Marina Developments Limited (“MDL”) sets out in this Privacy Notice how it handles personal data under the GDPR as amended, implemented and expanded by the Data Protection Act 2018 and secondary legislation made under it (together “the Data Protection Legislation”). MDL has notified the Information Commissioner’s Office (ICO) that it holds personal data as a data controller ( and its details can be checked at the ICO under No. Z5608424.
Terms which are given specific meanings in the Data Protection Legislation, such as “personal data” data controller” and “data processor” have the same meanings in this Privacy Notice.
Under the Data Protection Legislation, MDL has a legal duty to protect any information we collect from you or which we receive from third party sources about you. We set out below the sources of data relating to you which we process.
We won’t share your information with any other organisations for marketing, market research or commercial purposes, and we don’t pass your details to other websites.
MDL is committed to protecting the privacy and security of your personal data We adopt appropriate technical and organisational measures to mitigate security risks and to ensure that:
(i) we process data in strict compliance with Data Protection Legislation;
(ii) we are able to respond in a timely manner to subject access requests;
(iii) we can detect and report data breaches;
We hold your data in the UK. Where we do not own the systems on which personal data is held, the data is held on our behalf by a data processor operating under a written data processing agreement which complies with the Data Protection Legislation.
This privacy notice describes how we collect and use personal information about you, in accordance with the Data Protection Legislation.
We may update this notice at any time. The date at the top of the policy is the date on which the data policy was last revised
For data protection purposes Marina Developments Limited is the “data controller”. This means that, we are responsible for deciding how we hold and use personal information about you.
It is important that you read this notice, together with any other privacy notice we may provide from time to time, so that you are aware of how and why MDL is using such information.
MDL must comply with the data protection principles which state that the personal information we hold about you must be:
All berthing is subject to our Terms and Conditions and our Marina Regulations. The Marina Regulations and Freedom Berthing Terms and Conditions for the 2020/21 season can be viewed below and are also displayed in the marina office. At any time you can request a printed copy to be sent to you in the post.
‘Personal data’ means any information about an identifiable living individual. It does not include data which has been aggregated or anonymised so that an individual can no longer be identified from it
MDL may collect, store and use the following categories of personal information about you:
Certain categories of data are designated “special categories of data”. This is data which covers:
We will rarely need to process special categories of data, and where we do so it will only be done on the basis of an appropriate and documented reason as set out in the Data Protection Legislation.
MDL collects personal information directly during the purchase of services such as annual berthing agreements, purchase of boat yard services, visitor berthing or other services provided by MDL.
We collect certain information or data about you when you use our website or our Apps. This includes:
Access Control Data is held for 24 hours after which the data is removed from the Access Control Server and individual names and unique reference numbers are deleted. Whilst other non-identifiable information is kept for site usage statistics, this is no longer personal data.
(i) In selecting the location of the CCTV we have sought to limit the capture of irrelevant material and to ensure;
(ii) notices are placed near the location of the cameras indicating that they are in use and who to contact in the event of any concerns with the CCTV;
(iii) recorded material is overwritten every [ 30 ] days, and is not retained longer unless there is a security breach or other specific reason for doing so;
(iv) no-one reviews footage unless there is a specific incident requiring review, at which point a request must be submitted to the marina management to review; and
(v) it is only passed to third parties when a valid and compliant basis for transfer of that data has been established.
You can send us your feedback directly using the contact area on our website. We do not pass on any of your personal information outside our organisation when dealing with your enquiry. We will not use any information you supply for any other purpose without first seeking your permission.
Where your details are held in our tracking system these are archived after we have dealt with your enquiry and deleted after 36 months.
In addition to the personal data which you provide to us directly, we collect data from the following groups of people:
(i) Credit reference agencies where applicable
(ii) Professional advisers and consultants;
(iii) Complainants and enquirers;
(v) Local authorities; and
(vi) Other public sector bodies and service providers such as utilities companies.
MDL will only use your personal data when the law allows us to and in accordance with a valid basis for processing that data, as provided in the Data Protection Legislation. If we cease to have a valid basis for processing your personal data, we will stop doing so.
Most commonly, we will use your personal information in the following circumstances:
We may also use your personal information in the following situations, which are likely to be rare:
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Where this is required or permitted by law, we may process your personal information without your knowledge or consent, in compliance with the above rules.
MDL may have to share your data with third parties, including third-party service providers, other entities in the group and law enforcement authorities.
We will share your personal information with third parties where required by law, where it is necessary to administer the client - business relationship with you or where we have another legitimate interest in doing so.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We do not transfer your personal information outside the EU.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not give third-party service providers our permission to use your personal data for their own purposes. They are only allowed to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Once you are no longer a customer of MDL we will retain and securely destroy your personal information in accordance with our applicable legal obligations and legitimate interests.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your customer relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the MDL Privacy Officer in writing (contact details are provided below)
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Privacy Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
We have appointed a privacy officer (PO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the PO on email@example.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Changes to this privacy notice
MDL reserve the right to update this privacy notice at any time, and we may provide you with a new privacy notice when we make any important updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the Privacy Officer.
Marina Developments Limited
1 Channel Way