SAFE HARBOR DATA PRIVACY NOTICE
Last updated September 2020
This is the Data Privacy Notice (“Privacy Notice”) of Safe Harbor Marinas, LLC and its affiliate and subsidiary entities (“SHM”). We maintain 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 can make about the way your 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, employees, suppliers, and others who do business with us.
PERSONAL INFORMATION WE COLLECT AND USE
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. Depending on our interactions, we may collect the following categories of personal information within the past 12 months:
- • When you contact us with questions or RSVP to an event: We may collect your name, email address, phone number, boat information, or topic of interest;
- • When you interact with us through our website: We may collect your IP address, sex/gender, age, information regarding your interaction with our website, or network location based on your IP address;
- • When you make a purchase or payment or register to use a payment card with your SHM Black Card: We may collect your name, payment card number, expiration date, and security code from you;
- • When you become a SHM member: 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: We may collect your name, email address, phone number, address, SHM Member ID or loyalty card number, date of birth, photograph, driver’s license number, permit/car tag information, 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: We may collect your name, address, phone number, email address, and payment card number, expiration date, and security code from you;
- • 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 products 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 the Company, its employees, members, and people who use its websites.
We do not sell or disclose any personal information from individuals to third parties.
HOW WE MAY USE YOUR INFORMATION
Your privacy is important to us. We collect and use information we need to do our business, including providing you with the products and experiences you expect from us. When we collect and use your information, we take your privacy and security seriously.
We will use the information provided by you or on your behalf to provide our products and services, such as our marina rental services and member benefits. Specifically, we have used your personal information for the following purposes within the twelve (12) months preceding the date of this Notice:
|Category||Types of Information Collected||Purpose for Collection|
|A. Identifiers.Real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, or other similar identifiers.||Real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, or other similar identifiers.||Questions
Marina Rental, License, or Purchase
Boat Building or Repair
|B. Personal information categories
listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
|Name, signature, address, telephone number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information.
Some personal information included in this category may overlap with other categories.
Marina Rental, License, or Purchase
Boat Building or Repair
|C. Protected classification characteristics under
California or federal law.
|Age, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).||Website
Marina Rental, License, or Purchase
|D. Internet or other similar network activity.||Internet Protocol (IP) address, network location, IP address, and information on your interaction with our websites.||Website|
COOKIES AND SIMILAR TECHNOLOGIES
A “cookie” is a small text file that websites send to your computer, device, or other Internet-connected device to identify your browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and the cookies and may be used to transmit information collected through cookies back to a web server.
Behavioral Tracking/Third Party Cookies
We use third-party analytics services on our websites, including Google Analytics. To learn more about Google Analytics, visit: https://policies.google.com/technologies/partner-sites.
Your Internet browser may let you restrict or disable certain types of cookies. Without cookies, you may not be able to use all of the options on our websites.
Some web browsers allow you to turn on Do Not Track (“DNT”), which sends signals to websites you visit, telling those sites that you do not want your online activities to be tracked. Our websites currently are not designed to respond to DNT signals received from web browsers.
Sometimes we use technology to collect the information that your browser uses to auto-fill. We use this to tell you if there is a mistake in registration or if the registration cannot be submitted. You can stop this technology by turning it off in your browser, and you will still be able to use all of the options on our websites.
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.
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 the Company’s business, assets, or ownership interest (including any bankruptcy or similar proceedings).
We have not, sold, shared, or monetized any categories of personal information within the past 12 months.
Information We Disclose for a Business Purpose
In addition to the purposes described in this notice, we may use personal information listed below for business purposes.
- • To provide you with products and services, including customer service, processing orders or transactions, verifying consumer information, and processing payments, we use the following categories of information: identifiers, personal information subject to Cal. Civ. Code § 1798.80(e), protected classifications, and online activity.
- • To improve our websites, including responding to inquiries and improving functionality, we use the following categories of information: identifiers; protected classifications; and online activity.
- • To comply with your requests, including sending your information to third parties if you ask us to do so: identifiers, personal information subject to Cal. Civ. Code § 1798.80(e), protected classifications, and online activity.
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.
CALIFORNIA PRIVACY NOTICE
Your Rights and Choices
For all personal information that we collect about you, you may have the following rights or choices that we will accommodate where your requests meet legal and regulatory requirements and do not risk making our other data less secure or changing our other data. You may also designate an authorized agent to make a request on your behalf.
Access, Erase: You may have the right to know what information is being collected about you, to access your personal information, to receive a copy of your information, and to know whether your personal information is disclosed and to whom. You also may request that we erase your information. If you have questions about your information or want to ask us to erase your information, please contact us using the methods in the Contact Us section below.
Data Portability: If you would like to request that we provide a copy of your information to you, please contact us using the methods in the Contact Us section below.
Non-Discrimination: You have the right not to receive discriminatory treatment by the Company because you exercise your privacy rights. If you have any questions, please contact us using the methods in the Contact Us section below.
How to Make a Request: If you would like to make a request, please use the Contact Us section at the bottom of this page. Please provide your name, email address, and SHM member number.
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.
Verifying Your Identity: To protect you and your information, we may ask you to confirm certain information before we honor your request. For example, if you make a request, we will ask you to confirm your name, email address, and/or SHM member number to verify your identity, so that we can help protect your information. If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.
2019 Requests – In 2019, we did not receive any of the above requests.
CHANGES TO THIS NOTICE
We reserve the right to modify or change this Privacy Notice at any time. When we make a material change to this Privacy Notice, we will inform you by posting a prominent notice on the home page of our website or changing the date on this page noting when the Privacy Notice was last updated.
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:
Safe Harbor Marinas
14785 Preston Rd., 9th Floor
Dallas, TX 75254