Privacy & Cookie Policy

Privacy Notice

1. Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR and the UK Data Protection Act 2018.

Lungfish Dive Systems keeps and uses contact details of individuals from companies who use our services. To maintain the quality of our service, we will also keep and use records of the nature and content of the contact we have with them and the services we have provided. We may, from time to time, use this information in order to tailor our services and inform you of ways we can help. You may on occasion provide us with documentation and information relevant to issues we are advising on. We will retain and use this information to enable us to provide the relevant service to you. We will not disclose any information about individuals from our member companies unless they are operating as an agent or service provider for Lungfish Dive Systems, except where we are entitled or required by law to do so.

2. Responsibilities

2.1 The Privacy Officer is responsible for ensuring that this notice is made available to data subjects prior to Lungfish Dive Systems collecting/processing their personal data.

2.2 All Employees of Lungfish Dive Systems who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

3. Privacy notice

3.1 Who are we?

Lungfish Dive Systems is part of Highland Light Ventures Limited, a company registered in England and principally manufactures diving equipment.

We collect, store and process information about you if you use our website, subscribe to our communications, or use our services. This information includes:

Personal data type:

First name and last name
Email address
Company name
Job title
Contact number
Business address
Billing address
Preferences
IP address
Any other personal information you provide when interacting with us both online and offline

The personal data we collect will be used for the following purposes:

Communicating relevant information about our products and services based on customer preferences
Contacting customers directly about specific products and services they have purchased
Fulfilling any obligations to provide you with our services
Notifying customers about any changes or updates relevant to their relationship with Lungfish Dive Systems

Our legal basis for processing for the personal data:

Consent
Legitimate interests
Contract

Any legitimate interests pursued by us, or third parties we use, are as follows:

Manufacturing news and information
Information related to Lungfish Dive Systems training offering
Information related to Lungfish Dive Systems business support services
Information related to Lungfish Dive Systems in open venues such as Dive Shows and other media and retail events

3.2 Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for Lungfish Dive Systems to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by unsubscribing to any email marketing communications by contacting the Privacy Officer on info@divelungfish.com.

3.3 Sharing/transferring your data

Lungfish Dive Systems will never sell your personal information or otherwise disclose this data, except as described in this Privacy Notice. We share information with third parties who perform services for us, and these third parties are not authorised by us to use or disclose your information except where it is necessary to the service. We may also share information with our partners and affiliates, ensuring at all times that an adequate level of protection is in place to protect your information.

Additionally, we may on occasion transfer to, process and store the information we collect about you in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you provided the information. When we transfer your information to other countries, we will protect the information as described in this

Privacy Notice.

3.4 Retention period

Lungfish Dive Systems takes reasonable steps to ensure that the information we process is reliable for its intended use, is accurate, up-to-date and complete, and is limited to the information required to carry out processing for the purposes described in this Privacy Statement. We retain your information for as long as necessary to fulfil the purposes for which we collect it, except if required otherwise by law.

3.5 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.3 above) in the processing of your personal data.

3.6 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Lungfish Dive Systems (or third parties as described in 3.3 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority (Information Commissioner’s Office) and Lungfish Dive Systems’ data protection representative, the Privacy Officer.

4. Privacy statement

Read more about how and why we use your data here:

4.1 Personal data

According to data protection law personal data is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

4.2 How we use your information

When you register as a user, we will collect information necessary to validate your registration and to identify you for the purposes of providing the service.

We may also collect information from you if you voluntarily complete any other forms on our site, in person, by email or if you contact us with comments or specific requests.

Additionally, we may collect information relating to your use of the service for the purposes of monitoring and improving our provision and tailoring the provided service.

We will not disclose any information collected to any third party unless they are operating as an agent or service provider for Lungfish Dive Systems, except where we are required by law to do so.

4.3 Our Websites Use of cookies

The Lungfish Dive Systems website makes use of cookies (files which are sent by us to your computer or other access device) which we may then access when you visit our website in future.

We do this to enable us to gain a better understanding of our users and their needs, and to monitor the effectiveness of our website in delivering content to them. We also use cookies to authenticate and authorise registered users.

We do not store any personal information that you have provided to us in any cookie issued by this website.

If you want to delete any cookies that are already on your computer, please refer to the instructions for your operating system or browser. Our cookies are clearly identifiable and will have the file names <user>@www.makeuk.org.

4.3.1 How the Lungfish Dive Systems web site uses cookies

The main cookies used on this website may include the following:

Analytics: These cookies help us to improve this website over time, by giving us insights into how the various sections of the website are used and how users interact with the website. The information collected is anonymous and statistical.

Authentication: These cookies are used to identify unique visitors to the website. If you log in to the website, these are the cookies that allow us to remember who you are so that we can provide you with access to pages personal to you, for example your account pages. These cookies help keep your visit to the site secure.

Session: These are cookies that are designed to ensure that your visit to the website is as smooth as possible. Their main uses are:

Allowing us to identify your device as you use the website, so that you are not treated as a new visitor each time you go to another part of the website;
Ensure that the servers that we use to power the website each serve an equal number of users, to help make everyone's browsing as swift and responsible as possible;
Noting your browser's capabilities.

4.3.2 How to reject and delete them

Most web browsers automatically accept cookies. However you do not have to accept cookies and you can, should you choose to at any time, reject or block the use of cookies and delete all cookies currently stored on your device. You can find out how to do this for your particular browser by clicking “help” on your browser's menu, or by visiting: www.allaboutcookies.org

Please be aware however that if you chose to block cookies you may not be able to access certain features of this web site. For information on how to reject or delete cookies on the browser of your mobile device you may need to refer to your device's manual.

4.3.3 Third party cookies

We may allow third party organisations to set cookies using this website in order to deliver services. If you would like more information about the cookies used by these third parties, as well as details on how to opt-out, please see the table below.

Further information about cookies may be presented in updates to this policy from time to time.

Please note that by deleting or refusing cookies, you may be unable to access certain areas or features of our site.

4.4 Use of IP Addresses

An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our website, we may view (using also 3rd party services) the IP address of the device you use to connect to the Internet. We use this information to determine the general physical location of the device and understand from what geographic regions our website visitors come. We also may use this information to enhance our website.

4.5 Social media List

Lungfish Dive Systems may develop this are of policy in relation to specific social media platforms and update this policy from time to time.

4.6 Why does Lungfish Dive Systems need to collect and store personal data?

In order for us to provide you with our services, we need to collect personal data in order to fulfill this. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes Lungfish Dive Systems would contact you for additional consent.

4.7 Will Lungfish Dive Systems share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Lungfish Dive Systems in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Lungfish Dive Systems’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

4.8 How will Lungfish Dive Systems use the personal data it collects about me?

Lungfish Dive Systems will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Lungfish Dive Systems is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

4.9 Under what circumstances will Lungfish Dive Systems contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

4.10 Can I find out the personal data that the organisation holds about me?

Lungfish Dive Systems at your request, can confirm what information we hold about you and how it is processed. You can contact our Privacy Panel at info@divelungfish.com.

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.

4.11 What forms of ID will I need to provide in order to access this?

Depending on the services provided Lungfish may require details of the qualifications you hold and require that you identify yourself. Lungfish accepts any of the following forms of ID when information on your personal data is requested:

Passport
Driving licence
National Identity Card
Diver Qualification Cards

Contact details of the Privacy Officer: info@divelungfish.com