Privacy Policy

By continuing to use our website, or by making a booking, you agree to the terms of the privacy policy, as set out below.

1. Introduction

Welcome to Caribbean Sail Training Limited ("CST," "we," "us," or "our"). We are committed to protecting the privacy of your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you visit our website, www.caribbean-sail.com (the "Site"), and when you use our services, including but not limited to sail training programs.

This policy is designed to comply with applicable privacy laws, including those in the United States (USA) and the United Kingdom (UK), such as the UK General Data Protection Regulation (UK GDPR) and relevant US federal and state privacy laws.

By using our Site and services, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

We may collect and process the following types of information:

• Personal Identification Information:
  • Full name, date of birth, nationality, gender.
  • Contact details (e.g., postal address, email address, telephone number).
  • Passport details, visa information, and other identification document details necessary for course registration, certification, and compliance with maritime regulations.
  • Next of kin / emergency contact information.
  • Photographs (for identification, certification, and, with consent, promotional purposes).
  • Payment information (e.g., credit/debit card details, bank account information) for processing course fees. This data is typically processed by a secure third-party payment processor and we do not store full payment card details.

• Training and Certification Information: 
  • Previous maritime experience and qualifications.
  • Course enrollment details, progress, assessment results, and attendance records.
  • Certificates of completion and other qualifications obtained.
  • Dietary requirements, medical conditions, or allergies relevant to your safety and well-being during training (collected with explicit consent where required).

• Usage Data (Collected Automatically): 
  • Information about your device and how you access and use our Site, such as your IP address, browser type, browser version, operating system, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

• Cookie Data: 
  • We use cookies and similar tracking technologies to track activity on our Site and hold certain information. Please see Section 9 (Cookies and Tracking Technologies) for more details.

3. How We Use Your Information

We use the collected information for various purposes, including:

• To provide and maintain our services, including processing your application, enrolling you in courses, and managing your training.
• To issue certificates of completion and liaise with certifying bodies.
• To communicate with you, including responding to your inquiries, sending you information about your courses, and providing customer support.
• To comply with our legal and regulatory obligations, including reporting to Maritime Administrations (see Section 5).
• To process payments for our services.
• To ensure the health, safety, and welfare of our students and staff.
• To improve our Site, services, and customer experience, including through analysis of usage data.
• For marketing and promotional purposes, where you have provided consent (e.g., sending newsletters, special offers). You can opt-out of marketing communications at any time.
• To maintain records as required by law and for our internal administrative purposes.
• To prevent and detect fraud or other malicious activities.

4. Legal Basis for Processing Personal Information (UK GDPR)

Under UK GDPR, we rely on the following legal bases for processing your personal data:

• Contract: Processing is necessary for the performance of a contract with you (e.g., to provide the training services you have enrolled for).

• Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject (e.g., reporting to maritime authorities, maintaining training records as required by regulations).

• Legitimate Interests: Processing is necessary for our legitimate interests (e.g., improving our services, preventing fraud, direct marketing where appropriate and not overridden by your rights), provided such processing does not outweigh your rights and freedoms.

• Consent: Where required by law, or for specific uses (e.g., certain marketing communications, processing of special categories of data like health information for safety), we will obtain your explicit consent. You have the right to withdraw your consent at any time.

• Vital Interests: In rare circumstances, we may need to process your personal information to protect your vital interests or those of another individual.

5. Data Sharing and Disclosure

We may share your personal information in the following circumstances:

• Our Staff and Contractors: Your personal information will be shared with our staff (including instructors, trainers, examiners, and moderators) and contractors (such as freelance instructors or support service providers) on a need-to-know basis for the purpose of organizing, administering, and delivering your training course, assessments, and related services. This includes providing them with necessary information before a course starts to facilitate preparation and effective delivery. All staff and contractors with access to personal data are bound by confidentiality obligations.

• Maritime Administrations: We are required to share certain personal information, training records, and certification details with relevant Maritime Administrations for regulatory, compliance, and certification purposes. These include, but are not limited to: 
  • The UK Maritime and Coastguard Agency (MCA)
  • The United States Coast Guard (USCG) (Note: We are required by USCG regulations to electronically submit student course completion data for USCG-approved courses.)
  • The Antigua and Barbuda Department of Marine Services (ADOMS)

• Certifying Bodies: We will share necessary personal information and course data with the relevant certifying body or bodies responsible for issuing your qualifications and for them to maintain records of certifications.

• Service Providers: We may share your information with third-party vendors and service providers who perform services on our behalf, such as payment processing, IT support, data analytics, email delivery, hosting services, and customer service. These providers are contractially obligated to protect your information and use it only for the purposes for which it was disclosed.

• Business Transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Legal Requirements: We may disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency), or to protect our rights, property, or safety, or that of our customers or others.

• With Your Consent: We may disclose your personal information for any other purpose with your explicit consent.

6. International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

If you are located in the UK or European Economic Area (EEA), this may mean that your data is transferred outside of these areas. When we transfer your personal data to countries outside the UK/EEA, we will ensure that appropriate safeguards are in place to protect your information in accordance with applicable data protection laws. These safeguards may include:

• Transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government or European Commission.
• Using Standard Contractual Clauses (SCCs) approved by the UK government or European Commission.
• Obtaining your explicit consent for the transfer, after informing you of the possible risks.
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Data shared with US authorities like the USCG is done so to comply with legal and regulatory obligations.

7. Data Retention

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The retention periods will vary depending on the type of information and the purposes for which it is used. For example:

• Training and certification records may be kept for an extended period as required by maritime regulations and certifying bodies.
• Information related to financial transactions is kept for as long as required by tax and accounting laws.
• Website usage data may be kept for a shorter period for analytical purposes.

Once the retention period expires, personal data shall be securely deleted or anonymized.

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include, but are not limited to, data encryption, access controls, secure servers, and regular security assessments.

However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies (e.g., web beacons, pixels) to collect and track information about your use of our Site and to improve and analyze our Service.

• What are Cookies? Cookies are small files placed on your device (computer or mobile device) when you visit a website.

• How We Use Cookies: 
  • Strictly Necessary Cookies: Essential for the operation of our Site, enabling basic functions like page navigation and access to secure areas. The Site cannot function properly without these cookies.

• Performance/Analytical Cookies: Allow us to recognize and count the number of visitors and see how visitors move around our Site. This helps us improve the way our Site works.

• Functionality Cookies: Used to recognize you when you return to our Site and remember your preferences (e.g., language or region).

• Targeting/Marketing Cookies: Record your visit to our Site, the pages you have visited, and the links you have followed. We may use this information to make our Site and advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose, where you have consented.

• Your Choices Regarding Cookies: 
  • Consent: When you first visit our Site from the UK or other jurisdictions requiring explicit consent for non-essential cookies, we will ask for your consent to place such cookies. You can withdraw your consent at any time through our cookie management tool or by adjusting your browser settings.
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  • Browser Settings: Most web browsers allow you to control cookies through their settings. You can set your browser to refuse all or some cookies or to alert you when cookies are being sent. However, if you disable or refuse cookies, please note that some parts of our Site may become inaccessible or not function properly.

• Opt-Out for US Residents (California): If our use of certain cookies is deemed a "sale" or "sharing" of personal information under California law, California residents have the right to opt-out. Please see Section 10 for more details on your rights.

A detailed list of cookies we use and the purposes for which we use them can be found in our separate Cookie Notice or through our cookie consent management platform.

10. Your Data Protection Rights

Depending on your location and applicable laws, you may have the following rights regarding your personal information:

• Right to be Informed: The right to be provided with clear, transparent, and easily understandable information about how we use your information and your rights.

• Right of Access: The right to request access to the personal information we hold about you and receive a copy of it.

• Right to Rectification: The right to request that we correct any inaccurate or incomplete personal information we hold about you.

• Right to Erasure (Right to be Forgotten): The right to request that we delete your personal information, under certain conditions (e.g., where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent).

• Right to Restrict Processing: The right to request that we restrict the processing of your personal information, under certain conditions (e.g., if you contest the accuracy of the data).

• Right to Data Portability: The right to request that we transfer the personal information we have collected about you to another organization, or directly to you, in a structured, commonly used, and machine-readable format, under certain conditions.

• Right to Object: The right to object to our processing of your personal information where we are relying on legitimate interests as our legal basis, or for direct marketing purposes.

• Rights Related to Automated Decision-Making and Profiling: The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (we currently do not engage in such activities).

• Right to Withdraw Consent: If we are relying on your consent to process your personal information, you have the right to withdraw that consent at any time.

• Right to Opt-Out of Sale or Sharing (for California Residents under CCPA/CPRA): California residents have the right to opt-out of the "sale" or "sharing" of their personal information. While CST does not "sell" personal information in the traditional sense for monetary gain, certain uses of cookies for analytics or targeted advertising may be considered "sharing" under the CCPA/CPRA. If applicable, we will provide a "Do Not Sell or Share My Personal Information" link or mechanism.

• Right to Non-Discrimination (for California Residents): We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise any of these rights, please contact us using the contact details provided in Section 14. We may need to verify your identity before responding to your request. We will respond to your request within the timeframes required by applicable law.

11. Children's Privacy

Our Site and services are not intended for individuals under the age of 16, unless they are enrolling in a course with appropriate parental or guardian consent. We do not knowingly collect personally identifiable information from children under 16 without such consent. If you are a parent or guardian and you are aware that your child has provided us with personal data without your consent, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we will take steps to remove that information from our servers. 

For specific courses open to minors, we will provide clear information on data collection and obtain necessary consents.

US Residents: We comply with the Children's Online Privacy Protection Act (COPPA) for any data collected from children under 13.

12. Links to Other Websites

Our Site may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14. Contact Us

If you have any questions about this Privacy Policy, our data practices, or if you wish to exercise any of your data protection rights, please contact us on info"caribbean-sail.com

If you are in the UK and have a concern about our use of your information, you also have the right to lodge a complaint with the Information Commissioner's Office (ICO), which is the UK's supervisory authority for data protection issues (www.ico.org.uk) We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.