or organisations contracted by us to provide subscription or customer services. We will make sure it is clear when you can make these choices, for example, we have boxes you need to tick if you want to receive marketing and you can change your preferences if you no longer want to receive it. However, we may email you occasionally with information or questions about your registration, your subscription account or postings, for example, with reminders, warnings or copyright requests.
We will collect and use individual user details only if we have your permission or we have sensible business reasons for doing so, such as collecting enough information to manage subscriptions or for providing our e-newsletter.
We will be clear in our dealings with you as to what information about you we will collect and how we will use it.
We will use personal information only for the purposes for which it was originally collected.
If we or our service providers transfer any information out of the European Economic Area (EEA), it will only be done with the relevant protection being in place.
We have internal or external personnel to:
To monitor, implement and advise on compliance with the EU General Data Protection Regulation
Undertake Data Protection Impact Assessment (DPIA) to identify and manage data protection risks
Undertake Privacy by Design and by Default to give effect to the data protection principles at the time of determining the means of processing and to integrate the necessary safeguards
Keep records of processing activities
Draw up data processing or handling policies or practices to demonstrate compliance and accountability
WHAT INFORMATION DO WE COLLECT?
We collect information on you:
When you register on the website, register to receive our e-newsletter or become a subscriber;
When you use the website, through cookies;
If you choose to reveal information in postings; and
When you enter sales promotions.
HOW WE USE YOUR INFORMATION
We might use your information to:
Remember you when you visit our website, and see how you journey through it by using cookies. We explain what cookies are in Use of Cookies below,
Identify your interests. We might then put your information in aggregated form into groupings (known as “segments”) by a particular audience, which means we can serve you advertisements and offers that will interest you within the website, including by reference to data we receive from third parties. Please see Use of Cookies for more information about cookies and how we serve you more targeted messaging,
Make sure the products and services we provide to you are correctly administered,
Contact you to let you know about any of our products, services or promotions (which may in some cases be provided by third parties), including by email, mail, telephone, or SMS text message. We will always act having regard to your preferences,
Make sure materials on the website or in apps are presented in the most effective way for you and your computer or mobile device,
Collect and log numeric internet addresses to improve the website and to monitor website usage,
If you have subscribed to any of our services, we will use the information you provide to keep you updated on those services unless you have told us otherwise.
Subscriptions are managed on our behalf by a data processor. We know they have appropriate data protection policies and procedures in place to protect your information and will only use it for the purposes for which it was collected. If you want to contact them to hear more about their policies and procedures you can:
Post: Data Protection Officer
Unit 6, G/F, Aberdeen Marina Tower
8 Shum Wan Road Aberdeen
Hong Kong
Email: [email protected]
Call: +852-25558377
HOW LONG DO WE KEEP YOUR DATA?
We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
E-newsletter subscriber data is deleted within one week of being advised that the recipient has unsubscribed.
Un-subscription option is always available in our e-newsletter and subscriber data is deleted immediately once the recipient has confirmed to unsubscribe.
REGISTRATION
The minimum information we need to register you is your name and email address. We will ask you more questions for different services, including sales promotions.
We may also ask some other, voluntary questions during registration for certain services (for example, preference of yacht type) so we can gain a clearer understanding of what product is of your interest. This also allows us to personalise better services for you.
After you have registered, and with your permission, we may send you emails we think may interest you. Newsletters may be personalised based on what you have been reading on simpsonmarine.com or simpsonyachtcharter.com. At any time you can decide not to receive these emails and will be able to ‘unsubscribe’.
NO COLLECTION OF CHILDREN’S DATA
We do not knowingly collect or store any personal information about children under the age of 16.
LAWFUL BASIS
Article 6 of the General Data Protection Regulation (GDPR) states that we must have a lawful basis for processing your data. Our lawful basis for processing personal data is to enable the fulfilment of either print or digital subscriptions and or e-newsletters and the management of subscription renewals and queries.
UPDATING YOUR PERSONAL INFORMATION
You may contact our customer services team and ask them to update your information and change your marketing preferences.
Post: Data Protection Officer
Unit 6, G/F, Aberdeen Marina Tower
8 Shum Wan Road Aberdeen
Hong Kong
Email: [email protected]
Call: +852-25558377
SUBJECT ACCESS REQUESTS
All individuals who are the subject of personal data held by Simpson Marine Limited or organisations contracted by us to provide subscription or customer services are entitled to:
ask what information the company holds about them and why;
ask how to gain access to it;
be informed how to keep it up to date;
be informed how the company is meeting its data protection obligations.
Subject access request should be addressed to the Data Protection Officer in writing at the following address:
Data Protection Officer
Unit 6, G/F, Aberdeen Marina Tower
8 Shum Wan Road Aberdeen
Hong Kong
or by email to: [email protected]
The Data Protection Officer shall provide information on the action taken on a request without undue delay and in any event within one month. This period may be extended by a further two months where necessary taking into account the complexity and number of requests. The Data Protection Officer shall inform the data subject of any such extension within one month of the subject access request along with reasons for the delay.
A request may be refused or charged for if it is deemed to be manifestly unfounded or excessive.
If a request is refused we will inform the individual why and advise them of the possibility of lodging a complaint to the supervising authority and seeking a judicial remedy.
The Data Protection Officer will always verify the identity of anyone making a subject access request before handing over any information.
WHO WE SHARE DATA WITH
We will not share your personal information with others for marketing purposes.
We may make other organisations’ services available, through our sites, although we are not necessarily operating these sites. We process any information which we collect when you access a service provided by another organisation under this privacy policy. Information these other organisations collect is governed by their own privacy policies.
Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to data-protection and privacy laws which apply. We may also independently audit these service providers to make sure that they meet our standards. We may use service providers to help us run these sites (or services available on the sites), some of whom may be based outside the EEA.
Please be aware that while visiting our site, visitors can follow links to other sites that are beyond our sphere of influence. We are not responsible for the content or privacy policy of these other sites. If you browse these pages while still also logged in to your account with us, information they collect may be connected to your account on their site. For more information on how these organisations use information, please read their privacy policies.
USE OF COOKIES
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. They’re used by most websites nowadays to do a number of things like remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be.
We may use cookies when you visit our website to check your registration data and help you avoid having to register again on subsequent visits. We will also use personal data collected by cookies, such as your IP address, to analyse usage trends on the website and to administer it.
We may use ‘Flash’ cookies to store your preferences for your media player. If we didn’t, you wouldn’t be able to access some video content. If we need you to enable cookies in order to view something like this, we’ll tell you.
You can clear your cookies in your web browser. On some sites this might limit your ability to use certain services online and mean you see more pop-ups and advertising. But you will still be able to view all our content and it won’t affect what advertising you see on our website.
ACCEPTANCE OF THESE CONDITIONS
We assume that all visitors of our website and subscribers of our e-newsletters have carefully read this document and agree to its contents. If someone does not agree with this privacy policy, they should refrain from using our website and platform. We reserve the right to change our privacy policy as necessity dictates. Continued use of our website and platform after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy.
OUR LEGAL OBLIGATION TO DISCLOSE PERSONAL INFORMATION
We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to us or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.
CHANGES TO THE PRIVACY POLICY
Should we elect to change our privacy policy we will post the changes here. Where the changes are significant, we may also choose to email all our registered users with the new details. Where required by law, will we obtain your consent to make these changes.
Changes to this policy by date: May 2018: Policy amended to comply with EU General Data Protection Regulation
If you don’t feel we’re adhering to this Policy, what should you do?
If you believe that we have not adhered to this policy, please notify us by writing to:
Data Protection Officer
Unit 6, G/F, Aberdeen Marina Tower
8 Shum Wan Road Aberdeen
Hong Kong
or by email to: [email protected]
Please choose which cookies you want to consent to.
