Privacy Policy
PRIVACY NOTICE
This notice constitutes our privacy policy for the global organization of BWA Yachting. Here we describe the practices we follow to respect the privacy of all visitors to Our Site www.bwayachting.com (hereinafter referred to as the “Website”) in force from 24 of May 2018.
In this notice, personal information means data which relates to an individual and which identifies that individual, either directly or indirectly, such as your name or your contact information.
BWA Yachting operates globally and its domestic and foreign offices have a common data protection policy and common procedures.
If you have any questions regarding the processing of your personal information, please contact us.
BWA Yachting SA as data controller (hereinafter referred as “Data Controller”) hereby informs users that it processes personal data provided by them using the Website according to the data minimization principle. In particular: identifying personal data (e-mail address, first name, last name, company name/yacht and position– hereinafter referred to as “data” or “personal data”) which is provided by users of the Website by filling out the contact form.
Who we are
BWA Yachting SA is a Yachting Company based in Via Serafino Balestra 27 -Lugano 6900 CH- Switzerland. BWA Yachting SA exists to help managers, captains and crew with the increasing demands of managing a modern superyacht. The broad range of services we offer extends from fully integrated global packages, the handling of a single port call, to last minute specialist concierge requests. We also provide advance itinerary planning and implementation of every aspect of a yacht’s trip.
Information we may collect from you
Information you give us: Registration is not required for you to use our Website. If you are merely a visitor, we do not collect any personal information about you. However, there may be circumstances in which you choose to contact us by filling in forms on our website or by corresponding with us by phone and email. The information you give us may include name, surname, email address, phone number, company name/name of the yacht, position. In these cases, BWA may contact you to answer to your requests, provide you with more information about our services, inform you about any upcoming events or shows, or for other marketing purposes. If you make initial contact, you consent to BWA maintaining a marketing dialogue with you until you either opt out (which you can easily do at any stage) or until we decide to desist in promoting our services.
Information we receive from other sources. We may receive information about you if you use any of the other services we provide (ie. if you sign our standard billing form). In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, search information providers) and we may receive information about you from them.
Purposes of the processing
We use information held about you in the following ways:
Information you give to us. We will use this information:
to manage and answer to your requests;
providing you have given the necessary consent, to provide you with information about goods or services, or permit selected third parties (i.e. our business partners) to provide you with information about goods or services that we feel may interest you. Where we permit selected third parties to use your data, we (or they) will contact you by electronic means, only if you have consented to this. If you decide at any time that you do not wish us to use your data in this way, or that you do not wish us to pass your details on to third parties for marketing purposes, please contact us at info@bwayachting.com.
to notify you about changes to our service;
providing you have given the necessary consent, to send you marketing communications
Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive.)
Disclosure of your information
We may share your personal information with:
The Data Controller’s staff deputed to the processing of personal data (including, but not limited to):
Employees and consultants authorized to manage the Website and supply the related services (e.g. customer services, IT department, etc.) in their roles as processors of information or internal data processors and/or system administrators;
The Data Controller’s employees and consultants in the marketing, finance, administration, accounting and other relevant departments, in their roles as processors of information and/or internal data processors;
Third party companies (e.g. IT services providers, hosting providers, etc.) to which BWA outsources some services involving processing operations in role as external data processors.
Any BWA Yachting Agency worldwide and their employees as mentioned above, which means our subsidiaries as defined in section 1159 of the UK Companies Act 2006.
Selected third-parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, providing you have given the necessary consent. We don’t sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide.
We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
to fulfill the obligation provided by the law, regulations, protocols and national and EU legislation;
to implement laws required by public Authorities including the DPA of each member state where we operate;
to allow the defence in court, for example, in case of violations by the web-users.
to protect the rights, property, or safety of our company, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
How do we respond to legal requests?
We access, preserve and share your information with regulators, law enforcement or others in the following circumstances:
In response to a legal request, where we believe in good faith that the law requires us to do so. We can also respond to legal requests where we believe in good faith that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
When we believe in good faith it is necessary to: detect, prevent and address fraud, unauthorized use of our website or services, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
Where we store your data
The data that we collect from you will be stored in a destination inside the European Economic Area (“EEA”) and will not be transferred outside the EEA unless we have your explicit consent to such transfer and storage. Our servers are located in Europe. In any event, your data will only ever be transferred to organizations where an approved code of practice from the competent DPA in relation to data protection is adopted.
In any case, if personal data will be transferred to countries that do not provide the same level of protection, or in any case an adequate level of protection, BWA will ensure that it will enter into specific contractual obligations according to the applicable data protection legislation (including the execution of the Standard Contractual Clauses as approved by the European Commission) with each service provider, unless we can rely on any other legal basis for the transfer of personal data.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Security
BWA works to protect the confidentiality and security of information it obtains in the course of its business. Access to such information is limited and policies and procedures are in place, designed to safeguard the information from loss, misuse and improper disclosure.
Whilst we use strong encryption, both when your information is moving to or from our web services and also whilst your information is held by us, unfortunately the transmission of information via the internet can never be completely secure. Although, we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Cookie Policy
BWA website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. We only use session cookies and third party cookies that do not collect personal data. For more information visit our Cookie Policy
Data retention policy
BWA stores personal data for the time necessary to achieve the purposes for which data are collected and further processed, including any retention period required under the applicable legislation (e.g. retention of accounting documentation) and subject to any applicable laws, for a maximum of 5 years from the storage of the personal data.
Your rights
Under the General Data Protection Regulation, you have the right to access, rectify, port, limit and erase your data. You can exercise those rights by contacting us at s.graham@bwayachting.com.
If, at any time, you want to verify, update or amend your personal data or preferences please write to us at BWA Yachting Lugano -Corporate Management, Via Serafino Balestra 27 -Lugano 6900 CH – Switzerland or Email us at: s.graham@bwayachting.com
Verification, updating or amendment of personal data will take place within 28 days of your request.
You also have the right to object to and restrict certain processing of your data.
This includes:
the right to object to our processing of your data for direct marketing, which you can exercise by using the “unsubscribe” link in such marketing communications; and
the right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can exercise this right by contacting us at s.graham@bwayachting.com
Moreover, whilst we will obtain your consent prior to processing your data for marketing purposes or disclosing your data to third parties for marketing purposes, you have the right at any time to ask us not to process your personal data for such purposes. You can exercise your right to prevent such processing by contacting us at s.graham@bwayachting.com
You also have the right to complain to the Supervisor Authority.
Social Media Plug-ins
This Website uses social media plug-ins furnished by the most important social networks (e.g. Facebook and Twitter). When visiting the webpage the browsing data may be transferred directly to the social networks concerned, even without users’ direct interaction. Users acknowledge and agree that the operation of social networks’ plug-ins is managed directly by the company that manages the corresponding plug-in. When users use the plug-ins available through the Website (e.g. log in with their access credentials to a social network, or link their accounts, click on the Facebook “Like” or “Share” button), the users’ browser establishes a direct connection with the server of that social network, which sends the contents of the plug-in directly to the users’ browser.
BWA may therefore receive data relating to users, in accordance with the social network’s terms of use and privacy policy and may add data to users’ personal data already collected through its own services. If the user opts to share information with the social networks, BWA will share the data with them in accordance with the user’s preferences. To prevent those social networks from collecting the personal information of the user, please check the relevant conditions on the social network website.
Most specifically, the Website uses:
a) Facebook
b) Twitter
c) Instagram
d) Linkedin
Other links
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by BWA or its partners and affiliates, you have the right to complain to BWA’ legal officer at s.graham@bwayachting.com
If you do not get a response within 30 days you can then complain to the ICO. Please contact: ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, Telephone +44 (0) 303 123 1113 or visit: https://ico.org.uk/global/contact-us
Contacts
If you have any questions concerning this privacy policy and data protection, please contact BWA’s legal officer at s.graham@bwayachting.com.
Date of Last Revision: May 24, 2018
