1. General information
This Privacy Policy sets out the rules governing the processing of personal data and the use of cookies on the sailwith.pro website (hereinafter: the “Portal” or the “Website”).
The Controller takes particular care to protect users’ privacy and the security of the personal data processed. To this end, appropriate technical and organisational measures are implemented to ensure the protection of data against loss, unauthorised access or disclosure.
Data processing is carried out in accordance with applicable legal provisions, in particular:
· Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR),
· the Act of 18 July 2002 on the provision of electronic services,
· the Act of 16 July 2004 – Telecommunications Law
The processing of personal data on the www.sailwith.pro website takes place primarily, in accordance with Article 6 of the GDPR, on the following legal bases:
Article 6(1)(a) of the GDPR – user consent
· in particular in the case of sending newsletters, marketing offers and the use of marketing and retargeting cookies.
Article 6(1)(b) of the GDPR – performance of a contract
· creation and management of a user account, logging in, use of the portal’s functions, making bookings, communication within the scope of services.
Article 6(1)(c) of the GDPR – legal obligation
· the transfer of data to public authorities or financial institutions to the extent required by law, including for the purposes of accounting and combating crime or fraud.
Article 6(1)(f) of the GDPR – legitimate interests of the controller
· ensuring the security of the website, traffic diagnostics and analysis, content moderation, handling enquiries and complaints, personalisation of content and marketing offers (where this is based on a legitimate interest and the user has not objected).
2. Data controller
The data controller is:
with.pro Sp. z o.o., with its registered office in Olsztyn, ul. Stalowa 7,
10-420 Olsztyn, registered with the District Court in Olsztyn,
8th Commercial Division of the National Court Register; KRS: 0001211035 NIP: 7394025970 REGON: 543481826
The controller can be contacted at the following email address: office@sailwith.pro
3. Definitions
For the purposes of this Policy, the following definitions apply:
User – A User within the meaning of this Privacy Policy is any person using the Portal/Website, whether registered or unregistered, logged in or not logged in.
Personal data – information relating to an identified or identifiable natural person.
Cookies – small text files stored on the user’s device by the Website’s server.
IP address – a unique number assigned to a device connected to the Internet.
System log – a record of information about events related to the use of the server.
SSL – a protocol for encrypting data transmission between the user and the server.
4. What data do we collect and for what purpose
4.1 Registration data
Scope of data:
· email address
· first name and surname
· photo
· username
· account type (Private Individual / Business User – sailing school / company)
· analytical data
Purpose of processing:
· creation and management of the user account
· enabling login
· use of the portal’s features
· making bookings
· communication and sending messages
Retention period: until the user deletes the account.
4.2 Data published in advertisements
Scope of data:
· advertisement description
· photographs
· contact details provided in the advertisement (e.g. telephone number, email address)
Purpose of processing:
· enabling the publication of advertisements
· communication between users
Retention period: until the advertisement or user account is deleted.
4.3 Public profile data
Scope of data:
· first name and surname and/or nickname
· avatar/photo
· profile description
Purpose: to display the profile within the portal’s community.
All profile data is determined by the portal user.
4.4 Chat data
Scope of data:
· the content of messages between users
Purpose: to enable communication between users.
Retention period: 4 months from the date the message was sent, amongst other periods.
4.5 Ratings and comments
Scope of data:
· a rating on a scale of 1–5
· comment content
Purpose: to build community credibility and moderate the website.
4.6 Data in enquiries and communications
Scope of data:
· first name and surname
· email address
· content of the enquiry
Purpose: to handle enquiries, complaints and contact with the user.
4.7 Technical data and server logs
When using the Portal, technical data may be collected automatically, in particular:
· device IP address
· date and time of the request
· URL of the page visited
· referring page address (referrer)
· browser type
· operating system
· server response code
· error information
This data is used for the following purposes:
· ensuring system security
· technical diagnostics
· analysing traffic on the Website
· analytical purposes
4.8 Payment data
When making payments, data may be transferred to payment operators and financial institutions
4.9 Marketing and communication
Data may be used for:
· sending newsletters
· offers and promotions
· information about services
4.10 Data relating to rental/charter
Scope of data:
· email address
· first name and surname
· residential address
· ID card number or passport number
· sailing licence details
· PESEL number
Purpose: data processing and the provision of boat booking agency services (charter)
5. Data retention period
Data is retained for the period necessary to fulfil the purposes of processing, in particular:
· account data – for the duration of the account
· chat messages – 4 months
· report data – until the matter is resolved and for the limitation period of claims
· accounting data – in accordance with legal provisions
Inactive accounts may be deleted after 36 months of inactivity.
6. Data recipients
Data may be transferred to:
6.1 Data processors, e.g.:
· hosting providers
· cloud service providers
· analytics tool providers
· email service providers
These entities process data solely on the basis of a data processing agreement.
6.2 Other portal users
in respect of data voluntarily published by the user.
6.3 Public authorities
where required by applicable law.
6.4 Business partners
7. Transfer of data outside the EEA
Some of the services used on the Portal may involve the transfer of data outside the European Economic Area.
In such cases, appropriate legal safeguards are in place, in particular:
· the European Commission’s standard contractual clauses,
· other mechanisms compliant with the GDPR.
8. Your rights
You have the following rights:
· the right of access to data
· the right to rectification
· the right to erasure
· the right to restriction of processing
· the right to data portability
· the right to object to processing
· the right to withdraw consent
· the right to lodge a complaint
To exercise your rights, please contact the controller: office@sailwith.pro
9. Automated decision-making
Users’ data is not used for automated decision-making that produces legal effects concerning the user.
The controller may use statistical analysis and analytical tools to improve the functioning of the Portal.
10. Data security
The controller implements technical and organisational measures to ensure an appropriate level of protection for personal data, in particular:
· access control to systems
· server infrastructure security
· regular software updates
11. Cookies
This website uses cookies. Cookies may be set by the Website Administrator or by third parties.
Cookies are used for the following purposes:
· to ensure the website functions correctly
· to maintain the user’s session
· to remember the user’s preferences
· to analyse website traffic statistics
Types of cookies
The following types of cookies may be used on the website:
· session cookies – deleted when the browser is closed
· persistent cookies – stored for a specified period
· essential cookies – enabling the Portal to function correctly
· analytical cookies – used to analyse how the website is used
· functional cookies – remembering user preferences
· marketing cookies
Managing cookies
You can change your cookie settings in your browser, in particular:
· block the storage of cookies
· delete stored cookies
· set notifications regarding the storage of cookies
Disabling certain cookies may limit the functionality of the website.
12. Links to external websites
The website may contain links to other websites.
The owners of these websites set out their own rules regarding the use of cookies in their privacy policies; consequently, the Controller has no influence over the privacy policies or cookie usage practices of these third-party providers.
The Administrator is not responsible for the data processing practices of these entities. It is recommended that you familiarise yourself with the privacy policies and terms and conditions of these providers.
13. Changes to the Privacy Policy
The Privacy Policy may be updated from time to time to bring it into line with changes in legislation or the functionality of the Portal.
The new version of the policy will be published on the Website.
In the event of significant changes, users may be notified by email.
