Privacy Policy - Friot Yacht

Effective date: 16-03-2022

NAME AND CONTACT DETAILS OF THE CONTROLLER

Name: Friot Ship Management

Registered office: P. No. 801-11., Clover Bay Tower, Business Bay, Dubai – UAE
Trade Licence: No.: 974606
E-mail address: info@friotyacht.com

Name, address and contact details of the hosting service provider:
DigitalOcean LLC.
101 Avenue of the Americas, 10th Floor, New York, NY 10013 USA
privacy@digitalocean.com

https://www.digitalocean.com/legal/gdpr

PRIVACY NOTICE

The purpose of this privacy notice (hereinafter: ‘Privacy Notice’) is to make you aware of what personal data we collect, how and for what purposes we collect, use and safeguard your personal data

when you browse, register on and purchase from our website https://friotyacht.com/ and
in connection with Friot Ship Management’s services.

Friot Ship Management is committed to protecting and safeguarding your personal data. This Privacy Notice contains the contact details of Friot Ship Management as controller, the scope of the personal data we process, the purposes for which we process personal data, the legal basis for the processing, the methods and duration of the processing, the data protection and security requirements, and your rights and legal remedy options for the protection of your personal data.

What is personal data?

Personal data is any information or piece of information relating to you as a natural person which makes it possible to identify you directly (e.g. by name) or indirectly (e.g. by means of a unique personal identifier). Your personal data may include, for example: your surname and forename, your home address, your e-mail address, your IP address or the MAC address of your mobile device, cookie identifiers (i.e. cookies).

IF YOU ARE UNDER 16 YEARS OLD

If you are a minor under the age of 16, please ask your parent to read this Notice and provide the data requested on the website, e.g. name, e-mail address.

FOR PARENTS: Persons under the age of 16 may not independently consent to receive direct marketing messages and newsletters from Friot Ship Management. In the case of a child under the age of 16, the parent is therefore required to provide the child’s personal data and consent to the processing of such data. The consent of the parent (legal guardian) implies full responsibility for the child’s user activity. This section also applies to persons subject to a guardianship order restricting their legal capacity with regard to the processing of personal data.

AMENDMENT OF THE PRIVACY NOTICE

Friot Ship Management reserves the right to unilaterally amend this Privacy Notice. If Friot Ship Management‘s range of services expands in the future and the introduction of new services results in any changes to the collection or use of the personal data, we will provide you with further information. Unless otherwise indicated, new or additional services will be subject to this Privacy Notice. If this Privacy Notice is amended, we will post the current Privacy Notice on our website and, if you have provided us with your e-mail address, we will send it to the e-mail address you have provided to us. In order to be informed of any changes or amendments, we recommend that you regularly visit and check the Friot Ship Management website and the e-mail account you have provided.

SCOPE OF PERSONAL DATA PROCESSED, PURPOSE, LEGAL BASIS AND DURATION OF PROCESSING

Below is a summary table that provides important information on how we collect your personal data, the types of data we collect and why we use it, the legal basis for our processing and how long we store your personal data for each processing purpose.

In this Privacy Notice, you will also find a description of the processing in relation to our website and a description of the processing in relation to our non-website services.

NEWSLETTER, DIRECT MARKETING

For what purposes do we process your personal data?

To send you electronic direct marketing messages in the form of a newsletter from Friot Ship Management in order to contact you with customised offers, notifications and offers related to our services, announcements, sales, competitions, promotions and updates.

Which of your personal data do we process?

On what grounds do we process this personal data (legal bases)?

For how long do we process this personal data (duration of processing):

· name

· e-mail address

· IP address at the time of registration

· date of registration

Your consent for Friot Ship Management to contact you at the e-mail address you have provided for receiving the newsletter with promotional offers and personalised offers for its own business purposes and by means of its newsletter on behalf of itself and its partners, pursuant to Article 6(1)a) of the GDPR and Section 6(5) of Act XLVIII of 2008 on Commercial Advertising Activities.

You have the right to withdraw your consent and unsubscribe from the newsletter at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Until the end of the provision of the newsletter service or until you request the erasure of the data or unsubscribe from the newsletter service and there is no other legal basis for the processing.

What happens if you do not provide the data?

The provision of the data is voluntary, if you do not provide us with the relevant data, we will not be able to send you newsletters or personalised offers. The e-mail address is necessary to deliver the message to you, and your name is requested in order to identify you and to ensure that the newsletter is sent to the actual person subscribed.

Data erasure method:

You may unsubscribe from our newsletter at any time or opt out of receiving news and updates by sending a request to info@friotyacht.com or by contacting Friot Ship Management at one of the contact details listed in Section 1 of this Privacy Notice. In this case, your relevant data will be erased simultaneously with their processing. The withdrawal of consent shall not affect the lawfulness of processing before its withdrawal.

To whom do we transfer your data?

Friot Ship Management provides the data of subscribers to the newsletter to the following processors.

Name of the Processor	Registered office of the Processor	Purpose of data provision and data transfer
MailChimp	The Rocket Science Group, LLC 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA	Send promotional e-mails

EXCLUSION LIST PROCESSING

For what purposes do we process your personal data?

If you unsubscribe from our newsletter service or no longer wish to receive direct marketing material or advertising from us, Friot Ship Management is required to keep a record (an exclusion list) of your name and address data after you have unsubscribed. The purpose of the exclusion list is to ensure that your details are not repeatedly received, passed on to third parties or added to a new contact or business acquisition list. No advertising is sent to those on the exclusion list. We process the data of those on the exclusion list separate from the data of those who request direct marketing material.

Which of your personal data do we process?

On what grounds do we process this personal data (legal bases)?

For how long do we process this personal data (duration of processing):

· name

· address

· e-mail address

Fulfilment of a legal obligation

(Article 6(1)c) of the GDPR):

Friot Ship Management places the name and address data of Users who do not request direct marketing communications onto an exclusion list.

In case of exclusion of e-mail advertising, Section 6 (7) of Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities.

The controller Friot Ship Management processes your data on the exclusion list for an indefinite period, unless you explicitly request their erasure.

What happens if you do not provide the data?

The data retention is based on a legal obligation and the data are already available to Friot Ship Management, therefore no data are required from you.

Data erasure method:

You may request it at any time, free of charge, by sending a request to info@friotyacht.com or by contacting Friot Ship Management at one of the contact details listed in Section 1 of this Privacy Notice.

To whom do we transfer your data?

Friot Ship Management does not provide the data processed on the exclusion list to anyone.

BROWSING OUR WEBSITE, COOKIE

For what purposes do we process your personal data?

To ensure the proper functioning of our website, to ensure the proper display of content, to ensure the proper design of the user interface, to ensure the continuous improvement of our website to enhance the user experience, to ensure data security. In addition, to determine your interests, preferences and browsing habits and to compile statistics relating to our website, we collect anonymised personal data for statistical purposes. In order to personalise your visit, cookies are placed on your computer, which can be read back during a subsequent visit, for further details please refer to the COOKIE section of this Privacy Notice.

Which of your personal data do we process?

On what grounds do we process this personal data (legal bases)?

For how long do we process this personal data (duration of processing):

· the IP address of your computer

· the MAC address of your mobile device when browsing on your mobile phone

· the time (start and end time) and duration of the visit to our website

· depending on your settings, the type of browser and operating system used for browsing

· the website activity data

· data about where you are visiting our website from

· previously visited websites

· when using the like button on Facebook/Instagram/, facebook.com/friotyacht, instagram.com/friotyacht,

when posting a comment or message

· session cookies

Google traffic cookies

The legal basis for personal processing other than personal data processed by cookies is the legitimate interest

(Article 6 (1) f) of the GDPR)

To provide you with a high quality of service. Having taken into account your interests, rights and freedoms relating to the free use of your personal data, we determine that the processing of your data is necessary for the purposes of trend analysis, site usage statistics and to achieve a high level of service to you. Friot Ship Management has chosen the least restrictive measures, taking into account cost-effectiveness.

Among the cookies, we process user-input cookies, user-centric security cookies, multimedia player session cookies, load balancing session cookies and user interface customisation cookies on the basis of legitimate interest.

Safeguards: monitoring is not continuous, limited in space and time.

The Controller also grants you the right to object to the processing.

Until the purpose is achieved or until you object to the processing.

In the case of research-related cookies used with your consent, until the purpose is achieved (expiry of the validity period) or until you request the erasure of the data.

In the case of cookies not listed above, e.g. related to research, the legal basis for processing is your consent.

(Pursuant to Article 6 (1) a) of the GDPR).

You have the right to withdraw your consent at any time.

What happens if you do not provide the data?

The data is not provided to us by you, but is collected by Friot Ship Management. These data are automatically logged by the system. Such information is not suitable in itself for personal identification, Friot Ship Management does not link the data in the log file with other personal data, the data is used for trend analysis, to compile site usage statistics, to administer the services, to analyse and satisfy user needs, which contribute to the improvement of the services provided by Friot Ship Management and the quality of our website.

Data erasure method:

Cookies are automatically erased after their expiry date.

You can also erase the cookies from your own computer or even disable their use in your own browser. You can usually manage cookies in the ‘Settings’ menu of your browser, but this may vary from browser to browser.

Social or other content sharing websites:

If you consent to the sharing of your voluntarily provided data on other websites, you acknowledge that these other websites are governed by their own privacy notices, for which Friot Ship Management is not responsible.

To whom do we transfer your data?

Friot Ship Management provides the cookies when you browse the website to the following processors.

Name of the Processor

Registered office of the Processor

Purpose of data provision and data transfer

Calvus Communications Kft.

HotJar Ltd.

1134 Budapest, Károly krt. 41

Dragonara Business Centre,

5th Floor, Dragonara Road,

Paceville St Julian’s STJ 3141

Malta

Web optimisation

Friot Ship Management provides the cookies when you browse the website to the following processors outside the EU.

Name and registered office of the Processor

Adequacy decision – pursuant to Article 45 (1) of the GDPR

Purpose of data provision and data transfer

The Rocket Science Group, LLC

675 Ponce de Leon Ave NE

Suite 5000

Atlanta, GA 30308 USA

Commission Implementing Decision 2016/1250 (EU) (USA – EU Privacy Shield List)

MailChimp

Processing related to Registration (Account creation)

For what purposes do we process your personal data?

To identify our Users
To establish and maintain contact with you

Whose data do we process?

The data of all Users who register on the Website

What data do we process during Registration:

On what grounds do we process these data (legal bases):

For how long do we process these data (duration):

-name

-e-mail address

-password

Facebook login:

-the set FB profile picture and

-FB username

will be taken.

The processing is necessary for the performance of the contract concluded with you for the use of the Website and the Services or for taking steps at your request prior to its conclusion (Article 6(1)b) of the General Data Protection Regulation).

The period of processing is from the date of cancellation of the Registration until the end of the limitation period of the Civil Code or other legal claims (which is expected to be five (5) years), given that civil or other legal claims may arise after the termination of the service.

What happens if you do not provide the data?

Providing these data is a minimum prerequisite for Registration and their provision is therefore mandatory for Registration. If you do not provide the data, you will not be able to register on the Website and you will not be able to use our services subject to registration.

Cancellation of registration:

It is possible at any time during the duration of the User relationship, free of charge, by sending a request to info@friotyacht.com or by contacting the Controller at the contact details indicated in Section 1 of this Privacy Notice.

To whom do we transfer your data?

Friot Ship Management provides the data of registered users to the following processors.

Processing related to boat hire, guided tours and training

For what purposes do we process your personal data?

If you use our services in connection with a boatmaster training, tour or boat hire, we require the following data to provide the service, including in particular the ‘Crew List’ required by the shipping authorities.

Whose data do we process?

We process the data of persons who use our services in relation to boatmaster training, tours or boat hire.

Which of your personal data do we process?

On what grounds do we process this personal data (legal bases)?

For how long do we process this personal data (duration of processing):

· name

· place and date of birth

· identity card or passport number

· nationality

· boatmaster licence number (the latter applies only to boat hire)

· phone number

· e-mail address

The processing is necessary for the performance of the contract concluded with you in relation to the boatmaster training, tour or boat hire or for taking steps at your request prior to its conclusion (Article 6(1)b) of the General Data Protection Regulation).

The period of processing is from the date of conclusion of the training or boat hire until the end of the limitation period of the Civil Code or other legal claims (which is expected to be five (5) years), given that civil or other legal claims may arise after the termination of the service.

What happens if you do not provide the data?

If you do not provide us with these data, we will not be able to provide you with our services in relation to boatmaster training, tours or boat hire.

Data erasure method:

These data are erased after the legal limitation period, which is expected to be five (5) years.

To whom do we transfer your data?

Friot Ship Management provides the data of users to the following processors in relation to boat hire, boatmaster tours and trainings.

Friot Ship Management informs users immediately after the selection of the vessels involved in the boat hire, boatmaster tour or training, about which processor will receive their data.

Processing related to invoicing

For what purposes do we process your personal data?

For the purpose of keeping accounting records that directly and indirectly support the accounting statements.

Whose data do we process?

the data of persons using services for which payment is due

What data do we process:

On what grounds do we process these data (legal bases):

For how long do we process these data (duration):

Data required to be included in the accounting documents directly and indirectly supporting the accounts for natural persons: name, address.

In the case of payment by bank card, additional data:

In case of payment by bank transfer, additional data: bank account number

The legal basis for the processing of the data is the fulfilment of the legal obligations of the Controller pursuant to Section 169(1) to (2) of Act C of 2000 on Accounting (Article 6(1)c) of the General Data Protection Regulation).

The legal basis for the processing of data beyond the data in the supporting accounting documents is the performance of the contract between you and Friot Ship Management

(Pursuant to Article 6(1)b) of the GDPR)

We keep the data for 8 years from the date of issue

Personal data that do not constitute supporting documents for accounting purposes are kept for 5 years from the date of the order or the date of the warranty or, if this period is longer for any reason, until the end of the limitation period under civil law, in order to settle any disputes or warranty claims, and are erased after the expiry of this period.

What happens if you do not provide the data?

The provision of data is based on a legal obligation and is mandatory. If you do not provide these data, we will not be able to process your Order.

Data erasure method:

The erasure of these data is automatic once the legal deadline has expired, and is not possible before the deadline.

To whom do we transfer your data?

Friot Ship Management provides the data of users to the following processors in relation to invoicing.

Name of the Processor	Registered office of the Processor	Purpose of data provision and data transfer
Zoho Corporation Pvt. Ltd.	Dubai, Office 223, Builiding 09, Dubai Internet City, P.O. Box 502629	accounting, invoicing, customer records

Messages

For what purposes do we process your personal data?

We process data for the purposes of processing and responding to messages sent to Friot Ship Management via the Website (which can be accessed via the ‘About Us, Contact, Company Events, Boatmaster Trips’ section of the Website, by using the ‘Request a quote’ function or by sending a message to the e-mail address provided on the Website).

Whose data do we process?

data of persons who send us a message

Which of your personal data do we process?

On what grounds do we process this personal data (legal bases)?

For how long do we process this personal data (duration of processing):

‘About us, contact’ menu item:

· name

· phone number

· e-mail address

· other data voluntarily provided by the sender in their message

In the case of the ‘Request a quote’ function, no personal data is mandatory, so only the data voluntarily provided by the sender of the message are processed.

Friot Ship Management e-mail address:

· e-mail address (visible in the context of the message received)

· other data voluntarily provided by the sender in their message

Legitimate interest

(Article 6 (1) f) of the GDPR)

To ensure fast and interactive contact and the high quality of our services, and for any future legal claims. Having taken into account your interests, rights and freedoms relating to the free use of your personal data, we determine that the processing of your data is necessary for the purposes of trend analysis, site usage statistics and to achieve a high level of service to you. Friot Ship Management has chosen the least restrictive measures, taking into account cost-effectiveness.

Where data is retained because of a legal claim or the possibility of such a claim, it is also processed with regard to the legitimate interest of Friot Ship Management. In such a case, Friot Ship Management has a greater interest in enforcing its rights or defending against a legal claim than the interest of the data subject in the erasure of the personal data, taking into account that if the data were erased, the data subject would not be able to enforce or defend their claim or would find it significantly more difficult to do so.

Safeguards:

You may object to the processing at any time

The maximum duration of the processing is 13 months, taking into account that the previous year’s messages are cleansed in January each year.

In the case of a civil or other legal claim by or against Friot Ship Management in connection with the sending of a particular message, in which case the processing is

performed until the end of the limitation period (which is expected to be five (5) years), given that this is the period within which a civil or other legal claim may arise.

What happens if you do not provide the data?

The ‘About us, Contact, Company events, Boatmaster trips’ menu item: if you do not provide the data, you will not be able to send us a message using this function.
The ‘Request a quote’ function: if you do not provide the data, you will not be able to send us a message using this function.
The e-mail address of Friot Ship Management: if you send an e-mail to anyone, the email address is visible, so without your own e-mail address you cannot send an e-mail to anyone, including us.

Data erasure method:

These data are erased upon conclusion of the correspondence, unless it is retained for a legal claim or the possibility thereof, in which case they are erased after the expiry of the limitation period, which is expected to be five (5) years.

Processing related to social media activity

For what purposes do we process your personal data?

For the purpose of ensuring the use of the functions related to the presence on the social forum, the activity organised therein, liking, following, joining, commenting on social media platforms in relation to the profile and activity of Friot Ship Management. To be able to improve our services based on your opinion and feedback, to keep up to date with our awareness and possibly expand our services accordingly.

You have not provided the data directly to us, but to the provider of the social media platform. Please note that the processing of these social networking sites is governed by their own privacy policies, for which we are not responsible. Please do not forget that content posted on any of our social media platforms is often visible to the public, so please be careful when providing certain personal data.

Whose data do we process?

the data of those who like, follow, join, post comments on social media sites in relation to the profile and activities of Friot Ship Management.

Which of your personal data do we process?

On what grounds do we process this personal data (legal bases)?

For how long do we process this personal data (duration of processing):

· the username associated with their social profile (Facebook, Google+, Twitter, Pinterest, YouTube)

· occasionally: personal data you provide on your social media profile (name, nickname, photo, etc.)

· subject and content of opinions, comments

Legitimate interest

(Article 6 (1) f) of the GDPR)

To provide you with a high quality of service. Having taken into account your interests, rights and freedoms relating to the free use of your personal data, we determine that the processing of your data is necessary for the purposes of trend analysis, site usage statistics and to achieve a high level of service to you. We have chosen the least restrictive measures, taking into account cost-effectiveness.

Safeguards: Social media platform monitoring on our part is limited.

You may object to the processing at any time

If you unsubscribe from a particular social networking site or unlike, unfollow, leave a group or cancel a comment, the terms of use of that social networking site will determine how long we have access to your data.

What happens if you do not provide the data?

You cannot like, comment or recommend us on the social forum.

Data erasure method:

To whom do we transfer your data?

the following persons are involved in processing and fulfilling of requests:

Name and registered office of the Processor	Adequacy decision – pursuant to Article 45 (1) of the GDPR	Purpose of data provision and data transfer
Facebook Ireland Ltd. 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland	As not required within the EU.	Facebook platform provider
Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043. USA	Commission Implementing Decision 2016/1250 (EU) (USA – EU Privacy Shield List)	Google+ platform provider
Twitter, Inc 1355 Market Street, Suite 900 San Francisco, CA 94103	Commission Implementing Decision 2016/1250 (EU) (USA – EU Privacy Shield List)	Twitter social platform provider
Pinterest Europe Ltd. Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.	Commission Implementing Decision 2016/1250 (EU) (USA – EU Privacy Shield List)	Pinterest platform provider
YouTube LLC 901 Cherry Avenue, San Bruno, CA 94066, United States	Commission Implementing Decision 2016/1250 (EU) (USA – EU Privacy Shield List)	YouTube platform provider

Name	Registered seat	Purpose of data provision and data transfer

Social or other content sharing websites: If you consent to the sharing of your voluntarily provided data on other websites, you acknowledge that these other websites are governed by their own privacy notices, for which Friot Ship Management is not responsible.

COMPLAINT HANDLING

For what purposes do we process your personal data?

To handle and investigate customer complaints and complaints about the services offered by Friot Ship Management, in order to ensure your consumer rights and for the purposes of related proceedings.

Whose data do we process?

we process the data of persons who have customer complaints about or objections to our services.

Which of your personal data do we process?

On what grounds do we process this personal data (legal bases)?

For how long do we process this personal data (duration of processing):

· surname and forename

· address

· complaint registration number

· where and when the complaint was lodged

· details of the complaint, objection or registration

· list of files, data, documents and evidence attached to the complaint

· data relating to the product

· e-mail address

· phone number

Fulfilment of a legal obligation

(Article 6(1)c) of the GDPR):

Providing you with the opportunity to lodge a verbal or written complaint pursuant to Section 17/A(2) and (7) of Act CLV of 1997 on Consumer Protection.

Provision of the possibility of registration in the customers’ book pursuant to Section 5(4) of Act CLXIV of 2005 on Trade and Section 25 of Government Decree 210/2009 (29 September) on the Conditions for Performing Commercial Activities

The data provided by you in the course of complaint handling is kept for 5 years pursuant to Section 17/A (2) and (7) of Act CLV of 1997 on Consumer Protection.

The entries made in the Customers’ Book and the duplicate of the reply to the customer complaint are kept for 2 years, pursuant to Section 25 (5) of Government Decree 210/2009 (29 September).

What happens if you do not provide the data?

If you do not provide us with the relevant data, you may not be able to exercise your consumer rights fully or at all, as Friot Ship Management is unable to fully or partially investigate or comply with the relevant complaint in the event of a lack of data.

Data erasure method:

The above data are erased after the specified period of time, and the erasure is automatic upon expiry of the legal deadline.

To whom do we transfer your data?

The following persons are involved in the processing of complaints:

In case of complaint handling, Friot Ship Management, immediately after a verbal or written complaint has been made, informs users of the processor to which their data will be transferred.

Requests related to processing

For what purposes do we process your personal data?

In order to ensure that you can exercise your rights as described in the section ‘Your rights and enforcement’ to a high standard. In addition, to comply with the accountability requirement imposed by the GDPR on controllers in respect of the rights enforceable by you.

Which of your personal data do we process?

On what grounds do we process this personal data (legal bases)?

For how long do we process this personal data (duration of processing):

· surname and forename

· e-mail address

· subject and content of the request

Fulfilment of a legal obligation (pursuant to Article 6(1)c) of the GDPR).

in relation to the enforcement of the rights of the data subject under Article 5(2) of the GDPR (principle of accountability) and Article 12(2) of the GDPR, also taking into account Article 11 (rights of the data subject)

We keep the data for 5 years from the date of the request, for the purpose of our obligation to justify the rights granted to you under the GDPR.

What happens if you do not provide the data?

Providing the data may be a precondition for processing your requests. If you do not provide them, we may not be able to process your request or we may not be able to process it fully.

Data erasure method:

The above data are automatically erased after the specified period of time.

To whom do we transfer your data?

the following persons are involved in processing and fulfilling of requests:

Name	Registered seat	Purpose of data provision and data transfer
DigitalOcean LLC.	101 Avenue of the Americas, 10th Floor, New York, NY 10013 USA	Hosting service provider

ACCEPTANCE OF THE PRIVACY NOTICE

By using Friot Ship Management‘s website or by using our services, you confirm that you have read, understood and accepted this Privacy Notice in its entirety. When you decide to tick the box on the relevant interface confirming that you have read and understood the contents of the Privacy Notice, you accept Friot Ship Management‘s processing of your data in accordance with this Privacy Notice. If you do not agree with the terms of the Friot Ship Management Privacy Notice, please do not tick the relevant boxes and do not use the Website or our services.

ACCESS TO DATA, DATA SECURITY MEASURES

Friot Ship Management makes every effort to ensure the security of your personal data in accordance with Article 32 of the GDPR. Friot Ship Management also takes the necessary technical and organisational measures and establishes the rules of procedure required by the GDPR and other data protection and confidentiality rules, in compliance with the GDPR.

Friot Ship Management guarantees the appropriate level of data security as follows:

your data are stored in a secure technical environment and are made accessible only to authorised persons (after proper identification, our staff),
in the case of your data stored electronically, we use SSL encryption for processing,
Friot Ship Management uses the https protocol for processing, so you and the server communicate via an encrypted connection,
natural persons who have access to the personal data may only process the personal data in accordance with the instructions of the controller,
we ensure that the integrity of the data is verified,
we protect your data from unauthorised access by applying security measures,
we use appropriate technical encryption for the transfer of data,
our security measures are tested, evaluated, and improved on a regular monthly basis.

Your personal data processed by Friot Ship Management may be accessed by the following persons within Friot Ship Management‘s organisation, in accordance with the relevant internal procedures

Data breach incident: If an incident occurs involving your data, Friot Ship Management takes all necessary steps to mitigate the risks after becoming aware of it. If an incident involving your data occurs which, despite the safeguarding measures taken by Friot Ship Management (or its processor), is likely to result in a high risk to your rights and freedoms, we will inform you and the competent authority of this incident without delay and free of charge.

DATA TRANSFER

Processors: Personal data processed by the Controller are transferred to processors under contract with the Controller on the basis of the Controller’s instructions, as detailed in the individual processing operations.

Please note that in the event of a legal claim in relation to any processing, some data may be transferred to other persons (e.g. police, attorney-at-law, forensic expert) for the purpose of pursuing or defending against the legal claim.

DATA TRANSFER TO THIRD COUNTRIES

Personal data may be transferred to a third country (i.e. outside the EU) if the third country provides an adequate level of protection. Such a transfer shall not require any specific authorisation. Where such a data transfer takes place, it will be indicated separately.

Those receiving the personal data as described above are bound by confidentiality and data protection obligations.

COOKIE

The anonymous user identifier (cookie) is a unique sequence of signals, capable of identification and the storage of profile information, which service providers place on your computer. It is important to know that such a signal sequence itself cannot identify you in any way; it can only recognise your computer. In the world of the world wide web, personalised information and customised service can only be provided if the service providers can identify the habits and needs of each customer. Service providers opt for anonymous identification to learn more about the habits of their customers while using information in order to improve the quality of their services and to offer customisation options to their customers.

Disabling cookies: If you do not wish to have such an identifier placed on your computer, you can configure your browser to not allow unique identifiers or to allow only certain unique identifiers, however, in such a case, some of the services we provide may not be available, or may not be available in the form in which we would have provided if you had allowed the identifiers to be placed.

The following cookies are used on the Website: Google Analytics cookies, Google AdWords conversion tracking, HotJar information collection.

Google AdWords conversion tracking: The purpose of Google AdWords conversion tracking is to enable DSS to measure the effectiveness of AdWords advertising. This is done through the use of cookies placed on the User’s computer, which exist for 30 days and do not collect any personal data.

HotJar information collection: In order to tailor our website to the needs of our customers, we use a system provided by Hotjar Ltd (www.hotjar.com) to collect and store information for marketing and optimisation purposes. We use these data to create pseudonymised user profiles. Without the specific consent of the data subject, the data collected will not be used to identify the website visitor individually, nor will it be linked to the personal data of the pseudonymised holder. In this context, data about your browser and the device you use to surf the Internet (your country, your IP address in an anonymised form, the type of device, screen size, browser type, operating system type, pages visited, time of visit) will be processed and stored. You can disable the collection and storage of data in your browser, more information on which is available at https://www.hotjar.com/opt-out5.

Third-party cookie: We display various content on our websites through third-party web services, which may result in the storage of some cookies that are not under our control, therefore we have no control over how these websites or third-party domains collect information about your use of this embedded content

PROFILING

Please note that we perform profiling in the course of our processing as described below.

Social Platforms: If you use a social media platform, you have not provided the data directly to us, but to the service provider of the social media platform. Please note that the processing and possible profiling of these social media platforms is governed by their own processing policies, for which we are not responsible.

For your information, please find below the relevant Google Analytics service notice provided by Google:

Google Analytics: We use Google Analytics on our websites.

Google’s notice on the service: Friot Ship Management measures the traffic data of our website by using the web analytics service Google Analytics provided by Google, Inc. (hereinafter: ‘Google’). Google Analytics primarily uses internal cookies to compile reports on user interactions with Google Analytics client websites. The advertising features of Google Analytics can be activated by Google advertising cookies, such as remarketing, for Google Display Network products such as AdWords. For information on privacy settings and disabling cookies, please visit https://support.google.com/analytics/answer/6004245?hl=hu. Every computer and device that is connected to the Internet is assigned a unique number, called an IP address (Internet Protocol address). Such numbers are assigned in blocks by country, and an IP address can often be used to identify the country, state/county and city from which the computer is connected to the Internet. Because of the way the internet works, websites use IP addresses, which means that website owners can learn the IP addresses of their users even if they do not use Google Analytics. However, Google Analytics only collects the IP addresses of website users to protect the security of the service and to allow website owners to build up a picture of where their visitors originate from around the world. (also known as ‘IP geolocation’). Google stores the data in a performance-optimised, encrypted format instead of traditional file systems or databases. It distributes data across multiple physical and logical bundles to prevent data misuse and redundancy. Google apps run in environments distributed across multiple locations. Rather than keeping each customer’s data separate on a single machine or group of machines, it stores data for all Google customers (customers, businesses and even Google’s own data) in a mixed, distributed infrastructure of many homogeneous Google machines housed in Google’s data centres. For more information on Google’s privacy policy, please visit https://policies.google.com/privacy?hl=hu. You also have the option to opt-out of future Google Analytics tracking by downloading the Google Analytics Opt-out Browser Add-on and installing it on your current browser: tools.google.com/dlpage/gaoptout.

YOUR RIGHTS AND ENFORCEMENT OPTIONS

You have the following rights in relation to your personal data processed by Friot Ship Management:

Right of access
Right to rectification
Right to erasure
Right to restriction of processing
Right to data portability
Right to objection
Right to withdraw consent

1. RIGHT OF ACCESS

You have the right to receive feedback on whether your personal data are being processed, and in this context you may request information on what data Friot Ship Management processes about you, the category of personal data that these data belong to, the purposes for which they are processed and for how long, and to whom they are disclosed (category of recipients, including in particular recipients in non-EU Member States). Under this right, you may also be informed of your rights in relation to the processing; in particular, you may request the erasure of the data, the restriction of processing, the rectification of your personal data and may object to the processing of your personal data. In this context, you also have the right to lodge a complaint with the supervisory authority (National Authority for Data Protection and Freedom of Information). If you did not provide your data, you may also request information about the source of the data.

2. RIGHT TO RECTIFICATION

If your data has changed or has been incorrectly recorded, you may request the rectification, correction or clarification of your data. If your data is incomplete, you may also request that it be supplemented by means of a supplementary statement.

3. RIGHT TO ERASURE

You may request that we erase your personal data under the following conditions:

the personal data are no longer required for the purposes for which they were collected or processed
you withdraw your consent on which the processing is based and there is no other legal basis for the processing
you object to the processing and there is no overriding legitimate interest for the processing
the personal data have been unlawfully processed
the data have to be erased for compliance with a legal obligation
in relation to services offered directly to children.

Where Friot Ship Management has made the personal data public, we take reasonable steps to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

Please note that we will not be able to comply with your request for erasure if the data are necessary for the submission, enforcement or defence of legal claims or if we would restrict the right to freedom of expression and information or if we are subject to a legal obligation (or a legal obligation imposed on us by a legal obligation in the public interest or for scientific, research or statistical purposes) which is contrary to the erasure request.

4. RIGHT TO RESTRICTION OF PROCESSING

You may request that we restrict processing in the following cases:

you believe that the data are inaccurate, in which case the restriction applies for the period during which we verify the accuracy of the personal data
the processing is unlawful, but you oppose the erasure of the data and instead request the restriction of their use
we no longer require the personal data, but you require them for the submission, enforcement or defence of legal claims
if you object to the processing, in which case the restriction will apply for a period until it is determined whether our legitimate interest overrides your legitimate interest

Should the processing activity be subject to restriction, the personal data shall, with the exception of storage, only be processed with the consent of the data subject or for the submission, enforcement or defence of legal claims, for the protection of the rights of other natural or legal persons or for reasons of important public interest of the European Union or of a Member State.

Rectification, erasure or restriction of processing is communicated to all those to whom we have disclosed the personal data, unless this proves impossible or involves a disproportionate effort. You can obtain a list of such recipients upon request.

5. RIGHT TO DATA PORTABILITY

You have the right to receive your personal data processed by us, to transfer such data to another controller or, on the basis of your instructions, to have them transferred by Friot Ship Management to another controller designated by you, if the processing is based on your consent or on the performance of a contract and is performed by automated means. The portability shall not infringe the rights and freedoms of others or the right to erasure (right to be forgotten).

6. RIGHT TO OBJECTION

If the processing of your data is based on a legitimate interest of Friot Ship Management or is in the public interest or involves the exercise of official authority, you may object to this processing separately. In such cases, we will no longer process your personal data, unless the processing is justified by compelling legitimate interests which override your interests, rights and freedoms or is required for the submission, enforcement of defence of legal claims. Where your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data relating to you for these purposes, including profiling, and we can no longer process the data after your objection.

7. RIGHT TO WITHDRAW CONSENT

You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

FRIOT SHIP MANAGEMENT’S PROCEDURES TO ENSURE THE ABOVE RIGHTS

Friot Ship Management will inform you without undue delay, but in any event within one month of receipt of your request, of the action taken in response to your request or the reasons for not taking action. If the request is complex or if a large number of requests are received, the time limit may be extended by a further two months. Information is provided electronically where possible. The information and action is provided free of charge, except for requests which are clearly unfounded or excessive, in particular because of their repetitive nature. In such cases, we charge a reasonable fee or refuse to take the requested action. We may ask you for information necessary to confirm your identity in connection with your request. We also provide you with a free copy of your personal data processed by us upon first request, and charge a fee equal to the administrative costs for further copies.

Regarding the processing of your personal data by Friot Ship Management, you have the following right enforcement and legal remedy options:

Right to complain
Right to legal remedy
Right to compensation

You may enforce your rights pursuant to the GDPR and the Civil Code (hereinafter: ‘Civil Code’).

1. RIGHT TO COMPLAIN

You have the right to lodge a complaint about our processing with the supervisory authority if you believe that our processing is not in accordance with the law. In Hungary, the supervisory authority is the National Authority for Data Protection and Freedom of Information, whose registered office is: 1055 Budapest, Falk Miksa utca 9-11, website: www.naih.hu, phone number: +36 (1) 391-1400.

2. Right to seek legal remedy

You have the right to turn to the courts:

against any binding decision of the supervisory authority that applies to you
in the event that the supervisory authority does not deal with your complaint, rejects your legitimate complaint or does not inform you at all within three (3) months of the outcome of your complaint
without prejudice to your right to lodge a complaint, if you consider that your rights under the Regulation have been infringed as a result of processing that does not comply with the GDPR rules.

The Hungarian courts have jurisdiction to bring proceedings against the supervisory authority, but proceedings against Friot Ship Management may also be brought before the court competent according to the registered office of Friot Ship Management or your residential/habitually address.

3. Right to compensation

If you have suffered pecuniary or non-pecuniary damage as a result of a breach of the GDPR, you are entitled to compensation (restitution) from the controller (Friot Ship Management or the processor) for the damage suffered. Friot Ship Management or the processor shall be exempted from liability if it proves that it is not in any way responsible for the event giving rise to the damage. Such proceedings may also be brought before the court competent according to the registered office of Friot Ship Management or your residential/habitually address. The district court has jurisdiction over actions for the payment of restitution or property law cases (e.g. for compensation) not exceeding HUF 30 million, and the general court has jurisdiction over property law cases exceeding HUF 30 million.

LEGISLATION ON WHICH PROCESSING IS BASED

Friot Ship Management processes your personal data in accordance with the following laws:

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (EU) 2016/679 – GDPR – (27 April 2016) on the Protection of Natural Persons with Regard to the Processing of Personal Data and on the Free Movement of Such Data, and repealing Directive 95/46/EC
Act CXII of 2011 on Informational Self-determination and Freedom of Information (hereinafter: ‘Freedom of Information Act’)
Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities (hereinafter: ‘Commercial Advertisements Act’)

DATA PROTECTION CONTACT PERSON

Friot Ship Management will assist you with any questions you may have regarding the processing, provided that you send your questions, requests or comments in this regard to info@friotyacht.com.

APPLICABLE LEGAL AND OTHER PROVISIONS

This Privacy Notice is governed by Hungarian law.

If the applicable law in your country imposes more stringent rules on the parties than those set out in this Privacy Notice, you are obliged to comply with them. However, you acknowledge and agree that the Controller’s liability is based on the law applicable to this Privacy Notice and its liability is excluded to the fullest extent possible under applicable law and court decisions for non-compliance with the regulations of the User’s country.

The chapter titles in this Privacy Notice are for information purposes only and are not in themselves sufficient for an understanding of the processing.

If you have any questions that are not clearly answered in this Privacy Notice, please send an e-mail to info@friotyacht.com.

Friot Ship Management

The controller must be able to prove that the data subject has given their consent to the processing of their personal data (e.g. a separate tick may be appropriate for this purpose, and technically prove that it was not possible to proceed without consent, saving the server status with a timestamp and electronic signature)

The consent of the data subject must be clearly separated from other matters, if not, the statement is not binding.

The above also means that, if Friot Ship Management is not sure that it has the above-mentioned consent for its newsletter database, it is recommended to obtain the above-mentioned active consent from the users again.

Records: the records of processing activities must be kept in writing (may be electronic) Content:

a)	name and contact details of the controller,

b)	purposes of the processing;

c)	description of the categories of data subjects and of the categories of personal data;

d)	to whom the data is transferred

e)	transfers to countries outside the EU;

f)	erasure deadlines;

g)	general description of technical and organisational measures for data security.

As a general rule, a company with fewer than 250 employees is not required to keep records, unless the processing is risky or not occasional. However, the NADPFI registration and notification obligation ceases.

users must be informed thereof;
a dedicated person in the company should be assigned to control the processes
users should have the right to object to profiling and decisions based thereon.
an impact assessment must be performed and documented

users must be informed thereof;
a dedicated person in the company should be assigned to control the processes
users should have the right to object to profiling and decisions based thereon.
an impact assessment must be performed and documented

The GDPR places a strong emphasis on continuous updating (data, processing) and review, as well as on the training of the company’s employees and the persons who actually process the data.

The periods for storing and erasing data must also be respected, not just indicated. In addition, the company or entrepreneur, as the controller, must be able to give an account of the measures taken in all cases.

This Notice is addressed to the users of the websites and does not replace, for example, the Privacy Notice for the employees of the company.