Drew International

This Privacy Notice applies to personal data processed by Drew International (“Drew International”, “we”, “us”, “our”) in the context of our activities in the EEA and the UK. This Privacy Notice describes how we collect, use and otherwise process personal data about you, including when you use our websites at drew-marine.com and trac-online.com (the “Sites”), products and services (together with the Sites, the “Services”).

Drew International is made up of several different legal entities. This Privacy Notice is issued on behalf of the Drew International group so when we mention “Drew International”, “we”, “us”, “our” in this Privacy Notice, we are referring to the relevant company responsible for processing personal data (being the “data controller”). Drew International LLC is the data controller for our Sites. Otherwise, the Drew International entity that was originally responsible for collecting personal data will be the primary data controller. However, please note that personal data may be shared across other Drew International entities also acting as a data controller as part of our group operations.

By “personal data” we mean information about you which could identify you such as your name and contact details.

Should you have any questions about this Privacy Notice or would like further information about the controller of your personal data, please see the Contact us section below.

Information we process and how we collect it

The information that we collect or receive depends on the context of your interaction with us and our Services and the choices you make if and when you use the Services. For example, you may provide personal data directly to us (or to vendors or other unaffiliated entities acting on our behalf), or we may collect certain information about you automatically through your use of the Sites. We may also receive information indirectly from third-party sources.

We may also de-identify, aggregate and anonymise information such that it is no longer personal data as it no longer identifies you. We may then use this data for any purpose including to analyse and improve our Services and research purposes.

Information you provide to us

When you use or are considering using our Services, you may provide information to us or entities acting on our behalf when communicating or transacting with us in writing, by filling in forms or by corresponding with us by post, phone, email or otherwise. Such information may include the following:

• Name and contact details: such as first and last name, job title, employer or business you work for or otherwise represent, phone number, email address, country/region.
• Other information you choose to include in communications with us: such as when you fill out a form, request further information, send us a message or email, or otherwise contact us for support. Such information could include your reason for contacting us, your preferred method of contact, and the date and time you contacted us.

Information we collect automatically

We or providers on which we rely may also automatically collect certain data points when you interact with our Sites or open our emails such as technical data about your equipment, browsing actions and patterns, which may include (i) the type of browser and operating system you are using, (ii) your IP address or mobile device identifier, (iii) the domain name of your internet service provider, (iv) the date and time of a visit, information about the content you view and the features you access, the number of links you click as well as your activity and behavior on the Site or in relation to our emails, (v) location-based information regarding the state or country from which you accessed our Site or opened our emails, (vi) information regarding the advertisements you have interacted with, viewed, or accessed, such as the number of times you view an advertisement. We collect this personal data using cookies, server logs and other similar technologies. Please see the Cookies and other similar technologies section below for further details.

Information we generate or obtain from other sources

We may also generate certain information or obtain it from certain third parties or other sources, including the following:

• As part of our diligence to comply with sanctions laws: for example, we may receive the results of sanctions screening checks in relation to you.
• From our use of social media sites: for example, we may receive your profile and contact information when you interact with our social media profiles.
• Correspondence and Services records: for example, we may generate call notes and meeting summaries and keep records relating to the provision of our Services.

Special categories of personal data

There are more limited bases for processing special category personal data. This is personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation. Similarly, there are fewer bases for processing criminal convictions and offences data.

We do not intend to actively collect such categories of personal data about you. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally. For example, where you volunteer special category data to use, such as if you send us an email containing special category data.

What if you do not provide the personal data requested?

Unless and until you make a decision to engage in a business transaction with us, you are not required to provide us with any personal data although please note that our Sites may automatically collect some information as described above.

If you do not provide us with certain information when requested, as indicated to you at the time, we will not be able to perform all or part of the contract we have entered into with you, or we may be prevented from complying with our legal obligations.

How we use information

We may use your information, including personal data, for various reasons depending on the information provided and your relationship with us. For instance, we may use your information in the following ways, or as otherwise disclosed to you or as may be permitted or required by law:

• To provide the Services. For instance, we use your information to fulfil our contractual obligations, to create, administer and manage accounts, and provide information about our Services. Our lawful basis for these purposes if the performance of our contract and our legitimate interests in providing our Services.
• To communicate with you. We may contact you via email or other means with updates about the Services and to manage our relationship with you. We may also contact you for purposes of support (including to receive feedback and comments from you about the Services). We may also send you marketing communications as described further below. Our lawful basis for these purposes is the performance of our contract with you and our legitimate interests in providing such communications.
• For analytics and to improve the Services. We may use your personal data to evaluate your usage, preferences, and trends for statistical and analytical purposes which we may use for marketing purposes, operations and service development. We may also use it to improve customer experience and customise, measure and improve our Services. Our lawful basis is our legitimate interests in understanding, customising and improving our Services.
• To engage in marketing and advertising including online targeted advertising. We may use your personal data to market to you and for advertising purposes. This may include sending emails or other communications and marketing or advertising offers, promotions, news and events. We will only send marketing communications in accordance with applicable law. We may also partner with third parties in an effort to serve targeted, interest-based advertisements to you. For more information about this please see the Targeted Advertising section below. Our lawful basis for these purposes is your consent where required by applicable law or our legitimate interests in engaging in such marketing and advertising to grow our business. You may opt-out of receiving marketing messages at any time by using the opt-out/unsubscribe function available in those emails.
• For compliance with law, to enforce our rights and manage our activities. We may use your personal data to carry out our obligations, enforce our rights and manage our activities, including to enforce any agreement between you and us. We may also use your personal data to prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud, sanctions screening and security monitoring purposes. Our lawful basis is the performance of our contract with you and/or compliance with our legal obligations and/or our legitimate interests in managing our activities and detecting and preventing illegal or impermissible activity, conducting sanctions monitoring and monitoring security.

Change of purpose

We will only use your personal data for the purposes for which we collected it (as identified above), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

How we share information

• With other Drew International entities. Our affiliates help us provide the Services and manage our customer relationships as well as administrative support and other management services and oversight.
• To provide the Services and operate and promote the Services. We employ or engage other companies and people to perform tasks on our behalf and we may need to share your personal data with them to provide the Services, to provide support to you, to improve your experience with our Services and/or to otherwise assist us with providing the Services. For example, we may share your personal data with our platform providers and third party contractors such as CRM and email newsletter providers and web analytics providers. We may also disclose your personal data to providers when we promote our activities, including for marketing and advertising purposes, and to conduct audience engagement and analytics related to the Services. Our professional advisers including lawyers, bankers, auditors and insurers to the extent such information is relevant to their performance of their services may also need to receive some personal data.
• In connection with online and targeted advertising. We and third-party partners we engage may share your information in connection with our online advertising efforts. See Targeted Advertising below for more information.
• To comply with legal requirements and enable protection of rights. We may disclose your information at the request of law enforcement or government agencies, in response to subpoenas, court orders, or other legal processes, or as otherwise required by any law, regulation or legal order to which we are subject. We may also disclose your information to protect the rights, property, or safety of another person, to monitor for or prevent fraud, or to investigate or prevent your violation of any contractual or other relationships with us or your suspected illegal or unlawful activities.
• In connection with a business transaction. If we or any of our affiliates, subsidiaries or lines of business are merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of assets, any information collected pursuant to this Privacy Notice, including personal data we may possess about you, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.
• As otherwise described to you or with your consent. We may disclose your Personal Data to unaffiliated entities as otherwise described to you or with your consent.

Transfers

Drew International is a global business and so your personal data may be processed in various countries outside the EEA and UK, such as in the United States and Singapore for the purposes described above. These countries may not have the same standard of data protection laws as the EEA or the UK.

Where this is the case and where required by law, we have put in place appropriate safeguards to protect your personal data. If you require further information about this, please see the Contact us section below.

Data retention

We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. In doing this we will have regard to 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 requirements

Accuracy of personal data

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.

Your rights in relation to your personal data

Subject to applicable law, you may have rights as an individual which you can exercise in relation to the personal data we hold about you under certain circumstances. These rights are to:

• request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
• request rectification of your personal data;
• request the erasure of your personal data;
• request the restriction of processing of your personal data;
• object to the processing of your personal data;
• withdraw your consent where you provided it for a specific purpose;
• not be subject to a decision based solely on automated processing which significantly affects you;
• request the transfer of your personal data to another party.

If you would like to make a request to exercise these rights, please see the Contact us section below. We will do our best to accommodate your request or objection but please note that not all rights are absolute.

You also have the right to make a complaint at any time to a supervisory authority for data protection issues. We would, however, request that you contact us in the first instance to give us the opportunity to address any concerns you have.

Fees and what we may need from you

You will not usually 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Cookies and other similar technologies

We and service providers or partners we engage may use cookies and/or other similar technologies to understand usage of and improve our Sites, conduct analytics, and deliver advertisements in which you might be interested. Some of these technologies that we use are “strictly necessary” or “required” for the Sites to function. We also use analytics tools, such as to help us measure traffic and usage trends for the Sites. Such analytics tools may provide data, such as information about your engagement with the Sites which may be used to provide content, analysis or functionality or to measure and analyse engagement with the Sites. We may also use technologies to help us advertise to you and understand which ads you have seen.

Our Sites may use Google Analytics, a web analytics service offered by Google. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at http://www.google.com/policies/privacy/partners.

Targeted Advertising

We, our third-party partners, and others may use your information, which may include personal data collected via cookies and other similar technologies (as described above in Information we collect automatically) to engage in targeted advertising and display content that is believed to be relevant to you. Such ads and targeted content may appear on our website and/or across other domains. Our third-party partners and others may collect similar information from you across other websites and over time.

We take steps to contractually limit the rights our third-party partners have to the information they collect from you via cookies and other similar technologies. However, we may grant some of our third-party partners such as Google independent rights to your personal data, including rights to use your personal data for their own purposes. In such cases, we do not control those third parties’ further use of your personal data and such use is governed by those third-parties’ respective privacy policies. For instance, for further details on the processing of personal data in relation to Google products and services, please refer to the Google Privacy Policy at https://policies.google.com/privacy.

Managing Cookies

For more information about the cookies we use and for instructions on how to manage your cookie preferences and choices you may have, please access your Cookie Settings available on the Sites. For detailed information about the cookies we use, including their purpose and duration, please see our Cookie Notice.

You can also generally manage your cookie preferences through your web browser. Most web browsers will tell you how to stop accepting new cookies and how to disable existing cookies. For more information regarding how to manage your preferences, please consult the information made available by your particular browser or visit www.allaboutcookies.org. With respect to Google Analytics, you can also view Google’s currently available opt-out options at: https://tools.google.com/dlpage/gaoptout. Please note that if you disable cookies you may be unable to access certain parts of the Sites or parts of the Sites may not work properly. 

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our Sites and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

Contact us

If you require any further information, please do not hesitate to contact our team using the form below.

Last updated:  February 2026