Rockley Watersports Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.rockley.org (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
Means Rockley Watersports Limited, a limited company registered in England under company number 03722559, whose registered address is 6a Dover Road, Branksome Park, Poole, Dorset, BH13 6DZ, and whose main trading address is at 13 Parkstone Rd, Poole, Dorset BH15 2NN.
2. Information About Us
2.1 Our Website is owned by Us and operated by Us in conjunction with Fathom Communications.
2.2 Our VAT number is GB 730 2108 87
2.3 Our Data Protection Officer is Keiron Ranking and can be contacted by email at [email protected] by telephone on 01202 677272, or by post at 13Parkstone Road, Poole, Dorset BH15 2NN.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject of Ours, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as
explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to
lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office https://ico.org.uk or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.2 date of birth;
5.4 business/company/school name;
5.5 job title;
5.7 contact information such as email addresses and telephone numbers;
5.8 demographic information such as post code, preferences and interests;
5.9 financial information such as credit/debit card numbers.
5.10 Watersports experience
5.11 Medical information
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 and
GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it
is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account/booking;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our products or services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our products or services for you;
6.2.6 Replying to emails from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by [insert opt out method];
6.2.8 Market research and customer satisfaction purposes;
6.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or post and/or text with information, news and offers on Our products
or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and GDPR and
the Privacy and Electronic Communications (EC Directive) Regulations 2003, as applicable.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 On successful completion of your course or stay with Us your name, certificate number details and the date of issue will be stored for up to 7 years as recommended by the RYA. This information allows Us to verify or replace certificates if required. If you do not wish your details to be stored neither We nor the RYA will be able to replace or verify your certificate in the future.
6.5.2 For those who have subscribed to receive marketing information We will keep your details unless or until you withdraw your permission. This can be done at any time by contacting [email protected]
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored in the [UK] or [within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 A secure online database and booking system; and
7.4.2 Secure online storage of course information.
7.4.3 Secure storage for archived information for up to 7 years.
8. Do We Share Your Data?
8.1 Subject to section 8.2,We will not share any of your data with any third parties for any purposes, although in certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for
example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.2 We may share your data with other companies in Our group for marketing and administrative purposes.[A1]
8.3 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third
parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our
obligations, and the obligations of the third party under the law.
8.4 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any
anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used
within the bounds of the law.
8.5 The third-party data processors used by Us and listed below are all within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data
outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 or GDPR including:
8.5.1 We use Mailchimp to send e-newsletters on Our behalf, We gather statistics around the opening and clicks using industry standard technologies to Us to monitor and improve our e-newsletter updates. More information can be found on
Mailchimp’s privacy notice;
8.5.2 On successful completion of your RYA Instructor training, Powerboat Level 2 or to register you for the RYA Safe and Fun Safeguarding course your name, contact details, date of birth, certificate number and date of issue will be shared with
8.5.3 Our online booking system We use has been developed by Cinolla and all information is held securely online. For further information on how information is stored with Cinolla, please see their privacy notice at www.cinolla.co.uk[A2] .
8.6 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court
order, or a governmental authority.
9. How Can You Control Your Data?
9.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
9.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the
MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information
10.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
11. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at email@example.com, or using the contact details below in section 13.
provide and improve Our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
12.2 All Cookies used by and on Our Site are used in accordance with current Cookie Law https://www.aboutcookies.org/
12.3 Before Cookies are placed on your computer or device, you will be shown a prompt e.g. “pop-up” requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible
experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. [You will be given the opportunity to allow only first party Cookies and
block third party Cookies.]
12.4 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in clause 12 of this policy.5. Your consent will not be sought to place these Cookies, but
it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
12.5 The following first party Cookies may be placed on your computer or device:
Name of Cookie Purpose Strictly Necessary
_ga | Google Analytics - This performance cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.
_gat | Google Analytics - This is a performance cookie. It is used to throttle the request rate - limiting the collection of data on high traffic sites.
_gid | Google Analytics - This appears to be a new performance cookie and as of Spring 2017 no information is available from Google. It appears to store and update a unique value for each page visited.
CraftSessionId | Craft CMS - Craft relies on PHP sessions to maintain sessions across web requests. That is done via the PHP session cookie. Craft names that cookie “CraftSessionId” by default. This cookie will expire as soon as the session expires.
CRAFT_CSRF_TOKEN | Craft CMS - a cookie named CRAFT_CSRF_TOKEN will be created to facilitate CSRF protection.
Craft's default cookies | Craft CMS - For GDPR purposes, please note that Craft’s default cookies do not collect any personal or sensitive information. Craft's default cookies do not collect IP addresses. The information they store is not sent to anyone. Craft’s default cookies are only used to communicate the website's Craft CMS installation for the purposes of user authentication, form validation/security, and basic web application operations.
12.6 Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and/or services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
12.7 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
12.8 The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie First / Third Party Provider Purpose
_ga 3rd Google Used to distinguish users
_gid 3rd Google Used to throttle request rate. If Google Analytics
analytics is deployed via Google Tag Manager, this cookie will
be named _dc_gtm_<property-id>.
12.9 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default,
most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.10 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.11 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are
unsure about adjusting your privacy settings.
13. Responding to a Personal Data Breach
We have necessary processes in place should a breach accidently occur. These processes include;
13.1. The breach will be reported to the ICO within 72 hours of Us becoming aware of it
13.2. The case in such circumstances will be handled by Our Data Protection Officer, Keiron Ranking
13.3. We will inform the affected individual of the breach as soon as We become aware of it. We will notify them of;
a) the nature of the breach
b) details of Our Data Protection Officer
c) potential consequences of the data breach
d) appropriate measure taken to mitigate any possible adverse effects
13.4. All breaches will be documented even if they don't need to be reported
14. Contacting Us