Data Privacy Policy

Responsible:

Star Clippers Ltd.
Clipper Palace
4 Rue De La Turbie
MC 98000 Monaco

Phone: +377 9797 8410
Mail: info.monaco@starclippers.com

Date: March 30th, 2019

1. Basic information on data processing and legal bases

1.1. This data protection declaration explains to you the type, scope and purpose of the processing of personal data within our online offer and the associated websites, functions and contents (hereinafter jointly referred to as “online offer” or “website”). This privacy policy applies regardless of the domains, systems, platforms and devices (e.g. desktop or mobile) on which the online offer is executed.

1.2. The terms used, such as “personal data” or their “processing”, we refer to the definitions in Art. 4 of the Basic Data Protection Ordinance (GDPR).

1.3. The term “user” covers all categories of data subjects. These include our business partners, customers, interested parties and other visitors to our online offering. The terms used, such as “user”, are to be understood as gender-neutral.

1.4. We process personal user data only in compliance with the relevant data protection regulations. This means that user data will only be processed if a legal permission has been obtained. This means, in particular if data processing is necessary for the provision of our contractual services (e.g. processing of quotations) and online services, or is required by law, if the user has given his or her consent, as well as on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation and security of our online services within the meaning of Art. 6 Para. 1 letter f. GDPR, in particular for range measurement, creation of profiles for advertising and marketing purposes, collection of access data and use of third-party services.

1.5. We point out that the legal basis of the consents Art. 6 para. 1 lit. a. and Art. 7 GDPR, the legal basis for the processing for the fulfilment of our services and implementation of contractual measures Art. 6 para. 1 lit. b. GDPR, the legal basis for processing to fulfil our legal obligations Art. 6 para. 1 lit. c. GDPR, and the legal basis for processing to protect our legitimate interests Art. 6 para. 1 lit. f. GDPR is.

2. Security measures

2.1. We take organizational, contractual and technical security measures in accordance with the state of the art in order to ensure that the provisions of data protection laws are observed and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

The security measures include in particular the encrypted transmission of data between your browser and our server.

3. Disclosure of data to third parties and third-party providers

3.1. Data will only be passed on to third parties within the framework of legal requirements. We only pass on user data to third parties if, for example, this is necessary for contractual purposes on the basis of Art. 6 para. 1 lit. b) GDPR or on the basis of legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR on the economic and effective operation of our business operations.

3.2. If we use subcontractors to provide our services, we will take appropriate legal precautions as well as appropriate technical and organisational measures to ensure the protection of personal data in accordance with the relevant statutory provisions.

3.3. If content, tools or other means from other providers (hereinafter jointly referred to as “third party providers”) are used in the context of this data protection declaration and their named registered office is in a third country, it is to be assumed that data is transferred to the countries in which the third party providers have their registered office. Third countries are countries in which the GDPR is not directly applicable law, i.e. in principle countries outside the EU or the European Economic Area. The transfer of data to third countries takes place either if an appropriate level of data protection, user consent or other legal permission is available.

4. Performance of Contractual Services

4.1. We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 para. 1 lit b. GDPR.

When registering, re-registering and using our online services (processing of quotations), we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary to pursue our claims or there is a legal obligation in accordance with Art. 6 para. 1 lit. c GDPR.

5. Establishment of Contact

5.1. When contacting us (via contact form, price inquiry or e-mail), the user’s details will be processed for processing the contact request and its handling in accordance with Art. 6 Para. 1 lit. b) GDPR. These data are deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.

6. Collection of Access Data and Log Files

6.1. On the basis of our legitimate interests within the meaning of Art. 7 para. 1 lit. f. GDPR data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

6.2. Log file information is stored for a maximum of seven days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.

7. Cookies and Range Measurement

7.1. Cookies are information that is transferred from our web server or third party web servers to the user’s web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.

7.2. We use “session cookies” that are only stored on our website for the duration of your current visit (e.g. to enable the storage of your login status or the shopping basket function and thus the use of our online offer at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close your browser, for example.

7.3. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

8. Integration of Third-Party Services and Content

8.1. Within our online offer, we make no representations or warranties of any kind based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as may be linked to such information from other sources.

8.2 The following presentation provides an overview of third-party providers and their contents, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, possibilities of objection (so-called opt-out):

  • Videos from the Vimeo platform of third-party provider Vimeo, Inc.,555 West 18th Street New York, New York 10011, USA. Privacy Policy: https://vimeo.com/privacy
  • External fonts from Google, Inc., www.google.com/fonts (“Google Fonts”). The integration of the Google Fonts takes place via a server call with Google (usually in the USA). Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/
  • External code of the JavaScript framework “jQuery”, provided by the third-party provider jQuery Foundation, jquery.org.

9. Google Analytics

9.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer
in the sense of Art. 6 Para. 1 lit. f. of the European Civil Code), we shall assume no liability for the content of our website. GDPR) Google Analytics,
a web analysis service of Google Inc. (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the user
is usually transferred to a Google server in the USA and stored there.

9.2. Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

9.3. Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on activities within this
website and to provide us with other services related to the use of this website and the Internet. Pseudonymous user profiles can be created from
the processed data. We use Google Analytics to display ads placed by Google and its partners within advertising services only to users who have
shown an interest in our online services or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited)
which we transmit to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences, we would also like
to ensure that our ads correspond to the potential interest of the users and do not appear annoying.

9.4. We use Google Analytics only with IP anonymization enabled. This means that the IP address of the user is shortened by Google within member states
of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address
be transmitted to and truncated by Google on servers in the United States.

9.5. The IP address transmitted by the user’s browser will not be merged with any other data held by Google. Users may refuse the use of cookies by
selecting the appropriate settings on their browser, they may also refuse the use of cookies by selecting the appropriate settings on their browser,
they may refuse the use of cookies by selecting the appropriate settings on their browser, and they may refuse the processing of cookies by selecting
the appropriate settings on Google, and they may refuse the processing of cookies by selecting the appropriate settings on Google, and they may refuse the
processing of cookies by Google, by downloading and installing the browser plugin available from the following link: http://tools.google.com/dlpage/gaoptout?hl=e.

9.6. Further information on the use of data by Google, setting and objection options can be found on the websites of Google:
https://www.google.com/intl/de/policies/privacy/partners (“Use of data by Google for your use of websites or apps of our partners”),
“http://www.google.com/policies/technologies/ads (“Use of data for advertising purposes”),
http://www.google.de/settings/ads (“Manage information that Google uses to show you advertising”).

10. Rights of Users

10.1. Users have the right, upon request and free of charge, to receive information about the personal data that we have stored about them.

10.2. In addition, users have the right to correct inaccurate data, to limit the processing and deletion of their personal data, if applicable, to assert their rights to data portability and, in the event of the assumption of unlawful data processing, to file a complaint with the competent supervisory authority.

10.3. Users may also revoke their consent, in principle with effect for the future.

11. Deletion of Data

11.1. The data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no legal storage obligations to prevent deletion. If the user’s data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax reasons.

11.2. In accordance with statutory requirements, the records shall be kept for 6 years in accordance with § 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with § 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant to taxation, etc.).

12. Right of Objection

12.1. Users can object to the future processing of their personal data in accordance with legal requirements at any time. The objection may be lodged in particular against processing for direct marketing purposes.

13. Changes to the Data Protection Declaration

13.1. We reserve the right to change the data protection declaration in order to adapt it to changed legal situations or in the event of changes to the service or data processing. However, this only applies with regard to declarations on data processing. If user consents are required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes will only be made with the users’ consent.

13.2. Users are asked to inform themselves regularly about the contents of the data protection declaration.