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SAFE HARBOR DATA PRIVACY NOTICE
Last updated August 2025
This is the Data Privacy Notice (“Privacy Notice”) of Safe Harbor Marinas, LLC and its affiliate and subsidiary entities (“SHM”). We maintain websites and mobile applications (the “websites”) to provide products and services to you. These websites may ask for and collect your personal information to provide our products and services, enhance your experience, and provide you with other relevant information about our offerings. This Privacy Notice applies to activities SHM engages in on its websites and activities that are offline or unrelated to its websites. We are providing this notice to explain our information practices and the choices you may have about the way your personal information is collected and used.
This Privacy Notice governs our treatment of personal information. We expect all of our employees and those with whom we share personal information to adhere to this Privacy Notice.
SHM is committed to protecting the information that our customers, employees, suppliers, and others have entrusted to us.
This Privacy Notice applies to all personal information collected by SHM, relating to all customers, members, suppliers, and others who do business with us. SHM is the data controller for this information, and we can be contacted using the methods set out in the “Contact Us” section of this Privacy Notice.
1. PERSONAL INFORMATION WE COLLECT AND USE
A. Personal information You Provide
We only collect personal information that you provide to us or that we are authorized to obtain by you or by law. The types of personal information we collect will depend on how you are interacting with our websites or at our locations. For example, we may collect different information from you through online purchases than if you rented a slip at a marina. Depending on our interactions, we may collect the following categories of personal information:
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- • When you contact us with questions or RSVP to an event: To register you for an event or respond to your questions, we may collect your name, email address, phone number, boat information, or topic of interest, as well as any other information you choose to provide to us;
- • When you become a SHM member: To provide products and services and manage your account with us, we may collect your name, date of birth, email address, driver’s license number, permit/car tag information, or phone number from you;
- • When you rent or license a slip, storage, boat, or lodging: To provide and accept payment for these services, we may collect your name, email address, phone number, address, SHM Member ID, date of birth, photograph, driver’s license number, permit/car tag information, vessel insurance information, payment card number, expiration date, and security code, and bank account number and routing number from you;
- • When you engage with us to build or repair a boat: To provide and accept payment for these services, we may collect your name, address, phone number, email address, and payment card number, expiration date, and security code from you;
- • When you communicate with us via SMS: If you choose to communicate with us via SMS instead of by phone or email, in order to make and keep records of those communications, we may collect your name, contact information, billing records, call or message logs, and traffic routing information, as well as the content of communications sent through or integrated with the SMS services, such as audio recordings, message bodies, and call recording transcriptions;
- • Marketing: For SHM’s marketing and other purposes, we may collect information about your purchasing transactions; records of products or services considered; records of products or services purchased; social media contact; full name; home address; personal email; postal address; unique personal identifier; account age; date of birth; phone numbers; work email; age; and gender identity and gender expression. We will also collect certain information automatically from your devices and from third parties. You can find more details in the rest of this section;
- • Marina Security: In certain circumstances, when you visit one of our locations, we may collect a copy of your driver’s license for security purposes;
- • Superyacht Applications and Marketing: When you use Rybovich applications, in order to provide services and send marketing communications to you and others on a vessel, we may collect your name, and email address, and for vessel owners or responsible parties, we will also collect your payment information. In addition, we will collect this information for all brokers and subcontractors that operate in Superyacht facilities;
- • Invoice Processing: If you are a vendor, we may collect your company name, tax ID or Social Security number, address, phone number, email address, and banking information to process invoices and payments;
- • Automating Accounts Payable and Related Marketing: If you are a vendor, in order to automate accounts payable and payment processing, and to send you related marketing communications, we may collect your name, address, phone number, and Usage Information, as defined below. We will also collect certain information automatically from your devices and from third parties. You can find more details in the rest of this section;
- • Energy Conservation and Underground Gas Storage: If you are a vendor and are involved in energy conservation or underground gas storage, we may collect your name, address, phone number, or email address;
- • Contractor Management: If you are a vendor, in the course of managing our relationship with you, we may collect your name, address, insurance details, documentation of insurance, and payment card information.
De-Identified Information
Sometimes we will de-identify personal information by removing or modifying the personally identifiable elements or extracting non-personally identifiable elements so they can’t be associated with a person (“de-identified information”). De-identified information is non-personal information and may be used and shared without obligation to you, except as prohibited by applicable law. To the extent any non-personal information is combined by or on behalf of SHM with personal information SHM itself collects directly from you on the websites, SHM will treat the combined data as described in this Notice.
B. Information Collected Automatically
SHM, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the websites (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the websites, and data regarding network connected hardware (e.g., computer or mobile device). When you interact with us through our websites, we may collect your IP address, sex/gender, age, information regarding your interaction with our website, or network location based on your IP address using the methods detailed below
The methods that may be used on the websites to collect Usage Information include:
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- • Log Information. Log information is data about your use of the websites, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
- • Information Collected by Cookies and Other Tracking Technologies. Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the websites or e-mails, including information about your browsing and purchasing behavior. Here is more detail of types of Tracking Technologies:
- • Cookies. A cookie is a small text file that is stored on a user’s device, which may be session cookies or tracking cookies. Session cookies make it easier for you to navigate the websites and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the websites, and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the websites may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The websites may associate some or all of these types of cookies with your devices.
- • Web Beacons (“Tracking Pixels”). Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the websites, to monitor how users navigate the websites, and to count content views.
- • Embedded Scripts. An embedded script is programming code designed to collect information about your interactions with the websites. It is temporarily downloaded onto your computer from SHM’s web server, or from a third-party with which SHM works, and is active only while you are connected to the websites, and deleted or deactivated thereafter.
- • Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the websites, your device location may be tracked.
- • Device Fingerprinting. Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes of identification and/or tracking.
- • Device Recognition Technologies. Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
- • In-App Tracking Methods. There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps and/or devices.
Some information about your use of the websites and certain Third-Party Services may be collected using Tracking Technologies across time and services, and used by SHM and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the websites and certain Third-Party Services.
SHM may use any or all of the Usage Information detailed above for the following purposes:
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- • Online Experience: To facilitate, manage, personalize, and improve your online experience and for research and development, we may use the Usage Information we listed above;
- • To automate accounts payable and payment processing and send related marketing: We may collect your standard web measurement and tracking technologies such as cookies, web server logs, or other statistics programs to collect Usage Information, including Internet (IP) addresses, browser type, internet service provider (ISP), language, referring/exit pages, platform type, date/time stamp, and number of clicks, to monitor and record how you use the Websites.
- • When you interact with us through our website: To provide and improve our websites, may collect your IP address, sex/gender, age, information regarding your interaction with our websites, or network location based on your IP address;
- • Account Creation and Management: To manage your account with us, we may collect and use any of the Usage Information listed above;
- • When you make payments online: In addition to the information we collect directly from you, we may also collect information through your device, browser, cookies, or pixel tags, including your IP address and geolocation;
- • Marketing Sales and Analytics: To perform analytics on your experiences with us in order to provide more personalized experiences and advertisements, and to improve our products and services, we may collect your IP address, sex/gender, age, information regarding interactions with our websites, and network location based on IP address; and
- • Debugging: To fix any technical issues that arise in the course of providing the websites, we may use any of the information listed above.
C. Information Collected from Other Sources
Service Providers and Third-Party Services
SHM may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with personal information. We may use information collected from Service Providers and Third Parties for the following purposes:
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- • Communications and Transactions: When we transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices, we may collect your email address; chat logs; and social media contact(s);
- • Marketing: For SHM’s marketing and other purposes, we may collect your name; email address; social media contact; visual information (e.g., videos); alias; and username;
- • Account Creation and Management: To manage your account, we may collect your device information, email address, and social media contact(s); and
- • Debugging: To fix any technical issues that arise in the course of providing the websites.
Third-Party Services. The websites may include hyperlinks to, or include on or in connection with, the websites (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit personal information from you.
Analytics. SHM may use Google Analytics, Adobe Analytics or other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help SHM analyze website users and how they use the websites. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the websites, compiling statistic reports on the websites’ activity, and providing other services relating to website activity and other Internet usage
Other Purposes.
We may also use any of the Usage Information we listed above for the following purposes:
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- • To operate, evaluate, and improve our business, including improving and personalizing the experience for you and others;
- • Using Data Analytics to audit, research, and conduct analysis in order to maintain and improve our services and to protect people who use our websites;
- • For safety and security, by making sure third parties protect your information, and monitoring the technical functioning and security of our network;
- • For legal and compliance, including complying with applicable laws, regulations, and legal obligations; and
- • To protect the rights or property of SHM, its employees, members, and people who use its websites.
2. HOW WE SHARE PERSONAL INFORMATION
We may share information about you to third parties as indicated below:
Affiliates, Subsidiaries, and Locations: We may share your personal information with our different locations, affiliates, and subsidiaries. If we share your information, we will share only the information that is necessary and we will take reasonable steps to make sure that third parties take prudent steps to protect your information.
Service Providers, Suppliers, Agents, and Business Partners: Other companies sometimes provide certain services to us or on our behalf (e.g., maintenance, IT support, analysis, development, security). Unless we tell you differently or as described elsewhere in this Privacy Notice, our service providers are not permitted to use your information except to assist us.
Marketing: We may share your personal information to deliver marketing communications to you. Absent your consent (which may be by means of opt-in, or a third-party interaction described in the next bullet point), however, SHM will not share your personal information with third parties, other than Affiliates, for their own direct marketing purposes, except in connection with changes in business structure or ownership (defined below).
Your Disclosure or Agreement: Your activities on the website may, by their nature, result in the sharing of your personal information (as well as your non-personal information) with third parties and by engaging in these activities you agree to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third-party, not SHM.
Compliance with Legal Obligations: We may need to disclose certain information to auditors, government authorities, law enforcement, regulatory agencies, our legal counsel, third party litigants and their counsel, or other authorized individuals in order to comply with laws that apply to us, or other legal obligations such as contractual requirements.
Changes in Business Structure/Ownership: We may disclose or transfer your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of SHM’s business, assets, or ownership interest (including any bankruptcy or similar proceedings).
We do not sell any individual’s personal information, including information belonging to children under the age of 16, nor do we share that personal information with third parties for those parties’ commercial use.
3. CHOICES: SELLING, TRACKING AND COMMUNICATIONS OPTIONS
A. Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the websites may not work and that when you revisit the websites your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Some app-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer.
B. “Do Not Track” Signals; Opt-Out Preference Signals
Your browser settings may allow you to automatically transmit an opt-out preference signal or “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, SHM currently does not alter its practices when SHM receives an opt-out preference signal or “Do Not Track” signal from a visitor’s browser.
C. Analytics and Advertising Tracking Technologies
You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.
D. Communications
You can opt out of receiving certain promotional communications from SHM at any time by following the instructions provided in e-mails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account. Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, SHM may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or SHM’s ongoing business relations.
4. HOW WE PROTECT YOUR PERSONAL INFORMATION
We strive to take appropriate security measures to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are allowed to access personal information, and they may only access it for permitted business functions. We also use technology to protect your information, including encrypting sensitive personal information that is transferred to or from our systems.
While we cannot guarantee that loss, misuse, or alteration will never occur, we use reasonable efforts to prevent it. Please keep in mind that no method of storage or transmission over the Internet is completely secure, so your use of our services and provision of information to us is at your own risk.
Our websites may contain links to other third-party sites on the Internet. The information practices of those websites are not covered by this Privacy Notice. We are not responsible for the privacy policies of other websites.
5. REQUIRED DISCLOSURES
In certain circumstances, we may choose to or may be required to provide additional or different disclosures to residents of different U.S. states or other countries. Below are the disclosures that may be applicable to you.
A. “Legal Categories” of personal information
Certain laws require us to tell you about the personal information we collect about you in a certain way – specifically, we need to tie it back to “legal categories” of personal information that are listed in the law. To do this, we bundled up the information we gave you above in this Notice and matched the different types of personal information we collect about you with the legal category. To make things easier to understand, we’ve put this information in a chart that shows you five things:
1. The legal category of personal information,
2. Examples of the types of personal information included in each legal category,
3. The source from which your personal information is collected,
4. The purpose for why we collect and use your personal information for each legal category, and
5. The business purposes for which we share your personal information and with whom.
We’ve included these things in the personal information Privacy Chart at the end of this Notice. At the end of the personal information Privacy Chart, we also included a list of personal information We Disclose for a Business Purpose.
B. European Privacy Notice
This section of our Privacy Notice applies to residents of the European Economic Area (EEA) and the United Kingdom (UK).
International Data Transfers
SHM primarily stores the personal information we collect in the United States. To facilitate SHM’s global operations, staff who work for SHM and/or our service providers may transfer and access such personal information from locations around the world. This will involve transferring your personal information outside the EEA and the UK. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice. Whenever we transfer your personal information out of the EEA or the UK, we will ensure one of the following safeguards is implemented:
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- • We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission; or
- • We may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe; or
- • We will ensure there is some other protection in place which has been approved by the European Commission as giving personal information the same protection it has in Europe.
Your Privacy Rights
Under certain circumstances, individuals within the European Economic Area have rights under data protection laws in relation to your personal information as set out in the “Your Rights and Choices” section of this Notice.
Legal Bases For Processing
This section describes some of the legal bases we rely on to process your personal information. We may process your personal information for more than one legal basis depending on the specific purpose(s) for which we are using your personal information, including the following legal bases:
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- • Contracts. Where we need to perform the contract we are about to enter into or have entered into with you, including to provide you products or services.
- • Legitimate Interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. The following are non-exhaustive examples of where SHM relies on legitimate interest to process personal information:
- • SHM has a legitimate interest in processing personal information relating to our existing customers in order to manage our business relationship and provide communications and information that may be of interest, including marketing communications.
- • SHM has a legitimate interest in using cookies as outlined in this Privacy Notice.
- • Legal Obligations. Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal information.
6. YOUR RIGHTS AND CHOICES
A. Privacy Rights
Some privacy laws require that we disclose to you the privacy rights that you have regarding personal information. We have defined the various privacy rights below. To see which rights apply to you, refer to the “Privacy Rights Chart” immediately following this subsection.
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- •Know: You may have the right to know what personal information is being collected, used, shared, and sold about you, including the categories, sources, and business purposes for collecting your personal information.
- •Access: You may have the right to request access to your personal information.
- •Erase, Delete: You may have the right to request that we delete or erase your personal information if we do not have a legal or business reason to keep it.
- •Correct: You may have the right to correct inaccurate personal information we have about you.
- •Data Portability: You may have the right to obtain personal information in a portable and readily usable format.
- •Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- •Request restriction of processing of your personal information if: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- •Request the transfer of your personal information to you or to a third party in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided for us to use or where we used the information to perform a contract with you.
- •Complain to a government regulator if you are not satisfied with our response, depending on your location.
- •Opt Out of Sale or Sharing: You may have the right to ask us not to share or sell your personal information or use it for purposes of targeted advertising or profiling.
- •Limit Processing of Sensitive personal information: Sensitive personal information includes your Social Security number, driver’s license number, state ID card, passport number, precise geolocation, racial or ethnic origin, union membership, and health and genetic data. You may have the right to ask us to limit our use of your Sensitive personal information to only what is required to accomplish the purposes we included in this Privacy Notice or that you reasonably expect from us. Our practice is to not process your Sensitive personal information except when it is necessary to accomplish the purposes disclosed in this Notice
- •Non-Retaliation for Exercising Privacy Rights: You also may have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by applicable law.
These rights may be subject to certain limitations or exceptions depending on your state of residency and the purpose for which we process personal information about you.
B. Privacy Rights Chart
| Right to Know | Right to Access | Right to Portability or Transfer | Right to Limit Sensitive personal information | Right to Opt Out of the Sale or Sharing | Right to Non-Retaliation | Right to Correction | Right to Deletion | Object to Processing | Restrict Processing | |
|---|---|---|---|---|---|---|---|---|---|---|
| California Residents | ✔ | ✘ | ✘ | ✔ | ✔ | ✔ | ✔ | ✔ | ✘ | ✘ |
| Virginia Residents | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✘ | ✘ |
| Colorado Residents | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✘ | ✘ |
| Connecticut Residents | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✘ | ✘ |
| Utah Residents | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✘ | ✔ | ✘ | ✘ |
| EEA Residents | ✘ | ✔ | ✔ | ✘ | ✘ | ✘ | ✔ | ✔ | ✔ | ✔ |
Where applicable and technically feasible, SHM will accommodate your valid request to exercise your privacy rights and choices. You may also designate an authorized agent to make a request on your behalf.
Non-Discrimination and Bona Fide Loyalty Programs
As of the Effective Date of this Notice we did not offer any programs requiring you to limit any of your privacy rights, or otherwise require you to limit your privacy rights in connection with charging a different price or rate, or offering a different level or quality of good or service. If we do so, California Law requires certain program terms and notices for California consumers and the material aspects of any such program, and the rights of California participants, will be explained and described in its program terms. Participating in any such programs will be entirely voluntary. We may add or change programs and/or their terms by posting notice on the program descriptions so check them regularly.
C. Making Privacy Requests
How to Make a Request: If you would like to make a request, please use one of the methods in the “Contact Us” section of this Privacy Notice. You will need to provide your first and last name, email address, physical address, and SHM member number.
SHM may provide web pages or other mechanisms allowing you to delete, correct, or update some of the personal information, and potentially certain other information about you (e.g., account information). For instance, you can make changes to your account information by updating or modifying your online account information via the “Members” link in our settings menu. SHM will make good faith efforts to make requested changes in SHM’s then-active databases as soon as practicable, but it is not always possible to completely change, remove, or delete all of your information or public postings from SHM’s databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
Responding to Requests: Your request will be evaluated to determine whether the requested change meets legal regulatory requirements and does not risk making our other data less secure or changing our other data. If we are not able to honor any part of your request, we will tell you that in our response, as well as the reason(s) we cannot do so.
Verifying Your Identity: In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the consumer we may have collected personal information about or a person who has been duly authorized to make the request on behalf of the consumer. For example, if you make a request, we will ask you to confirm your name and email address. For certain requests, we will use a combination of your email address, name, and/or zip code to verify your identity, so that we can help protect your information.
Appealing a Denied Request: If we deny all or part of your privacy request, you may have a right to appeal that decision. If you would like to make an appeal, please contact us using the methods in the “Contact Us” section below, and include your name, email address, SHM member number, physical address, the type of request you made, and the reason for requesting an appeal.
Requests by Authorized Agents: You may have the right to designate an authorized agent to make a request on your behalf. Authorized agents of consumers may make a request by using the methods in the “Contact Us” section of this Privacy Notice. As permitted by California privacy law, any request you submit to us is subject to an identification and verification process, and confirmation of the agent’s authority, which may include attestation under penalty of perjury. Absent a power of attorney, we will also require the consumer to verify their own identity. We may verify identity based on matching information you provided with data we have maintained on you in our systems. This data could include, but is not limited to, email address, mailing address, or phone number.
D. Third Party Marketing and Your Additional California Privacy Rights
Separate from your “Do Not Sell” rights, California residents have the following additional rights regarding disclosure of your personal information to third parties for their own direct marketing purposes:
We provide California residents with the option to opt-in to sharing of “personal information” as defined by California’s “Shine the Light” law with third parties, other than with our affiliates, for such third parties’ own direct marketing purposes. We do not share personal information with non-Affiliate third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law and/or withdraw previously given consent to sharing with non-Affiliate third parties for their direct marketing purposes by contacting using the methods in the “Contact Us” section below. Requests must include “California Marketing Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mailing address
As these rights and your privacy rights are not the same and exist under different laws, you must exercise your rights under this law and the other privacy laws separately.
E. Children’s Privacy
SHM does not seek to or intentionally collect personal information of children. If you suspect that a child is using our websites, please contact SHM by email at MemberHelp@SHMarinas.com.
7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We cannot (fully) comply with a request to erase or delete if we have to retain your personal information for certain purposes and for a longer period due to a statutory retention period. After the retention period has expired, we will delete your personal information.
8. CHANGES TO THIS PRIVACY NOTICE
We reserve the right to change this Notice prospectively effective upon the posting of the revised Notice and your use of our websites indicates your acknowledgement of the Notice posted at the time of use. However, should we update this Notice, we will post a new version online, and will notify you if the personal information processed about you will be materially different than that which was represented to you at the time it was collected. To the extent any provision of this Notice is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
9. CONTACT US
For questions regarding this Privacy Notice or to submit any of the requests mentioned above relating to your personal information, contact us using any of the following options:
Mail
Safe Harbor Marinas
14785 Preston Rd., 9th Floor
Dallas, TX 75254
Email
notices@shmarinas.com
Telephone
1-972-488-1314
PERSONAL INFORMATION PRIVACY CHART
We collect customers’ personal information as described above for the following purposes, when permissible under applicable law.
| Category | Types of Information Collected | Source | Purpose for Collection | Sharing with Third Parties |
|---|---|---|---|---|
| A. Identifiers. | Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | •Directly from You • From Third Parties • Automatically from Your Devices |
•Questions & Events • Product Purchase • Membership • Rental, License, or Purchase • Boat Building or Repair • SMS Communications • Marketing • Marina Security • Superyacht Applications and Marketing • Invoice • Accounts Payable and Marketing • Energy Conservation • Contractor Management • Online Experience • Interactions with Websites • Debugging • Communications and Transactions |
• Affiliates, Subsidiaries, Locations • Service Providers • Marketing • Your Request • Legal Obligations • Changes in Business Structure or Ownership |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | •Directly from You • From Third Parties |
• Questions & Events • Product Purchase / Black Card • Membership • Rental, License, or Purchase • Boat Building or Repair • SMS Communications • Marketing • Marina Security • Rybovich Applications and Marketing • Invoice • Accounts Payable and Marketing • Energy Conservation • Contractor Management • Online Experience • Interactions with Websites • Debugging • Communications and Transactions |
• Affiliates, Subsidiaries, Locations • Service Providers • Marketing • Your Request • Legal Obligations • Changes in Business Structure or Ownership |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | •Directly from You • Automatically from Your Devices • From Third Parties |
• Membership • Rental, License, or Purchase • Marketing • Marina Security • Online Experience • Interactions with Websites • Debugging • Communications and Transactions |
• Affiliates, Subsidiaries, Locations • Service Providers • Marketing • Your Request • Legal Obligations • Changes in Business Structure or Ownership |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | •Directly from You • From Third Parties |
• Membership • Rental, License, or Purchase • Marketing • Rybovich Applications and Marketing • Invoice • Accounts Payable and Marketing • Online Experience |
• Affiliates, Subsidiaries, Locations • Service Providers • Marketing • Your Request • Legal Obligations • Changes in Business Structure or Ownership |
| E. Biometric information | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Not collected | Not collected | Not collected |
| F. Internet or other similar network activity. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | • Automatically from Your Devices | • Online Experience • Interactions with Websites • Debugging • Communications and Transactions |
• Affiliates, Subsidiaries, Locations • Service Providers • Marketing • Legal Obligations • Changes in Business Structure or Ownership |
| G. Geolocation data | Physical location or movements | • Automatically from Your Devices | • Online Experience • Interactions with Websites • Marketing |
• Affiliates, Subsidiaries, Locations • Service Providers • Marketing • Legal Obligations • Changes in Business Structure or Ownership |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | Not collected | Not collected | Not collected |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | Not collected | Not collected | Not collected |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records | Not collected | Not collected | Not collected |
| K. Inferences drawn from other Personal Information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Not collected | Not collected | Not collected |
| L. Sensitive Personal Information as defined in § 1798.140(ae) of the California Privacy Rights Act | Social Security number, driver’s license number, state ID card, passport number, precise geolocation, racial or ethnic origin, union membership, and health and genetic data. | • Directly from You • Automatically from Your Devices |
• Membership • Rental, License, or Purchase • Marketing • Marina Security • Invoice • Accounts Payable and Marketing • Online Experience • Debugging |
• Affiliates, Subsidiaries, Locations • Service Providers • Marketing • Legal Obligations • Changes in Business Structure or Ownership |
We may also collect information to comply with applicable law or regulatory requirements or legal requests.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
-
- Category A: Identifiers
- Category B: California Customer Records Categories
- Category C: Protected Classifications
- Category D: Commercial Information
- Category F: Internet and Network Activity
- Category G: Geolocation Data
- Category L: Sensitive Personal Information