“Personal Data” is information that can be used to identify you, directly or indirectly, alone or together with other information.
Sensar Marine is the controller for any processing of your Personal Data as a user the Sensar Boat Monitor service (hereinafter «Sensar Service»). As controller, Sensar Marine is responsible for defining the purposes for processing your personal data and for complying with current data protection legislation. The address and contact details to Sensar Marine can be found at the end of the policy document.
1. INFORMATION SENSAR MARINE COLLECTS
When you sign up for and use the Sensar Service Sensar Marine collects the following types of information:
1.1 Account information:
When you sign up for the Sensar Service some information is required to create an account, including:
first and last name
date of birth
vessel registry no.
You may also choose to voluntarily provide Sensar Marine with other types of information, such as a profile photo etc.
1.2 Payment information:
When you subscribe to the Sensar Service, you provide or the payment service provider, provide your payment card number or other relevant financial information.
1.3 Usage and device information
The Boat Monitor main unit collects data measuring a variety of metrics such as:
date and time of use
information from sensors such as;
air and water thermometers
GPS location data
relevant emergency data in case of emergency situations.
Some of these metrics/data will not be considered Personal Data covered by the GDPR. However, when Sensar Marine collects and uses data from sensors part of the Boat Monitor system that is regarded as Personal data, the legal basis for processing such data is the Terms of Service contract where processing such data is necessary to perform our Services, cf. GDPR Art. 6 (1) (b).
1.4 Analytics and advertising services provided by others
Sensar Marine works with the following partners to gather analytical data and deliver advertising services:
By subscribing to the newsletter, you provide information such as name and email. This information is not stored until you confirm your subscription through e-mail from Hubspot (The Newsletter Platform). It will be possible to check for what kind of info you receive in the confirmation.
Cookies give Sensar Marine insight into the visitors’ usage patterns, as well as how many visitors have visited the site. Cookies are categorized as Personal Data under the GDPR, even though the data is anonymous.
Service development: Cookies help Sensar Marine keep track of the use of the digital services. Sensar Marine uses this information to improve the services. Sensar Marine receives information about which websites are visited the most, if the user comes from a link outside the website, if they click on, and how long the users (anonymized) stay on the website. Sensar Marine also monitors how far the user scrolls down the page, and where the user points and clicks.
Marketing Targeting: Using cookies, Sensar Marine can also collect generic information that can be used to create marketing campaign audiences. This information is not descriptive enough to identify individuals.
The legal basis for processing your Personal Data as described in this section is GDPR Art. 6 (1) (f), which allows Sensar Marine to process information that is necessary to safeguard a legitimate interest that weighs heavier than that of the individual’s privacy. The legitimate interest is to get services on the website to work.
2. HOW SENSAR MARINE USES INFORMATION
Sensar Marine uses the information collected for the following purposes:
2.1 Administer your account and provide the Sensar Service
Sensar Marine uses the information collected to create and manage your account, as well as deliver the Sensar Service.
The legal basis for processing your Personal Data as described in this section is that it is necessary for the performance of the services and to fulfil obligations in accordance with the Terms and Conditions, cf. GDPR Art. 6 (1) (b).
In order to provide the Sensar Service, Sensar Marine uses payment information, mentioned in section 1.2, to complete your transactions. Your account information is used for order management and billing.
The legal basis for processing your Personal Data as described in this section is that it is necessary for the performance of the Sensar Service and to fulfil obligations in accordance with the Terms and Conditions, cf. GDPR Art. 6 (1) (b).
2.3 Communication with the user
Sensar Marine uses your information when you send service notifications or feedback, in order to respond to your inquiries and provide you with customer service. Sensar Marine may also use your information to promote new features or products.
When you communicate with Sensar Marine or sign up for promotional materials, the legal basis for the processing of such data is legitimate interest, cf. GDPR Art. 6 (1) (f), and Sensar Marine’s legitimate interest is to provide you with promotional messages. Where Sensar Marine is required under applicable local law to obtain your consent for sending you marketing information, the legal basis is your consent, GDPR Art. 6(1) (a).
3. HOW SENSAR MARINE SHARES INFORMATION
Sensar Marine only shares your personal information in the following circumstances:
3.1 For legal reasons or to prevent harm
Sensar Marine may preserve or disclose information about you to comply with law, regulations, government/law enforcement investigation, to assert legal rights, defend against legal claims or other legal requirements. Sensar Marine may also disclose information to assist in the prevention or detection of crime or to protect the safety of any person.
When Sensar Marine investigates suspected illegal or wrongful activity, processing of Personal Data is done on the legal basis of legitimate interest, GDPR Art. 6 (1) (f), and the legitimate interest is to ensure compliance with legal requirements and law enforcement requests and for public safety purposes.
If Sensar Marine becomes involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control, Sensar Marine may transfer your information.
When Sensar Marine processes or shares Personal Data in the event of an actual or contemplated sale, processing such data is in Sensar Marine's legitimate interest in offering, maintaining, providing, and improving the services, GDPR Art. 6 (1) (f).
3.2 With reliable third parties
Sensar Marine may choose to commercialize the Personal Data obtained through the Sensar Service. Sensar Marine may therefore share Personal Data with reliable and approved third parties who may process users Personal Data, with the relevant third parties having controller responsibility. Sensar Marine will still ensure the safety and privacy of such data while it is inside the company.
When Sensar Marine discloses Personal Data to the mentioned third parties, Sensar Marine does this on based on your acceptance of the Terms of Service Contract, GDPR Art. 6 (1) (b).
4. YOUR RIGHTS AND HOW TO EXERCISE THEM
Sensar Marine takes steps to keep your Personal Data accurate and up to date. To exercise the rights to your Personal Data, please contact Sensar Marine at the address listed below. Sensar Marine will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.
If you reside in the EU/EEA or other regions with similar statutes, you have the following rights:
Right of access to your Personal Data (GDPR Art. 15): You have the right to ask for confirmation on whether Sensar Marine is processing your Personal Data, and access to the Personal Data and related information on that processing (e.g., the purposes of the processing, or the categories of Personal Data involved).
Right to correction (GDPR Art. 16): You have the right to have your Personal Data corrected, as permitted by law.
Right to erasure (GDPR Art. 17): You have the right to ask for the deletion your Personal Data, as permitted by law. This right may be exercised among other things: (i) when your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed; (ii) when you withdraw consent on which processing is based according to GDPR Art. 6 (1) (a) or Art. 9 (2) (a) and where there is no other legal ground for processing; (iii) when you object to processing pursuant to GDPR Art. 21 (1) and there are no overriding legitimate grounds for the processing, or when you object to the processing pursuant to GDPR Art. 21 (2); or, (iv) when your Personal Data has been unlawfully processed.
Right to restriction of processing (GDPR Art. 18): You have the right to request the limiting of the processing under limited circumstances.
Right to data portability (GDPR Art. 20): You have the right to receive the Personal Data that you have provided to Sensar Marine, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including having it transmitted directly, where technically feasible.
Right to object (GDPR Art. 21): You have the right to object to the processing of your Personal Data, as permitted by law. This right is limited to processing based on GDPR Art. 6 (1) (e) or (f), and includes profiling based on those provisions, and processing for direct marketing purposes. After which, Sensar Marine will no longer process your Personal Data unless it can be demonstrated compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
5. HOW SENSAR MARINE PROTECTS YOUR INFORMATION
Sensar Marine works hard to protect your personal information from unauthorized access, disclosure or destruction. As with all technology companies, although Sensar Marine takes steps to secure your information, Sensar Marine does not promise, and you should not expect, that your personal information will always remain secure.
Sensar Marine regularly monitors the Sensar Service for possible vulnerabilities and attacks and regularly review the information collection, storage and processing practices to update Sensar Marine physical, technical and organizational security measures.
Sensar Marine may suspend your use of all or part of the services without notice if there is reason to suspect any breach of security. If you believe that your account or information is no longer secure, please notify Sensar Marine immediately.
6. HOW LONG SENSAR MARINE RETAINS YOUR INFORMATION
Sensar Marine keeps your personal information only as long as it is needed for legitimate business purposes or for providing the Sensar Service, and as permitted by applicable law.
In practice, Sensar Marine anonymizes your information upon deletion of your account (following a safety retention window of three months), unless:
it must be kept to comply with applicable law
there is an issue, claim or dispute requiring Sensar Marine to keep the relevant information until it is resolved; or
it is necessary to keep the information for Sensar Marine's legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
7. CROSS-BORDER DATA TRANSFERS
Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions, or vice versa. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. Sensar Marine uses standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.
9. HOW TO CONTACT SENSAR MARINE
You are encouraged to contact Sensar Marine directly if you have concerns regarding the processing of Personal Data. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority if you consider that the processing of Personal Data relating to you infringes applicable data protection laws.