We value your privacy and take our obligations under privacy and data protection law very seriously. This Privacy Notice gives you information about how we process your Personal Information when you visit the Website (defined below) or otherwise contact ABP in relation to marina services provided by ABP at the following marinas:
This Privacy Notice does not cover the links within linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
In this Privacy Notice:
For more details about how ABP collects and uses Personal Information, including the Personal Information we collect when you visit our marinas, please see our full Privacy Policy on www.abports.co.uk
When we say “we”, “our”, “ABP” we mean Associated British Ports who is the “data controller” for the Personal Information collected and used in connection with the provision of marina services. This means we are responsible for deciding how we can use your Personal Information.
Personal Information means information about a living person by which that person can be identified either directly or indirectly.
Sensitive Personal Information is a special category of Personal Information which is particularly sensitive and which requires higher levels of protection, such as information about a person's health or sexual orientation.
We collect the following information about you:
Our Websites are not intended for children and we do not knowingly collect data relating to children via our Websites.
We may collect Sensitive Personal Information from you in the course of our business depending on the context of our particular relationship with you. In particular we may collect information relating to your disability status.
We collect Personal Information from you when you interact with our Website or contact us by telephone, email, post or in person.
In the course of us providing goods or services to you, you may provide us with Personal Information relating to third parties. For example, information about additional individuals who may be accessing your vessel at the marina.
We will use this Personal Information in accordance with this Privacy Notice. If you are providing Personal Information to us relating to a third party, you confirm that you have the consent of the third party to share such Personal Information with us and that you have made the Personal Information in this Privacy Notice available to the third party.
Your Personal Information may be used by us, our employees, service providers, and disclosed to third parties for the following purposes. For each of these purposes, we have set out the legal basis on which we use your Personal Information.
| Purpose | Legal Basis |
|---|---|
| To communicate with you and other individuals about our services. | The legal basis will fall into one of the following four categories, depending on the communication and the purpose for which it was sent:
|
| To carry out our obligations arising from any contracts entered into between you and us, and to provide you with our services. | Depending on the circumstances:
Where this involves the processing of sensitive personal information such as your disability status, we process such information with your explicit consent. |
| To improve our products, services and our staff training. | This processing is necessary for our legitimate business interests in order for us to manage our relationship with you and to improve/develop our products, services and staff training. |
| To manage any service or quality related issues, complaints, feedback and queries. | Depending on the context, this processing could be necessary for:
|
| To send you direct marketing communications about our services, including newsletters. | Depending on the circumstances:
|
| To carry out satisfaction surveys and analysis. | The processing is carried out for our legitimate business interests because it enables us to develop and improve our services offered to you. |
| To prevent and detect fraud, financial crime and anti-money laundering. | Depending on the circumstances:
|
| To comply with any legal or regulatory obligations (including in connection with a court order). | The processing is necessary for compliance with a legal obligation to which we are subject. |
| To enforce or apply the contracts concerning you (including contracts between you and us). | Depending on the circumstances:
|
We may be required to obtain your Personal Information to comply with our legal requirements, to enable us to fulfil the terms of any contract that we have with or in preparation of us entering into a contract with you. For example, if you do not provide the relevant Personal Information to us such as your name and postal address, we will not be able to provide the relevant product to you or another person (as may be requested by you).
We will only retain your Personal Information for as long as is necessary to fulfil the purposes we collected it for. The length of time we hold on to your personal information will vary according to what that information is and the reason for which it is being processed, including for the purposes of satisfying any legal, accounting or reporting requirements or defending any potential claim.
When it is no longer necessary to retain your Personal Information, we will delete or anonymise it.
We share your Personal Information with:
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Sometimes it is necessary for us to process or share your Personal Information outside of the European Economic Area (EEA), e.g. with our service providers located outside the EEA (i.e. our IT suppliers) or if you are based outside the EEA.
When we transfer Personal Information outside of the EEA, we will implement appropriate and suitable safeguards to ensure that such Personal Information will be protected as required by applicable data protection law (e.g. contractual protections).
For further information as to the safeguards we implement please contact our Data Protection Officer as detailed in the section "How to contact us".
You have certain rights with respect to your Personal Information. The rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights.
| Summary of your rights | |
|---|---|
| Right of access to your Personal Information: | You have the right to receive a copy of your Personal Information that we hold about you, subject to certain exemptions.
Any access request is free of charge. We may require further information in order to respond to your request (for instance, evidence of your identity and information to enable us to locate the specific Personal Information you require). |
| Right to rectify your Personal Information: | You have the right to ask us to correct your Personal Information that we hold where it is incorrect or incomplete. |
| Right to erasure of your Personal Information: | You have the right to ask that your Personal Information be deleted in certain circumstances. For example (i) where your Personal Information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your Personal Information; (iii) if you object to the use of your Personal Information (as set out below); (iv) if we have used your Personal Information unlawfully; or (v) if your Personal Information needs to be erased to comply with a legal obligation. |
| Right to restrict the use of your Personal Information: | You have the right to suspend our use of your Personal Information in certain circumstances. For example (i) where you think your Personal Information is inaccurate and only for such period to enable us to verify the accuracy of your Personal Information; (ii) the use of your Personal Information is unlawful and you oppose the erasure of your Personal Information and request that it is suspended instead; (iii) we no longer need your Personal Information, but your Personal Information is required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the use of your Personal Information and we are verifying whether our grounds for the use of your Personal Information override your objection. |
| Right to data portability: | You have the right to obtain your Personal Information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies where the use of your Personal Information is based on your consent or for the performance of a contract, and when the use of your Personal Information is carried out by automated (i.e. electronic) means. |
| Right to object to the use of your Personal Information: | You have the right to object to the use of your Personal Information in certain circumstances. For example (i) where you have grounds relating to your particular situation and we use your Personal Information for our legitimate interests (or those of a third party); and (ii) if you object to the use of your Personal Information for direct marketing purposes. |
| Right to object to decision which is based solely on automated processing: | You have the right in certain circumstances not to be subject to a decision which is based solely on automated processing without human intervention. |
| Right to withdraw consent: | You have the right to withdraw your consent at any time where we rely on consent to use your Personal Information. |
| Right to complain to the relevant data protection authority: | You have the right to complain to the relevant data protection authority, which is in the case of us, the Information Commissioner's Office, where you think we have not used your Personal Information in accordance with data protection law. |
If you wish to contact us about how we handle your Personal Information or this Privacy Notice or to exercise any of your rights, please contact the Group Data Protection & Security Officer at dataprotection@abports.co.uk, 077204 16654 or by post FAO Group Data Protection & Security Officer, Associated British Ports, 25 Bedford Street, London WC2E 9ES.
We will amend this Privacy Notice from time to time to ensure it remains up to date. Any changes we make to this Privacy Notice in the future will be posted on this page and, where appropriate, we will give you reasonable notice of any changes. Please visit our Website to keep up to date with any changes. The current version will always be posted on our Website. This Privacy Notice was first published on 25 May 2018.
We’re here to help, so please do not hesitate to contact us through any of the channels below.
Associated British Ports, Management Office, Town Quay, Southampton SO14 2AQ
Nella Pang
D: 023 8038 5611
M: 07738 625 431
E: nella.pang@eu.jll.com
Nik Cox
M: 07870 557 410
E: ncox@vailwilliams.com
William Elgeti
M: 07584 214 668
E: welgeti@vailwilliams.com