Draft — not yet approved. Pending review by our Data Protection Officer. Highlighted passages depend on decisions still open (newsletter setup, server error logs) and will be completed before launch.

Information pursuant to Art. 13 and 14 GDPR

Privacy Policy

1. Who is responsible

The controller for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is:

TRENZ GmbH
Anne-Conway-Straße 1
28359 Bremen, Germany
Phone: +49 421 595 89-0
Email: info@trenz.de
Commercial Register: Bremen HRB 33764
Managing Directors: Frank Diegel, Steffen Schmedes

Data Protection Officer
Stefan Lutz, LL.M., Lawyer
Specialist lawyer for information technology law
datenschutz@trenz.de

2. Scope

This policy covers the website pilot-boat.net, including the newsletter sign-up. Pilot-Boat.net is a project of marine-pilots.com, which is also operated by TRENZ GmbH. When you follow a link to marine-pilots.com or any other website, that site's own privacy policy applies.

3. The short version

No tracking, no advertising, no analytics. We do not use Google Analytics, advertising pixels, tracking cookies or social media plugins.
No cookies. This website sets no cookies and stores nothing on your device.
No account needed. Everything on this site is readable without signing up.
Everything is served from our own server — fonts, images and the world map. Your browser contacts no third party when you load a page.
The only personal data we ask for is your email address, if you subscribe to our newsletter.
We never sell your data, and we do not pass it to third parties for advertising.

4. Visiting the website (server log files)

To deliver a page, our web server necessarily processes your IP address, the page requested and the usual technical request data (browser type, time of the request). We do not keep access logs for this website: this data is used only to answer the request and is not stored afterwards.

Technical error messages of the server may be recorded for a short time to keep the service running; they are not used to identify visitors. [to be confirmed with our IT: retention of server error logs]

Purpose: to deliver the site and keep it stable and secure.

Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in operating a secure and functioning website.

5. Visitor statistics

We currently do not collect any visitor statistics. [If cookieless statistics are introduced later, this section will describe them before they go live.]

6. Cookies and local storage

This website sets no cookies and uses no local or session storage. There is therefore no cookie banner.

Pilot Boat Monthly is our free newsletter about pilot boats. You can subscribe on our website.

What we store: your email address, the time you submitted the form and, once you confirm, the time of your confirmation. We do not ask for your name or company.

Double opt-in: straight after you submit the form, we send you an email with a confirmation link. Your address counts as confirmed only after you click the link. This protects you against someone else entering your address.

Unconfirmed requests: an unconfirmed address receives no further emails from us. We delete unconfirmed addresses after 90 days, or straight away if you write to datenschutz@trenz.de.

What we send: once your address is confirmed, Pilot Boat Monthly [frequency as finally decided: monthly / quarterly]. Nothing else is sent to this address, and you can unsubscribe at any time.

Legal basis: Art. 6(1)(a) GDPR — your consent.

Withdrawal: you can withdraw your consent at any time, using the unsubscribe link in every newsletter or by writing to datenschutz@trenz.de. We then send you nothing further. We keep a record of your request, confirmation and withdrawal for as long as necessary to demonstrate that consent was given. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

The subscriber list is kept and the emails are delivered by our email service provider — see section 8. [To be confirmed in the SendGrid setup: open and click tracking switched off. Then: “We do not use tracking pixels in our emails and do not measure whether you open them or which links you click.”]

8. Recipients and processors

We pass personal data to third parties only where necessary to operate this website, and only under a data processing agreement pursuant to Art. 28 GDPR.

Hosting

This website is hosted by a specialist hosting provider on servers located within the European Union. The infrastructure is operated by the TRENZ IT team. Hosting therefore involves no transfer of your data to a country outside the EU/EEA. The provider processes data solely on our instructions, under a data processing agreement pursuant to Art. 28 GDPR.

If you would like to know which provider we currently use, write to datenschutz@trenz.de and we will tell you.

Newsletter — Twilio SendGrid

The newsletter subscriber list is stored and the newsletter emails, including the confirmation email, are delivered by Twilio Inc. (SendGrid), 101 Spear Street, San Francisco, CA 94105, USA. This means your email address and the times of your subscription and confirmation are processed by a provider in the United States, a country outside the EU/EEA.

Safeguards for this transfer: Twilio Inc. is self-certified under the EU-U.S. Data Privacy Framework, which the European Commission has recognised by an adequacy decision as providing a level of protection equivalent to that of the EU. Should that certification lapse, Twilio's data protection addendum provides for its Binding Corporate Rules and, failing those, the Standard Contractual Clauses under Art. 46(2)(c) GDPR to take effect instead. A copy of the addendum is available from us on request.

Privacy notice: twilio.com/legal/privacy

Beyond these, we do not transfer your data to third parties unless we are legally obliged to do so, or you have expressly consented.

9. Fonts, images and external content

This site uses the Barlow, Barlow Condensed and IBM Plex Mono typefaces. The font files are hosted on our own server and delivered together with the page. Your browser makes no request to Google Fonts or any other external provider.

The world map is drawn by our own page; no map service is contacted. Preview images of articles and videos are stored on our own server. Videos are not embedded: a video opens only when you follow the link to marine-pilots.com.

We do not embed social media plugins, external video players or advertising scripts.

10. Your rights

Under the GDPR you have the following rights in relation to your personal data:

Access (Art. 15) — to be told whether we process data about you, and to receive a copy.
Rectification (Art. 16) — to have inaccurate data corrected or incomplete data completed.
Erasure (Art. 17) — to have your data deleted, where one of the grounds in the GDPR applies.
Restriction (Art. 18) — to have processing limited instead of deleted, in certain cases.
Data portability (Art. 20) — to receive data you provided in a machine-readable format.
Withdrawal of consent (Art. 7(3)) — at any time, with effect for the future.

Right to object (Art. 21 GDPR). Where we process your data on the basis of our legitimate interests (Art. 6(1)(f)), you have the right to object at any time on grounds relating to your particular situation. We will then stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims.

To exercise any of these rights, write to datenschutz@trenz.de or to our postal address. Exercising them is free of charge.

Right to lodge a complaint. You may complain to a supervisory authority, in particular in the Member State of your residence, place of work, or the place of the alleged infringement. The authority responsible for us is:

Der Landesbeauftragte für Datenschutz und Informationsfreiheit der Freien Hansestadt Bremen
Georgstraße 122–124, 27570 Bremerhaven, Germany
Phone: +49 421 361 2010 · Email: office@datenschutz.bremen.de
www.datenschutz.bremen.de

11. Data security

We protect your data with technical and organisational measures against loss, manipulation and unauthorised access, and review these measures as technology develops. The site is delivered over TLS-encrypted HTTPS, recognisable by the lock symbol in your browser's address bar.

12. Obligation to provide data

You are under no obligation to provide personal data. You can use the entire site without disclosing anything about yourself. If you choose not to enter your email address, we simply cannot send you the newsletter.

13. Automated decision-making

We do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.

14. Changes to this policy

We may update this policy to reflect changes to our services or to legal requirements. The current version is always available from the footer of every page. Where a change materially affects processing based on your consent, we will ask for your consent again.

Status: [date of approval]