Sea Feedback Privacy Notice 2023
Owned by Just Yachts Solutions Ltd, Sea Feedback is a yacht crew communication platform designed to promote safe working practices on board. Just Yachts Solutions Ltd is committed to your privacy. This privacy notice explains our collection, use, disclosure, retention and protection of your personal information.
Scope
Just Yachts Solutions is a processor of personal information provided by users on our platform and this Privacy Notice applies to all work conducted by Just Yachts Solutions for all organisations and associated individuals to which the company is contracted, irrespective of how the information is provided.
What is personal information?
Personal Information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We do not consider personal information to include information that has been anonymised or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.
We collect personal information about yacht crew members and their personal details from the yachts to which Just Yachts Solutions is contracted. We also collect personal information from both Management Companies and Owners Representatives as required to support our service delivery and to ensure effective on board safeguarding as defined under our terms of service.
The personal information that we collect includes names, addresses, information about work activities. It can also include information about home, family, ethnicity and health issues that may be relevant to the supply of our services as defined in the Service Order entered into between Just Yachts Solutions Ltd and their customers.
How does Just Yachts Solutions use personal information?
Just Yachts Solutions uses personal information to work with yacht crew members and yacht owners, yacht agents, management companies (and 3rd party HR service providers retained by our customers) to encourage industry-leading on board working practices and effective crew safeguarding; and to report back on the outcome of that work.
This provides information to the management and owner representatives can use to encourage and support good working practice attainment and monitoring. Anonymized data will be used unless specifically required under the terms of service or required for crew safeguarding under the defined terms of use agreed by the user.
Just Yachts Solutions staff will only share personal information about crew members with the appropriate contact(s) stipulated in the Service Order entered into between Just Yachts Solutions Ltd and their customers.
Just Yachts Solutions staff will never discuss or provide personal information about crew members to other people, unless specifically requested to do so by their customers or where legally obligated to do so. Just Yachts Solutions does not use any sub-processors and does not transfer personal data outside the EU.
Just Yachts Solutions will provide access to and update personal information
You have choices about how we use your personal information to communicate with you. We respect your right to access, correct, request deletion or request restriction of our usage of your personal information as required by applicable law. We also take steps to ensure that the personal information we collect is accurate and up to date.
- You have the right to know what personal information we maintain about you.
- We will provide you with a copy of your personal information in a structured, commonly used and machine-readable format on request.
- If your personal information is incorrect or incomplete, you have the right to ask us to update it.
- You have the right to object to our processing of your personal information.
- You can also ask us to delete or restrict how we use your personal information, but this right is determined by applicable law.
How long does Just Yachts Solutions keep your personal information?
We retain your personal information for as long as necessary to work with yacht crew and relevant customer staff to deliver the outcome of the work defined in the Service Order entered into between Just Yachts Solutions Ltd and their customers, or for other essential purposes such as complying with our legal obligations.
How does Just Yachts Solutions protect your Personal Information?
Just Yachts Solutions protects your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are:
- Just Yachts Solutions’ contract with our customers includes a confidentiality clause.
- All Just Yachts Solutions staff are aware that the confidentiality clause must be rigorously maintained.
- Just Yachts Solutions only share any information which is relevant to the job and does not retain any information that is not appropriate.
- Just Yachts Solutions maintain a robust Information Security Policy with personal data on a highly secure, cloud-hosted server in Amazon’s London Data Centre. Platform access is controlled via an enforced strong password policy, role-based content privacy and best-in-class online malware detection and quarantining to ensure the detection and removal of any malicious code.
- Just Yachts Solutions e-mails containing personal information are sent using an encrypted format.
Just Yachts Solutions are registered with the Information Commissioners Office (Link below) to ensure that the company complies with all aspects of Data Protection legislation.
If we become aware that there may have been any breach of the Data Protection Act 1998 and the General Data Protection Regulations 2018, Just Yachts Solutions will inform you, our customer and the ICO immediately and provide full details of the breach and action taken to rectify the situation as soon as possible.
Data Protection Officer
The Just Yachts Solutions Data Protection Officer is Mrs Emma Gillet, a Company Director. Mrs Gillet can be contacted on +44 7565 919961 or +39 3271 317380 or at info@justyachts.solutions.
Subject access requests All individuals who are the subject of personal data held by Just Yachts Solutions are entitled to:
Ask what information Just Yachts Solutions holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how Just Yachts Solutions is meeting its data protection obligations.
If an individual contacts Just Yachts Solutions requesting this information, this is called a subject access request. Subject access requests must be made in writing to Mrs Emma Gillet, the Data Protection Officer at info@justyachts.solutions. Individuals making such requests must provide two forms of identification, including one which contains a photograph. Mrs Gillet will aim to provide the relevant data within 14 days.
Policy Dated March 2023