Privacy Policy
COMMITMENT TO YOUR PRIVACY
This website and the information sharing tool are owned and operated by Oceana, Inc. (“Oceana” or “we”). We understand that you value your privacy and take the protection of your personal data very seriously. This policy governs personal data you provide to us or that we learn from your use of the website www.pulltheplugonpiratefishing.org, the functionalities and services offered via the website, in particular the information sharing tool, and any other contact with Oceana in that context, like receiving emails. This policy explains how we may collect, use, and in some instances share or otherwise process your personal data.
According to the applicable data protection laws, we are obliged to inform you about the processing of your personal data (Art. 13 and 14 EU General Data Protection Regulation (“GDPR“) as further developed by local laws). Oceana implements this requirement by providing this privacy policy.
Oceana treats your personal data as strictly confidential and takes all necessary measures to protect your data in accordance with data protection requirements, in particular the GDPR.
- Personal Information – Definition
WHO IS RESPONSIBLE / CONTROLLER FOR PROCESSING MY DATA?
Oceana is responsible for the processing of your Personal Information as a data controller within the meaning of the GDPR. You can contact Oceana at any time. Please find the contact details in the section below “Contacting Oceana.”
PERSONAL INFORMATION OCEANA COLLECTS AND HOW WE USE IT – FOR WHICH PURPOSES AND ON WHICH LEGAL BASIS WILL MY DATA BE USED?
We may ask you to provide us with Personal Information if you would like to participate in some activities available on, or benefit from services offered on, this website. Through the use of forms, we may collect this information to help provide you with Oceana services and respond to your requests.
Registered users may use the website to upload certain information on IUU fishing, receive emails with notification of such an alert, and comment on the alerts (see our Terms of Use).
Specifically:
- Registration and Login
If you are an employee of one of the companies we cooperate with and want to use the website, you first have to register, accept to comply with the Terms of Use and be authenticated as an authorized employee of one of the cooperating companies.
For the registration and authentication, we collect the following Personal Information, that we ask you to submit when registering:
- Name
- Username (You can choose your username freely and do not have to use your real name. Other users will be able to see your username).
- Company name
- Company email address
- Job title/position in the company
We will first send a confirmation email with a link to the email address you provided, as this allows us to verify whether you are the owner of this email address. Only if you click on this link, your request will be further processed (Double-Opt-In process). We will then verify that you are an authorized employee of one of our cooperating companies by matching your information to a list of this company’s employees, containing authorized employee’s name and email address, which we receive from each of our cooperating companies. If we can confirm that you are an authorized employee with one of our cooperating companies, we enable your use of the website. If you are an employee with a company that is not yet cooperating with us and we decide that we will cooperate with this company, we will reach out to this company in order to receive a list of authorized employees before enabling your use of the website.
In order to access the website, you must provide your email address as well as your password.
Other users will generally not be able to see your Personal Information. They will, however, see your username along with your comment when you comment on alerts (see below – Section “Participate – your active use of the information sharing portal”) and see a list of all cooperating companies, which will not contain any of your Personal Information, except if the company name includes your real name.
This processing of your Personal Information for the purposes described in this section is necessary for the performance of the Terms of Use you accept upon registration (Art. 6 Sect. 1 lit.b GDPR).
In addition, as this website and the information sharing tool are intended to be used by employees of cooperating companies, we have a legitimate interest in ensuring only authorised individuals use them, and to share and confirm with these companies that you are their employee. For this purpose, and based on our in the due performance and good use of our platform and website, we share your name and email address with cooperating companies as described above, and receive from them the confirmation of your employment with them. We have carried out a balancing test -available upon request- to ensure that our interest is not overridden by your rights, freedoms and interest.
- Fraud and misuse of the website
- Surfing the website – informational use of the information sharing portal
If you access the website, Oceana will collect data that your browser automatically transmits to us, including:
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Type of browser/version/language
We process this data to enable your visit of and use of the website and the information sharing tool. This processing is based on our legitimate interests to effectively and lawfully provide our website and guarantee its stability (Art. 6 Sect. 1 lit.f GDPR). We have carried out a balancing test -available upon request- to ensure that our interest is not overridden by your rights, freedoms, and interests.
- Participate – your active use of the information sharing portal
Once logged in, you may submit an alert with information on IUU fishing (for details, see our Terms of Use). You have the option to submit the report anonymously, in which case only Oceana knows that you submitted the alert. Please note that you shall not submit Personal Information of any third person in the alert and if you do, we will immediately delete this Personal Information (see our Terms of Use). Oceana will verify your alert and either inform you that your publication request has been denied or post your alert on the information sharing portal and inform you about the posting.
If you wish, you can comment on the alerts posted on the information sharing portal. Your comments can be seen by all other users along with your username.
When a user’s alert has been posted on the information sharing portal, we will notify you by email that there has been a new alert. You can choose to receive notifications by email from us every time that a new alert has been posted on the information sharing portal to stay up to date with the latest alerts. You can turn these notifications on when registering and turn them on or off in your settings.
We process your data for these purposes to perform our contractual obligations we have towards you (see our Terms of Use) to provide an information sharing tool where users can submit and receive information on vessels involved in IUU fishing (Art. 6 Sect. 1 lit. b GDPR) and on our legitimate interests to maintain a forum that allows the exchange of information, including our legitimate interest to be able to defend ourselves against claims of other users or third persons, if a comment contains illegal content. We have carried out a balancing test -available upon request- to ensure that our interest is not overridden by your rights, freedoms, and interests.
- User Relations
We will use the Personal Information that you provide to us, such as requests made through the “Contact Us” page of our website, to contact you in response to requests for information and process your requests and/or your comments, insofar as this is necessary for the purposes of our legitimate interests (ensure the effective and lawful processing of requests as well as the establishment, exercise or defence of legal claims) (Art. 6 Sect. 1 lit.f GDPR) and to the extent that such requests are not directly related to the performance of our obligations under the Terms of Use – where the lawful basis will be the performance of such terms (Art. 6 Sect. 1 lit. b GDPR) –. We have carried out a balancing test -available upon request- to ensure that our interest is not overridden by your rights, freedoms, and interests.
We try to limit our requests for Personal Information to information we believe is necessary to achieve our stated collection purposes.
- Usage Tracking
We track website usage data to improve our website. We collect user traffic patterns throughout our website using web logs, cookies, and similar technologies. This information is collected to help improve website flow and usability. In addition, when we send emails to our members and supporters, we track information on clicks-through to our website, including IP addresses. This is done to gauge the effectiveness of our marketing campaigns and to discourage fraudulent use.
- Cookies
We may place a text file called a “cookie” in the browser files of your computer. A cookie cannot read data off your hard disk or read cookie files created by other websites. Oceana may use cookies to track user traffic patterns (as described above). In addition, Oceana uses encrypted cookies to authenticate the user on each page after the user logs onto the website. You can refuse cookies by turning them off in your browser. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. Some Oceana website features and services may not function properly if your cookies are disabled.
- Our Usage of Personal Information
- To advance our mission including delivering information that may be of interest to our supporters;
- To conduct research and analysis in order to maintain and improve our website and advance our mission;
- To alert you to news updates and related developments, special offers, and other new Oceana offerings. We provide you with controls so that you can determine whether or not you would like to continue to receive such communications if you so choose (as described below).
FOR HOW LONG WILL MY PERSONAL INFORMATION BE STORED?
- All Personal Information processed for your informational use of the website (see section “Surfing the website – informational use of the information sharing tool” above) will in general be deleted after two years.
- The Personal Information we process for your further use of the information sharing portal (see above sections “Registration and login”, “Fraud and misuse of the website” and “Participate – your active use of the information sharing portal”), will in general be stored fortwo years.
- Your Personal Information processed for user relations (see above section “User relations”) will only be processed for as long as this is required for processing and concluding your request.
- Your Personal Information processed for tracking purposes (see above sections “Usage Tracking” and “Cookies” will be processed for as long as indicated on our Cookie Policy.
DO I HAVE TO PROVIDE MY PERSONAL INFORMATION?
The processing of your Personal Information by Oceana is necessary for the purposes above and based on the legal bases identified above. Please note that by not providing some information (specifically that required for the provision of our services or to comply with applicable laws), you may not have or may only have limited access to the information sharing tool.
WHICH RIGHTS DO I HAVE AND HOW CAN I EXERCISE THEM?
To the extent you are affected by the data processing carried out by Oceana, you have rights in accordance with applicable legal provisions. Particularly:
- to obtain information on the personal data processed concerning you and to obtain a copy of such data (right of access)
- to obtain the rectification of any inaccurate personal data and, having regard to the purposes of the processing, the completion of incomplete personal data (right to rectification);
- if there are legitimate reasons, to request the deletion of the personal data (right to erasure);
- to request the restriction of the processing of the personal data, if the legal requirements are met (right to restriction of processing);
- if the legal requirements are met, to receive the personal data provided by you in a structured, commonly used and machine-readable format and to transfer this personal data to another controller or, if technically feasible, to have it transferred by Oceana (right to data portability); and
- not to be subject to a decision based solely on automated processing which produces legal effects concerning you or significantly affects you in a similar way, if the legal requirements are not met. An automated decision-making process is not carried out by Oceana.
You also have the right to object, in accordance with the statutory provisions, to the processing of personal data, which is necessary for the purpose of Oceana’s legitimate interests, on grounds relating to your particular situation (right to object). If your personal data is processed by Oceana for direct marketing purposes, you have the right to object to this processing at any time, without any special reason.
If the data processing is based on consent, you can withdraw the consent at any time. The withdrawal of your consent does not affect the lawfulness of the processing of your personal data until withdrawal.
In order to exercise your rights (including the withdrawal of your consent), as well as in the event of questions regarding the processing of your personal data, please contact Oceana at any time using the contact details set out in the section “Contacting Oceana” below or contacting FUNDACIÓN OCEANA at Gran Via, 62 7º Izquierda – 28013 Madrid, Spain and OCEANA UNITED KINGDOM Bates Wells & Braithwaite 10 Queen Street Place, London EC4R 1BE, United Kingdom or by Email: . Please note that for the exercise of your right to erasure, you can also delete your personal account in the settings page of the information sharing tool.
Without prejudice to any other remedies, you also have the right to lodge a complaint with a supervisory authority at any time.
OCEANA TRANSFER AND INFORMATION SHARING POLICY – WHO HAS ACCESS TO MY PERSONAL INFORMATION?
Inside Oceana, only those persons that need your Personal Information for the performance of the abovementioned purposes and only to the extent necessary for such purposes will have access to it. We do not rent, sell, or share Personal Information collected on this website with third parties for their direct marketing purposes without your permission. However, we may disclose your Personal Information with the following third parties:
- Other members of our Group. We may share certain information about you with Oceana affiliates, on the basis of our legitimate interest, for internal administrative purposes and insofar it is reasonably necessary for the purposes stated in this Privacy Policy. These affiliates include Fundación Oceana and Oceana United Kingdom.
- Service providers. We may provide Personal Information to or permit access to Personal Information by vendors and service providers who are contracted to help us administer this website. These service providers may process Personal Information on our behalf or use Personal Information to assist Oceana with your registration and authentication, in administering our website (e.g. an IT service provider that hosts our website), or in sending out emails. Our vendors and service providers are obligated to ensure all necessary technical and organisational measures to protect your Personal Information pursuant to statutory data protection requirements. Our vendors and service providers are not allowed to transfer your Personal Information to third parties or process them for their own purposes.
- Asset purchasers. We will also, on the basis of our legitimate interest in the due process of sale, disclose your Personal Information with any third party that purchases, or to which we transfer, all or part of our assets and business. In these situations, we will require the recipient of the data to protect it in accordance with the relevant principles under the applicable data protection regulations and take steps to ensure that your information is appropriately protected.
Oceana does not otherwise share Personal Information about website users with third parties unless doing so is appropriate to carry out this user’s request or Oceana is legally required to do so or it is in Oceana’s legitimate interest to establish, exercise or defend against legal claims or to protect its property or other legal rights or the rights or property of others.
It is possible that some of the recipients mentioned above are based in countries outside the European Union and the contracting states of the European Economic Area (so-called third countries). The laws of these countries may not ensure a level of data protection that has been found adequate by the European Commission in an adequacy decision. In these cases, however, we have taken appropriate and reasonable measures to ensure that your data is also adequately protected by the recipients in third countries and that the level of data protection required by European laws is not undercut (e.g. by concluding EU standard contractual clauses and other additional protective measures that may be required). To find out more about the recipients of your data and the measures we have taken to protect your data, including the possibility of obtaining a copy of the measures, please contact us using the contact details listed in section “Contacting Oceana” below.
INTERNATIONAL VISITORS AND CUSTOMERS
This website is hosted in the United States. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law please note that your personal data will be processed in the United States, where a statutory level of data protection applies that is not comparable to the level of data protection within the EEA.
SECURITY
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy, including encrypting data, using secure HTTPS protocol for transmission and ensuring that all access to data by Oceana staff is limited. No data transmissions over the Internet can be guaranteed to be completely secure. Consequently, we cannot ensure or warrant that information you transmit to us will never be accessed. If Oceana learns of a security systems breach we may need to notify you electronically so that you can take appropriate protective steps. By using this website or providing Personal Information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of this website. Oceana may post a notice on our website if a security breach occurs. Oceana may also need to send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us at info@oceana.org.
CHANGES AND UPDATES
We may occasionally update this Privacy Policy. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of Personal Information you have provided to us, we will attempt to obtain your consent before implementing the change. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the Personal Information we collect. Your continued use of this website constitutes your agreement to this Privacy Policy and any updates.
CONTACTING OCEANA
If you have any questions, comments, or concerns about Oceana or this Privacy Policy, please email us at info@oceana.org. In the event that we are still unable to resolve your concerns Oceana is committed to cooperating to achieve a proper resolution of your privacy concerns.
Contact details of the controller,
Oceana Inc.
1025 Connecticut Avenue, NW, Suite 200,
Washington, DC 20036
Contact details of controller’s representative in the European Union:
Fundación Oceana:
Gran Via, 62 7º Izquierda
28013 Madrid, Spain
Contact details of Oceana’s Data Protection Officer in the European Union:
Mar Tello