PRIVACY POLICY



Malta Yacht Management Limited (‘MYM’, ‘Company’, ‘Us’, ‘We’, or ‘Our’) operates mym.mt , mym.com.mt, maltayachtmanagement.mt, maltayachtmanagement.com.mt (collectively ‘Website’).

The privacy of our Website visitors is very important to us, and we are committed to safeguarding it. We are required under data protection legislation to notify you of the information contained in this Privacy Policy (‘Policy’). This Policy does not form any part of any contract to provide services and explains what we will do with your personal data in accordance with the General Data Protection Regulation (‘GDPR’). The Policy includes our policies regarding the collection, use, and disclosure of personal data and other data and the choices you have associated with that data.

It is important that you read this Policy, together with any other notice we may provide on specific occasions when we are collecting or processing your personal data, so that you are aware of how and why we are using such data. By using the Website, you agree to the collection and use of information in accordance with this Policy. Consenting to our use of cookies in accordance with the terms of this policy when you first visit our Website permits us to use cookies every time you visit our Website.

PERSONAL DATA

While using our Website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (‘Personal Data’) and depending on your relationship with the Company, we may collect, store, process and use the following categories of Personal Data about you:

  • First name and surname

  • Title

  • Address

  • Phone number

  • E-mail address

  • Date of birth

  • Place of birth

  • Gender

  • Passport details

  • Nationality

  • National identification number, tax reference number and tax code

  • Tax status information

  • Next of kin and emergency contact details

  • Recruitment information (copies of right to work and identification documents, employment references, employment background history included in a CV, job application or covering letter as part of the application process)

  • Employment records (job titles, employment history and working hours)

  • Training and educational records

  • Salary, annual leave and benefits information

  • Payroll records

  • Bank account details

  • Family information

  • Disciplinary, capability and grievance information

  • Photographs

  • Any other relevant information

SPECIAL CATEGORY OF DATA

There is also a special category of more sensitive Personal Data. We may also collect, store, process and use the more sensitive personal information, such as:

  • Health information including medical conditions

  • Health and sickness records

  • Medical reports

  • Passport copy

  • Driving license copy

  • Criminal convictions and offences information

USAGE DATA

We may also collect information on how the Website is accessed and used (‘Usage Data’). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

COOKIES DATA

We use cookies and similar tracking technologies to track the activity on our Website and hold certain information.
Cookies are files with a small amount of data that may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Website. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website.

PROCESSING OF DATA

We do not need your consent when processing your Personal Data in accordance with this Policy. Your Personal Data is required to enable us to comply with our legal obligations and for our legitimate interests. In some circumstances, we may approach you for your written consent to allow us to process certain special categories and sensitive data. In this case, we will provide you with full details of the information and the reason we need it, so you can consider whether you wish to consent.

If you supply us with Personal Data of another individual or third party you must ensure that:

  • You have notified the individual or third party that you are providing their Personal Data to us and obtained their permission

  • You have provided the individual or third party with a copy of our Policy or any changes to our Policy

  • The provided Personal Data, to the best of your knowledge, is accurate and up to date, and notify us if you become aware that it is incorrect

We comply with our obligations under the GDPR by keeping Personal Data up to date, storing and destroying it securely, not collecting or retaining excessive amounts of data. We are protecting the Personal Data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate measures are in place to protect your Personal Data.

USE OF DATA

We use the collected data for various purposes:

  • To provide you with our services and process your service request or deal with your enquiry or request, to contract with you and to help us provide or administer our services. The processing is necessary to meet contractual obligations into which you have entered as a client, supplier or worker. We use your Personal Data to fulfil the services you have requested from us

  • To send statements, invoices and payment reminders and collecting the payments

  • To keep you informed and updated on relevant services, sales and charters in which you may be interested

  • To maintain records of current, past and potential clients, business contacts, members, suppliers and workers

  • To help us improve our Website, for marketing research purposes, conducting client’s satisfaction surveys and responding to your Website visits in order to improve our services

  • To verify your identity

  • To provide you with useful data, news and information by post and e-mail

  • To maintain your contact preferences

  • To administer our Website and keep it secure

  • To provide analysis of the valuable information so that we can improve our Website

  • To monitor the usage of our Website

  • To monitor emails coming in and out of the business, which may contain personal data

  • To detect, prevent and address technical issues

TRANSFER OF DATA

The Personal Data may be stored, processed and transferred outside the EU & EEA so that we can use your Personal Data as described in this Policy. We will make sure that any transfers of your Personal Data from one country to another comply with those data protection and privacy laws which apply to us. European data protection laws include specific rules on transferring Personal Data outside the EU & EEA.

On transferring Personal Data, we will:

  • Include standard data protection clauses approved by the European Commission for transferring Personal Data outside the EU & EEA into our contracts with those third parties (such clauses approved under Article 46.2 of the GDPR)

  • Ensure that the country in which your Personal Data will be handled has been deemed ‘adequate’ by the European Commission (under Article 45 of the GDPR)

We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

DISCLOSURE OF DATA

We may disclose your Personal Data to any of our employees, insurers, professional advisers, agents, suppliers, service providers or subcontractors as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

  • To the extent that we are required to do so by law

  • In connection with any ongoing or prospective legal proceedings

  • In order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)

  • to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information

SECURITY OF DATA

We have implemented appropriate security measures designed to protect your Personal Data from accidental loss, use, unauthorised access, alteration and disclosure. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. These parties are limited in number and will only process your Personal Data on our instruction and are subject to a duty of confidentiality. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

THIRD-PARTY SERVICE PROVIDERS

We may employ third-party companies and individuals (‘Service Providers’) to facilitate our services and provide the service on our behalf. We also may use Service Providers to monitor and analyse the use of our Website, to perform related services on our Website or to assist us in analysing how our services are used. These third parties may have access to your Personal Data only to perform certain tasks on our behalf and are obligated not to disclose or use it for any other purpose.

GOOGLE ANALYTICS

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

LINKS TO OTHER WEBSITES

Our Website may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third-party’s website. We strongly advise you to review the Privacy Policy of every website you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

CHILDREN’s PRIVACY

Our Website does not address anyone under the age of 18 (‘Children’). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information.

YOUR RIGHTS

Subject to an exemption under the GDPR, you have the following rights with respect to your Personal Data:

  • The right to request a copy of your personal data which we hold about you

  • The right to object to processing that is likely to cause or is causing damage or distress

  • The right to prevent processing for direct marketing

  • The right to object to decisions being taken by automated means

  • The right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed

  • The right to claim compensation for damages caused by a breach of the respective law.

You will not have to pay a fee to exercise any of your rights. However, if your request for access is clearly unfounded or excessive we may charge a reasonable fee. Alternatively, we may refuse to comply with the request in such circumstances.

We may require specific information from you to assist us in confirming your identity and ensure your right to access the information such as a supply of appropriate evidence of your identity for this purpose, we will usually accept a photocopy of your passport certified by a notary plus an original copy of a utility bill showing your current address.

CHANGES TO PRIVACY POLICY

We may update our Policy from time to time. We will notify you of any changes by posting the new Policy on this page. You are advised to review this Privacy Policy periodically for any changes.

CONTACT MYM

If you have any questions about this Policy, please contact us by email: info@mym.mt.

DATE OF ENFORCEMENT

This Privacy Policy is effective from 20 January 2020.