PEMBROKESHIRE PERFORMANCE SAILING ACADEMY
PRIVACY POLICY

1. This Privacy Policy describes the information that we gather and how we use and process
such information. For each processing purpose we will articulate the reason for requiring the data, what
data we will process, the legal basis for processing the data and how long we will keep the data.

2. Where the legal basis of consent is to be used, this will be gathered freely, and we will use
clear, plain language that is easy to understand, and you will be able to remove your consent at any
point.

References in this Privacy Policy and on our website to “we”, “our” or “us” are references to
Pembrokeshire Performance Sailing Academy. References to “you” and “your” means each natural or
legal person who uses our website or the associated services.

What Information do we collect about you and how do we use it?
3. We collect/process information so that we can provide the best possible experience when you
utilise our services. This section of the policy will describe the purpose for processing your personal
data, the legal basis to do so and how long we will keep your data.

4. Our Product / Service. If you choose to use our service, including email notifications,
newsletters and product/service updates, you must provide us with some personal data so that we can

provide our services to you; this will include your name, email address and IP address. Other non-
mandatory personal data may also be gathered.

a. We will process data using two legal rationales, if you are an individual and not
associated with a contracted client we will use legitimate interest based upon our Terms and
Conditions. If you are associated with a contracted client we will use legitimate interest as the
legal basis to process the data, as we may not have a direct relationship with you as the data
subject.
b. Our ability to retain the personal data will be determined by account activity, if the
account is not used for over 2 years we will delete your data. Accounts associated with
contracted clients will be deleted on termination of the contract. Evidence of qualifications gained
with PPSA will be retained for 7 years.

5. Our use of Productivity Tools. If you choose to use our service, personal data items such
as name, email address, telephone number and other non-mandatory personal data may be stored on
our IT systems and in paper format which will be stored securely when not in use.

a. We will process data using two legal rationales, if you are an individual and not
associated with a contracted client we will use legitimate interest based upon our Terms and
Conditions. If you are associated with a contracted client we will use legitimate interest as the
legal basis to process the data.
b. Our ability to retain the personal data will be determined by account activity, if the
account is not used for over 2 years we will delete your data. Accounts associated with
contracted clients will be deleted on termination of the contract. Evidence of qualifications gained
with PPSA will be retained for 7 years.

Marketing
6. We would like to send you information about new products and services of ours which may be
of interest to you. You have a right at any time to stop us from contacting you for marketing purposes. To
distribute our marketing information, we may use personal data such as names, addresses, and email
addresses.

7. We will process data using the following legal rationale to send marketing information: if your
role within an organisation is associated with learning and development we will use legitimate interest as
the legal basis to process the data. We use this legal basis after completing a legitimate interest
assessment process. The assessment states we will only send low volume, customised messages to
email addresses who have a legitimate interest in developing their employees and may find our product
useful. If you do not want us to contact you please inform PPSA at the earliest opportunity.

8. We will retain personal data for active customer leads for a period of up to 2 years, a lead will
be active under the following circumstances

a. An email sent by our organisation has not received an unknown account bounce back.
b, An email has been sent to our organisation from the data subject

Updating These Terms
9. We may change our Service and Policies, and we may need to make changes to these Terms
so that they accurately reflect our Service and Policies. Unless otherwise required by law, we will notify
you at least 30 days before we make changes to these Terms and give you an opportunity to review
them before they go into effect. Then, if you continue to use the Service, you will be bound by the
updated Terms. If you do not want to agree to these or any updated Terms, you can request an account
deletion.

Your Rights
10. Accessing or Rectifying your personal data. We want to make sure that your personal
information is accurate and up to date and you have the right to request a copy and update the personal
data that we hold about you. You may ask us to correct or remove information you think is inaccurate. If
you would like to invoke this right, please email us at enquires@ppsa.co.uk

11. Deletion. Based upon the retention periods described above we will remove your personal
data from our platforms.

12. Object, Restrict or Withdraw Consent. You may wish to object to or restrict our ability to
process your personal data, this can be done either via email. Further context may need to be requested
to ensure we can carry out the relevant tasks on our platforms to perform the request.

To Whom We Disclose Information
13. Occasionally, information is provided to the RYA for certification purposes (such as
Powerboat Courses) where certificate registration is held on a central data base. Other than this, no
personal information is provided to 3rd party organisations for marketing or other purposes.

14. Service Providers. We work with third party service providers who provide email hosting,
core corporate applications, web hosting, maintenance, and other services for us. These third parties
may have access to, or process Personal Data as part of providing those services for us. We limit the
information provided to these service providers to that which is reasonably necessary for them to perform
their functions, and our contracts with them require them to maintain the confidentiality of such
information.

15. Law Enforcement, Legal Process and Compliance. We may disclose Personal Data or
other information if required to do so by law or in the good-faith belief that such action is necessary to
comply with applicable laws, in response to a valid court order, judicial or other government subpoena or
warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
16. Change of Ownership. Information about data subject, may be disclosed and otherwise
transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale
of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in
which information is transferred to one or more third parties as one of our business assets and only if the
recipient of the personal data commits to a Privacy Policy that has terms substantially consistent with this
Privacy Policy.

Our Data Security
16. We have appropriate security measures in place to prevent personal information from being
accidentally lost, used or accessed in an unauthorised way.