Edition 1

1. INTRODUCTION

1.1 We are committed to safeguarding the privacy of our website visitors and service users. 1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. 1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. 1.4 If you engage with Newneek Marine, we will hold your data securely for value business reasons for 7 years. 1.5 In this policy, “we”, “us” and “our” refer to Newneek Marine. (“Newneek Marine”).

2. CREDIT

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

2.2 Photos of jacuzzi used on LINKS are courtesy of #####

3. HOW WE USE YOUR PERSONAL DATA

3.1 In this Section 3 we have set out: (a) the general categories of personal data that we may process; (b) In the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (c) the purposes for which we may process personal data; and (d) the legal bases of the processing which are set out below: (i) Consent: the individual has given clear consent for you to process their personal data for a specific purpose. (ii) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract. (iii) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations). (iv) Vital interests: the processing is necessary to protect someone’s life. (v) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law. (vi) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. 3.2 We may process your information included in our personal profile on our website (“profile data“). The profile data may include your name, profile pictures and employment details. In this instance the legal basis for processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. 3.3 We may process your personal data that are provided in the course of the use of our services (“service data“) provided when you either engage with Newneek Marine to complete the works as agreed or signed up to receive updates from Newneek Marine. 3.4 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. 3.5 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. 3.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. 3.7 We may process information that you provide to us for the purpose of subscribing to our newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. 3.8 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. 3.9 We may process testimonials and include the full name and company and/or employment details of the author that have been received whether via email or on social media. This data may be processed to be shared on Newneek Marines’ social media platforms and any digital marketing activities. 3.10 We may process photographs that have taken under our photography services. This data may be processed to be shared on Newneek Marines’ website, social media platforms and digital marketing activities. 3.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 3.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. 3.13 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 3.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4. PROVIDING YOUR PERSONAL DATA TO OTHERS

4.1 We may disclose to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 4.2 We may disclose your personal data to our subcontractors insofar as reasonably necessary upon your approval. Each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data. 4.3 Financial transactions relating to our website and services are handled by Xero. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at: https://www.xero.com/uk/about/terms/privacy 4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. RETAINING AND DELETING PERSONAL DATA

5.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. 5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 5.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. AMENDMENTS

6.1 We may update this policy from time to time by publishing a new version on our website. 6.2 You should check this page occasionally to ensure you are happy with any changes to this policy. 6.3 We may notify you of changes to this policy by email.

7. YOUR RIGHTS

7.1 Your principal rights under data protection law are: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent. 7.2 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address). 7.3 We may withhold personal information that you request to the extent permitted by law. 7.4 You may instruct us at any time not to process your personal information for marketing purposes. Please contact us at matt@newneekmarine.co.uk with your request. 7.5 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes. 7.6 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. 7.7 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. 7.8 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. 7.9 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. 7.10 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. 7.11 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. 7.12 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. 7.13 To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. 7.14 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. 7.15 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. 7.16 You may exercise any of your rights in relation to your personal data by written notice to us.

8. ABOUT COOKIES

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. COOKIES THAT WE USE

9.1 We use cookies for the following purposes: (a) authentication – we use cookies to identify you when you visit our website and as you navigate our website; (b) status – we use cookies to help us to determine if you are logged into our website; (c) security – we use cookies [as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally; (e) analysis – we use cookies to help us to analyse the use and performance of our website and services; and (f) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

10. COOKIES USED BY OUR SERVICE PROVIDERS

10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website. 10.2 We use Google Analytics and Hotjar to analyse the use of our website. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/ and Hotjar: https://www.hotjar.com/legal/policies/privacy

11. MANAGING COOKIES

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain upto-date information about blocking and deleting cookies via these links: (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera); (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-deletemanage-cookies (Internet Explorer); (e) https://support.apple.com/kb/PH21411 (Safari); and (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). 11.2 Blocking all cookies will have a negative impact upon the usability of many websites. 11.3 If you block cookies, you will not be able to use all the features on our website.

12.OUR DETAILS

12.1 This website is owned and operated by Newneek Marine. 12.2 We are registered in England and Wales under registration number ########. 12.3 Our registered business address is #########. 12.4 You can contact us: (a) by post, to the postal address given above; (b) using our website contact form; (c) by telephone, on +44 (0) 77 74 777777; or (d) by email, using matt@newneekmarine.co.uk.