International Foundation for Aids to Navigation ("IFAN") and/or its wholly owned trading subsidiary Menas Marine Services Limited ("MMSL") (together, "us", "we", "our") will be a 'data controller' of any 'personal data' (including individuals' names, contact details, and other personal information) you provide to us. IFAN will be the data controller whenever it communicates with or provide services to you and MMSL will be the data controller whenever it communicates with or provides services to you.
This Privacy Notice sets out the basis on which any personal information we collect about you or you provide to us will be used by IFAN or MMSL, as applicable.
How we collect your personal information.
Information you provide to us - you may provide us with personal information when you discuss our services with us, or afterwards if you receive our services (for example in relation to payment of Nav Dues by a company you represent), and/or when you are corresponding with us by post, telephone, email or via our website(s).
We will only collect basic personal information from you which will include, for example, your name, postal address, email address, telephone number.
Information from other sources - IFAN may receive information relating to Nav Due payments (which includes a limited amount of personal data associated with invoicing) from third parties such as Lloyds List. MMSL may receive information relating to vessel chartering from its broker (which will include a limited amount of personal data relating to individuals who own, operate or represent the vessel in question).
The purposes for which we use your personal information.
We need to process your personal data to:
- provide you with products and services (including processing Nav Due payments) as detailed in the applicable contract / terms (as is necessary for the performance of that contract);
- to comply with any court order, request from or referral to an appropriate authority, including, in the case of IFAN, the Charity Commission (as is necessary for compliance with our legal obligations); and
- to provide you with information about other products and services we offer that are similar to those that you have already engaged us to provide or enquired about, provided that you have not told us that you do not wish to receive this information (as is necessary for our legitimate interests in promoting our services and, in respect of contacting you for marketing purposes, where we have your consent).
How we keep your personal information secure (including when it is transferred outside the European Economic Area).
We take appropriate technical and organisational measures to ensure the secure processing of your personal data. Where we use third parties to process personal information on our behalf, we will ensure that there are robust agreements in place to provide the same data security standards that we have - and that there is a suitable lawful basis for any transfer of personal information outside the EEA. You can obtain more details of the protection given to your personal information (including when it is transferred outside the EEA) via the contact details below.
Who we share your personal information with.
For the purposes referred to in this Privacy Notice and relying on the bases for processing as set out above, we may share your personal information:
- with third party agents and contractors for the purposes of providing services to us;
- our external advisers for the purposes of obtaining professional advice;
- other members of the IFAN Group;
- where we are legally required to do so (by a court, government body, law enforcement agency or other authority of competent jurisdiction).
What are your privacy rights?
You have a number of rights in respect of your personal information under UK and European data protection laws, including the right:
- to request access to, and copies of, the personal information that we hold about you;
- to require us to correct the personal information we hold about you if it is incorrect;
- to require us to erase your personal information, in certain circumstances;
- to require us to restrict our data processing activities, in certain circumstances;
- where our processing is based on your consent, the right to withdraw that consent;
- where the processing relies on your consent and is carried out by automated means, to receive from us the personal information we hold about you which you have provided to us, in a reasonable format specified by you (including for the purpose of you transmitting that personal information to another data controller); and
- to object, on grounds relating to your particular situation, to any of our processing activities where you feel this has a disproportionate impact on your rights.
Please note that these rights are not absolute and we may be entitled or required to refuse requests where exceptions apply. If you wish to exercise any of these rights, please contact us using the contact details below.
How long we keep your personal information.
We will retain your personal data for as long as we are providing you or the company or vessel you represent with the services referred to in any relevant contractual document, and/or for as long as permitted or required for legal and regulatory purposes.
Questions and complaints.
If you have any queries about this privacy notice or how we process your personal data, or if you wish to exercise any of your rights under applicable law, you may contact us:
- by email: Schasles@ifan-maritime.org;
- by telephone: 020 7220 9520.
If you are not satisfied with our response or believe we are processing your personal data unfairly or unlawfully, you can complain to the Information Commissioner's Office.