Privacy Policy - GoMarina

1 Purpose of data processing

The purpose of processing personal data in GoMarina is to provide the visitor with an easy and safe way to purchase products and services offered by the port visited, including creating the right conditions for effective customer follow up, as well as ensuring that inspectors can verify valid port fees.

There are individual ports and recreational sites that offer their services via GoMarina (hereafter referred to as the "Data controller") who are responsible for processing the personal data through GoMarina.

GoMarina is a product by WTW AS (hereafter referred to as the "Data Processor"), that processes your personal information on behalf of the Data Controller, in accordance with a separate data processing agreement, cf. Item 6.

2 Legal basis

Fulfilling the agreement

Processing of your personal information is necessary in order for you to use the app, including fulfilling the service contract between you and the Data Controller. The agreement is a contract that you enter into as you use and accept the terms of the app. Before signing up for the app, you will be informed that your personal data is processed in accordance with this Privacy Policy.

3 Personal data

For this solution, the following general personal information about you is processed:

Username - mobile number or email: At least one type of username (mobile number or email) is required to be registered in your user profile to provide a secure and verified login service. It is also necessary to ensure that you can access a valid proof of port fee and receipts for your prior purchases if you change mobile devices or number. You can choose whether to enter a mobile number or email as your username. This personal information is required for your user profile.

Boat or vehicle: When you sign up for the app, you will be asked to enter information about which boat or vehicle you use as a visitor to the port. This is required for the harbor owner to be able to carry out a boat/vehicle inspection against registered port fee payments.

Email address for receipts: It is optional to enter your email address to use for receipt under Settings in the app. Email for receipts is only required if you wish to receive your purchase receipts in your email.

Other user info: Under Settings in the app, you have the option to register your name, phone number, home address and email. These fields are only required if you rent a spot in the port which, for reasons of national or regional regulations, requires this information from its visitors. If you have registered a mobile number in the profile, either as a username or as other personal info, the harbor owner will be able to use this contact information to send important messages to visitors at their port.

Information related to specific port products: For port fees in individual ports, you may be asked to fill out information that is specifically required for the particular purchase. An example of this is the number of guests at the time of arrival/departure. This information is sent to the port and is only kept as separate data relating to the relevant purchase. It will not be further transferable to other ports or stored further in connection with your profile.

Sales documentation: All sales documents are stored in accordance with the Norwegian Bookkeeping Act and Regulations applicable in the country in which the port is located.

Information about payment methods:

Bank cards (credit and debit cards)- In order to pay by bank card, there is an interface to the payment service that allows you to register a payment card via GoMarina app, without the full bank card details being stored in GoMarina. Even if you choose to save one or more payment cards in your profile, only the payment service has your full bank card details. The app will only store the first six and last four digits of the card number along with the expiry date. This information is essential for the customer to be able to recognize his/her card, in order to generate the necessary details that should be on a receipt and to effectively enforce the customer´s right to a refund.

Technical information: When you use the GoMarina app or visit www.gomarina.com, your IP address, timing of request, browser or mobile phone information along with the version number and mobile platform of the app, and language selection is stored into an application log. This information is required for the solution to work on a given platform / mobile phone and is stored to ensure that the service functions as intended. This also provides us with necessary information to solve any issues if an error occurs. No kind of analytics tool (e.g., Google Analytics) is used to identify and log the behavior of identifiable users. The only analytical function is crash reporting via HockeyApp, which provides completely anonymous crash reports and helps us swiftly rectify the problem if the app were to crash.

Location information: By accepting that the app accesses the phone´s GPS, location data is processed only locally on the phone. No location data that is stored in the app is shared with the back-end system. The only location information to be processed is the information about the selected port and docking spot/parking area, if stated. This is required to document purchases and provide information to the correct port / Data Controller.

4 Cookies

In order to use gomarina.com or GoMarina´s web-based port admin interface, cookies are required in the browser. Cookies are small text files that are placed on your computer when downloading a webpage and necessary for the login, navigation, and features of the site to work as intended. Note that through the use of cookies, information is never stored that can identify you personally. It is possible to change settings in the browser to prevent the site from using cookies. If you choose to turn off cookies, you will experience problems signing out. This is because cookies are used to keep you logged in until you actively log out again or you have been inactive for too long.

5 Statistics

GoMarina uses statistics to improve and further develop the service offered to GoMarina customers. Examples of what the statistics can tell us include the number of purchases per port and product category at different times of the year and how many buy tickets through which mobile platform (Android or iOS). All statistics generated in the GoMarina system are de-identified and therefore cannot be linked to you personally.

6 Data Processor

WTW AS, a provider of GoMarina, acts as data processor on behalf of the ports represented in GoMarina. A data processing agreement has been established between WTW AS and each of the ports. The data processing agreement ensures that WTW processes all personal data in accordance with the specifications given by the ports and described in this Privacy Statement.

The Data Controller (Port) and WTW AS process personal data in accordance with European Privacy Policy and Accounting Laws in all countries associated with GoMarina ports.

7 Other data processors associated with GoMarina

The ports are subject to national and regional reporting obligations which require them to pass on different information about the visitors at their ports to the authorities that require it. The personal information collected or generated in the GoMarina solution will not be processed in systems belonging to sub-contractors other than WTW and the payment service provider(s) in the solution.

8 Sources of personal data

All personal data processed by GoMarina is uploaded or generated by you. No information is obtained from external registers or services.

9 Access to personal information

The personal data processed by GoMarina will only be accessible on a need-to-know basis by authorized personnel with the Data Controller and their sub-contractors, including payment service providers, WTW AS and the service operator.

No information will be disclosed to third parties, whether in or outside of Europe, which are not mentioned in this Privacy Policy.

10 Rights and Informational Requirements

You must be informed about the processing of your personal information. This privacy policy is therefore available from the app´s menu at any time. As a GoMarina user, you are entitled to:

11 Storage and deletion

All data is stored in Norway at WTW´s server center in Norway. Servers are operated by personnel in Norway. All data stored in the back-end system is stored in accordance with prevailing legislation. Your personal information will not be stored for longer than necessary to fulfill the purpose for which they are intended. Both the Data Controller and Service Developer, WTW AS, have put in place information security measures and internal procedures to ensure that no personal information is being used for purposes other than those described in this Privacy Policy.

Both the Data Controller and its Processors work in accordance to the principles of privacy by design and by privacy by default. This implies that your personal information will not be stored longer than is necessary to fulfill the purpose of the service.

Profile Information: Your profile information is retained as long as you as a customer have an active agreement. At any time, you are entitled to request that your user be deleted from GoMarina. You will then have to register again in the service if you wish to use it later. Your mobile number / email is verified at each login. If you have added other personal information to the app, you have the option of editing these in your profile at any time under "Settings".

Transaction history and sales documentation: All sales documents are kept in accordance with the Norwegian Bookkeeping Act and Regulations applicable in the country in which the port is located. The receipts for your last purchase will be available at any time via the app. Ports can provide you with access to sales documents for all purchases of services for a period of 20 months, performed by the user.

Technical information and application log: Various sections of the application log are stored for an appropriate amount of time to ensure that the service is functioning properly and that customers receive the service they are required to. For example, complaints that are based on errors in the service can save retention time for relevant application log so that it follows the require time slow to process the completed complaint.

12 Security

All communication between the solution and the applications running on the end-user´s phones is encrypted. All access to the system via the web is encrypted. All internal data transfers between the various components of the system are encrypted. Access to retrieve data can only be done via APIs that are encrypted and secured with access keys. Access to data via the Port Administration Interface is role-based and personal with incident logging to ensure traceability. The administration interface for the solution is designed with different access levels so that individuals who require access with the Data Controller (Port) or WTW will be able to access only the amount of information they need.

13 Contact information

If you require extended information about the processing of your personal data at the port you are visiting, you can directly contact the port in question. Contact information can be found under port information in the app.

If you need extended privacy and security information in GoMarina, contact WTW AS. Updated contact information can be found at any time under "About GoMarina" in the app, or on the website, www.gomarina.com.

We note that the privacy statement will be updated as changes are made to the solution. Updated privacy statement will always be available through the GoMarina app so that you are always informed about how personal information is processed.

Published: 14.05.2018

Updated: 14.05.2018