Nautilus Marine Services PLC, together with its wholly-owned subsidiary, Nautilus Management Resources, Inc., (Nautilus, we/us/our) are committed to protecting the privacy of our investors, shareholders, business contracts and users of our website (you/your). This privacy statement (Privacy Statement) sets out our practices with respect to the handling of your personal data and covers the following areas:
- When we collect your personal data and the type of personal data we collect
- How we may use your personal data
- Security of your personal data
- Export of your personal data
- How long we keep your personal data
- Your rights, complaints and how to contact us
- Third party Links
- Changes to the Privacy Statement
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controllers’ possession or likely to come into such possession.
When we collect your personal data and the type of personal data we collect
Nautilus will only collect your personal data when it is specifically and knowingly provided by you (whether provided to us directly, or to us via authorised third party sources), for example by subscribing to a newsletter or other marketing materials, filling out an online form or by sending an email.
We will collect and process some or all of the following personal data about you. We also record what time you give us this information and keep track of where it is sent to.
- Information you provide to us ► personal information that you provide to us, or which is provided to us via authorized third parties, such as when you fill out an online form, including your name, email address, other contact details, your employer, job title and your investments or dealings with us.
- Our correspondence ► if you contact us, we will typically keep a record of that correspondence.
- Website usage ► When you visit Nautilus’ website, we may collect basic information such as your internet service provider's domain name, which pages you accessed on the site, and when. We use this information to analyse the use of our website to help guide improvements. This data does not consist of any personally identifiable information.
- Your marketing preference ►details of your marketing preferences (e.g. communication preferences) and information relevant to selecting appropriate products and services to offer you.
How we may use your personal data
In this section, we set out the purposes for which we use personal data that we collect. Under European data protection laws, we are also required to identify the “legal grounds” on which we rely to process the personal data. We have listed the relevant legal grounds that we rely on below and a full description of each of these grounds can be found here.
Please note that in addition to the disclosures we have identified below, we may disclose personal data for the purposes we explain in this Privacy Statement to third-party service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) and affiliates of Nautilus that perform activities on our behalf, as well as other members of the Nautilus group.
- To make and receive investments ► to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any contracts entered into between you and us.
Legal bases: contract performance, legitimate interests (to enable us to perform our obligations and provide our products and services to you).
- To provide you with marketing materials ► to provide you with updates and offers, where you have chosen to receive these. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in the “How to contact us” section below.
Legal bases: consent, legitimate interest (to keep you updated with news in relation to our products and services).
- To reorganise or make changes to our business ► in the event that we undergo a re-organisation or are involved in a sale or demerger, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed transaction. We may also need to transfer your personal information to that re-organised entity or third party after the reorganisation for them to use for the same purposes as set out in this Privacy Statement.
Legal bases: legitimate interests (in order to allow us to change our business).
- In connection with legal or regulatory obligations ► We may process your personal information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so.
Legal bases: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities).
Security of your personal data
No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with data protection legislative requirements. All information you provide to us is stored on our or our service providers’ secure servers and accessed and used subject to our security policies and standards.
Export of your personal data
Your personal data may be accessed by staff or third-party service providers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard personal data as set out in this Privacy Statement.
If you are based in the European Economic Area (EEA) and we transfer your personal data outside of the EEA, we take steps to ensure your personal data is adequately protected. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.
Please contact us as set out in the “How to contact us” section below if you would like to see a copy of the specific safeguards applied to the export of your personal data.
How long we keep your personal data
We will only hold your personal data for as long as necessary to fulfil the purposes for which it was collected, before making it non-identifiable or deleting it. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. We will keep your personal data securely, and it will be destroyed securely if it is no longer needed for the lawful purposes for which it was obtained.
If you consent to receiving marketing from us, any information we use for this purpose will be held by us until such time as you notify us that you no longer wish to receive marketing information from us. If you choose to unsubscribe from a service, we may keep a ‘suppression list’ containing your details so we know you have unsubscribed.
If you send us any ‘contact us’ messages, we will delete or de-identify these messages once we have finally satisfied your query.
Your rights, complaints and how to contact us
If you are in the EU, you have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing at any time by contacting us as set out in this section.
Under certain conditions and depending on where you are located, you have the right to
- access your personal data;
- ask for your personal data to be rectified;
- ask for deletion of your personal data where we no longer have a lawful ground to use;
- where processing is based on consent, withdraw your consent so that we stop that particular processing;
- ask us to transmit the personal data you have provided to us and we still hold about you to a third party electronically;
- object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
- restrict how we use your information whilst a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are in the EU, you also have the right to raise a privacy concern with the Data Protection Authority established in the relevant EU country e.g. the Information Commissioner’s Office in the UK.
If you would like to exercise your rights or have any questions or concerns relating to the handling of your personal data, or other privacy related query, please get in touch with us using firstname.lastname@example.org or the 'Contact us' functionality in the website's header. You may also use these links for non-privacy related queries.
Our website contains links to third-party web sites. This Privacy Statement does not apply to those third-party web sites.
We recommend that you read the privacy statements of any other sites that you visit as we cannot accept responsibility for the privacy practices of these sites, which may be different to ours. If you decide to access websites linked to ours, you do so at your own risk.
To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout
Changes to the Privacy Statement
We may change our Privacy Statement from time to time in the future. If we change this Privacy Statement, we will update the date it was last changed below. If these changes are material, we will indicate this clearly on our website. This Privacy Statement was last updated on September 26, 2018.
These are the principal legal grounds that justify our use of your personal data:
Consent: where you have consented to our use of your information (you will have been presented with a consent form in relation to any such use).
Contract performance: where your information is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.