MEDITERRANEAN YACHT MANAGEMENT – PRIVACY POLICY

Due to the Article 13 of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) we wish to inform you that Mediterranean Yacht Management SARL processes the personal data of its customers and those who have voluntarily provided their registration data, directly or by telephone, fax or email to our office.

In conformity with the law (Article 5 – Principles relating to processing of personal data), Mediterranean Yacht Management SARL guarantees that your personal data will be processed lawfully, fairly and in a transparent manner in relation to the data subject; (b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; (c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; (d) accurate and, where necessary, kept up to date; every reasonable step is taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay; (e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; (f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Controller: the controller is Mediterranean Yacht Management SARL, 9 Avenue d’Ostende, 98000 MONACO

Purposes for which personal data is processed

All data provided by interested parties are exclusively processed to fulfill obligations related to the company’s business and, in particular:

• to enter registration data in the company’s computer database;

• to calculate internal statistics;

• preparing technical service sheets for support and/or training;

• to issue delivery documents, invoices and credit memos;

• issuing quotations and proposals to active and/or potential clients;

• to issue requests for quotations and proposals to active and/or potential suppliers;

• to process ordinary and VAT accounting;

• to process collections and payments;

• to send commercial and promotional information about its activities, or those of its connected companies to active and/or potential clients;

• to profile clients (‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s economic situation, personal preferences, interests or behaviour);

• to exchange information about the company’s economic, administrative and sales activities by telephone, mail, shipping companies, fax, e-mail and the private areas of the website;

• to satisfy obligations envisaged by law, regulations, Community directives and the civil and tax codes;

Communication and diffusion of data

If necessary, the personal data of interested parties can also be communicated:

• to all subjects who are legally entitled to access the data;

• to our collaborators, employees and agents in the context of their relative duties and/or any contractual obligations with them, related to the commercial relationship with interested parties;

• to companies that produce and/or grant licenses to use any services/products supplied, only when the communication is necessary for the use of the services/products purchased by the interested party;

• to post offices, shipping companies and couriers for sending documentation and/or materials;

• to suppliers of Unified Messaging services via the Internet, when this channel is used to send letters and messages to interested parties;

• to all those physical and/or legal entities, both public and private (the offices of legal, administrative and tax consultants, the offices of payroll services, judicial offices, chambers of commerce and labor offices, etc.), when the communication is necessary or functional for our activities and in the manner and for the purposes described above.

Nature of the collection and the consequences of any failure to provide

For those who intend to open a commercial relationship with our company, even if purely for the purpose of obtaining information about our activities/services, providing personal data is optional; however, a failure to provide the information could make it impossible to continue the relationship, conduct it properly or fulfil legal and even tax obligations. Mediterranean Yacht Management SARL stores personally identifiable data for the time necessary to fulfil the purposes for which said data is collected and processed, including any retention period required by applicable law.

Rights of the data subject

The data subject has the right to receive information about the processing of his or her personally identifiable data (for example the origin of this data, the purpose of the processing, the modalities of data processing). Furthermore, the data subject is entitled at any time to object to the processing of data for the future, to restrict it, or to demand the deletion of the data. Finally, the data subject can prevent the sending of promotional material or the execution of market research or commercial communications at any time.

To summarise, the data subject has the right to:

• Information (Article 15: The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data)

• Rectification (Article 16: The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement)

• Erasure (right to be forgotten) (Article 17: The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay)

• Restriction of processing (Article 18: The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; (d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject)

• Data portability (Article 20 The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided)

• Object to the processing of personally identifiable data (Article 21: The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. 2.Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. 3.Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.)

• Lodge a complaint with a supervisory authority

Processing methods

The personal data collected directly or through email, fax or online services provided by Mediterranean Yacht Management SARL will be held and stored in 9 Avenue d’Ostende, 98000 MONACO.

All personal information is processed exclusively by technical staff specifically employed for this purpose.

The personal data is exclusively processed at the headquarters of Mediterranean Yacht Management SARL, using both the telephone and computers and even using automated equipment for the storage, handling and transmission of the data, taking every precaution to guarantee its security and confidentiality.

MEDITERRANEAN YACHT MANAGEMENT – COOKIES

Treatment of personal data – Cookies

To improve website usability, Mediterranean Yacht Management SARL uses cookies. Cookies are small text files that usually consist of letters and numbers that are stored by the user’s web browser on their PCs and contain pseudo-anonymised data. Cookies allow a website to recognise the user’s computer, in order to track the browsing of multiple pages of a website and to identify the users who return to a website. There are cookies for technical, analytical and profiling purposes.