Privacy Policy

Review date: 12.01.27

1. Introduction

1.1 This Privacy Policy describes in detail who is responsible for the personal information that we collect about you, what personal information we collect, how we will use such personal information, who we may disclose it to and your rights and choices in relation to your personal information.

1.2 In this Privacy Policy references to:

1.2.1 we, us or our means Subsea Craft Limited (company number 186312112) with its registered address at The Camber, East Street, Portsmouth PO1 2JJ.
1.2.2 you or your means the person accessing and using our website or social media pages, or a customer or potential customer of our products, or a supplier or potential supplier of goods of services, or a visitor to one of our trade shows or to our premises, or a job applicant;
1.2.3 website means www.subseacraft.com;
1.2.4 personal information is personal data that is about you and which identifies you; and

2. WHO IS RESPONSIBLE FOR THE PERSONAL INFORMATION THAT WE COLLECT?

2.1 We are a controller for the purpose of data protection law in respect of your personal information that is collected and processed by us through your use of our website or your access to our social media pages.

2.2 We are also a controller in certain circumstances in respect of your personal information that is collected and processed by us if you purchase one of our products, or if you are one of our suppliers or prospective suppliers, or if you visit us (at our premises or trade shows) or if you apply for a job with us.

2.3 If you have any questions regarding this Privacy Policy or the way we use your personal information, you can contact us at enquiries@subseacraft.com

3. WHAT PERSONAL INFORMATION DO WE HOLD ABOUT YOU?

3.1 The personal information we collect includes:

3.1.1 Information that you provide to us

your name and contact information (including email, telephone and postal address);
your bank or other financial account details;
identity verification information in connection with anti-money laundering requirements, customer and supplier due diligence and job applications (including, where applicable, copies of your passport, identity card and utility bills);
your CV; and
the results of any criminal records checks.

This information may be provided:

in the course of communications between you and us (including by phone, email or otherwise);
as part of a supplier quotation, tender and/or onboarding process;
when you purchase or subscribe to our products;
in the course of our warranty and after-sales services;
when you complete our forms (including forms on our website such as the enquiry form on the ‘Contact Us’ section);
when you attend our stands at trade shows;
when you visit our premises;
via our social media pages, other social media content, tools and applications; and
when you apply for a job with us.

3.1.2 Information we collect from you

With regard to each of your visits to our website we may automatically collect the following information:

technical information, including the Internet Protocol (IP) address used to connect your computer or device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
information about your visit, including the website you originated from before landing on our website and the website you went to from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

4. INFORMATION ABOUT THIRD PARTIES

4.1 In the course of your dealings with us you may provide us with personal information relating to third parties. For example, we may collect personal information about referees you provide as part of a job application.

4.2 We will use this personal information in accordance with this Privacy Policy. If you are providing personal information to us relating to a third party, you confirm that you have the permission of the third party to share such personal information with us and that you have made the information in this Privacy Policy available to the third party.

5. HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT ABOUT YOU?

5.1 Your personal information may be used by us, our employees and service providers, and disclosed to third parties for the purposes set out below:

5.1.1 to communicate with you and other individuals about our products and to respond to any queries that you submit to us;
5.1.2 to provide you with a quote or proposal for our products;
5.1.3 to provide you with information about the products that we offer;
5.1.4 to obtain from you a quote or proposal for your products or services;
5.1.5 to carry out our obligations arising from any contracts entered into between you and us and to provide you with our products;
5.1.6 to enforce or apply the contracts concerning you (including contracts between you and us);
5.1.7 to provide warranty and after-sales services;
5.1.8 for credit checking our suppliers and prospective suppliers;
5.1.9 to notify you about changes to our website;
5.1.10 to manage complaints, feedback and queries;
5.1.11 to comply with any legal or regulatory obligations (including in connection with a court order);
5.1.12 to prevent and detect fraud, financial crime and money laundering;
5.1.13 to assess your suitability for a job with us; and
5.1.14 to understand how our users use our website and how we can improve the website.

5.2 For each of the purposes set out above, we have set out below the main legal bases on which we use your personal information. Depending on the circumstances, more than one legal basis may apply.

5.3 Depending on the circumstances, the main legal bases are as follows:

5.3.1 the processing is necessary for our legitimate business interests which include, depending on the circumstances:

to manage our relationship with you;
to undertake customer due diligence;
to assess the credit worthiness of our suppliers and potential suppliers;
to enable us to improve and develop our business operations, our products and our website;
to keep you updated as to changes to our website; and
to conduct and manage our business.

5.3.2 the processing is necessary for performance of a contract between you and us or in order to take steps at your request prior to entering into a contract;
5.3.3 the processing is necessary for compliance with legal obligations to which we are subject;
5.3.4 the processing is carried out with your consent; or
5.3.5 the processing is carried out in connection with legal proceedings (i.e. the establishment, exercise or defence of legal claims).

6. WHO MAY WE DISCLOSE YOUR PERSONAL INFORMATION TO?

6.1 We may share your personal information with:

6.1.1 our business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
6.1.2 credit reference agencies (in relation to suppliers);
6.1.3 other professional advisers (including accountants, lawyers and insurers) that assist us in carrying out our business activities;
6.1.4 police and other law enforcement agencies in connection with the prevention and detection of crime;
6.1.5 other external agencies and organisations (including the National Crime Agency and Serious Fraud Office) for the purpose of preventing and detecting fraud (including fraudulent transactions), money laundering and criminal activity;
6.1.6 the Disclosure and Barring Service, as part of our recruitment process;
6.1.7 HMRC; and
6.1.8 any other third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or instructions of a regulatory body (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us) or to protect our rights, property or safety of our customers, employees or other third parties.

6.2 We may also disclose your personal information to other third parties, for example:

6.2.1 in the event that we sell or buy any business or assets we will disclose your personal information to the prospective seller or buyer of such business or assets;
6.2.2 if we or substantially all of our assets are acquired by a third party (or are subject to a reorganisation within our corporate group), personal information held by us will be one of the transferred assets; and
6.2.3 if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply the agreements concerning you (including agreements between you and us).

7. WHERE WILL WE TRANSFER YOUR PERSONAL INFORMATION?

7.1 We will process your personal information both within and outside the United Kingdom (UK). Where we transfer personal data outside of the UK, we will implement appropriate and suitable safeguards to ensure that such personal information will be protected as required by applicable data protection law.

7.2 These safeguards generally include either:

7.2.1 transferring personal information to countries that have been deemed to provide an adequate level of protection for personal information by the UK Government under Articles 45(1) of the UK General Data Protection Regulation (UK GDPR); and
7.2.2 transferring personal information where the recipient has agreed to a UK Government approved data transfer agreement or addendum issued under the Data Protection Act 2018.

7.3 Please contact us at enquiries@subseacraft.com if you would like further information on the specific mechanism used by us when transferring your personal information outside of the UK.

8. HOW LONG WILL WE KEEP YOUR INFORMATION?

8.1 We will keep your personal information for no longer than is necessary for the purposes for which your personal information is processed.

8.2 If you purchase a product from us, we will generally keep your personal information for 6 years from the end of the relevant warranty period.

8.3 Please note the above retention period may be extended where we need to preserve and use personal information for the purpose of bringing or defending a legal claim. In such cases, we will continue to hold and process your personal information for as long as is necessary to deal with the legal proceedings.

9. YOUR RIGHTS

9.1 You have certain rights with respect to your personal information. The rights may only apply in certain circumstances and may be subject to certain exemptions. Please see the table below for a summary of your rights.

9.2 If you wish to exercise any of the rights below, please contact us at enquiries@subseacraft.com or by post at Human Resources Department, SubSea Craft Limited, The Camber, East Street, Portsmouth PO1 2JJ.

	Summary of your rights
Right of access to your personal information	You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions. Any access request is free of charge. We may require further information in order to respond to your request (for instance, evidence of your identity and information to enable us to locate the specific personal information you require).
Right to rectify your personal information	You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
Right to erasure of your personal information	You have the right to ask that your personal information be deleted in certain circumstances. For example (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation.
Right to restrict the use of your personal information	You have the right to suspend our use of your personal information in certain circumstances. For example (i) where you think your personal information is inaccurate but only for as long as required for us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.
Right to data portability	You have the right to object to the use of your personal information in certain circumstances. For example (i) where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party) including for profiling; and (ii) if you object to the use of your personal information for direct marketing purposes, which includes profiling to the extent it relates to such direct marketing.
Right to object to decision which is based solely on automated processing	You have the right in certain circumstances not to be subject to a decision which is based solely on automated processing without human intervention.
Right to withdraw consent	You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
Right to complain to the relevant data protection authority	You have the right to complain to the relevant data protection authority, which is in the case of us, the Information Commissioner’s Office, where you think we have not used your personal information in accordance with data protection law.

10. THIRD PARTY LINKS

The website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for how they handle your personal information. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

Cookies are small text files that may be stored on your device when you access a website. We use CookieYes to manage cookies on our website. Please click on the icon on the bottom left of your screen to alter your preferences.

12. CHANGES TO OUR PRIVACY POLICY

Any changes we make to this Privacy Policy in the future will be posted on this page and, where appropriate, actively communicated on our website or by email. The updated Privacy Policy will take effect as soon as it has been updated or otherwise communicated to you.

Policy Approved on and effective date: 12.01.26
Review date: 12.01.27