We, at Ankor Software Pty Ltd (“Akor“, “we“, “us“, “our“), operate and provide a platform which provides listing information in relation to yachts (the “Platform“) as part of, and in conjunction with, our website [www.ankor.io](the “Website“) (the Platform and Website
together referred to as the “Digital Media“).
We believe it is important to protect the privacy of personal information and for you to know what type of information we collect and how we treat information we may receive from you.
In this Privacy Notice, we detail what we do with your personal data in our role as data
controller. We also set out how we collect personal information about you when you use our services or communicate with us, including when you download or interact with information in our Digital Media, or by third party users of the Digital Media.
Where we process your data as a data processor on behalf of third party agents, information about the handling of your personal data with be set out in their privacy notices.
We may collect and store the following types of personal information about you in the following ways:
- When you use our Digital Media;
- When you communicate with us (for example, by e-mail or telephone);
- When you use our social media functions;
- Through automatic collection through cookies, server logs and other similar
- Where third parties provide your data to us (for example, by agents acting on your behalf).
We may process the following personal data about you:
- “Contact Information” means your first and last name, your address, your telephone number and your email address;
- “Profile Information” means your username, password and other registration information used on our Digital Media;
- “Identity Information” means information about you, such as your age, date of birth, country of residence, medical conditions, allergies, passport details, details of yachts you have chartered or worked on, or financial information;
- “Communication Information” means information in connection with communications you send us, for example, to report a problem or submit queries and might include voice recordings of telephone calls;
- “Data and Usage Information” means data about how you use our Digital Media, including details of the functions and services you use on our Digital Media, your visits to our Digital Media, traffic data, location data and weblogs;
- “Technical Information” means information about the type of internet browser and operating system you use, your device’s IMEI number, the MAC address of the device’s wireless network interface, mobile network information and the time zone setting; and
- “Cookie and Tracker Information” means information we collect through cookies and similar technologies, which may include Data and Usage Information and Technical Information.
We shall only process your personal data where we have a legal basis for doing so. These legal bases include:
- “Contractual obligation” which means our processing of your personal information is necessary for performance of contracts to which you will be a party to and in order to take steps at your request prior to you entering into those contracts
- “Legitimate interests” which means our processing is necessary for the purposes of legitimate interests pursued by us. Primarily our legitimate interests are to provide our services to you or our other customers. Other legitimate interests may include we are conducting the processing to make sure: (i) the Digital Media is safe, efficient and customised; (ii) you receive updated information on Ankor’s business activities; (iii) to provide the services you have requested; (iv) to ensure that the content on our Digital Media is presented in the most effective manner for you and your device; (v) to allow you to participate in any features on our Digital Media when you choose to do so; and (vi) for our own marketing and research.
- “Legal obligation” which means our processing is necessary for us to comply with the law or a court order.
|Purpose||Categories of personal data||Legal Basis|
|To provide the Digital Media services to our customers||
|To provide access to our Digital Media and to ensure you have a safe, smooth, efficient, and custo||
|To train our employees||
|To manage, customise and improve our services and content on the Digital Media||
|To make sure you receive updated information about our services||
|To provide you with targeted marketing and promotional offers||
|To ensure that the content on the Digital Media is presented in the most effective manner for you and your device||
|To allow you to participate in any features on the Digital Media when you choose to do so||
|For our own research to understand the trends in the Yacht industry and the Digital Media’s place within it.||
personal information with any third parties for the purposes of direct marketing.
We may disclose your personal information to provide our services, respond to legal
requirements, enforce our policies and protect our rights and property. The personal
information you provide to us may also be shared with affiliated companies if this is
necessary to provide you with our services, respond to your inquiries or for any other related purposes.
We may also share your personal information with:
- Our affiliates.
- Other companies we have instructed to provide services for us, including payment
collection or service providers and other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted. We will only provide those companies the information they need to deliver the service and they are prohibited from using that information for any other purpose(s);
- Law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances. For example, we may share your personal information if required by a court order or regulatory authority,
or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect our Digital Media, our technology assets or the rights, property or personal
safety of any person).
- Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
Information for Data Subjects in the EEA or UK
If you are a data subject based in the European Economic Area (“EEA”) or the United
When we, or our permitted third parties, transfer your information outside the EEA or UK (either to Australia or elsewhere), we or they will impose contractual obligations on the recipients of that data to protect your information to the standard required in the UK or EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we will only transfer your information outside of the EEA or UK where: (i) the transfer is to a country deemed by the UK government or European Commission to provide adequate protection of your information; (ii) where you have consented to the transfer; or (iii) where such transfer is otherwise permissible under Data Protection Legislation (for example where we are required to provide such information by law).
You have a number of rights concerning the way that we use your information. At any time, you have the right to:
- be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
- request access to or a copy of any personal data we hold about you;
- request the rectification of your personal data, if you consider that it is inaccurate;
- request the erasure of your personal data, if you consider that we do not have the
right to hold it;
- object to your personal data being processed for a particular purpose or to request
that we stop using your information;
- request not to be subject to a decision based on automated processing and to have
safeguards put in place if you are being profiled based on your personal data;
- ask us to transfer a copy of your personal data to you or to another service provider
or third party where technically feasible; and
- ask us to stop or start sending you marketing messages at any time by using the
below contact details (see “Opt Out” below).
Although we maintain physical, electronic, and administrative safeguards to protect your
personal information from unauthorised or inappropriate access, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to us or provided though our Digital Media. Personal information that you submit may be sent to, and stored on, secure servers owned by or operated for us by third-party providers. Any payment transactions carried out by our chosen third-party provider will be encrypted using appropriate technology. We may collect and store personal data on your device using application data caches or browser web storage. If we collect personal information about you through the use of our Digital Media we will only retain that information for as long as is reasonably necessary to fulfil the activity requested, or as may be required by law.
If we collect personal information about you through the use of our Digital Media we will only retain that information for as long as is reasonably necessary to fulfil the purpose for which the data was collected by us, or as may be required by law. We may retain recordings of telephone calls for up to 6 years in order to help resolve any potential disputes and improve the quality of our services.
If you provide us with personal information, you will be given a choice at the time to “opt out” of certain uses we may intend (such as sending you newsletters, updated information about us, our services and offers) by checking or un-checking (as directed) the relevant box.
You also have the option of “unsubscribing” from our mailing list for newsletters, alerts and updates at any time, thereby disabling any further such e-mail communication from being sent to you. To unsubscribe just send an e-mail to [insert email] with the word ‘remove’ in the subject line and the email address that you wish to be removed within the email. In addition, each electronic mailing we send you will contain details of how you can unsubscribe.
Please note that it may take up to 28 days to action your request.
We will endeavour to respond to you within 30 days of you contacting us with a complaint and attempt to resolve the complaint as quickly as possible. If you are unsatisfied with our response, you also have the right to make a complaint to:
- the Information Commissioner’s Office, which regulates and supervises the use of
personal data in the UK, via their helpline on 0303 123 1113; or
- the Office of the Australian Information (OAIC), who is the regulator responsible for the Australian Privacy Principles which govern the use of the personal information in Australia, in writing via the OAIC’s secure online form, by email to [email protected] or by post to GPO Box 5218, Sydney NSW 2001.