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Privacy Policy

Privacy Policy

Oceanskies Limited and its associated companies (“the Oceanskies Group”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or use our apps (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

PURPOSE OF THIS PRIVACY NOTICE 

This privacy notice aims to give you information on how the Oceanskies Group collects and processes your personal data in line with the requirements of the European Union General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) through your use of this website, including any data you may provide through this website when you complete any of our contact forms or if you request information, proposals or any marketing materials.

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

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice is intended to deal with information you provide to us via our website and supplements the other notices and is not intended to override them.

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.

CONTROLLER 

The Oceanskies Group is made up of different legal entities including but not limited to:

Oceanskies Limited (Guernsey Company Number 56102)

Oceanskies Crew Limited (Guernsey Company Number 56682)

Oceanskies (Jersey) Limited (Jersey Company Number )

Oceanskies (UK) Limited (UK Company Number 08436008)

Oceanskies (Malta) Limited (Malta Company Number C77899)

This privacy notice is issued on behalf of the entire Oceanskies Group so when we mention “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Oceanskies Group responsible for processing your data. We will let you know which entity will be the controller for your data if you formally engage us to provide you with a service or you provide your personal data to us as part of our obligation to provide a service to a third party or parties.

Oceanskies Limited, a company incorporated in Guernsey, (Company Number 56102), is the controller of personal data you may input to this website and is responsible for this website.

Our Data Protection Officer 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 our Data Protection Officer using the details set out below.

CONTACT DETAILS 

Our full details are:

The Data Protection Officer
Oceanskies Limited
Castle Emplacement
St. Peter Port
Guernsey GY1 1AU

Email address: [email protected]

Telephone : +441481711994

If you are unhappy with our treatment of your personal data, you have the right to make a complaint at any time to the Data Protection or Information Commissioner’s Office in the jurisdiction in which you live or to the Office of the Data Protection Authority in Guernsey:

The Office of the Data Protection Authority
St Martin’s House, Le Bordage
St. Peter Port, Guernsey GY1 1BR

Email address: [email protected]
Telephone : +441481742074

We would, however, appreciate the chance to deal with your concerns before you approach such authorities so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES 

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.

 THIRD-PARTY LINKS 

This 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 of every website you visit.

THE DATA WE COLLECT ABOUT YOU 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

From this website we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you via this website (this includes 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.

HOW IS YOUR PERSONAL DATA COLLECTED THROUGH THIS WEBSITE? 

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

HOW WE USE YOUR PERSONAL DATA 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• In order to send you further information about our services
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting [email protected]

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity

 

 

Type of data

 

 

Lawful basis for processing including basis of legitimate interest

 

 

To register you as a potential new customer or intermediary

 

 

(a) Identity

 

(b) Contact

 

Necessary for our legitimate interests (to expand our customer and intermediary referrer base to grow our business)

 

 

To manage our relationship with you which will include:

 

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

 

(b) Contact

(c) Marketing and Communications

 

(a) Performance of a contract with you

 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

 

To enable you to partake in a prize draw, competition or complete a survey

 

 

(a) Identity

 

(b) Contact

(c) Usage

(d) Marketing and Communications

 

(a) Performance of a contract with you

 

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

 

(a) Identity

 

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

 

(b) Necessary to comply with a legal obligation

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

 

(a) Identity

 

(b) Contact

(c) Usage

(d) Marketing and Communications

(e) Technical

 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

 

(a) Technical

 

(b) Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

 

(a) Identity

 

(b) Contact

(c) Technical

(d) Usage

 

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

 

MARKETING 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising :

PROMOTIONAL OFFERS FROM US 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or if you provided us with your details and expressly consented to receiving that marketing.

THIRD-PARTY MARKETING 

We will never share your personal data with any company outside the Oceanskies Group for marketing purposes.

OPTING OUT 

You can ask us to stop sending you marketing messages at any time by email to [email protected] or by letter to:

The Data Protection Officer
Oceanskies Limited
Castle Emplacement
St. Peter Port
Guernsey GY1 1AU

COOKIES 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

CHANGE OF PURPOSE 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

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 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it than operates in the Guernsey by ensuring at least one of the following safeguards is implemented:

If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA please contact the Data Protection Officer.

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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Sending information over the internet to us is generally not completely secure, and we can’t guarantee the security of your data while it’s in transit. We have procedures and security features in place to keep your data secure once we receive it.

DATA RETENTION 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances you can ask us to delete your data.

In some circumstances we may 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 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary section entitled “Your Legal Rights” to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact the Data Protection Officer at [email protected]

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 may 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 may 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.

GLOSSARY 

LAWFUL BASIS 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES 

 YOUR LEGAL RIGHTS 

Your legal rights will depend upon a number of factors including your country of residence and the location of company which operates this website and will generally include 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

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