Why you should read this policy
For the purposes of the Data Protection Act 2018, UK General Data Protection Regulation and all other relevant legislation, Wightlink Limited (‘we’ or ‘us’) is the ‘data controller’ (i.e. the company who is responsible for, and controls the processing of, your personal data).
Who we are
https://www.wightlink.co.uk/ (Website) and the Wightlink App (APP) is brought to you by Wightlink Limited, a company incorporated and registered in England and Wales under company number 01059267 whose registered office address is Gunwharf Terminal, Gunwharf Road, Portsmouth, Hampshire, PO1 2LA.
Our collection and use of your personal data
Information that you provide
Personal information about you will be obtained, whenever you complete forms, create an account or make a booking with us.
We will also obtain personal information you provide when you send feedback, contact us for any reason and by any medium, sign up to a service, share information via the Website’s and App’s social media functions, enter a competition, complete a survey or report a problem with the Website or App. Additionally, we will take payment details when you purchase tickets, for example when you use a ticket machine or pay via the Website.
We may collect, store or process data that is labelled as sensitive from time to time. If such data is requested, you will be given additional information as to why the sensitive personal data is being requested and how it will be used.
We may retain a record of any contact you make with us.
The personal information we collect about you includes, but is not limited to:
- your name, address and contact details;
- special category data such as health information;
- details of any feedback you give us by phone, email, post or via social media; and
- information about the services we provide to you.
Personal information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
- give consent on his/her behalf to the processing of his/her data;
- receive on his/her behalf and data protection notices;
- give consent to any transfer of his/her data;
Information from third parties
Occasionally we may receive information about you from other sources (such as credit reference agencies), which will be added to the information already held about you in order for us to help supply our services and products to you.
Information that will be collected automatically
Device information: We may also collect information about your device each time you use the Website or the App. For example, we may collect information on the type of mobile device, laptop or computer that you are using and its unique device identifier (for example, the IMEI number, IP address or the MAC address of the device’s wireless network interface).
Information on your device: We may also collect information which is stored on your device each time you use the Website or App. For example, we may collect contact information, login information and friends lists with your prior consent.
Location data: We may also collect information to determine your location using GPS technology or such other location tracking software we may use from time to time. Some of the features of the Website and App may require access to such location data to work. If you would like to use any such feature, you will be asked to consent to provide such location information. You can withdraw your consent to providing this information at any time by emailing us at firstname.lastname@example.org or contacting us via the contact details at the bottom of this policy.
CCTV, Body Worn Cameras (BWC) and ANPR: When you pass through Wightlink Ferry Ports we will collect static or moving imagery via our CCTV and ANPR systems. Wightlink collects imagery via cameras located throughout the Wightlink owned car parks, customer areas (inside and on the perimeter of Wightlink owned premises), onboard our ferries, and public areas surrounding our premises. Some of our staff will also collect static and moving imagery via BWC during the course of their duties. BWC footage is used to promote the safety of Wightlink’s staff and to reduce the potential number of confrontational situations experienced by our staff.
Wightlink may use CCTV, BWC and ANPR imagery for a number of purposes including but not limited to the following:
- To maintain the safety and security of the ferry ports for our customers, passengers, colleagues and service providers including but not limited to control authorities, national security and detection and prevention of crime;
- To support the effective management of the port and ship operations and any incidents. For investigative purposes or as evidence to support any formal follow-up to incidents;
- To provide evidence to the regulatory shipping authorities; and
- In response to a subject access request.
- CCTV footage is stored for 29 days
How your personal data will be used
Under data protection legislation, we can only use your personal information if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
In most cases, our processing of your personal data is necessary for the performance of our services to you.
When we say, “legitimate interests”, we mean our (or a third party’s) interests in enabling us to provide our services to you as efficiently and securely as possible. For example, we may choose to use a third party to store your personal data; we may do this in part because our use of that service means that your personal data is more secure.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To help identify you and any accounts you hold with Wightlink;||For the performance of our contract with you or to take steps at your request before entering into a contract.|
|Providing our services to you;||For the performance of our contract with you.|
|Administration;||For our legitimate interests, i.e. following internal processes.|
|Research, statistical analysis and behavioural analysis;||For our legitimate interests.|
|Customer profiling and analysing your purchasing preferences;||For our legitimate interests, i.e. providing the best service to you.|
|Marketing – see ‘Marketing’ below;||We have a legitimate interest in processing your personal information for promotional purposes. However, where consent is needed, we will ask for this consent separately and clearly. See more below.|
|Fraud prevention and detection;||To comply with our legal and regulatory obligations.|
|Billing and order fulfilment for purchases and bookings made, whether through the Website, ticketing machines, App or ticket office for example;||For the performance of our contract with you or to take steps at your request before entering into a contract.|
|Credit scoring and credit checking;||For the performance of our contract with you or to take steps at your request before entering into a contract.|
|Customising the Website and App and their content to your particular preferences;||For our legitimate interests, i.e. providing the best service to you.|
|To notify you of any changes to the Website, App or to our services or products that my affect you;||For our legitimate interests, i.e. providing the best service to you.|
|Improving our services and products;||For our legitimate interests, i.e. providing the best service to you.|
|Obtain feedback from you, via email and through a third-party, about your use of our services.||For our legitimate interests, i.e. providing the best service to you.|
Disclosure of your personal data
We may disclose your personal data to:
- other companies that become partners or part of a group with Wightlink Limited;
- a third party who acquires Wightlink Limited or acquires substantially all of its assets, in which case the personal data shall be one of the acquired assets;
- our agents, professional advisors and service providers;
- third parties we use to help deliver our services to you, e.g., payment service providers;
- other third parties we use to help us run our business, e.g., marketing agencies, email feedback agencies or website hosts;
- third parties approved by you, e.g., social media sites you choose to link your account to or third-party payment providers;
- business partners in accordance with the ‘Marketing’ section below.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Keeping your data secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also confirm that your data will be stored on secure servers.
Whilst we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never share it with other organisations outside the Wightlink group for their own marketing purposes unless we have your express permission to do so.
In relation to our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others via our Website and/or App, we do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women on the Isle of Wight).
Transfers of data outside of the UK/EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- with our service providers located outside the EEA;
- if you are based outside the EEA.
These transfers are subject to special rules under European and UK data protection law.
Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.
We may monitor and record communications with you (such as emails) for the purpose of quality assurance, training, fraud prevention and compliance.
Under the General Data Protection Regulations (GDPR), you have the following rights:
- You have the right to be informed about the collection and use of your personal data.
- You have the right of access to your personal records or other information that we hold about you. We reserve the right to charge a reasonable fee for our administrative costs involved with providing you with access if we receive a request which is manifestly unfounded or excessive to access personal records. We may also charge a reasonable fee, in relation to administrative costs, if further copies of your data is requested following your initial request.
- You have the right to rectify any errors in the data we hold about you. If any data or information we hold about you is inaccurate, or out of date, please contact us and we will correct this immediately.
- You may have the right to have the data we hold about you erased.
- You have the right to restrict processing.
- You have the right to ask us to stop processing your personal data for direct marketing purposes. You may also specify that you object to direct marketing by particular channels such as by email or telephone. If this is the case, please specify the channels you are objecting to in your communications with us.
- You have the right to data portability. If you wish to obtain your data for your own purposes across different services, we will provide this information to you in an electronic format such as a PDF file, CSV file or via other electronic means. We reserve the right to charge a reasonable fee for the administrative costs of complying with any requests that are manifestly unfounded or excessive.
- You have the right not to be subject to automated decision-making, including profiling.
To revise your consent, request access, amend or remove your records or assert any of your rights set out above, you should send your request in writing to us using our email: email@example.com.
You will need to provide proof of identity and address (e.g., a copy of your driving licence or passport, and a recent utility or credit card bill); and specify the personal data you want access to, to be amended or be removed.
How long we store your data
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Wightlink Limited offers services directly to individuals over the age of 12. If you are aged 16 or under, please get your parent/guardian’s permission before you provide any personal information to us. In using our services, you confirm that you have read and consented to this Policy and verify that you are over the age of 16 or have received the permission of a parent or guardian to do so.
Wightlink will process the personal data of any individual, including children, as per this policy when providing our services to such individuals.
- keep track of the items stored in your shopping basket and take you through the checkout process;
- recognise you whenever you visit the Website (this speeds up your access to the Website as you do not have to log on each time);
- obtain information about your preferences, online movements and use of the internet;
- carry out research and statistical analysis to help improve the Website content, products and services and to help us better understand our visitor and customer requirements and interests;
- target our marketing and advertising campaigns and those of our partners more effectively by providing interest-based advertisements that are personalised to your interests; and
- make your online experience more efficient and enjoyable.
How to turn off cookies
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of the Website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org.
This policy was last updated on 11 October 2023.
We may change this Policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version that will apply each time you use the Website.
Our contact details
We welcome your feedback and questions. If you wish to contact us or our Data Protection Officer, please email us at firstname.lastname@example.org specifying that the communication is for the Data Protection Officer. You can also write to us Wightlink Ltd, PO Box 59, Portsmouth, PO1 2XB.
Data protection supervisory authority
The Data Protection Supervisory Authority in the UK is the Information Commissioners Office. Should you have any complaints about the way we handle your data, you may direct them to the ICO. More information on the ICO can be found on their website here: https://ico.org.uk.
Description of cookies
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