Offshore Sailing School, Ltd, Inc. Privacy Statement

Updated 2023

Offshore Sailing School respects your privacy and is committed to protecting your personal data.

1. Introduction

This privacy policy tells you how Offshore Sailing School uses your personal data when you visit our website, interact with us, and buy our goods and services.

It also tells you about your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.

This privacy policy was last updated on June 21, 2023.

If you have any questions, or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See How to contact Offshore Sailing School about privacy below.

2. Offshore Sailing School’s Websites

Our websites at OffshoreSailing.com and Colgate26.com sell sailing certification course packages and special sailing activities, Colgate Sailing Adventures, and Colgate 26 sailboats which are aimed at sailing intenders, meeting and event planners, and boat buyers. This website is not intended for children and we do not knowingly collect data relating to children.

Offshore Sailing School is one legal entity:

  • Offshore Sailing School Ltd., Inc. located at 6338 Presidential Court, Suite 201, Ft. Myers, FL 33919.

Offshore Sailing School is the data controller responsible for this website and any handling of personal data carried out by or on behalf of the company.

Offshore Sailing School brings sailing courses, events and sailboats goods and services to its customers all over the world, and we may sometimes be acting as joint data controllers.

3. Personal Data Which We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect a variety of information about our customers and visitors to Offshore Sailing School’s and Colgate 26 websites. This personal data falls into these categories:

Identity Data includes title, first name, last name. If you interact with us through social media, this may include your social media user name.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Profile Data includes purchases or orders made by you, preferences, feedback and survey responses.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access websites.

Usage Data includes information about how you use our websites, products and services.

Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.

Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. To provide better content and service, Offshore Sailing School’s website uses the Google web analytics service. Google Analytics does not track your browsing habits across other third-party websites and all information about you which reaches google analytics. Please see Google Analytics’ privacy policy.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.

4. How is Your Personal Data Collected?

We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or through chat or social media.

This includes personal data you provide when you:

  • Sign up to receive Offshore Sailing School’s newsletter;
  • Make inquiries or request information be sent to you;
  • Order our products or services;
  • Ask that marketing messages and material are sent to you;
  • Engage with us on social media;
  • Enter a competition, promotion or survey;
  • Contact sales, marketing, operations, financial, management, customer services; or
  • Leave comments or reviews on our products or services.

Automated technologies or interactions. As you interact with us, including via the OffshoreSailing.com or Colgate26.com websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our advertisements (including those shown on third party websites).

Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:

  • Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
  • Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
  • Identity and Contact Data from data partners; and
  • Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites. 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.

5. How We Use Your Personal Data

  • Where we need to perform the contract Terms & Conditions we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the purchasing process, or when reviewing reports following your completion of a Personality Index before being hired to work for Offshore Sailing School.
  • Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.

See Explaining the legal bases we rely on to process personal data to find out more about the types of lawful basis that we will rely on to process your personal data.

6. Explaining the Legal Basis We Rely On to Process Personal Data

The table as an addendum to our Privacy Policy shows you a description of all the ways we plan to use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

We do not carry out any automated decision making.

If you ever have any questions about this, contact us. See How to contact Offshore Sailing School about privacy below.

7. Advertising, Marketing and Your Communications Preferences

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing.

We may carry out direct marketing by email, phone, text or post. For example, you might have Offshore Sailing School or Colgate 26 newsletters hit your inbox, voicemail, or a cool promotion land in your mailbox.

On our websites, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up for Offshore Sailing School or Colgate 26 newsletters or as part of the purchasing process. You have a right at any time to change your mind and say no thank you and opt out of our communications. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.

Of course, there are lots of different ways you’ll see advertisements for Offshore Sailing School and Colgate 26, and not all of these are based on using personal data – sometimes we just buy advertising space in different mediums, and websites and social media. If you see Offshore Sailing School’s advertisements on websites and in social media, these may not be directed specifically at you, we might have bid for the space. But here’s some things we may do that may be specifically directed at you:

  • Emails, for example Offshore Sailing School or Colgate 26 newsletters;
  • Text messages, for example with discount codes;
  • Promotions by post, such as great money off offer from us, and/or
  • Phone calls, to tell you something that might be relevant to you.

We use Zoho CRM software to manage our prospect, customer, supplier, partner, vendor database. Read Zoho’s Privacy Policy here.

We also work with partners to try and promote the reach of our advertisements and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media.

Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new customers of Offshore Sailing School. The cookies used for this purpose are often placed on our website by specialist organizations – and this is also why when you’ve been on the offshoresailing.com or colgate26.com website, you might see that sailing course, activity or sailboat again. This includes retargeting.

Cookies can also tell us if you have seen a specific advertisement, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our advertisements and control the number of times people might be shown our advertisements). Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.

If you want more information about Tracking Data, in particular cookies, see Cookies below.

Almost all the cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which advertisements you see online, see opt-out programs established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.

8. Cookies

You can see from Advertising, marketing and your communications preferences above, that cookies are a tool which we (and everyone else who operates online) uses for advertising. That is just part of why cookies are used.

Cookies help offshoresailing.com and colgate26.com work better and provide lots of help in the background to make the process of being an Offshore Sailing School prospect, customer, partner, vendor, supplier a lot easier.

Other cookies collect information about how visitors use offshoresailing.com and colgate26.com, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how offshoresailing.com and colgate26.com work.

There are also cookies that allow offshoresailing.com and colgate26.com to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.

There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

When you use offshoresailing.com or colgate26.com, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It’s important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

9. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.

We may share personal data with the following categories third parties:

  • Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
  • Offshore Sailing School;
  • auditors and professional advisers like bankers, lawyers, accountants and insurers; and
  • Government, regulators and law enforcement.

We share personal data with the following specific third parties:

  • Microsoft Office 365 and Outlook, the Cloud, Zoho, Adventure Office software for online reservation system, Verizon phone system. We retrieve and share your data with Zoho CRM software systems to send our direct marketing campaigns to prospective and current customers, and Colgate 26 purchasers and prospects. Please see Zoho’s privacy policy.

We also share data with third parties connected to advertising, retargeting and analytics.

We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

10. Payment Information

Offshore Sailing School uses third party payment processors Authorize.net and PayPal to process payments made for products and services made via the Website, over the phone, or in-person. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your or our browser to these payment processors.

For Authorize.net Payments, if on the payment page you have requested that your card details be remembered and the payment was successful, Adventure Office and authorize.net stores the card type, a Masked PAN (only the first 6 and last 4 digits) and the card’s expiry date as well as an associated token. We store this information so that you and we can identify your stored card and use it for further payments at Offshore Sailing School or Colgate 26. This stored information can be deleted per your request. We also store separately the last 4 digits and card type so that we can identify transactions made by a particular card.

For PayPal we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.

11. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, 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 instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

12. Third-party Links

These websites may include links to third-party websites, plug-ins and applications (for example, the ability to sign in with Facebook). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

13. Data Retention

We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.

We also make a promise to you that you can come back at any time in the future and enroll in Offshore Sailing School courses or purchase a new or used Colgate 26 sailboat. So, unless you actively delete this information, we keep it, so we can keep our promise to you.

In some circumstances you can ask us to delete your data; see Your Legal Rights below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

14. Your Legal Rights

If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:

  • The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing in this privacy policy);
  • The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
  • The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
  • The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
  • The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
  • The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
  • The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
  • Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.

These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.

If you wish to exercise any of the rights set out above, please contact us (see How to contact Offshore Sailing School about privacy).

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.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one week. Occasionally it may take us longer than a week if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Our Director of Marketing is also appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details in How to contact Offshore Sailing School about privacy below.

15. How to Contact Offshore Sailing School About Privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at Sail@OffshoreSailing.com or write to us with your letter addressed to: Director of Marketing, Offshore Sailing School, 6338 Presidential Court, Suite 201, Fort Myers, Florida, 33919.

If you need help about our products and services, or this website generally, please contact us here.

16. A Request from Offshore Sailing School to You

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can do this by contacting us here. Thank you.

17. Changes to this Privacy Policy

This Privacy Policy update was in affect starting May 25, 2018 and only minor changes were made on June 20, 2023. The General Data Protection Regulation was new at the time and the ICO was still issuing new bits of guidance about how businesses should follow it. So, you may see updates to our Privacy Policy over the coming months. Be sure to review this Privacy Policy now and then. Thank you.

If you have any questions, please contact Offshore Sailing School at 800-221-4326, 239-454-1700 or email Sail@OffshoreSailing.com.

© Offshore Sailing School Ltd., Inc. 2023

Offshore Sailing School, Ltd., Inc.
Attention: Director of Marketing
Offshore Sailing School
6338 Presidential Court, Suite 201
Fort Myers, Florida 33919

Offshore Sailing School, Ltd., Inc. will use commercially reasonable efforts to promptly respond and resolve any problem or question.