General Data Protection Statement and Privacy Policy Cockwells Modern & Classic Boatbuilding Ltd. provides goods and services to customers from their premises at Mylor Creek Boatyard, Mylor Bridge, Falmouth, Cornwall, TR11 5NS and via their website at www.cockwells.co.uk

The Company uses a database and information is held and processed in the following ways: Customers who use our Products and Services We hold and process customer data in order to supply goods and services: to fulfil contracts for work requested by customers and to provide quotes or estimates or other such information. We will also hold data from prospective customers who have requested the provision of services. Personal data of customers that is held and processed by Cockwells Modern & Classic Boatbuilding Ltd. can include: names, addresses, email addresses, phone numbers and bank details (for Direct Debit purposes). Customer information and details are held in our secure account through Intuit Quickbooks. Intuit is highly committed to the security of data and information they hold on behalf of their customers.

Their policy can be found at: https://quickbooks.intuit.com/uk/gdpr Credit card information given by customers over the phone will be used only to take payment. The card information is not held by Cockwells Modern & Classic Boatbuilding Ltd. once the transaction has taken place. Other details held and processed by Cockwells Modern & Classic Boatbuilding Ltd. may include customer’s boat name, boat type, dimensions, records of work carried out and other associated details. Details are used: to identify customers and their property; to fulfil contracts and supply services to record details of work carried out to create contracts or estimates to monitor & report on work processes, discuss issues and manage accounts As a result, we are unable to provide any goods or services without holding and processing such relevant customer data.

As part of fulfilling a service or contract, certain customer information (as appropriate) may be passed to:

• Couriers or companies where goods are ordered and sent directly to customers.

• Credit service providers when this is requested as part of a berthing contract.

• Manufacturers where warranties are registered on behalf of a customer or where warranty claims have been made.

• Companies to whom we sub contract specialist work (this is usually boat name only)

Data is also held of contractors, retailers, service providers and manufacturers that supply Cockwells Modern & Classic Boatbuilding Ltd. with goods or services for the purposes of payment of invoices relating to purchases.

Customer Data held for this purpose is processed under the lawful basis of Contract as set out in the General Data Protection Regulations. Newsletter Subscribers We hold and process the email addresses of customers or interested individuals who voluntarily subscribe through our website.

Customers or individuals who subscribe have requested to receive our newsletters by email and the information is not used for anything other than this purpose. Customers have the option to unsubscribe from this service at any time. For the sending of newsletters, Cockwells Modern & Classic Boatbuilding Ltd. uses an email delivery service (Mail Chimp) and customer’s data is held and processed by them solely for email delivery purposes.

Mail Chimp assure us that: “Mail Chimp never sells subscriber lists, and neither we nor our third parties have a direct relationship with your subscribers or advertise our services to your subscribers”. Data held for this purpose is processed under the lawful basis of Consent as set out in the General Data Protection Regulations.

Mailchimp’s Privacy Policy statement can be found at: https://mailchimp.com/legal/privacy/ Communication with Customers Customer data will be held and processed in order to communicate with our customers or to provide information that we that we believe may be of interest or benefit to them. This may include relevant marine or other information, newsletters and any other information of interest to our customers. Such information will directly come from and relate solely to Cockwells Modern & Classic Boatbuilding Ltd. and never from a third party.

Where this information is processed for email distribution, customer’s email addresses may be uploaded to a bona fide third party email distribution service (Mail Chimp) and customer’s information is held and processed by them solely for email delivery purposes. Customer Data used for this purpose is processed under the lawful basis of Legitimate Interests as set out in the General Data Protection Regulations.

Whenever data is processed for Legitimate Interest purposes such as these, we believe that this is reasonable, proportionate, would not be wholly unexpected and would have a minimal privacy impact. Cockwells Modern & Classic Boatbuilding Ltd. will always keep customer’s personal data rights in high regard, take account of these rights and offer an opt out at any time. Data may be passed to third parties in the event of a legal dispute or for debt recovery purposes where there is a legitimate business reason for us to do so. CCTV cameras take images of the site which may include images of customers, site users and car registration numbers. This data is held in the Legitimate Interests of site security and crime prevention but may be shared with our insurance company in support of a claim or under Legal Obligation with appropriate Law Enforcement Agencies.

Further Information Based on the nature of our business, and for the purposes of processing data, we define a customer as:

• Someone we would reasonably expect to do business with as a result of an enquiry or request

• Someone who holds a berthing licence, service agreement, lease or is currently in receipt of services

• Someone who we have done business with previously and we realistically expect to do business with them again in the future.

This could be annually or longer in the case of visiting boats or services customers. As a result, data is held for the period that we would expect to do business with a customer or as is statutorily required. When Required by Law Data will be processed where we are required to do so by legal obligation under common law or statute. Where holding & processing customer data is necessary for other legal requirements, the appropriate source for the obligation in question will be identified.

Information held for these purposes is processed under the lawful basis of Legal Obligation as set out in the General Data Protection Regulations Use of Cookies – Cookies are small files stored on your computer or mobile device by websites that are widely used to make them work more efficiently. These cookies collect anonymous information about the number of visitors to our website, where they have come to the site from and the pages they visit which is then compiled through Google Analytics & used internally only to improve the website.

Security of Data Other than as part of the processing of data as outlined above for consent, contract, legal or legitimate business purposes, we do not sell or pass on customer data to any third parties for their use. The companies that we do pass data on to as outlined above do not have our permission to use the data for any other purpose other than that which we have requested. Electronic Data is held by Cockwells Modern & Classic Boatbuilding Ltd. on secure servers protected by appropriate firewall and anti-virus measures and backed up regularly.

Paper data is held & used in premises which are locked when unoccupied, stored in locked filing cabinets/rooms where appropriate & securely destroyed when not required. Your Data Rights Cockwells Modern & Classic Boatbuilding Ltd. recognise that customers have rights to their personal data and take the protection of these rights seriously. As a result, we only ever use customer data for the purposes outlined in this privacy notice.

Should you wish to discuss any aspect of Cockwells Modern & Classic Boatbuilding Ltd.’s Privacy Policy, our use of your data or if you have a question, objection or complaint about anything relating to the use of your data, please contact the Office on 01326 377366 or email info@cockwells.co.uk Please note that the information in this notice may be amended from time to time to ensure complete compliance with the relevant regulations or to provide additional information as to how we store and process our customer’s personal data.