privacy policy
Introduction
Our customer’s trust in our brand is very important to us. Therefore, at Sail by the Sea, we make our best effort to process Personal Data in a responsible, transparent, and secure way.
This Privacy Policy identifies the grounds on which we process Personal Data and describes our main data processing activities and other general rules and guidelines we follow.
When you use our website you consent to the collection, storage, use, disclosure, and other uses of your Personal Data as described in this Privacy Policy.
We encourage all our website users and our customers to carefully read this Privacy Policy and use it to make informed decisions.
Personal Data processing
Personal Data, as defined by the GDPR (Regulation (EU) 2016/679 – General Regulation on Data Protection), corresponds to information relating to an identified or identifiable natural person (“data subject”).
At Sail by the Sea, we only process Personal Data:
i. that is necessary for the performance of our contractual obligations towards customers and to provide our services;
ii. to protect our legitimate interests; and
iii. for compliance with legal and financial regulatory obligations.
The main activities in which we process Personal Data are:
i. booking and reservation management;
ii. billing and payment management;
iii. advertisement and marketing campaigns; and
iv. website and service optimization.
The Personal Data that we process are related to:
i. identification (full name, id, passport);
ii. navigation qualification (navigation license and experience);
iii. fiscal information (VAT, fiscal address);
iv. contact information (mobile phone, e-mail address);
v. emergency contact (name and mobile phone);
vi. web and device information (e.g. geolocation data, IP address, unique identifiers as MAC address and UUID, and other information which relates to your activity through our website).
The Personal Data is collected from users who access our website www.sailbythesea.com or other persons that share their personal information with us by other means (e.g. e-mail or mobile phone), and is mostly managed in on our booking platform www.beds24.com.
Non-personal data processing
While browsing our website, user’s web browsing data may also be collected and processed. This information is usually un-identified and does not allow, by itself, the univocal identification of a natural person.
This non-personal data may include aggregated usage information and technical information transmitted by user’s devices, including certain software and hardware information (e.g. device properties and type of browser and operating system, language preference, access time, etc.). We may also collect information about user’s activity on our website (e.g. pages viewed, online browsing, clicks, actions, etc.).
We use this information so that we can continuously improve the functionalities and performance of our website and services.
Cookies
We and our trusted partners use cookies and other technologies in our related services, including when you visit our website or access our services.
A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences, and making the interaction between you and our services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our services.
Our website uses the following types of cookies:
i. session cookies, which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
ii. persistent cookies, which are read only by the website, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
iii. third-party cookies, which are set by other online services who run content on the page a user is viewing, for example by third-party analytics companies who monitor and analyse our website access.
Cookies do not contain any information that personally identifies a user, but Personal Data that we store about users may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our website may not operate properly, and your online experience may be limited. For more information about cookies and how to disable them, visit http://www.allaboutcookies.org.
We also use a tool called “Google Analytics” to collect information about user’s use of our website. Google Analytics collects information such as how often users access the website, which pages they visit, when they do so, etc. We use the information we obtain from Google Analytics only to improve our website and services. Google Analytics collects the IP address assigned to a user on that date, rather than the name or other identifying information. We do not combine the information collected using Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about user visits to our website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
Third-party collection of information
Our policy only addresses the use and disclosure of information we collect from users. To the extent a user discloses his information to other parties or websites, throughout the internet, different rules may apply to their use or disclosure of the information disclosed to them. Accordingly, we encourage users to read the terms and conditions and privacy policy of each third party that they choose to disclose information to.
Our website contains references (links) for quick access to external social networks, such as Facebook and Instagram. The functions assigned to the links, in particular the transmission of user information and data, are activated only when the user clicks on the respective link. Once this click on the social network link is made, a direct connection is established with the servers of the respective social network and there may be a transfer of user data. From that moment onwards, the Social Network will be solely responsible for the processing of user data. If users can “share” content from our website with friends via social media such as Facebook, Instagram or others, cookies may be sent to them from these websites.
This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy.
Marketing and advertisement
We may use Personal Data (e.g. name, e-mail address, mobile phone number) ourselves or by using our third-party subcontractors, for the purpose of providing you with promotional materials concerning our services which we believe may interest you.
To respect your right to privacy, within such marketing materials we provide you with the means to opt out of receiving further marketing offers from us. If you unsubscribe, we will remove your contact from our marketing distribution lists.
Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out. These may include customer service announcements or administrative notices.
We may also use a third-party advertising technology to serve advertisements when you access our website. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g. by placing third-party cookies on your web browser).
You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
Data sharing
We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Customers and online users accept that subcontracted third parties may process their Personal Data, to make deliveries, process payments or to provide support services for our activity or the maintenance of any of our computer systems. All third parties that are subcontracted will be bound by the privacy rules legally in force and those defined in this Privacy Policy.
Your Personal Data will also be transmitted to official entities, such as the Tax Authority, by legal imposition. Data may also be transferred to national authorities, within the scope of inspection or combating fraud, according to applicable laws and regulations or requests by legal authorities.
Security in data processing
Sail by the Sea undertakes to adopt protective measures aimed at preventing unauthorized access and illegal treatment, accidental loss, destruction, and any damage to Personal Data. All navigation on our website is done by HTTPS (Hyper Text Transfer Protocol Secure) and which guarantees encrypted communication.
The user accepts that the transmission of information via the Internet is not completely secure and that, despite Sail by the Sea’s best efforts, it cannot guarantee the total security of Personal Data. Keep any password for accessing user’s online account confidential, not disclosing it to anyone. Please contact us immediately If you detect any anomaly or irregularity with online account information.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our website, and we make no warranty, express, implied, or otherwise, that we will prevent such access.
Data Retention
We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes and enforce our policies.
Retention periods will be determined considering the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity. Under applicable regulations, we will keep records containing client Personal Data, account opening documents, communications, and anything else as required by applicable laws and regulations.
Data subject’s rights and responsibilities
The users should guaranty that the Personal Data provided to us is true, accurate, complete, and up to date. If the data provided belongs to a third party, the customer guarantees that he has informed the third party of the aspects contained in this document and has obtained its authorization to provide his data for the indicated purposes.
Under GDPR, the subject of Personal Data has the following rights:
i. Right to information about the treatment
ii. Right of access and portability
iii. Right of rectification
iv. Right of erasure
v. Right of opposition and/or limitation of treatment
vi. Lodge a complaint with a supervisory authority.
However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the above rights or receive more information, please contact our Data Protection Officer (“DPO”) using the following e-mail address: geral@sailbythesea.com. Sail by the Sea will analyse all requests, assessing their legitimacy and relevance, committing to respond in a timely manner.
Updates or amendments
We reserve the right to periodically amend or revise this Privacy Policy. Material changes will be effective immediately upon the display of the revised Privacy Policy. The last revision will be reflected in the “Last modified” section. Your continued use of the website and our services, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
Last modified 11/05/2022
