Cookie & Privacy Policy

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 you which we have grouped together as follows: 

• Identity data (such as first and last name)
• Contact data (such as email address, phone number, billing address)
• Individual data (such as your photograph, or images captured by CCTV)
• Booking data (such as routes travelled, dates, times, booking references, ticket types, on-board service bookings)
• Travel data (such as vehicle registration, and journey defaults)
• Payment data (such as debit or credit card details or other payment information)
• Location data (if you enable location services)
• Device data (such as internet protocol (IP) address, your login data, address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website)
• Medical data (such as disabilities or medical information which Red Funnel may need to know to provide its services)
• Marketing and communications data (such as your preferences in receiving marketing from us and our third parties and your communication preferences). 

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://www.redfunnel.co.uk/cookie-privacy-policy#cookie for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data is collected from the following parties:
    • analytics providers such as Google and Hubspot based outside the UK;
    • advertising networks such as Google, Microsoft, which are based outside of the UK and Skyrise based in the UK; and
    • search information providers
    • Contact, Financial and Transaction Data is collected from providers of technical and payment services such as eKashu based inside the UK, and VERB Interactive based inside the UK.
    • Identity and Contact Data is collected from publicly available sources where addresses are auto populated during the booking procedure.
• Photographs / recordings. 
  Red Funnel may capture images, recordings or take photographs of you for security monitoring at the terminals, on board our ferries, inside buildings, around the yard, including the on-boarding and offboarding of passengers (Premises). This may include the use of CCTV to monitor the safety and wellbeing of passengers. See the CCTV Fair Processing section below for more information.
• CCTV Fair Processing
  We currently use CCTV surveillance systems to view and record individuals at our Premises. As a result of the CCTV at our Premises, we will process personal data of employees, directors, officers, consultants, contractors, workers, customers, passengers and other members of the public, including visitors. 
  
  Red Funnel uses CCTV for the following purposes:
• preventing crime, anti-social behaviour and protecting buildings and assets from damage, disruption, vandalism and other criminal activity;
• ensuring the personal safety of staff, customers, passengers and other members of the public, and acting as a deterrent against crime;
• monitoring compliance with health and safety requirements and safe working practices;
• preventing or reducing the risk of uncontrolled or unauthorised access at the Premises; and
  assisting in the investigation of any incident, accident or complaint.

CCTV cameras are located at various locations throughout the Premises, with appropriate signage displayed to inform you that recording is taking place. CCTV continually records footage 24 hours a day at each location.

CCTV footage is retained for a period of 90 days, unless it is required for a longer period in connection with an incident, investigation, legal proceedings, or a subject access request, in which case it will be retained for as long as necessary for that purpose. After the applicable retention period, footage is securely deleted.

As far as reasonably practicable, CCTV cameras are positioned so as not to focus on private property and are not hidden from public view.

Red Funnel monitors its CCTV footage internally and does not appoint an external provider to undertake live monitoring of the footage.

CCTV is not routinely disclosed to third parties. However, in appropriate circumstances, Red Funnel may:

• allow law enforcement agencies to view or remove CCTV footage where this is required in connection with the detection or prosecution of crime; or
• share CCTV footage with insurers in connection with an insurance claim or a notifiable event.

Footage is only transferred (in a secure manner) to hard copies following an incident or request, subject to internal approval.

Please refer to your right to request a disclosure of your personal information, which may include CCTV images, as set out in the “your rights” section below.

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
• Purposes for which we will use your personal data:
  We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Purposes for which we will use your personal data:
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Direct marketing 
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing. We may also analyse your Identity, Contact and Technical data to form a view which services and offers may be of interest to you, so that we can then send you relevant marketing communications.

Third-party marketing 
We will get your express consent before we share your personal data with any third party for their own indirect marketing purposes. 

Opting out of marketing 
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the contact details below.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for ticket purchases, updates to our Terms and Conditions, checking that your contact details are correct.
 
Cookies 
For more information about the cookies we use and how to change your cookie preferences, please see https://www.redfunnel.co.uk/cookie-privacy-policy. 

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above. with third parties in the following circumstances:

• With specific third parties such as: eKashu and VERB Interactive.
• With third parties whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We 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 if 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 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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Payment data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

You have a number of rights under data protection laws in relation to your personal data.

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING above for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table above for details of when we rely on your consent as the legal basis for using your data). 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
   If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend 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.

If you wish to exercise any of the rights set out above, please contact us using the contact details below.

No fee usually required
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 could refuse to comply with your request in these circumstances.

What we may need from you 
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
 
Time limit to respond 
We try to respond to all legitimate requests within one month. Occasionally it could 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.

We have put in place appropriate security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

• Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place for example: we will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data/
• e may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.

If you have any questions about this privacy policy or about the use of your personal data, or you want to exercise your privacy rights, please contact us in the following ways:

Email address: [email protected]

Postal address: 12 Bugle Street, Southampton, Hampshire, England, SO14 2JY 

We may update this privacy policy from time to time. Historic versions can be obtained by contacting us.

It is important that personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

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. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Like most websites, ours requires the use of "cookies" to work correctly and to provide you with the high level of functionality and convenience that you expect.

We also work with third party organisations who place advertisements about our company on the Internet on our behalf. These organisations may use tracking technologies to collect anonymous but identifiable information about users who view or interact with these advertisements. We do not provide any personal information about users to these third parties and third party cookies and tags are subject to the privacy policy of the company placing them.

Cookies cannot be used to run programs or deliver viruses to your computer. Some cookies are deleted once you leave our website "session cookies", while other cookies remain after you leave our website "persistent cookies" so that you are recognized when you return to the website.

If you pro-actively click to indicate that you wish the website to remember certain details (such as a username and password) a cookie will be downloaded so that, upon re-visiting the same page in the website, the cookie will automatically re-populate the information remembered, without your having to re-enter it. Cookies identify a computer rather than an individual, unless you have knowingly provided us with personal information.

Most Web browsers automatically accept cookies, but you can change your browser settings to prevent this. The "help" section of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. For more information about cookies and how to stop cookies being installed or how to delete existing cookies from your hard drive visit the following website: http://www.allaboutcookies.org 

All web browsers off an easy way to delete cookies that have been placed; you can choose to delete cookies every time you close your website browser or you can delete them manually whenever you choose to. You will generally be able to delete cookies from the "Setting" of your website browser. As all website browsers are different, you can click the "Help" button in your browser and enter the word "cookies" to search for information on how to delete them.

These cookies are required to make the website work correctly and to ensure that you experience the level of service and functionality that you expect.

These cookies are activated when you make choices such as remember usernames and passwords, to make it more convenient for you when you next visit our website.

Full information about Google Analytics cookies can be found on the Google Analytics website.

These cookies may be placed by Twitter to enable their functionality to work correctly. We have no control over these cookies but full information about Twitter's cookies can be found on the Twitter website.

These cookies may be placed by Facebook to enable their functionality to work correctly. We have no control over these cookies but full information about Facebook's cookies can be found on the Facebook website.

All of the pages of the Red Funnel website contain commonly used web tags, which enable us to monitor basic but invaluable information about the use of the website, such as how a visitor found the website, which pages were visited and whether a purchase was made, among others. We use Google Analytics to generate these tags and for the tracking, analysis and reporting of the resulting data. The information collected by these tags is anonymous.

The information from these tags allows us to build an accurate picture of how our website is being used and to identify any areas for improvement.