DATA PROTECTION PRIVACY NOTICE

OUR APPROACH TO PRIVACY

We are committed to safeguarding the privacy of our customers and contacts. In this policy we explain how we will treat and use your personal information.  We are registered as a data controller with the UK Information Commissioner's Office and our data protection registration number is Z1881310.

Personal information is data which personally identifies you, such as your name, address, email address, payment details or any other data from which you could be identified.

We may update this policy from time to time on our website and recommend that you check this page occasionally to ensure that you are aware of any changes.

If you wish to contact us about your personal information or this privacy policy, please see our contact details set out at the end of this policy. You can opt out of receiving our marketing communications at any time by emailing [insert email address].

COLLECTING AND USING YOUR PERSONAL INFORMATION

We may collect, store and use the following:

• information about your computer and data in relation to your visits to our website. Examples include your IP address, geographical location, browser type and version, how you accessed the website (e.g. through a search engine), length of visit, date of visit, page views and the order of pages you accessed during your visit 
• your sensitive personal data (such as data relating to your physical or mental health) if you volunteer it during our dealings. If you volunteer such information, you will be consenting to our processing of that data for the purposes of those dealings. For example, we may use your sensitive personal data to better manage your needs such as if you tell us you have a visual impairment we may provide documentation to you in large print 
• any other personal information that you choose to send to us.

The personal information we collect from you or you submit to us through our website (such as when you register to receive our newsletters or make an enquiry) will be used for the purposes specified in this policy or on the relevant page of our website.

EXAMPLES OF HOW WE MAY USE YOUR PERSONAL INFORMATION

The following are examples of how we may use your personal information:

• to understand your journey on our website 
• administration purposes 
• research, statistical analysis and behavioural advertising 
• to advertise our services to you as you browse the internet 
• marketing - please see the Marketing and opting out section below 
• credit scoring and credit checking and other financial background or security checks - please see the Credit checking section below 
• fraud prevention and detection (including money laundering checks) 
• to deal with enquiries and complaints made by you through our website 
• to notify you of any changes or improvements to this website or our services that may affect you.

MONITORING

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud protection and compliance purposes.

MARKETING AND OPTING OUT

If you have given your permission, we may contact you by post, email or telephone with marketing communications relating to our products and services and business.

We will not (without your consent) supply your personal information to any third party for the purpose of their own or any other third party's direct marketing.

If you prefer not to receive any direct marketing communications from us, you may opt out of receiving these at any time. Please see the Your rights and Contact us sections below for further information.

DISCLOSURE OF YOUR PERSONAL DATA

We may disclose the personal information we collect from you to:

• any other companies within our group 
• our agents and service providers 
• credit reference agencies - please see the Credit checking section below 
• law enforcement agencies in connection with any investigation to help prevent unlawful activity.

CREDIT CHECKING

To enable us and other companies in our group to make credit or other financial decisions about you and members of your household and for fraud prevention and money laundering purposes, we may search the files of credit reference and fraud prevention agencies (who will record the search).

We may disclose information about how you conduct your account to such agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked.

Other credit grantors may use this information to make credit decisions about you and the people with whom you are financially associated, as well as for fraud prevention, debtor tracing and money laundering purposes. If you provide false or inaccurate information or we suspect fraud, we will record this.

INFORMATION AND OTHER INDIVIDUALS

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on their behalf and has agreed that you can:

• give consent on their behalf to the processing of their personal data 
• receive on their behalf any data protection notices 
• give consent to the processing of their personal information abroad 
• give consent to the processing of their sensitive personal data (such as their physical or mental health).

INTERNATIONAL DATA TRANSFER

Information that we collect from you including via our website (such as when you register to receive our newsletters or make an enquiry) may be stored, processed and transferred between our offices in the UK, Turkey and Egypt, to enable us to provide you with the services you have requested and/or administer our relationship with you. 

If we need to transfer your personal information outside of the European Economic Area we will either do so with your consent or that transfer will be subject to a European Commission approved contract that will safeguard your personal information.

RETIANING PERSONAL INFORMATION

Personal information that we process for any purpose will not be kept for longer than is necessary. When you sign up for our regular newsletters for example, you will keep receiving these indefinitely until you opt out, until the publication/s cease to exist or until your relationship with Sunseeker London has ended.

Personal information that you publish on our website (if you comment on our blogs for example), will remain on our website. The comments you publish may be available via the internet around the world and we cannot prevent the use or misuse of this information by others.

SECURITY OF YOUR PERSONAL INFORMATION

We will use technical and organisational measures to safeguard your personal information and take reasonable precautions to prevent the loss, misuse or alteration of your personal information. For example:

• we will store all the personal information that you provide on our secure servers, which are password and firewall protected 
• access to your account is controlled by a password and user name that are unique to you.

We cannot, however, guarantee the security or integrity of all data as the transmission of information over the internet is inherently insecure.

YOUR RIGHTS

You can ask us to provide you with any personal information we hold about you (this is called a Subject Access Request). If you wish to exercise this right, you should:

• put your request in writing; 
• include proof of your identity and address (for example, by enclosing a copy of your driving licence or passport (certified by a solicitor or a bank) and a recent utility or credit card bill dated within the last three months and showing your current address); and
• specify the personal information you want access to, including any account or reference numbers where applicable.

Please note that we may withhold personal information that you request to the extent permitted by law.

You have the right to require us to correct any inaccuracies in the personal information we hold about you free of charge. If you wish to exercise this right, you should:

• put your request in writing 
• provide us with enough information to identify you (for example, account number, user name, registration details), and 
• specify the information which is incorrect and what it should be replaced with.

You also have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you should:

• put your request in writing 
• provide us with enough information to identify you (for example, account number, user name, registration details), and 
• if your objection is not to direct marketing in general, but to direct marketing by a particular channel, such as by email or telephone, please specify the channel you are objecting to.

COOKIES

Our website uses cookies to give you the best possible experience on our website. 

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Personal information that we store about you may be linked to the information stored in and obtained from cookies.

CONSENT TO USE COOKIES AND CHANGING SETTINGS

We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested e.g. to enable you to make enquiries about the yachts and the services that we offer for sale.

If you wish, you can set your browser not to accept cookies. The following websites show you how to remove cookies from your browser. However, some of our website features may not function if you choose not to accept cookies. 

For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org  or www.allaboutcookies.org

THIRD PARTY WEBSITES

Our website includes hyperlinks to, and details of, third party websites over which we have no control. We are not responsible for the privacy policies and practices of third parties.

CONTACT US

If you have any questions about our privacy or cookie policy and information we may hold about you, you can get in touch with us by emailing info@sunseekerlondon.com. If you prefer to write to us our address is 34 – 36 Davies Street, Mayfair, London, W1K 4NF.  Please mark any such correspondence for the attention of the Group Legal Counsel.