In compliance with General Data Protection Regulations 2018
1 About this policy
1.1 This policy explains when and why we collect personal information about our clients, how we use it and how we keep it secure and your rights in relation to it.
1.2 We may collect use and store your personal data as described in this policy when we collect data from you.
1.3 We reserve the right to amend this data policy on occasion without prior notice.
1.4 We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details can be found at the website for the information commissioner www.ico.gov.uk. For the purposes of the GDPR we will be the ‘controller‘ of all personal data we hold about you.
2 Who are we?
2.1 We are Zephyr Sailing.
We can be contacted at: Mayflower Marina, Richmond Walk, Plymouth
Email firstname.lastname@example.org Tel. 00447824535340
3. What information we collect and why
Type of information 1. Your name, address, contact details (email/‘phone) Purpose – So we can contact you, register your certificate(s) with the RYA if doing a course Lawful basis – Fulfil our contractual obligations.
Type of information 2. Your date of birth Purpose – So we can register you certificate(s) with the RYA (if doing a course) Lawful basis – Fulfil our contractual obligations.
Type of information 3. Gender Purpose – Provision of adequate accommodation and facilities Lawful basis – Fulfil our contractual obligations/register your certificate(s) with the RYA.
Type of information 4. Personal insurance details Purpose – In the case of accident/ emergency Lawful basis – Vital interests
Type of information 5. Emergency contact details (next of kin) Purpose – Contacting next of kin in an emergency Lawful basis – Vital interests.
Type of information 6. Dietary requirements/food allergies Purpose – So we don’t inadvertently poison you – so we can respect your cultural and dietary preferences Lawful basis – Vital interests.
Type of information 7. Passport number Purpose – As required by Authorities Lawful basis – legal requirement
Type of information 8. Swimming declaration Purpose – so we take action to reduce the risk of drowning Lawful basis – vital interests
Type of information 9. Medical declaration/sensitive data Purpose – so w can be best prepared if you have a medical condition that may affect your ability to manage on board or other crew members Lawful basis – vital interests
Additional Special Category Data – Processing is necessary to protect the vital interests of the data subject or of another person where the data subject is physically or legally incapable of giving consent.
Please note that by booking with us you agree for your insurers, their agents and
medical staff to disclose relevant information (which may contain sensitive
personal data) to us in circumstances where we need to act in the interests of
everyone in the group you are travelling with. For example, should you be affected by an illness during the trip which is infectious we may need to make special arrangements for you where you do not return to the group immediately.
If you do not agree to our use of your information we cannot do business with you or accept your booking.
4. How we protect your data
4.1 We will not transfer your data outside the EU without your consent
4.2 We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse or unauthorised alteration or destruction
4.3 Please note that where you are transmitting information over the internet this can never be guaranteed to be 100% secure.
4.4 For any payments that we take from you online we will use a recognised online secure payment system.
4.5 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
5. Who else has access to your data?
5.1 We will never sell your personal data. We will not share your personal data with any third parties without your prior consent ( which you are free to withhold) except where required to do so by law ( eg with port authorities for crew lists etc )or as set out in section 3 above or paragraph 5.2 below.
5.2 We may pass your personal data to third parties who are service providers, agents and sub contractors to us for the purpose of providing services to you on our behalf. However, we only disclose data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep your data secure and not to use it for their own purposes.
6. How long do we keep your information?
6.1 We will hold your personal data for as long as is necessary to meet our legal obligations. We will review your personal data every year whether we are still entitled to process it. If we decide that we are not entitled to do so we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment exercise or defence of legal claims.
6.2 We securely destroy all financial information once we have used it and no longer need it
7. Your rights
7.1 You have rights under the GDPR:
a) to access your personal data
b) to be provided with information about how your personal data is processed
c) to have your personal data corrected
d) to have your personal data erased in certain circumstances
e) to object to or restrict how your personal data is processed
f) to have your personal data transferred to yourself or to another business in certain circumstances
7.2 You have the right to take any complaints about how we process your personal data to the information commissioner
0303 123 1113
Information Commissioner’s Office Wycliffe House
Cheshire SK9 5AF
For further details please address any questions, comments and requests regarding our data processing practices to our Data Protection Manager at