Date of last revision: 17 January 2022

Footloose Sailing Adventures LLP is committed to protecting and respecting your privacy. We want you to understand how we collect and use information about you.

The privacy notice describes to you:

• Who we are
• What personal data we collect and store about you, and how we collect it
• Why we collect personal data and what we do with it
• The categories of third parties with whom we share your personal data
• How we retain your information and keep it secure
• Your rights and how to exercise them
• How to contact us

1. Who are we?

For the purposes of data protection law, the “controller” is Footloose Sailing Adventures LLP, a company incorporated and registered in England and Wales under company number OC440664 and having its registered office address The Old Chapel, Marsh Road, Upton, Norfolk, NR13 6BS United Kingdom (from now on referred to as “Footloose Sailing Adventures”, or as “we” and related words such as “us” and “our”).

As controller we are responsible for, and control the processing of, your personal data. We are registered as a data controller with the Information Commissioner’s Office, which is the UK’s supervisory authority for data protection matters.

If you would like to contact us about this notice, including if you wish to receive further information about any aspect of it, our details are as follows:

E-mail :
Ian@footloosesailing.com

Post :
Footloose Sailing Adventures, The Old Chapel, Marsh Road, Upton, Norfolk, NR13 6BS

2. What information do we collect from you?

In the course of our business, which is the sale of, Adventure Sailing holidays and events. We collect the following personal data when you provide it to us:

personal details, such as

• name and title
• username
• gender
• date of birth

contact data, such as

• address
• e-mail address
• telephone and mobile number(s)

biographical data from job applications and CVs, such as

• institutions attended
• academic and other results gained
• employment history
• any other personal information you provide

payment card details

transaction data, such as

• details about payments to and from you
• details of products and services you have purchased from us

technical data, such as

• internet protocol (IP) address

usage data, such as

• information about how you use our website, products, and services

marketing data, such as

• your preferences in receiving marketing and communications.

We do not knowingly collect “special category” personal data. This is a special type of sensitive data to which more stringent processing conditions apply, and comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and/or biometric data.

We also do not collect information about criminal convictions or offences.

3. How do we collect personal data?

We obtain personal data from sources as follows:

directly from you when you interact with us, for example when you

• buy our products
• sign up to our mailing lists
• request information
• write to us
• phone one of our team
• enter a competition
• take part in a survey
• give us feedback or post comments or reviews
• apply for a job or send a CV

from customers if they provide your details in relation to an order: if you are providing another person’s details, please ensure you have that person’s explicit consent to do so

from automated technologies such as cookies and tags when you use our website – for more information, please see our cookies notice to find out more

4. How do we use your personal data?

Introduction

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

to perform a contract, we are about to enter or have entered with you
if it is necessary for our legitimate interests (or those of a third party) and these are not overridden by your own rights and interests where we need to comply with a legal or regulatory obligation.

Lawful processing
In order to process personal data, we must have a lawful reason (sometimes called a lawful basis). We always ensure that this is the case, and we set out our lawful bases below – but please note that more than one may apply at any given time: for example, if we inform you of changes to our privacy notice, we may process your personal data on the ground of complying with law and on the ground of legitimate interests.

We will use your personal data only for the purposes for which we collected it, unless we fairly consider that we need it for another reason that is compatible with the original purpose.

Please contact us if you would like more information on this, and on situations in which more than one lawful basis applies.

Contractual Necessity

If you are our customer or applying for a job, we will process your personal data for the following purposes, on the legal basis that it is necessary for us to provide our products and services to you:

• to enable us to carry out our services
• to identify you
• to respond to your inquiries
• to the extent necessary to provide you with information you have requested in relation to our products and services before you decide to purchase them
• to provide our products and services, including enabling them to be delivered to you and contacting you about your order (for example, regarding stock or availability)
• to carry out billing and administration activities, including refunds and credits
• to evaluate your job application and take any next steps, and to evaluate your suitability for roles where you have asked to be considered for future opportunities.

Of course, you are not obliged to provide us with any of this information, but if you chose not to, we may be unable to provide the product or service that you have requested.

Legitimate Interests

We process your personal information for our legitimate business purposes, which include the following:

• to conduct and manage our business
• to ensure our website and systems are secure (for example, by conducting security penetration tests on our website to ensure our security tools are effective)
• to personalise your web experience – for example, by tailoring our products and offers to you
• to allow you to review a product you have purchased
• to analyse, improve and update our services for the benefit of our customers
• to deal with complaints
• where you have made a purchase from us, to let you know about our products, services, promotions, or events that we consider may be of interest to you (and which may be tailored to your interests as construed from your purchase history). We do this only where you have provided us with a preferred means of contact for this purpose. We carry out this processing on the legal basis that we have a legitimate interest in marketing our products and services, and only to the extent that we are permitted to do so by applicable direct marketing laws. You can opt out of receiving this information by unsubscribing from our emails, or by contacting us as set out in Section 1 above.

Whenever we process your personal data for these purposes, we ensure that your interests, rights and freedoms are carefully considered.

Compliance with laws

We may process your personal data in order to comply with applicable laws (for example, if we are required to co-operate with an investigation pursuant to a court order).
Consent

If you have never purchased from us or have not purchased from us for a long time, but have given us your explicit consent to hear from us about our products, services, promotions or events that we consider may be of interest to you, we will contact you by post or email (according to the contact preference you have provided). You have the right to withdraw consent to marketing at any time.

5. Do we share your personal data?

We may provide your personal data to the following recipients for the purposes set out in this notice:

• our service providers, including

logistics providers, such as those who deliver our orders
e-mail and mail service providers
technical and support partners, such as the companies who host our website and who provide technical support and back-up services

• law enforcement agencies, government or public agencies or officials, regulators, and any other person or entity that has the appropriate legal authority where we are legally required or permitted to do so, to respond to claims, or to protect our rights, interests, privacy, property or safety

• any other parties, where we have your specific consent to do so.

6. Do you have to provide personal data – and, if so, why?

To form a contract with you, we will need some or all of the personal data described above so that we can perform that contract or the steps that lead up to it: this is set out above in this notice. If we do not receive the data, the contract could not be performed.

If you sign up to our mailing list, you will have to provide certain personal data. Of course, you may decide to stop receiving our mailings at any time.

7. How long will your personal data will be kept for?

We carefully consider the personal data that we store, and we will not keep your information in a form that identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law. In some instances, we are required to hold data for minimum periods: for example, UK tax law currently specifies a six-year period for retention of some of your personal data.

8. Do we transfer personal data outside the EEA?

Although we are based in England, we may transfer your personal information to a location (for example, to a secure server) outside the European Economic Area, if we consider it necessary or desirable for the purposes set out in this notice.

In such cases, to safeguard your privacy rights, transfers will be made to recipients to which a European Commission “adequacy decision” applies (this is a decision from the European Commission confirming that adequate safeguards are in place in that location for the protection of personal data), or will be

carried out under standard contractual clauses that have been approved by the European Commission as providing appropriate safeguards for international personal data transfers, or by the adoption of EU-US Privacy Shield.

9. How do we keep your personal data secure?

Footloose Sailing Adventures has security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only authorised Sail & Power Boat Training Ltd employees and third parties processing data on our behalf have access to your personal data.

All Footloose Sailing Adventures partners who have access to your personal data are required to adhere to the Footloose Sailing Adventures Privacy Notice and we have in place contractual safeguards with our third-party data processors to ensure that your personal data is processed only as instructed by Footloose Sailing Adventures.

The security measures we have in place include:

• regular reviews of information collection, storage and processing practices to protect against unauthorised access
  restriction of access to personal information
• monitoring of systems storing and processing information
• use of secure technologies (e.g. SSL, encryption)
• scenario planning and crisis-management exercises to ensure we are ready to respond to cyber security attacks and data security incidents.

We take all reasonable steps to keep your data safe and secure and to ensure the data is accessed only by those who have a legitimate interest to do so. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us. Any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Please contact us using the details in section 1 of this notice if you would like more information about this.

10. Your information rights

We draw your attention to your following rights under data protection law:

• • right to be informed about the collection and use of your personal data
  • right of access to your personal data, and the right to request a copy of the information that we hold about you and supplementary details about that information – you will be asked to provide proof of your identify and residential address, and we may ask you to provide further details to assist us in the provision of such information
  • right to have inaccurate personal data that we process about you rectified – we want to ensure that the personal information that we process and retain about you is accurate, so please do remember to tell us about any changes, for example if you have moved house or changed your contact details. It is your responsibility to ensure you submit true, accurate, and complete information to us; please also update us in the event this information changes.
  • right of erasure – in certain circumstances you have the right to have personal data that we process about you blocked, erased or destroyed
  • the right to object to, or restrict:

processing of personal data concerning you for direct marketing decisions being taken by automated means which produce legal effects concerning you or that similarly significantly affect you in certain other situations, to our continued processing of your personal data

• the right of portability of your data in certain circumstances.

You will not 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Please contact us using the details in section 1 of this notice if you would like to exercise any of these rights or know more about them.
These rights are subject to certain limitations that exist in law. Further information about your information rights is available on the ICO’s website: https://ico.org.uk/.

11. Cookies

Our website uses cookies. For more information on which cookies we use and how we use them, please see our cookies notice.

If you still would like to remove cookies, you can do this by Revoke cookies

12. Changes to this privacy notice

We may change this notice from time to time. You should check this notice on our website occasionally, in order to ensure you are aware of the most recent version.

13. What should you do if you have a complaint?

We hope that you will be satisfied with the way in which we approach and use your personal data.
Should you find it necessary, you have a right to raise a concern with the information regulator, the Information Commissioner’s Office: https://ico.org.uk/.
However, we do hope that if you have a complaint about the way we handle your personal data, you will contact us in the first instance using the contact details in section 1 above, so that we have an opportunity to resolve it.

END OF PRIVACY NOTICE