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PRIVACY POLICY

All of us at TradeWinds respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data which you provide to us.

The following privacy policy applies from the 21st May 2018.

1. What do you do with my personal data?

We use your data to provide you luxury vacation opportunities. That includes doing things like:

  • Improving our products and services, performing market research to understand our members views and personalising our experiences to make them more intuitive & engaging;
  • Providing you with the products and services you have selected, keeping you up-to-date and informed and responding to your enquiries or highlighting luxury vacation experiences we think you will be interested in;
  • Legal, regulatory or business reasons such as keeping you abreast of updates to our Rules and Regulations and ensuring we provide your with updates to any products or services you have selected.

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We may use information about you to:

Improve our products and services

  • Enhance and personalise the products and services that we offer you and to develop new products and services;
  • Perform analysis and research and monitor usage behaviour;
  • Manage your use of our services;
  • Aggregate information about you and your use of our services in order to identify trends;
  • Analyse information about you including your calling, searching, browsing and location data on a personalised or aggregated basis.

Provide you with services and information

  • Provide you with the products and services you have selected and to manage your account with us;
  • Provide you with access to parts of this site;
  • Contact you if necessary;
  • Tell you about any new services or functionality;
  • Market our products and services to you;
  • Send you information about our products and services by email or other means if you have opted in to receiving relevant marketing communications;

Satisfy our legal, regulatory and business requirements

  • Help us keep your account safe, eg: checking your identity;
  • Investigate any complaints or other enquiries that you raise;
  • Inform you of changes to our fees and/or Rules and Regulations (if you are a Member of our Club)

We may also disclose your personal information or information about your usage of our services to certain third parties. This data may identify you personally or may be included in aggregated and anonymised data (which means you will not be identified). These third parties may use this information:

  • To give them a better understanding of our business; and/or;
  • To provide you with products and services or to improve the products or services you are already receiving.

Please see “Who do you share my personal information with (and why)” for further details about the types of third parties your information may be disclosed to.

We are allowed to use your information in these ways because:

  1. We need it to provide you with products and services and to manage your account with us;
  2. We need to use some of your information to comply with legal and regulatory obligations;
  3. We have a legitimate business interest in some uses of your information (such as conducting market research); and/or;
  4. You may have given your consent to us to use your data for certain activities, eg: marketing communications.

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2. How long will you keep my personal data?

We keep information while you're our customer and after you've left us.

We use your information to provide you with the products and services you have selected and for a variety of other reasons including providing you support.

For example, to record your vacation preferences such as dietary requirements and/or any medical information you give.

In each case, the length of time that we need to keep the information may be different.

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3. Who do you share my personal data with and why?

We will share your information in the following situations:

  • With partners, suppliers, agents and subcontractors who help us deliver the products and services you've chosen to use;
  • When you have provided your consent;
  • When we have legal or regulatory requirements such as a request from the competition authority or law enforcement agency.

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We may share your information:

  • With other companies in our group, including their respective partners, agents and sub-contractors;
  • With our current and prospective partners, agents, suppliers, affiliates and subcontractors including but not limited to:
    1. Our web hosting service supplier;
    2. Our call centre service supplier;
    3. Our mailing list service supplier.
  • With any relevant public authority or law enforcement agency;
  • Where there is a change (or prospective change) in the ownership of Tradewinds Experience Inc. to new or prospective owners. In these circumstances we would require them to keep it confidential;
  • Where we (or an affiliate processing your data on our behalf) are required to do so by law, regulation or legal proceedings;
  • Where we believe it is necessary to protect Tradewinds Experience Inc. or third-party rights and property;
  • Where you give us false or inaccurate information and/or we identify or suspect fraud;
  • In response to a valid, legally compliant request by a competent authority;
  • During emergencies when we believe physical safety is at risk;
  • In response to a complaint that you have breached the services terms & conditions or any other product or service terms.

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4. What data do you hold about me? (and how do you get it?)

We collect information in two ways:

  1. Directly from you, such as information filled in within application or registration forms, surveys and community posts;
  2. From your browsing history including the websites you visit and your location data;

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We collect such information as:

  • Your contact information including name, address, email address and telephone number;
  • For anyone boarding one of our yachts; your passport details which are presented to local Customs and Immigration authorities for clearance of the vessel;
  • Your order history including bookings and Membership activities;
  • Your payment details excluding debit or credit card details;
  • Your account settings;
  • Your communications with us including requests and complaints;
  • Your activity/interactions on our website;
  • Your device location data and Internet Protocol (IP) address.

Please note that we do not store Credit Card information however, in using your Credit Card in conjunction with our services you are giving your credit card information to your payment processor.

How we collect information:

We collect information directly from you when you are asked to provide personal details about yourself, including but not limited to when you:

  • Purchase products or services from us;
  • Register to become a Tradewinds Experience Inc. customer (or Member);
  • Submit enquiries or comments to us or contact us;
  • Enter any promotions, competitions or prize draws via the services;
  • Use any Tradewinds Experience Inc. products and services;
  • Take part in market research; and/or;
  • When you make changes to or terminate your account with us.

We collect information about you indirectly:

  • When you use any Tradewinds Experience Inc. products and services, including but not limited to when you visit or browse this site;
  • From third parties including but not limited to those who take payments;
  • Our website uses a website recording service which records mouse clicks, mouse movements and page scrolling. Data collected by this service is used to improve our website usability. The information collected is stored and anonymised and then used for aggregated and statistical reporting. You will not be personally identified;
  • We use cookies and similar technologies to provide us with information about your usage of our website, to support our functionality and to give you the best possible on-line experience. “Cookies” are small text files that store basic information that a web site can use to recognise repeat site visits and as an example, recall your name if this has been previously supplied. Cookies do not attach to your system and damage your files.

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5. What rights do I have?

You have the following rights:

  • To be informed about how we use your personal data (the purpose of this Privacy Notice);
  • To update your personal data. You can update or amend your information by contacting our support team;
  • To ask us to delete your personal data;
  • To get a free copy of your personal data;
  • To object to the processing of your data and have it restricted. There may be circumstances where you ask us to restrict the processing of your information, but we are legally entitled to refuse that request;
  • The right to make a complaint if you think that any of your rights have been infringed by us.

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To exercise any of your rights, you will need to contact our support team. You will need to provide the following information so that we can verify your identity:

  • a colour copy of your passport or picture driving licence;

Tradewinds Experience Inc. are required to respond to your request within 1 month. Where requests are complex and excessive, Tradewinds Experience Inc. is permitted an additional 2 months to process your request. However, in these circumstances we would provide an update on your request within 1 month of receiving it.

Tradewinds Experience Inc. reserve the right to charge an admin fee or refuse a request where requests for data are clearly unreasonable or excessive, particularly if they are repetitive.

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6. How do I change my marketing preferences?

You can also opt out of marketing communications by following unsubscribe links at the bottom of any marketing emails or text messages received from Tradewinds Experience Inc.

We will never give your personal data to a third party for marketing unless you have expressly given us your permission.

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7. How do you ensure my data is secure?

Tradewinds Experience Inc. is committed to keeping your data secure. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure.

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Security of Communications
Please be aware that communications over the Internet, such as e-mails and webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered - this is the nature of the World Wide Web/Internet. Tradewinds Experience Inc. cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

Users 13 and under
If you are aged 13 or under, please get your parent or guardian's permission before providing any personal information. Users without this consent are not allowed to provide us with personal information.

We will always take steps to ensure that your information is used by third parties in accordance with this policy. This can be done in a number of different ways, for instance:

    • The recipient company that we send the data to might be approved by the European Commission;
    • The recipient company might have signed up to a contract obliging them to protect your information; or;
    • The recipient is located in the US and is a certified member of the EU-US Privacy Shield scheme.

In other circumstances the law may permit us to otherwise transfer your information outside the EEA. In all cases, however, we will ensure that any transfer of your information is compliant with data protection law.

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8. What else can I do to ensure my data is secure?

Along with a section on Privacy, Get Safe Online has plenty of other good advice about protecting yourself online

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9. How can I contact you?

If you would like more information or would like to raise any queries with us in relation to your information, you can contact us by writing to the Data Protection Officer at:

Data Protection Officer
TradeWinds
Mill Mall, Suite 6
Wickhams Cay 1, PO Box 3085
Road Town, Tortola
British Virgin Islands
privacy@trade-winds.com

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10. Changes to this Privacy Policy

We will check this policy from time to time and post any changes here.

We may also let you know about these changes by email.

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11. Resolving Privacy Issues

We will always try our best to resolve any data privacy issue you may have. European Economic Area; you have the right to refer any data privacy issue to your countries Information Commissioner's Office at any time.

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