1.2 Certain provisions only apply to you if you are located within the United Kingdom (UK), and these are flagged within this policy.
1.3 Further notices highlighting certain uses we wish to make of your personal data together with the ability to opt in or out of selected uses may also be provided when we collect personal data from you.
1.4 Our Site may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal information to such third party websites.
(a) Personal data we may collect about you;
(b) Uses made of your personal data;
(c) Transmission, storage and security of your personal data;
(d) Your rights (this section only applies if you are located in the UK);
(e) Contacting us;
(f) Cookies policy;
2 Personal data we may collect about you
2.1 We will collect and process all or some of the following personal information about you:
(a) Information you provide to us ► personal data that you provide to us, such as when registering on our Site, including your name, email address, and other contact details, login information and other information you provide to us as part of your profile;
(b) Preference information ► where you are looking to find a boat, information relating to your preferences including where you would like to board, your check-in and check-out dates, number of guests, types of boats you prefer, preferred price ranges and preferred boat facilities;
(c) Listing information ► where you are a boat owner/Host, information you provide in relation to your listing including location and facilities of your boat, preferred price and rent dates;
(d) Reviews ► where you are a boat owner/Host, reviews written about your or your boat by guests/Renters;
(e) Credit and Anti-Fraud information ► your financial information such as bank account details and information relating to your financial situation, your creditworthiness or any criminal or fraudulent activities provided to us by you or third parties [including information which establishes your identity, such as driving licences, passports and utility bills; information about transactions, credit ratings from credit reference agencies; fraud, offences, suspicious transactions, where your details are included];
(f) Correspondence ► if you contact us [or other users of the Site], we will typically keep a record of that correspondence;
(g) Survey information ► we may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;
(h) Your transactions ► details of transactions you carry out through our websites or through other channels and of the fulfilment of the services we provide; and
(i) Website and communication usage ► details of your visits to the websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.
3 Uses made of your personal information
In this section, we set out the purposes for which we use personal data that we collect
3.1 With respect to individuals located in the UK, use of personal data must be based on one of a number of lawful bases and we are required to set out the grounds in respect of each use. In the list below, we have set out the relevant grounds that apply to each purpose. You can find an explanation of each of the grounds relied on at Appendix 1.
3.2 Please note that in addition to the disclosures we have identified below, we may disclose personal data for the purposes we explain in this notice to service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) and affiliates of Flotespace that perform activities on our behalf, as well as other members of the Flotespace group. Please also note that personal data you make available on the Site e.g. listings information and review information is accessible to the public.
(a) To communicate effectively with you and conduct our business ► to conduct our business, including to enable you to use our service, to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us.
Legal bases: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you);
(b) To enable boat owners/Host and boat guests/Renters to communicate and transact with one another ► to facilitate interaction between boat owners/Hosts and boat guests/Renters including notifying boat owners of booking requests and facilitating payments between boat guests/Renters and boat owners/Hosts once bookings are confirmed. This will require disclosure of personal data about each party to one another.
Legal bases: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you);
(c) In relation to fraud prevention ► we and other organisations may also access and use certain information to prevent fraud as may be required by applicable law and regulation and best practice at any given time. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them.
Legal bases: legal obligations, legitimate interests ((to cooperate with law enforcement and regulatory authorities), legal claims. With respect to Special Categories of Personal Data, we will usually rely on legal claims, substantial public interests (processing for the prevention and detection of fraud/crime) or very rarely where necessary, explicit consent;
(d) For research and development purposes ► to analyse your personal data in order to better understand your and our other clients’ services and marketing requirements, to better understand our business and develop our products and services.
Legal bases: legitimate interests (to allow us to improve our services);
(e) To monitor certain activities ► to monitor queries, complaints and transactions to ensure service quality, compliance with procedures and to combat fraud.
Legal bases: legal obligations, legal claims, legitimate interests (to ensure that the quality and legality of our services). With respect to Special Categories of Personal Data, we will usually rely on legal claims, substantial public interests (processing for the prevention and detection of fraud/crime) or very rarely where necessary, explicit consent;
(f) To inform you of changes ► to notify you about changes to our services and products.
Legal bases: legitimate interests (to notify you about changes to our service);
(g) To ensure Site content is relevant ► to ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers.
Legal bases: legitimate interests (to allow us to provide you with the content and services on the websites);
(h) To provide you with marketing materials ► to provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own products and services to you by post, email, SMS, and phone, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in the “Contacting Us” section below.
Legal bases: consent, legitimate interest where are not required to rely on consent (to keep you updated with news in relation to our products and services);
(i) To reorganise or make changes to our business ► in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy.
Legal bases: legitimate interests (in order to allow us to change our business);
(j) In connection with legal or regulatory obligations ► We may process your personal information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Legal bases: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities). With respect to Special Categories of Personal Data, we will usually rely on legal claims, substantial public interests (processing for the prevention and detection of fraud/crime)or very rarely where necessary, explicit consent.
We may use and share irreversibly de-identified data for any other legitimate purposes, including product and service development and improvement activities. We base this de-identification on the ground that it is within our legitimate interests (to enable us to improve our services).
4 Transmission, storage and security of your personal data
Security over the internet
4.1 No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
4.2 All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
International transfer of personal data
4.4 With respect to individuals located in the UK, where we transfer personal data from inside the UK to outside the UK, we will transfer your information subject to approved safeguards unless we are permitted under UK data protection law to make such transfers without such formalities.
4.5 Please contact us as set out in the “Contacting Us” section below if you would like to see a copy of the specific safeguards applied to the export of your personal information.
4.6 Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. When personal data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.
5 Your rights (this section only applies if you are located in the UK)
5.1 You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your personal information. You can also exercise the right at any time by contacting us as set out in the “Contacting Us” section below.
5.2 We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set out in the “Contacting Us” section below.
5.3 If you have any questions in relation to our use of your personal information, you should first contact us as per the “Contacting Us” section below. Under certain conditions, you may have the right to require us to:
(a) provide you with further details on the use we make of your personal data;
(b) provide you with a copy of information that you have provided to us;
(c) update any inaccuracies in the personal information we hold (please see paragraph 2);
(d) delete any personal information the we no longer have a lawful basis to use;
(e) where processing is based on consent, to withdraw your consent so that we stop that particular processing (see paragraph 5.1 for marketing);
(f) ask us to transmit the personal data you have provided to us and we still hold about you to a third party electronically;
(g) stop any processing you object to which is based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
(h) restrict how we use your personal data whilst a complaint is being investigated.
5.4 Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
5.5 If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the Information Commissioner’s Office (ICO). The ICO can be contacted at:
Information Commissioner’s Office (Head Office)
Tel: 0303 123 1113
6 Contacting us
23 College Street, Drummoyne NSW 2047 Australia
6.2 If you have any questions in relation to this policy, please contact our Chief Operating Officer at email@example.com
7 Cookies policy