1. Overview

Your privacy is very important to us and we understand how important it is to you. We want you to feel safe when visiting our website or using our services and are committed to maintaining your privacy when you do. We require our employees, suppliers and partners to maintain confidentiality in accordance with applicable data protection laws.

This privacy notice (together with our Terms and Conditions, our Cookie Policy and any other documents referred to herein) sets out the basis on which we process any personal data we collect from you, or that you provide to us (“Privacy Notice”). Please read the following carefully to understand our views and practices regarding your personal data.

This Privacy Notice can be changed over time to comply with law or to meet our changing business requirements. The most up-to-date Privacy Notice can be found on our website. We will inform you appropriately of any relevant changes to this Privacy Notice.

For the purposes of the General Data Protection Regulation, the controller is Top Marina W.L.L. with its registered office at Industrial Area, Doha, State of Qatar (from now on referred to as “Top Marina”, “we”, or “us”).

Top Marina has adopted an ‘opt-in’ policy where you can decide whether you would like to receive our newsletters and offers. You may submit a request to withdraw your consent at any time by contacting Top Marina.

2. Applicability

This Privacy Notice applies to the processing by Top Marina of all Personal Data we gather or use in connection with your relationship with us as a customer or potential customer of our company when you use our website, www.oceanescapes.qa (from now on referred to as our “Website”), services provided by us or others acting on our behalf and when you interact with us. We will only use your Personal Data in accordance with this Privacy Notice.

3. Responsibility

Our Website may contain links to enable you to visit third-party websites, mobile sites and mobile applications. Please note that we do not have any control over these and are not responsible or liable for the protection and privacy of any information that you provide whilst visiting those sites. Third-party websites, mobile sites and mobile applications are governed by their own privacy policies and not this Privacy Notice.

4. Data collection

(a) use any of our services;

(b) use or access our Website, particularly when completing the “customer details” section during the course of a booking, even if you do not complete the booking;

(c) communicate with us such as by email, telephone, in writing or through our customer services pages or social media platforms.

We may also collect your Personal Data through our Website and third party providers or subcontractors where you have consented to providing your Personal Data to them or where we subcontract them to assist us in providing services to you (e.g. special requests).

Where you disclose Personal Data on behalf of another person, you undertake and will ensure that the individual whose Personal Data is supplied to Top Marina has authorised the disclosure, is informed of and consents to the terms and conditions of this Privacy Notice. Where the disclosure is in respect of a child’s Personal Data, you should do as only as the parent or legal guardian of that child and enter into relevant contracts on behalf of that child.

5.1. Bookings and Service Delivery

If you get in touch with us in person, through email, by telephone, in writing or through our customer care services pages or social media, your Personal Data is collected only to the extent necessary to reply to and answer your question or to respond to your complaints or requests (e.g. to assist you in processing a transaction or to provide technical assistance).

We will process your Personal Data based on the performance of our service provision contract with you or in our legitimate business interests in providing customer care to you based on your request.

We may use your Personal Data including special categories of Personal Data; for example full name, contact details, email address, country of primary residence, gender, date of travel, origin, special requests such as wheelchair assistance, your health information (if needed), your correspondence with us about your question and all other Personal Data necessary to answer your question.

When you book products and services with us that are offered through our Website, we process your Personal Data for administrative purposes such as:

(a) administrating your bookings; and

(b) delivery of our products and services.

As part of our service to you we provide you with informational emails regarding the relevant service.

By using our services, our Website and by providing any Personal Data to us, you agree to your Personal Data being sent to and processed in countries outside of your country of residence, and for individuals resident in the European Economic Area (“EEA”), this includes transfers outside of the EEA. Some of these countries may not have data protection laws that provide an equivalent level of data protection as the laws in your country of residence.

When you make a booking, you will be provided with a booking reference. Disclosing your booking reference to other persons may allow them to access your booking details through our system.

5.2. For the development and improvement of our products and/or services

It’s important for us to uphold the Ocean Escapes brand. In order to achieve this, we use your Personal Data so that we can assess, analyse and improve our services to you.

For this purpose, we keep track of how often you read our newsletters, visit our Website, which pages you click on and what services you purchase through our Website.

We also regularly use surveys to find out whether you are satisfied with our service. These surveys are conducted through our Website. We use your responses to surveys for quality assessments and to improve your customer experience.

We will process your Personal Data based on the performance of our contract with you or in our legitimate business interests in enhancing our services to you.

For this purpose, we use your contact details such as your nationality, email address, name, age and any correspondence with us. In addition, we may use the Personal Data you entered into the Website or based on the functionalities of the Website and the technical data from your device such as its IP-address, the pages you visited on our Websites, your click-through and surf behaviour and the length of your session.

If you choose to participate in our surveys, we can ask you to provide us with Personal Data, such as age group, gender and preferences in terms of choice of services and experiences. We can also use the Personal Data that you have provided in the survey for this purpose.

5.3. For compliance with law and to monitor and investigate compliance

We need to comply with certain legal obligations and monitor our Website and IT systems to check compliance with our internal policies and regulations. During monitoring activities, your Personal Data can be accessed and viewed by our personnel or by third party regulators or government authorities.

5.4. Special Offers and Newsletters

We will occasionally inform you about our special offers, news and new products and may invite you to participate in Contests via the email address you provide us. You will only receive our newsletters if you subscribe to this mailing list.

We will ask for your consent to send you personalised newsletters.

For this purpose we process your name and email address, your preferences and interests, (including those that you have actively shared with us, but also those inferred through your registered interactions with our Website), (please see our Cookie Policy for more information), shopping history (both online if you link your purchases to your profile, and offline when making an offline purchase), and the links you click on in our emails.

6. Cookies

Cookies are small files of information which save and retrieve information about your visit to our Website – for example, how you entered our site, how you navigated through the site and what information was of interest to you. Read more about how we use cookies in our Cookie Policy which is available on our Website.

7. Access to your personal data

Data we collect may be disclosed to our shareholders and any member of our group for business and administrative purposes.

When you make a booking or other purchase, we use support and other functions which may require the transfer of your Personal Data to and from countries outside of your country of residence from time to time, including outside of the EEA.

To provide you with our services, we may be required to disclose certain of your Personal Data in the following cases:

• to you or those acting on your behalf. Where local regulations require, we may obtain your consent in writing for the purpose of allowing anyone else to act on your behalf.
• to third parties including, partners connected with Top Marina, other service providers including those who are acting as our agent or sub-contractor, including, without limitation, hoteliers, insurance companies, medical assistance providers, credit card and credit reference agencies, data processing service providers and our legal and other professional advisors.
• to third parties in connection with a proposed or actual financing, securitization, insuring, merger, restructure, sale, acquisition, assignment or other disposal of all or part of our business or assets or the assets of any affiliate or to anyone whom we may transfer our rights and/or obligations for the purposes of evaluating and performing the proposed transaction.
• to third parties, including law enforcement officials, law courts and government and regulatory authorities:(a) if we believe disclosure is required by any applicable law, regulation or legal process (such as to respond to subpoenas or judicial orders); or(b) to protect and defend our rights, or the rights or safety of third parties, including to defend against legal claims; and/or.
• where you have made a booking, to customers under the same booking as you.

Your Personal Data may be processed and stored by these third party service providers in order to perform the services contracted to them.

When a third party processes your Personal Data based on our instructions, it acts as a data processor. We enter into an agreement with the relevant data processor for the processing of your Personal Data. In this agreement, we include obligations to ensure that your Personal Data is processed by the data processor solely to provide services to us and to ensure that the data.

8. Data safeguards

We will retain Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes as described in this Privacy Notice and in line with our data retention policies, or as required by relevant laws.

When erasing Personal Data, we will take commercially reasonable and technically possible measures to make the Personal Data irrecoverable or irreproducible in accordance with the applicable laws.