How2Yacht is registered business name of How2Holdings Ltd under Business Names Registration Act (no of Business Name 12102) in Gibraltar. How2Holdings Ltd is an independent introductory organisation and is the parent company of several brands. Other brands include (but not limited to) How2Yacht, How2Bunker, How2Career, How2Jobs, How2Academy, How2Gibraltar and others.

How2Agency Limited is independent introductory organisation and is the parent company of several brands. Other brands include (but not limited to) How2Holdings, How2Bank, How2Qatar, How2Portugal and How2Offshore.


Licencing:
Gibraltar Fair Trading Act 2015 – Business Licence #BL160469
Gibraltar Port Authority – Port Operators Licence #121- Yacht Concierge Services Operator


Savings and Financial investment services are the sole services Regulated by the Financial Services commission in Gibraltar.

The financial advisers trading under How2Yacht Financial Services/BFMI are members of Nexus Global (IFA Network). Nexus Global is a division of Blacktower Financial Management (International) Limited (BFMI). All approved individual members of Nexus Global are Appointed Representatives of BFMI. BFMI is licenced and regulated by the Gibraltar Financial Services Commission (FSC) and bound by the rules under licence number FSC00805B.

Nexus Global

Nexus Global specialises in providing a regulatory platform and compliance support to international financial advisers and intermediaries to enable them to meet the regulatory requirements of EEA (European Economic Area) financial regulators and to provide their clients with a professional service.

The intermediaries Nexus Global represent, provide face to face advice and specialise in meeting the financial needs of people or companies that have created more capital, or who earn higher incomes, than average, and whose circumstances are therefore more complicated than usual.

www.nexus-global.net

Regulated By

All approved individual members of Nexus Global are Appointed Representatives of Blacktower Financial Management (International) Limited (BFMI). BFMI is licensed and regulated by the Gibraltar Financial Services Commission (FSC). 

The Financial Services Commission regulates the financial services industry in Gibraltar. The FSC supervises a broad range of firms including: auditors, banks, company managers, e-money institutions, professional trustees, payment services providers, funds and fund service providers, insurance companies, managers and intermediaries, investment firms, and insolvency practitioners.

http://www.fsc.gi/regulated-entity/blacktower-financial-management-international-limited-3647

Complaints Procedure

It is important that we hear any concerns you have regarding the services we offer.

Should you have a complaint we ask that you inform Nexus Global Head Office in the first instance. Head Office will then review and make contact with the relevant office. If you have already spoken to someone regarding your complaint, please include their name in your correspondence as this will assist in your complaint being answered more promptly. Complaints can be emailed to complaints@nexus-global.net or you can also write to:-

Nexus Global
Suites 34 & 43 Victoria House
26 Main Street
POBox 1354
Gibraltar

Nexus Global will endeavour to respond to all complaints within 14 days of receipt.

If you do not feel that your complaint has been resolved satisfactorily by Nexus Global, you may refer the matter to the Financial Services Commission, P.O. Box 940, Suite 3, Ground Floor, Atlantic Suites, Europort Avenue, Gibraltar.

It is useful for the FSC to be aware of complaints against firms it supervises. The FSC has no statutory powers to neither undertake the role of an ombudsman in respect of complaints nor act as arbitrator in commercial disputes


Blacktower Group Privacy Policy

Last Updated: 29thMay 2018

The Blacktower Group was formed in 1986 to provide independent wealth management advice and a bespoke service for both individual and corporate clients. We value your privacy and are committed to protecting the privacy of all our clients, business partners and users of our services and website. We therefore ask that you please read our Privacy Policy before providing us with any information about you or any other person.

This Policy explains when and why we collect personal information about people who enquire about or make an investment using the services of Blacktower Group. The policy also explains how we use that information, the conditions under which we may disclose information to others and how we keep personal information secure.

When using the terms “personal data”, “personal information” or simply “your information” in our Privacy Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. This pieces of information are also known as “identifiers” and include a name, an online identifier, or a reference to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. It does not include data where the identity has been removed (anonymous data)

When using the term “processing”, we mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (so practically anything we do to your personal data is processing!)

When using the term “Blacktower Group”, we mean the group of companies forming part of the corporate structure of which the data controller (identified below) forms a part. This Privacy Policy is issued on behalf of Blacktower Group so when we mention ”Blacktower Group”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Blacktower Group responsible for processing your data. We will let you know which entity will be the controller or processor for your data when you purchase a product or service with us.

 

Navigating this policy

If you are viewing this policy online, you can click on the below links to jump to the relevant section:

  • Who are we are and how to contact us
  • How we collect information from you
  • What type of information is collected?
  • How we use your personal information
  • How long we keep your information for
  • Your individual rights
  • Sharing your personal information
  • Keeping your information safe
  • Additional Information

 

Who we are and how to contact us

Blacktower Financial Management (International) Limited (“BFML”) is the data controller of any personal data you provideand responsible for this website. BFML isregulated and authorised by the Gibraltar Financial Services Commission under Licence No. FSC00805B.

 

Our business is to help clients protect the financial assets they already have and advise them on how to manage and grow them to achieve their financial aspirations. We use our experience to findthe right products for each individual’s circumstances; personal or business, both home or abroad.

 

Any questions regarding our Privacy Policy should be sent to:

 

Privacy Manager

Blacktower Financial Management (International) Limited

Suites 34 & 43 Victoria House

26 Main Street

Gibraltar

Phone: +350 200 42353

Fax: +350 200 42953

 

Questions can also be sent by email to: philip@how2yacht.com

 

What type of information is collected?

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Dataincludes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Dataincludes billing address, delivery address, email address and telephone numbers.
  • Financial Dataincludes bank account and payment card details.
  • Transaction Dataincludes details about payments to and from you and other details of products and services you have purchased from us or from a Blacktower IFA.
  • Technical Dataincludes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. More information on this is contained in our Cookie Policy.
  • Profile Dataincludes your username and password to access our client portal, your interests, preferences, feedback and survey responses.
  • Usage Dataincludes information about how you use our website, products and services, and navigate through the website.
  • Marketing and Communications Dataincludes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share ‘Aggregated Data’such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does notdirectly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

In most cases, we do not collect any ‘Special Categories’of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, in limited cases, we may need to collect such categories of data and if so will rely on a lawful basis (such as your explicit consent) to ensure that we can lawfully process that data only as may be required as part of an ongoing business relationship you have with us.

 

 

How we collect information from you

We collect information about you when you:

  • use our website ‘contact us’ form to enquire about products and services
  • meet with an independent financial adviser (IFA) which is part of our network and acts as an Appointed Representative of Blacktower Group (a “Blacktower IFA”)– at this meeting an IFA may ask you questions which will be recorded onto our client take-on documents including for example our Fact-Find forms, Risk Profile Questionnaires or Client Agreements
  • register to receive one of our newsletters, or attend one of our events
  • call our office to enquire about our services
  • enter into a formal business relationship with a Blacktower IFA and/or any entity within the Blacktower Group

 

Other than from information you enter on our website, or provide on our documentation, we may also collect your personal data from documents you provide to us. For example, we may also ask you to provide evidence of your identity such as asking for a copy of your passport, driving licence, proof of residence or income. We are required to ask for this information to comply with anti-money laundering (AML) legislation such as the Proceeds of Crime Act 2015, to ensure we safeguard against and report any suspicious activity.

 

 

Monitoring

Please note that if you communicate with us electronically, including by e-mail, telephone or fax, this communication may be monitored and/or recorded to protect the interests of our business and our customers. This includes for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that Blacktower Group employees and Blacktower IFA’s comply with legal obligations.

 

 

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services or those of a Blacktower IFA). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time

 

How we use your personal information

We use personal information about you in connection with the following purposes:

 

Provision of services and account management:

  • to provide you with the information, products and services that you have requested from us.
  • to complete any transaction you are undertaking with us;
  • to manage and operate your account with the chosen Blacktower IFA as well as any platform providers they recommend, including sending you information relating to your account controlled by Blacktower Group;
  • to meet a legal or regulatory obligation.

 

Service improvements:

  • to ensure that content from our site is presented in the most effective manner for you;
  • to administer our site and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to notify you about changes to our service;
  • as part of our efforts to keep our site safe and secure;

 

Direct Marketing:

  • to provide you with information about other services we offer that are similar to those that you already have or have enquired about;
  • to provide you with other marketing material such as our Newsletter.

 

 

If you do not want your personal information to be used for marketing purposes, please contact us on the above details.

 

Where you are an existing client, we will rely on our legitimate interests as the lawful basis for processing your personal information for the purposes of direct marketing. To this end, it may be necessary to process your information so we can directly market in our legitimate interest. In addition, we consider it reasonable for you to expect you may receive marketing material from us in the same methods we normally communicate with you (e.g. via email) and that there is no disproportionate impact to your individual privacy rights in this case.

 

In this context, “legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us on the above details.

 

Change of Purpose:

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us on the above details.

 

Automated decision-making

 

We do not use automated-decision making methods (including profiling), save that we may risk profile our clients in compliance with applicable anti-money laundering legislation.

 

Decisions as to how your data is processed are therefore based on your instructions to us under any agreement we may have with you, or on our initiative in order to fulfil our agreement with you or to comply with our legal obligations (and on an occasional basis, to further our legitimate interests as outlined in this Privacy Policy. This means decisions are not made by robots or computers, and therefore not ‘automated’. However, certain third parties may use certain automated decision-making tools or software. We are not responsible for the privacy practices of others and will take reasonable steps to bring such automated decision-making to your attention, but you are encouraged to become familiar with the privacy practices of any third parties you enter into any agreements with.

 

How long we keep your information for

We retain your information only for as long as is necessary for the purposes for which we process the information as set out in this Privacy Policy. Records can be held on a variety of media (physical or electronic) and formats.

 

Retention periods are determined based on the type of record, the nature of the record and activity and the legal or regulatory requirements that apply to those records. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

However, we may retain your personal data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or where we have a legitimate interest to do so for example, to manage your pension, tax and social security obligations etc.

 

Your individual rights

You have certain rights under applicable legislation, and in particular under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’). We explain these below. You can find out more about the GDPR and your rights by accessing the European Commission’s website.

 

Right Information and access

You have a right to be informedabout the processing of your personal data (and if you did not give it to us, information as to the source) and this Privacy Policy intends to provide the information. Of course, if you have any further questions you can contact us on the above details.

 

Right to rectification

You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information about you completed. You may also request that we restrict the processing of that information.

The accuracy of your information is important to us. If you do not want us to use your Personal Information in the manner set out in this Privacy Policy, or need to advise us of any changes to your personal information, or would like any more information about the way in which we collect and use your personal information, please contact us at the above details.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Right to erasure (‘right to be forgotten’)

You have the general right to request the erasure of your personal information in the following circumstances:

  • the personal information is no longer necessary for the purpose for which it was collected;
  • you withdraw your consent to consent based processing and no other legal justification for processing applies;
  • you object to processing for direct marketing purposes;
  • we unlawfully processed your personal information; and
  • erasure is requiredto comply with a legal obligation that applies to us.

 

We will proceed to comply with an erasure request without delay unless continued retention is necessary for:

  • Exercising the right of freedom of expression and information;
  • Complying with a legal obligation under EU or other applicable law;
  • The performance of a task carried out in the public interest;
  • Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances; and/or
  • The establishment, exercise, or defence of legal claims.

 

Right to restrict processing and right to object to processing

Instead of requesting erasure, you also have the right to right to restrict processing of your personal information where:

 

  • you contest the accuracy of the personal information;
  • processing is unlawful, but you do not want us to erase it;
  • we no longer need to process your personal information but you need us to retain your information as you need it for the establishment, exercise, or defence of legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

 

You also have the right to object to processing of your personal information under certain circumstances, such as:

 

  • where the processing is based on your consent and you withdraw that consent;
  • where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms; or
  • where we are processing your personal data for direct marketing purposes

 

Exercise of this right may impact the services we can provide and we will explain this to you if you decide to exercise it. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and this may allow us to continue to (wholly or partly) process your personal information.

 

Right to data portability

With respect to automated information which you initially provided consent for us to use, or where the processing is necessary for the performance of a contract to which you are party (or in order to take steps at your request prior to entering into a contract), you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.

 

Right to freedom from automated decision-making

As explained above, we do not use automated decision-making, but whereany automated decision-making takes place, you have the right in this case to express your point of view and to contest the decision, as well as request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.

 

Right to object to direct marketing (‘opting out’)

You have a choice about whether or not you wish to receive information from us.

We will not contact you for marketing purposes unless:

 

  • you have a business relationship with us, and we rely on our legitimate interests as the lawful basis for processing (as described above)
  • you have otherwise given your prior consent (such as when you download one of our guides)

 

You can change your marketing preferences at any time by contacting us on the above details. On each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out at any time by contacting us on the below details.

 

Please note that any administrative or service-related communications (to offer our services, or notify you of an update to this Privacy Policy or applicable terms of business, etc.) will solely be directed at our clients or business partners, and such communications generally do not offer an option to unsubscribe as they are necessary to provide the services requested. Therefore, please be aware that your ability to opt-out from receiving marketing and promotional materials does not change our right to contact you regarding your use of our website or as part of a contractual relationship we may have with you.

 

Right to request access

You also have a right to access information we hold about you. You can exercise this right at any time by contacting us on the above details.

 

We are happy to provide you with details of your personal information that we hold or process. To protect our customers’ personal information, we follow strict storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated

 

Right to withdraw consent

Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us on the above details. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

 

Raising a complaint about how we have handled your personal data

If you wish to raise a complaint on how we have handled your personal data, you can contact us as set out above and we will then investigate the matter.

 

Right to lodge a complaint with a relevant supervisory authority

If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Data Protection Commissioner under the Data Protection Act, which is presently the Gibraltar Regulatory Authority(GRA). You may contact the GRA on the below details:

 

Gibraltar Data Protection Commissioner

Gibraltar Regulatory Authority

2nd Floor, Eurotowers 4

1 Europort Road

Gibraltar

Email:info@gra.gi

Phone:(+350) 200 74636

Fax:(+350) 200 72166

 

You also have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of our rights has taken place, if that is based in the EEA.

 

Sharing your personal information

We may pass your information to our Blacktower IFAs, business partners, administration centres, third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, or to enable us to obtain a quote for you or provide you with other related services.

 

These third parties may include:

  • Fund managers, insurers, insurance brokers, or credit brokers.
  • {list other relevant third parties}

 

When we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

 

We also work closely with various third-party product and service providers to bring you a range of wealth management solutions. When you enquire about or invest in one or more of these products or services, the relevant third-party provider will use your details to carry out their obligations arising from any contracts you have entered into with them. These third-party providers will share your information with us which we will use in accordance with this Privacy Policy.

 

We may transfer your personal information to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.

 

Transferring your information outside of the European Economic Area

There may be instances where as part of the services offered to you by Blacktower Group, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). The EEA includes the European Union countries as well as Iceland, Liechtenstein and Norway. Transfers outside of the EEA are sometimes referred to as ‘third country transfers’.

 

This may happen if any of our Platform providers are located in a ‘third country’ outside of the EEA. If we transfer your information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Policy. This may require us to take certain additional steps to ensure that appropriate safeguards are in place if that third country is not deemed by the European Commission to offer an adequate level of protection for your privacy rights, which may include use of contractual safeguards to allow you to be able to enforce your rights and ensure these are preserved. In certain circumstances, we may need to ask you for your explicit consent to such third country transfers, and will always do so in writing and giving you full information about why we need your consent and your right to withdraw that consent at any time (together with the consequences of withdrawal).

 

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see further information on the European Commission’s website: European Commission: EU-US Privacy Shield.

If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

 

 

Keeping your information safe

At Blacktower Group, we take our responsibility to look after your personal information and privacy seriously. In today’s world, we have all seen a growing trend in cybercrime and security breaches. We have a number of security measures in place to help prevent fraud and cybercrime.

 

If we become aware that a personal data breach has occurred and is likely to result in a high risk to the rights and freedoms of our clients, business partners or employees, we will inform them without undue delay.

 

We educate and train our employees on our information security, fraud prevention and privacy obligations annually. Information Security awareness also forms part of our new employee induction program.

 

We also educate our employees in identifying potential financial crime and internal fraud; any suspicious activity is reported to the Gibraltar Financial Intelligence Unit.

 

We will always interact with you in a safe, secure and consistent manner

To keep your information secure and to protect our clients from fraud, Blacktower Group will only interact with you in the following ways. If in doubt, call our office or email us.

 

When interacting with you, we will:

  • Post information electronically
  • Verify who you are when speaking to you on the phone, by asking you security questions.

 

We will not:

  • Ask you for any password over the phone.
  • Send you an unsolicited email with a link to our login page asking you to enter your
  • Ask you for payment or credit card details by email or telephone.

 

Physical controls– As well as protecting your digital information, Blacktower Group also protects its offices where personal data may be used and stored. This includes secure disposal of confidential waste and hardware, personal card access and locks on doors and file storage cabinets, with a ‘clear desk’ policy to ensure all information is locked away and protected.

 

Logical controls– Blacktower Group uses technical security measures to make sure our systems where we store and use personal information are protected from unauthorised access. Tools such as authentication controls, antivirus, firewalls, malware detection and back-up procedures are used across the business. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

 

We have a business continuity plan.

The key drivers in developing the business continuity plans are;

  • To mitigate the risks that could lead to the significant disruption of our services to our clients.
  • To provide a recovery plan that supports a timely and full restoration of our services for our clients

 

Whilst we take appropriate technical and organisational measures to safeguard your personal information, please note that we cannot guarantee the security of any data that you transfer over the internet to us.

 

Additional Information

 

Privacy Protections for Children Using the Internet

Protecting children’s privacy is important to us. For that reason, we do not collect or maintain information on our website from those we actually know are under the age of 16, nor is any part of our website targeted to attract anyone under 16. We request that all visitors to our website who are under 16 not disclose or provide any personal data and discontinue use of our website.

 

Third Party Links

This 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 their privacy statements. The privacy policies of others may differ significantly from our Privacy Policy. Therefore, we encourage you to read the privacy statement/policy of each and every website you visit.

 

Review of this Privacy Policy

We may make changes to this Privacy Policy from time to time. Where we do so, we will notify those who have a business relationship with us or who are subscribed to our emailing lists directly of the changes, and change the ‘Last updated’date above. We encourage you to review the Privacy Policy whenever you access or use our website to stay informed about our information practices and the choices available to you. If you do not agree to the revised Privacy Policy, you should discontinue your use of this website.

WEBSITE:

The contents of How2Holdings websites is for general information only and does not constitute legal or other professional advice. Every reasonable care has been taken to ensure that the information given on our sites is accurate and up-to-date, and we cannot accept responsibility for any consequences whatsoever arising out of reliance upon or usage of such general information as aforesaid. Your use of any of our sites does not create attorney/consultant/advisor – client relationship with How2Yacht and How2Holdings Limited, nor does such use constitute the receipt of legal or other professional advice from How2Yacht and How2Holdings Limited. All users of our sites, whether or not the users are an existing clients of How2Yacht and How2Holdings Limited, are advised to Contact Us and/or to take appropriate professional advice before committing themselves to any act or taking any decision regarding services requested.

 

Personal information collected on this website and sharing this Information.

In order for us to provide certain information on services, it may be necessary for us to provide some details about you to third parties. Please note that certain information services may not be available if you do not want to disclose the personal information you are asked for. In addition, we may pass your information onto selected business partners or to other selected third parties to enable them to send you information which may be of interest to you but only if you have given us permission to do so. You can tell us to stop this at any time by sending an e-mail to info @ how2yacht.com. We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected. Other than as set out above, we will not disclose any of your personal information without your permission unless we are required by law to do so (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).

Blacktower Group Cookie Policy

Last Updated: 29thMay 2018

 

As described in our Privacy Policypart of our processing of your personal data (as defined therein) involves us collecting certain data which we have called “technical data” for ease of reference and convenience. One way in which we collect this data is using cookies, and we do it for the key purpose of giving you a better browsing experience, developing our website and making it more attractive and useful to our clients and customers, and generally improving our overall service and expanding our international reach.

 

For general web-browsing of this website, your personal data is not revealed to us, although certain statistical information is available to us via our internet service provider as well as through the use of special tracking technologies. Such information tells us about the pages you are clicking on or the hardware you are using, but not your name, age, address or anything we can use to identify you personally. Provided you cannot be identified, it will not be personal data.

 

This Cookie Policy sets out some further detail on how and why we use these technologies on our website.

 

When using the term “Blacktower Group”, we mean the group of companies forming part of the corporate structure of which the data controller (identified in our Privacy Policyforms a part. This Cookie Policy is issued on behalf of Blacktower Group so when we mention ”Blacktower Group”, “we”, “us” or “our” in this Cookie Policy, we are referring to the relevant company in the Blacktower Group responsible for processing your data. We will let you know which entity will be the controller or processor for your data when you purchase a product or service with us.

 

By using our website, you consent to storage and access to cookies and other technologies on your device, in accordance with this Cookie Policy.

 

What are cookies?

 

Cookies are a feature of web browser software that allows web servers to recognize the computer or device used to access a website. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

 

What are the different types of cookies?

 

A cookie can be classified by its lifespan and the domain to which it belongs.

 

By lifespan, a cookie is either a:

 

  • session cookiewhich is erased when the user closes the browser; or

 

  • persistent cookiewhich is saved to the hard drive and remains on the user’s computer/device for a pre-defined period of time.

 

As for the domain to which it belongs, cookies are either:

 

  • first-party cookieswhich are set by the web server of the visited page and share the same domain (i.e. set by us); or

 

  • third-party cookiesstored by a different domain to the visited page’s domain.

 

What cookies do we use and why?

 

We list all the cookies we use on this website in the below. They include cookies set by Blacktower Group via our web developers (first-party cookies), and those set by others (third-party cookies). We use session and persistent cookies on our website.

 

Cookies are also sometimes classified by reference to their purpose. We use the following cookies for the following purposes:

 

  • Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that allow us to comply with legal obligations.

 

  • Analytical/performance cookies:They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it, as well as dates and times they visit, or how long they visit. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

 

  • Functionality cookies:These are used to recognise you when you return to our website. This enables us to personalise our content for you, and remember your preferences for example, your choice of language or region. Other cookies may be used when you submit data to us through a form such as those found on contact pages, and may be set to remember your user details for future correspondence.

 

  • Targeting cookies:These cookies record your visit to our website, the pages you have visited and the links you have followed, as well as time spent on our website, and the websites visited just before and just after our website. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

 

In general, we use cookies and other technologies (such as web server logs) on our website to enhance your experience and to collect information about how our website is used. This information is put together (‘aggregated’) and provides general and not individually specific information. None of this information is therefore associated with you as an individual and the cookie-related information is not used to identify you personally. It is therefore anonymised and ‘de-identified’. The pattern data is fully under our control and these cookies are not used for any purpose other than those described here.

 

We will retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive. The information also helps us to understand which parts of this website are most popular and generally to assess user behaviour and characteristics to measure interest in and use of the various areas of our website. This then allows us to improve our website and the way we market our business.

 

This information may also be used to help us to improve, administer and diagnose problems with our server and website. The information also helps us monitor traffic on our website so that we can manage our website’s capacity and efficiency.

 

Other Technologies

 

We may allow others to provide analytics services and serve advertisements on our behalf. In addition to the uses of cookies described above, these entities may use other methods, such as the technologies described below, to collect information about your use of our website and other websites and online services.

 

Pixels tags. Pixel tags (which are also called clear GIFs, web beacons, or pixels), are small pieces of code that can be embedded on websites and emails. Pixels tags may be used to learn how you interact with our website pages and emails, and this information helps us and our partners provide you with a more tailored experience.

 

Device Identifiers. A device identifier is a unique label can be used to identify a mobile device. Device identifiers may be used to track, analyse and improve the performance of the website and ads delivered.

 

 

What data are collected by cookies and other technologies on our website?

 

This information may include:

–       the IP and logical address of the server you are using (but the last digits are anonymised so we cannot identify you).

  • the top level domain name from which you access the internet (for example .ie, .com, etc)
  • the type of browser you are using,
  • the date and time you access our website

–       the internet address linking to our website.

 

This website also uses cookies to:

–       remember you and your actions while navigating between pages;

  • remember if you have agreed (or not) to our use of cookies on our website;
  • ensure the security of the website;
  • monitor and improve the performance of servers hosting the site;
  • distinguish users and sessions;
  • Improving the speed of the site when you access content repeatedly;
  • determine new sessions and visits;
  • show the traffic source or campaign that explains how you may have reached our website; and
  • allow us to store any customisation preferences where our website allows this

We may also use other services, such as Google Analytics (described below) or other third-party cookies, to assist with analysing performance on our website. As part of providing these services, these service providers may use cookies and the technologies described below to collect and store information about your device, such as time of visit, pages visited, time spent on each page of our website, links clicked and conversion information, IP address, browser, mobile network information, and type of operating system used.

 

Third party advertisers: We may work with advertisers, and advertising service providers to serve ads that may be relevant to you based on your inferred interests, location or other information collected about you, which may use a cookie or the technologies described below, placed by us or the third party (although we would not share any other information that identifies you with an advertiser) on our website, or on a third party website or online service. The placing of these technologies on your device may enable you to be identified across multiple websites and online services.

 

We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; Facebook, Twitter and Linked-In, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies

 

Google Analytics Cookies

 

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).

 

We use Google Analytics to track your preferences and also to identify popular sections of our website. Use of Google Analytics in this way, enables us to adapt the content of our website more specifically to your needs and thereby improve what we can offer to you.

 

Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

 

In particular Google Analytics tells us

  • your IP address (last 3 digits are masked);
  • the number of pages visited;
  • the time and duration of the visit;
  • your location;
  • the website you came from (if any);
  • the type of hardware you use (i.e. whether you are browsing from a desktop or a mobile device);
  • the software used (type of browser);
  • your general interaction with our website; and
  • your search history (if you decide to use the search bar at the top of our page).

 

As stated above, cookie-related information is not used to identify you personally, and what is compiled is only aggregate data that tells us, for example, what countries we are most popular in, but not that you live in a particular country or your precise location when you visited our website (this is because we have only half the information-  we know the country the person is browsing from, but not the name of person who is browsing). In such an example Google will analyse the number of users for us, but the relevant cookies do not reveal their identities.

 

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Google Analytics, its purpose and function is further explained on the Google Analytics website.

 

For more information about Google Analytics cookies, please see Google’s help pages and privacy policy: Google’s Privacy Policy and Google Analytics Help pages. For further information about the use of these cookies by Google click here.

 

Other Google Services

 

We also make use of other technologies offered by Google, such as advertising services. In doing so, we allow Google to place cookies on our website for this purpose. Google uses a variety of domains to set cookies used in their advertising products and it may not be immediately apparent these domains are associated with Google (e.g. such as “gstatic.com” or “doubleclick.net”). For more information about the types of cookies used by Google click here.

 

What if you don’t agree to us monitoring your use of our website (even we don’t collect your personal data)?

 

Enabling these cookies is not strictly necessary for our website to work but it will provide you with a better browsing experience. You can delete or block the cookies we set, but if you do that, some features of this website may not work as intended.

 

Most browsers are initially set to accept cookies. If you prefer, you can set your browser to refuse cookies and control and/or deletecookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your device and you can set most browsers to prevent them from being placed. You should be aware that if you do this, you may have to manually adjust some preferences every time you visit an Internet site and some services and functionalities may not work if you do not accept the cookies they send.

 

Advertisers and business partners that you access on or through our website may also send you cookies. We do not control any cookies outside of our website.

 

If you have any further questions regarding disabling cookies you should consult with your preferred browser’s provider or manufacturer.

 

In order to implement your objection it may be necessary to install an opt-out cookie on your browser. This cookie will only indicate that you have opted out. It is important to note, that for technical reasons, the opt-out cookie will only affect the browser from which you actively object from. If you delete the cookies in your browser or use a different end device or browser, you will need to opt out again.

 

To opt out of being tracked by Google Analytics across all websites, Google have developed the Google Analytics opt-out browser add-on. If you would like to opt out of Google Analytics, you have the option of downloading and installing this browser add-on which can be found under the link: http://tools.google.com/dlpage/gaoptout.

 

 

Review of this Privacy Policy

 

We may make changes to this Privacy Policy from time to time. Where we do so, we will notify those who have a business relationship with us or who are subscribed to our emailing lists directly of the changes, and change the ‘Last updated’date above. We encourage you to review our Privacy Policyand our Cookie Policy whenever you access or use our website to stay informed about our information practices and the choices available to you.

 

If you do not accept changes which are made to this Cookie Policy, or take any measures described above to opt-out by removing or rejecting cookies, you may continue to use this website but accept that it may not display and/or function as intended by us. Any social media channels connected to Blacktower Group and third party applications will be subject to the privacy and cookie policies and practices of the relevant platform providers which, unless otherwise indicated, are not affiliated or associated with Blacktower Group. Your exercise of any rights to opt-out may also impact how our information and content is displayed and/or accessible to you on this website and on other websites.