AYM Limited, a company registered in Guernsey with registered number 67004 and registered office La Cherverie, Ruette des Cherfs, Castel, Guernsey is registered as a data controller pursuant to the Data Protection (Bailiwick of Guernsey) Law, 2017.  AYM respects your privacy and is committed to protecting your personal data and this privacy statement describes how AYM will treat personal data collected by it or provided to it.

This website and the services provided by AYM are not intended for children and we do not knowingly collect data relating to children. 

If you have any questions about this privacy statement or our privacy practices please contact Dan Armsden at the registered address or at dan@aym.gg.

We keep our privacy policy under regular review.  This version was last updated on 28 June 2020.  

We do not control and are not responsible for the privacy policy of any website or organisation to which this website provides links. By including references, hyperlinks or other connections to such third party websites we do not imply any endorsement of them or any association with their owners or operators.

Who do we Collect Data on?

This privacy statement applies to the following individuals whom we collect personal data from or about. An individual falling in to any of the below categories is a Data Subject for the purposes of this statement:

• Visitors to our website;
• Those who request information, newsletters, marketing material or other publications from us;
• Individuals who have entered into, or are contemplating entering into, a contract for the provision of services;
• Individuals such as directors, officers, employees or agents associated with AYM’s corporate clients who have entered into, or are contemplating entering into, a contract for the provision of services; and
• Individuals associated with the clients of AYM’s clients such as crew members, yacht or ship owners and those persons associated with or involved in the management of such vessels and crew.

What Personal Data Do We Collect?

Personal data means any information about an individual from which that person can be identified. 

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

• Identity data (including name, date of birth);
• Contact data (including email addresses, telephone numbers, addresses, website addresses);
• Financial and Employment Data (including salary, contractual terms and disputes); and
• Marketing and Communications Data (includes your preferences in receiving marketing from us and your communication preferences).

General visitors to our website are dealt with below. 

How is Personal Data collected?

We use different methods to collect data in relation to Data Subjects including:

Direct Interactions: we may receive your Identity Data, Contact Data and/or Marketing and Communications Data when you fill in forms or correspond with us by phone, post, email or website form submission.

Direct Interactions: We may receive your Identity Data, Contact Data and/or Financial and Employment Data from you when we enter into a contract with you or a client of AYM with which you are associated.

Indirect Interactions: We may receive your Identity Data, Contact Data and/or Financial and Employment Data when we enter into a contract with you or a client of AYM with which you are associated

What are your Data Subject Rights?

As Data Subjects you have certain rights which are explained in brief below. Should you wish to receive any additional information please contact us using the details below. 

Your rights include:

• Right of access – You have the right to ask us for copies of your personal information.
• Right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
• Right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at hello@aym.gg if you wish to make a request.

Data Security

Data security is of great importance to us and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your collected data. 

Website visitors

Cookies

AYM.gg puts small text files (known as ‘cookies’) onto your computer to collect information about how you browse this site. The information collected is not personally identifiable.

Cookies are used to:

• measure how you use the website, using Google Analytics, so it can be updated and improved based on your needs; and
• remember the notifications you’ve seen so that we don’t show them to you again;

Google Analytics stores information about:

• the pages you visit on AYM.gg;
• how long you spend on each AYM.gg page;
• how you got to the site;
• what you click on while you’re visiting the site.

Purposes and Basis of Processing

AYM processes personal data for certain purposes which we explain below.  The law requires that for each purpose that we process data for, there is a legitimate basis for doing so.   The legitimate bases that AYM may rely on are explained below and for each purpose we indicate which basis we are relying on.

Legitimate basis

Contractual necessity – personal data is processed in order for AYM to discharge its contractual relationship with its Client. 

Legitimate Interests – personal data is processed in circumstances were AYM can balance its legitimate interests with the Data Subject’s legitimate interests.  AYM considers its legitimate interests to include providing its services effectively 

Legal and regulatory requirement – personal data is processed in order for us to comply with a legal obligation (other than one imposed by a contract). 

Consent – in limited circumstances where the processing cannot be justified on contractual necessity, legitimate interests we may seek to rely on your consent for the processing.

Legal proceedings: personal data is processed on the basis that it is necessary for any legal proceedings, obtaining legal advice or establishing, exercising or defending legal rights.

Purposes

We process personal data for the following purposes:

• Providing AYM’s services

Delivering and performing AYM’s services to our Clients, developing those services and managing, maintaining and developing our relationships with our Clients.   

Debt management and collection.

The legal basis for such processing is contractual necessity and legitimate interests. 

• Marketing

To promote AYM’s services and provide newsletters, marketing material or other publications and to invite you to conferences, events or similar.  This may involve contacting you or where applicable individuals within your organisation using contact details you have provided to us. 

The legal basis for such processing is AYM’s legitimate interests.  You have the right to unsubscribe from marketing materials via a link in such marketing materials, or by emailing hello@aym.gg. 

• Legal and Regulatory Requirements

Respond to requests, enquiries or complaints received.

The legal basis for such processing is legal proceedings 

How long will we keep the data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  We may retain your personal data for a longer period in the event of a complaint or it we reasonably believe there is a prospect of litigation in respect of our relationship with you.

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 through 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 mean, and the applicable legal, regulatory, tax, accounting or other requirements. 

Transfers of Your Personal Data

We may transfer your Personal Information to others where it is necessary to fulfil one or more of the purposes outlined above.  Where we share your personal data whether internally or externally, we will ensure that the sharing of such data is kept to the minimum necessary.

The following is a list of the potential recipients of your information:

• any sub-contractors, agents or service providers providing services to AYM including without limitation, our information technology and telecommunications providers, insurers, providers of background checks and business risk screening, third parties for marketing or business development purposes;
• other professional advisers, agents or third parties providing services in relation to any matter on which AYM has been instructed. This may include counterparties (and their professional advisers) to a transaction or other proceedings involving you and/or the services which we have been engaged to provide to our Clients;
• any registrar of a public register where the data is to be held in a public registry;
• a regulatory, governmental or judicial authority with whom we are legally obliged to share your information.

We will seek to ensure that our suppliers and service providers are contractually bound to process your personal information in line with our policies and that they have adequate measures in place to protect your information from unauthorised access, disclosure, loss or destruction. We do not allow our third party service providers to use your personal information for their own purposes. We only permit them to process your personal information only in accordance with our instructions.

As part of the transfer of information to third parties, your personal information may be transferred to or accessed by the recipients described above from countries located anywhere in the world.  Such countries may not be the subject of an adequacy decision under Article 45 of the GDPR and therefore may not have the same level or type of statutory (or other legal) protection as countries within the European Economic Area, or your respective local data protection laws.  Where we share your personal information we will seek to ensure that transfers of such data complies with all applicable laws and regulations by ensuring that either:

• you have expressly consented to the cross border transfer; or
• the recipient is in a country which has been deemed to have an adequate level of protection under GDPR or equivalent legislation or if the recipient is in the United States of America, that they are part of the Privacy Shield; or
• the recipient is contractually bound to protect the information to the same or higher standards applicable to the data being transferred.

Where it is necessary we will enter into the relevant form of EU standard contractual clauses to ensure that any transfers of Personal Information to any entities outside of Europe (pursuant to GDPR or equivalent legislation) continues to be protected to the relevant standards.

Automated Decision Making

AYM does not have systems or procedures that make a decision without human intervention.  Therefore there are no circumstances where decisions will be taken about you using fully automated means. 

Last updated: 28 June 2020