This Privacy Policy defines the law which governs how we collect and treat your data; it explains the types of personal data we may collect about you when you interact with us. This policy outlines when and why we collect that data and how we keep it safe. This policy will be updated from time to time.

Overview

• Kindred Spirit Sailing has never, and will never, share or sell your details to third party companies for marketing purposes

• We do work with the RYA, other training providers and other relevant third-party providers; if you interact with our website and choose to make payment online via the Stripe application on our website, some of your data is shared with these providers.  Below we describe how and why we share data

• Your consent is required to join our mailing list. You can opt out of receiving our news and updates at any point in time. See the section, ‘Your Legal Rights’ below

• If you have any questions about anything covered in the policy, please contact us at ruthbaverstock@hotmail.com

• If you are unhappy with the way we have treated your data or responded to your data request it is your right to make a complaint to the Information Commissioner’s Office (ICO), who are the UK’s independent authority to uphold information rights www.ico.org.uk/concerns/ or 0303 123 1113

The Data Protection Act 2018 and UK GDPR
The Data Protection Act 2018 (DPA 2018) sets out the framework for data protection law in the UK. It replaces the DPA 1998 and sits alongside the General Data Protection Regulation (EU) 2016/679 (GDPR), tailoring how the GDPR applies in the UK. The DPA 2018 came into effect on 25 May 2018, the same date the GDPR came into effect. The GDPR sets out the key principles, rights and obligations for processing personal data. The GDPR continues to remain in force in a post-Brexit UK, as it forms part of the UK Law under the European Union (Withdrawal) Act 2018. 

When we collect your data
Kindred Spirit Sailing collects your personal data when you:

• Visit our website,

• Book on a sailing event

• Purchase an event via the Stripe application on our website

• Engage with us on social media

• Sign up to receive news and offers from us

• Contact us with a query or complaint

• Give us feedback or a review on our products or customer services

If you are an instructor or skipper, we ask to see copies of your qualifications and certificates to ensure you have the correct credentials to run a course or event on our behalf.

The types of data we collect
Kindred Spirit Sailing collects the following types of data:

Personal data

‘Personal data’ is data that includes information relating to natural persons, which when combined with the name of a person, makes them identifiable. Kindred Spirit Sailing collects the following types of personal data, depending on how you interact with us:

• Your address, email address and telephone numbers

• Name and contact details for an emergency contact

• Your payment records

• Your comments and feedback

• Your preferences in receiving marketing from us and your communication preferences

• If required, your bank details for making a refund or for making payment to an instructor or skipper working with us

• As above, certificates and qualifications for instructors and skippers who wish to work with us. 

Special category data
‘Special category’ data is personal data which requires additional protection because it is more sensitive. The UK GDPR singles out 9 types of personal data which is likely to be more sensitive, of these 9 groups, Kindred Spirit Sailing only collects the following special category data:

• Data concerning health - health information we need to be aware of when you sail with us

• Data which may reveal religious or philosophical beliefs – dietary requirements provided by you to ensure we can cater for your needs while you sail with us. 

Legal basis for processing data
The principle of accountability in the UK GDPR requires every organisation that processes data to be able to demonstrate that they are complying with UK GDPR and have appropriate policies and processes. This includes being able to demonstrate that an organisation is processing data lawfully and so has properly considered which 'lawful basis' applies to each processing purpose, and this decision can be justified. 

Kindred Spirit Sailing processes data on the following legal basis:

Personal data

• Consent: In specific situations, we can collect and process your data with your consent, for example, when you complete and return a booking form, agreeing to our Terms and Conditions and tick a box to receive email newsletters

• Contractual obligations:  We need your personal data to comply with our contractual obligations, for example, if you book onto an event, we require your data to enable us to provide your sailing event 

• Legitimate interest: In specific situations, we need your personal data to pursue your and our legitimate interests in the usual way that would reasonably be expected as part of running a sailing business and which does not materially impact your rights, freedom or interests. We will also analyse your sailing experience and interests to identify potential needs and send you marketing information, telling you about courses, sailing events and other items of potential interest. If you no longer wish to hear from us, you can unsubscribe from our mailing list at any time. If you are an instructor or skipper who would like to work with us, we process your personal data in the form of your certificates and qualifications on the basis that it is in the legitimate interest of both parties to confirm that you are suitably qualified to work with us. 

Special category data
UK GDPR requires an additional ‘condition’ in conjunction with the legal basis for an organisation to process special category data. Kindred Spirit Sailing processes special category data on the basis that explicit consent has been provided when you complete and return your health declaration form and booking form. 

How we protect your personal data:

Data security and sharing data

Our customers’ data security is very important to us. We treat your data with the utmost care and take all appropriate steps to protect it. 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 instruction, and they are subject to a duty of confidentiality.

We will notify you and the ICO of a data breach where we are legally required to do so.

There are instances where your data is shared with a third party: 

SquareSpace
When you visit the Kindred Spirit Sailing website some of your personal data, such as your IP address, information about your browser, your preferences and the address of the site you visited before the Kindred Spirit Sailing website may be captured via the use of website cookies. Some of this information is shared with SquareSpace to enable them to protect and improve their service through analysis of our customers use of our website. The data shared with SquareSpace is done so via cookies and is anonymised, pseudonymised, de-personalised and aggregated form. More information about the data shared with SquareSpace and how this is used can be found in the SquareSpace Privacy Policy here.

SquareSpace transfer data outside of the UK to their servers in the US. The methods they use for the transfer of data are in accordance with the GDPR. SquareSpace retain personal data regarding you or your use of the Kindred Spirit Sailing website for as long as needed to provide you and Kindred Spirit Sailing with their services. SquareSpace also retain data to comply with legal obligations. Details of the methods used for the transfer of data and the retention of data by SquareSpace can be found here.

Stripe
If you choose to make payment for your course or event via the online payment application Stripe, your data, such as your name, address and bank card details will be shared with Stripe. More information about the data shared with Stripe and how this is used can be found here. This link also contains information about the cookies used by Stripe. 

Stripe transfers data outside the European Economic Area (EEA) including to the US. Stripe retains data for as long as Stripe are providing services and after the services have been provided to comply with legal and regulatory obligations. More information on how Stripe transfers and retains data can be found here. 

Mailchimp
If you sign up to receive our newsletters your name and email address will be added to MailChimp, the third-party application we use to generate our newsletters and other email updates.  You can opt out of receiving our email updates at any time by clicking the ‘unsubscribe’ option at the bottom of each email. Once clicked, your data will be automatically deleted from our mailing list and you will no longer receive our updates. Alternatively, you can contact us directly at ruthbaverstock@hotmail.com and we will manually delete your details from our mailing list. 

MailChimp use cookies and similar technology to collect information about how you interact with our email updates as part of their service, for example web beacons are placed in every email sent by Kindred Spirit Sailing from MailChimp and record your email address, IP address, date and time associated with opening our email. More information about the MailChimp use of cookies can be found here. 

MailChimp are based in the US and your data may be transferred to their US servers. More information on how MailChimp transfers data can be found can be found in their Privacy Policy here. 

Kindred Spirit Sailing Data retention and deletion
When we have collected and processed your personal data, we will keep it only for as long as is necessary for the purpose for which it was collected.

Special category data
All special category data is deleted as soon as practicably possible and no later than three months after the completion of a practical course or sailing event. This data includes any health information that you may have provided to us, along with dietary requirements and details of an emergency contact. 

Third party data retention and deletion
Please refer to the links above for details on a third-party data retention and deletion policies. 

Data retention:

Kindred Spirit Sailing website and the use of cookies
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are used to enable a website or associated services to work, to work more efficiently and to provide analytics and reporting information. 

When you visit the Kindred Spirit Sailing website, we may record your IP address and use cookies and other similar technologies such as web beacons to gather general information about visitors to the site, to determine which pages on our site are being visited and topics that may be of interest so we can provide you with information about relevant products and services.

These tools collect certain standard information that your browser sends to our website, such as your browser type and language, access times and the address of the website from which you arrived at the website. 

More details about the cookies we use on our site, refer to our Cookie Policy, available here. 

For third-party uses of cookies, please refer to the section ‘Data Security and sharing data’ above.

Links to other websites
The Kindred Spirit Sailing website may contain links to other websites of interest. Once you have used the links and leave our site, we do not have any control over the other website and therefore cannot be responsible for the protection and privacy of any information you provide while visiting these sites. These sites are not governed by this Privacy Policy.

Your legal rights
The UK GDPR provides the following rights for individuals:

• To request access to or a copy of your personal data that we hold

• To request the rectification of your personal data when incorrect, out of date or incomplete

• To withdraw your consent (or to object) to us holding your data where we have no legitimate overriding interest or once the purpose for which we hold the data has come to an end 

• Request that your data be deleted. Please note that if you request your data is deleted before your course or event takes place, we will be unable to continue your booking with us as we will be unable to fulfil our obligations as outlined in our Terms and Conditions

• Request the transfer of your personal data

• Ask that we stop any consent-based processing of your personal data (for example where you opt-out of receiving email marketing from us). You can change your ‘marketing preferences’, by following the ‘unsubscribe’ link at the base of all our newsletter communications. Any other requests should be emailed to info@equinoxsailing.com

We will seek to respond to any request within one calendar month. If you feel that your data hasn’t been handled correctly or you are unhappy about our response to any requests you have made about the use of your personal data, please let us know. You also have the right to lodge a complaint with the Information Commissioner’s Office.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

www.ico.org.uk/concerns/  

0303 123 1113

Changes to the Policy and Enquiries
Kindred Spirit Sailing may update and/or make changes to this policy by updating this page.  Kindred Spirit Sailing encourages you to periodically review this statement to remain informed of how Kindred Spirit Sailing is protecting your data.  This policy was last updated on 26 January 2024.

If you have any questions about this privacy policy or if you wish to confirm the information, we hold about you, please contact us at ruthbaverstock@hotmail.com.