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Privacy

Privacy Policy

Published 24/05/2018

 1      Who are we?

In this Privacy & Cookies Policy (the "Policy"), the terms "we", "our", and "us" are used to refer to Argyll Ferries Limited of The Ferry Terminal, Gourock, PA19 1QP, company number SC391762.

You can contact us with any queries regarding this Policy using the details set out in section 13 of this Policy.

2      Purpose

We are a controller of your data which means that we are responsible for looking after it. This Policy sets out how we use and protect any personal data that you provide to us, whether by phone call, text, email, social media, postal letter, through using our website or when you attend one of our community stakeholder events.

We are committed to protecting the privacy of users when using our services. Any personal data that is collected will be used fairly, lawfully and in a way which is transparent, and in accordance with the General Data Protection Regulation and other relevant legislation (the "Data Protection Laws").

Personal data collected by us will be retained for as long as is necessary and will only be used for the purpose for which it was originally collected.

3      What personal data we may collect about you

We may collect, store and use the following types of personal data:

  • communications you exchange with us (for example, your emails, letters, phone calls, social media interactions with us, or your participation and interaction at community stakeholder events) which may include personal data such as your full name, gender (title), full postal address, contact information such as phone numbers, email address or social media identifiers;
  • mobile phone number if you register for Service Status SMS text updates;
  • job application details including CVs if you apply for a job vacancy;
  • CCTV image data at ports and on vessels, and
  • data collected through your access to, and use of, the WiFi service on our vessels and in ports (your e-mail address, hardware device MAC address, and the date and time you connect to the WiFi Service);

 The personal data you provide is used for service and operational purposes, for example responding to your queries, alerting of service interruptions via SMS text, or fulfilling your requests.

 

4      How we collect the personal data

Where we collect your data from is set out in more detail in this section.

Information that you give us

You may share your personal data about yourself and your circumstances when you:

  • provide feedback or otherwise interact with us, including via social media, email, text or at community stakeholder events;
  • sign up for any of our services or activities;
  • enter a competition;
  • respond to a survey;
  • register to use the WiFi Service;
  • participate in our recruitment processes, or
  • make a complaint or passenger claim.

 Information that we collect about you

We also collect personal data by using technology such as cookies (please refer to section 8 for further information in relation to the use of cookies on our website and how you can reject our use of cookies).

Our legal basis for using your information

We will only process your personal data where we have legal grounds to do so. The legal grounds will depend on the purpose of the personal data collected and its processing requirements. 

The legal grounds on which we rely to use your personal data are:

  • To allow us to perform our contract with you. When you purchase services from us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract, we will need to collect and process your personal data, including payment information. Failure to provide the requisite personal information on sign-up and payment information on entering into the contract or objecting to this type of processing/exercising your deletion rights will mean that we cannot provide our services to you;
  • To allow us to exercise our legitimate interests as a data controller. We rely on our legitimate interests as a data controller to process the personal data that you provide to us when using our services. It is in our legitimate interests as a business to process the above personal data in order to administer our website, to ensure that content from our website is presented to you effectively and securely, and to run contests and other promotional features;
  • In certain circumstances we may need to use your personal data to comply with a legal or regulatory obligation;
  • On the basis that you have consented to us storing and using your personal data for a particular purpose, or
  • To protect the vital interests of you or another person.

 

5      How we will use the personal data we collect

We will use your personal data in order to:

  • manage your travel arrangements and/or provide you with the services you request;
  • send status updates and service communications to you.;
  • communicate with you about your interactions with us and send you information about our products and services;
  • support specific management and administrative purposes;
  • analyse and improve the services offered on our website;
  • comply with our legal obligations, and
  • undertake our company administrative purposes, such as billing, accounting, invoice processing, concession processing, service and marketing analysis, and systems development.

Consistent with your choices, and subject to your consent, we may send you information regarding offers and promotions. You can alter your choices and withdraw your consent at any time using the process set out in section 7.

We will not share your personal data with third parties for marketing purposes without your explicit consent. You have right to withdraw your consent to processing of this nature at any time using the process set out in section 11.

Security of your personal data

We are committed to implementing appropriate technical and organisational measures in order to prevent your personal data from being accidentally or unlawfully destroyed, lost, altered or accessed or otherwise used in an  unlawful manner.

The personal data that you provide to us will be held in our systems, which are located on our premises or those of an appointed third party.

We will only transfer your data outside of the European Economic Area (‘EEA’) if it is necessary in order to comply with a legal obligation or to provide our products and services.Where personal data is transferred outside of the EEA, we will ensure that it is protected at least to the same standards as if it was being processed within the EEA. To ensure this, we will apply one or more of the following data security provisions:

  • only transfer the personal data to a non-EEA country with privacy laws that give the same protection as the Data Protection Laws in the EEA;
  • ensure that any appointed processor is only engaged through a contract which incorporates a set of contractual provisions approved by the European Commission for use when establishing  contractual safeguards that meet the data protection compliance standards that are imposed  under the Data Protection Laws in the EEA; or
  • transfer the personal data to organisations that are certified under a data protection regime specific to the country to which the personal data is being transferred (an example being the US Privacy Shield arrangement, administered by the International Trade Administration within the U.S. Department of Commerce which sets an EU Commission-approved privacy standards for data transferred between the US and EU countries.

For further details regarding these data security provisions please refer to the European Commission and Information Commissioner’s Office (ICO) websites.

 

6      When and why we disclose your details to anyone else

We will not share your personal data except where disclosure is required or permitted by law. Examples of organisations who may require us to disclose your personal data are Government Bodies and Law Enforcement Agencies.

We are a member of the David MacBrayne Group of companies (referred to in this Policy as "DML Group").  In common with many businesses that operate as part of a group, different members of DML Group carry out certain administrative tasks that need to be undertaken in order to allow us to provide our services to you.  In order to allow those tasks to be carried out, we may share your personal data with other DML Group members, but we will only do so where it is necessary in order to allow us to provide our services to you.  Any sharing of your personal data with another DML Group member will always be carried out in accordance with the terms of this Policy and we will be responsible to you for the data processing activity that is carried out.

In addition to the DML Group arrangements referred to above, we do, on occasion, use carefully selected third parties to process personal data on our behalf. We will only share your data with these third parties where it is necessary for them to provide us with the services that we rely upon to operate our business. We tightly control that processing activity, requiring that the third parties concerned only process personal data on our behalf securely, in accordance with the Data Protection Laws and then only for the purposes that we have set out.

 

7      Your choices regarding the personal data you provide to us

The security, integrity and confidentiality of your personal data is extremely important to us and we take all reasonable precautions to prevent the loss, destruction, misuse or alteration of your personal data.

You may choose to restrict the collection or use of your personal data in the following ways:

  • Whenever you are asked to fill in a form on the website, you will have the option of ticking the box that indicates you are satisfied for your personal data to be used for marketing purposes. If you do not tick that box, we will not use your personal data for marketing purposes.
  • If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by emailing us at:

emarketing@calmac.co.uk

We will not sell, distribute or lease your personal data to third parties. With your permission, we may use your personal information to send you promotional information about third parties which we consider may be of interest to you.

 

8      The use of cookies on our websites and how you can reject these cookies

Cookies are small files that websites put on your computer hard disk drive or mobile device when you first visit. Think of a cookie as an identification card that is uniquely yours. Its job is to notify the site when you've returned. Many websites use cookies.

Cookies tell us how often you visit our website, which helps us learn what information interests you. In this way, we can give you more of the content you like and less of the content you don't.

Cookies let you store preferences and user names, register products and services, and personalise pages.

Most web browsers automatically accept cookies but you can usually modify your web browser settings to decline or delete cookies if you prefer, this may however prevent you from taking full advantage of our website.

The following table lists the use of cookies on this website:

Cookie Name

Purpose

More information

AcceptCookies

This is used to store whether you have agreed to receive cookies.

Persistent for one year.

 

Google Analytics

_utma
_utmb
_utmc
_utmz

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

Click here for an overview of privacy at Google

 

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

9      Links and Third Party Websites

This Policy applies to this website only.

This website may include links to other websites. Once you have used these links to leave our website, you should note that we do not have any control over that other website. We cannot therefore, be responsible for the protection and privacy of any data you may supply whilst visiting such websites. We advise you to familiarise yourself with the individual privacy policies and other terms for each linked website prior to submitting your personal data.

10    Changes to this Privacy Policy

From time to time we may change this Policy to accommodate industry practices, new regulatory requirements, or for other purposes. Any changes will be effective when posted and your continued use of this website will indicate your acceptance of these changes.

This Policy was last reviewed and updated on 23rd May 2018.

11    Your rights

You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below.  You may contact us using the details in section 13 of this Policy to exercise any of these rights.

In some instances, we may be unable to carry out your request, in which case we will write to you to explain why.

  1. You have the right to request access to your personal data

You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.

  1. You have the right to ask us to rectify your personal data

You have the right to request that we rectify your personal data if it is not accurate or not complete.

  1. You have the right to ask us to erase your personal data

You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data.  This right would apply if you object to the way we process your personal data (see right 6 below).

  1. You have the right to ask us to restrict or block the processing of your personal data

You have the right to ask us to restrict or block the processing of your personal data that we hold about you.  This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we don't need to use your personal data for the purpose we collected it for but you may require it to establish, exercise or defend legal claims.

  1. You have the right to port your personal data

You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services.  This allows you to move personal data easily to another organisation, or to request us to do this for you.

  1. You have the right to object to our processing of your personal data

You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims.

  1. You have the right not to be subject to automated decisions

You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.

  1. You have the right to withdraw your consent

You have the right to withdraw your consent where we are relying on it to use your personal data.

 

12    How long do we keep personal data?

Any personal data collected and stored by us will be retained only as long as it is necessary and will only be used for the purpose for which it was collected. For example, we will store data needed to process and manage your enquiry only for the duration that the enquiry is active. Upon satisfactory resolution of your enquiry, your personal details will thereafter no longer be held.

Where data is held for longer, for example to provide longer term statistical and trends analysis on our services, then the data will be anonymised to the extent that no personal data remains in that dataset.

13    Contacting us

If you have any questions or comments about this Policy, or our treatment of your personal data, please write to us by post or by email at:

By post:                                                                        

Records and Data Protection Manager                        
David MacBrayne Group
Ferry Terminal
Gourock
PA19 1QP

By email:

information.act@calmac.co.uk

Argyll Ferries 60030
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