online-project owned by Glory Yachting OU, later referred to as "Company", customer registry
The Data Protection Regulation is a directly applicable legal framework in all EU Member
comprehensive explanation of the processing of personal information to customers using www.online-schoo.yacht-travel.eu
(later referred to as "User").
1. Name and Address of the Registry
2. Contact Information in Registry Matters
3. Name of Registry
Kind of Information is collected?
Is My Information Collected?
6. What Are the Legal Grounds for Information
7. Which Sources Does the Information Come from?
8. Will Personal
Information Be Shared with Third Parties?
9. Will Information Be Transferred Outside
the EU or the ETA?
10. Right to Inspect and Right to Request Correction
Rights Related to Processing of Personal Information
12. Storing of
If you have any questions about the way your personal
information is handled, please contact us at the address below. 1. Name
and Address of the Registry Keeper
Glory Yachting OÜ (registry code
Harju maakond, Keila linn, Linnamäe tee 10, 76605, Estonia
2. Contact Information in Registry Matters firstname.lastname@example.org
+380 67 327 36 33
3. Name of Registry
Customer Registry of the
Online-school.yacht-travel.eu service. 4. What Kind of
Information is collected?
Information submitted by the user during
In order to register for the Online-school.yacht-travel.eu service and
to use the service, the User has to provide their name, email address, preferred password
for the user ID (email address) and the country where the service is being accessed from.
If the User registers for the service through Facebook, the Company will know
User's Facebook username.
In addition, the User has the option
to voluntarily give the following information during registration or use: phone number, town
and country of living, year of birth, gender, and where they heard about the service. The
reason for asking the phone number is for providing customer service. Information about age,
town, country of living, gender and first language is used to develop the service, optimise
the exercises and setting the default translation language.
where the User heard about the service is used for marketing development purposes.
Information collected automatically during registration:
Personal User identifier
Time of registration
Free sample activation data
User interface language
generated automatically during use of the service:
First login day
Start and end date of license
Login data ("Remember me" cookies)
Offer campaign data
Analytics data (Google
Hints and reminders shown to User
Information submitted or selected by the User during use of the service:
study material (optional)
User recommendations (optional)
Study group data
(for organisation users)
General service usage settings
Other information collected and handled for purposes described in
- Notes added manually by customer service
- Information about which
emails sent by Company the User has opened 5. Why Is My Information
The information specified in section 4 is collected and
processed for the following purposes:
Use of the service
email address and password are required for registering and logging in to the service.
During purchase events, information related to the purchase, such as the chosen course
package and the duration of the license, is stored so that we can deliver the User the
service the User has bought. Information about country is required to set the correct
currency and tax.
Online-school.yacht-travel.eu service is based on personal
optimisation (profiling), which requires storing information such as the User's exercise
data, including selected and recorded answers. Optional information, such as age and gender,
is also used to develop the service and optimise the exercises. Information about first
language is used to set the default translation language.
The profile formed as a
result of this optimisation consists of information collected from the User during
registration and use of the service. This information is necessary for individual
optimisation of the service.
Much of the other information specified in section
4 is required to use the different features of the service. For example, certificates are
sent based on stored results, and rewards for recommendations are given based on stored
information about recommendations. The settings selected by the user are stored in order to
adjust the functioning of the service according to the User's wishes.
The development of Online-school.yacht-travel.eu features and
exercise algorithm is based on different tests and statistical analysis of User behaviour
data stored in the database, as well as User learning results. The data used in research and
development is not traceable to an individual User. According to the applicable data
protection legal framework, the analysis is made statistically using a large mass of data
(e.g. all Users learning English), where the information is stored anonymously and
individual Users are no longer identifiable.
Customer service and informing
The User's contact information, payment information and exercise information is
also required to answer customer support requests. These requests usually involve looking at
the User's information and exercise data in online-school.yacht-travel.eu
management panel and checking payment
information in various payment service providers' management panels. User email addresses
are also required for informing purposes.
platform pixels and other similar techniques collect information about Users' movement and
actions on the online-school.yacht-travel.eu service. This information can be used to show
them targeted advertising. The purpose of targeted advertising, e.g. in Facebook and Google,
is to show each consumer advertisements for products and services the consumer is interested
in rather than completely random advertisements.
The visiting User has the right to
resist this kind of profiling-based advertising or withdraw consent by disabling "Targeting
cookies" from the website's cookie settings.
The registered User can manage their ad
settings directly in the social media services they use. Instructions for managing the ad
settings of our marketing partners can be found in the following links: https://www.facebook.com/help/247395082112892?help...
The User's personal information is also handled while fulfilling the
Company's legal duties, such as taxation and accounting. For accounting and taxation
purposes, the Company must know e.g. which products the Users have purchased, how much the
products cost, which payment service provider was used and which country the purchases were
made from (country information affects e.g. the amount of Value Added Tax). User contact
information is required in case any problems or misuse issues related to payments arise.
Changes or additions to information usage purposes
In case there are
essential changes to the usage purposes of personal information or new purposes are taken
into use, the Company will inform the User in advance before carrying out the changes. In
these cases, the Company must also ask the User's consent to such essentially changed or new
usage. 6. What Are the Legal Grounds for Information
There are six legal grounds for processing personal
information defined in the EU data protection regulation. These are:
Performance of a contract
Compliance with a legal obligation
Grounds related to public interest or official authority
Glory Yachting OU collects and processes personal information
mainly on the grounds of consent, performance of a contract, grounds related to the
Company's compliance with legal obligations, and legitimate interests.
User registers to www.online-school.yacht-travel.eu
and submits personal information
to the Company, the User is requested to read the
consenting to the processing of the User's personal information. The request for consent is
presented clearly and separately from other matters, in an understandable and accessible
form, in clear and simple language. At the same time, the User is informed that the User has
the right to withdraw consent at any time. More information about withdrawing consent is
may choose which consent-based personal data usage purposes the User consents to.
Grounds related to performance of a contract means that certain information has to be
collected from the User to make it technically possible to use and purchase the service.
Compliance with a legal obligation means processing personal information e.g. for the
purposes of performing the Company's duties related to accounting and taxation.
Company may have legitimate interests related to the following functions among others:
customer service, handling of misuse cases, product and service development.
collecting and processing of all information listed in section 4 is based on some of these
legal grounds. If you would like to get a more detailed explanation of these legal grounds,
you may request it by email at email@example.com.
If the User does not want to
submit personal information which is required on the grounds of performance of contract,
grounds related to the Company's compliance with legal obligations or the Company's other
legitimate interests, the service cannot be used. 7. Which Sources Does
the Information Come from?
Personal information is collected mainly from
the Users themselves, either directly or through cookies (see section 14). Information is
also generated automatically during registration, purchase and use of the service (see
If necessary, personal information can also be collected and
updated from other registries of the Company and other companies in the same enterprise
group or the registries of third parties. 8. Will Personal Information
Be Shared with Third Parties?
Personal information will be shared
with payment service providers which charge for products and services ordered from Glory
Yachting OU (online-school.yacht-travel.eu
). Certain personal information will also be
shared with Zoho CRM software, which is used in customer service, as well as the Zoho
Campaign software, which is used to send newsletters and operates under the EU-U.S. Privacy
Certain purchase data is also transmitted to Google and
Facebook in order to monitor the efficacy of our advertising campaigns. However, Google and
Facebook are not able to connect the transaction data transmitted to them to individual
Some personal data is also transferred to Glory Yachting OU marketing
Facebook and Google, for showing activity-based ads. The visiting User
has the right to resist this kind of profiling-based advertising or withdraw consent by
disabling "Targeting cookies" from the website's cookie settings. The registered User can
manage their ad settings directly in the social media services they use. Instructions for
managing the ad settings of our marketing partners can be found in the following links:
Some personal data of our mobile app Users is also transferred to analytics
like Zoho SalesIQ and Google. By analyzing the behavior of our Users we can
Company transfers personal data in its customer
registry to the ZOHO Campaign service for the purposes of email marketing in accordance with
applicable data protection legal framework.
Glory Yachting OU may share
information about the User to other third parties if the User has consented to it. Yacht
Travel may also use other subcontractors not mentioned here to handle the User's
information, if such usage happens according to the requirements of the EU Data Protection
Regulation. Yacht Travel is responsible to the User for the subcontractors' processing of
personal information as well as its own.
Glory Yachting OU may also transfer
information to a company belonging to the same business group (Yacht Travel LLC, Private
Entepreneur Oleg Lytvyn) as well as during company reorganisation. 9.
Will Information Be Transferred Outside the EU or the ETA?
mentioned in section 8, namely Facebook, Google, Zoho, are located outside the EU. However,
they are all large, reliable operators that have many clients in the EU area and they follow
the principles of the EU Data Protection Regulation.
More information about
data protection in these companies as well as their international data protection
certificates can be found at the following links:
Zoho Campaign: https://www.zoho.com/privacy.html
10. Right to Inspect and Right to Request Correction
Glory Yachting OU does not check the correctness of the information submitted by the User.
Users logged in to the service can check and change their settings related to
the use of the service, as well as the personal information submitted during registration.
The User has the right to request a copy of all other information concerning
themselves from the Glory Yachting OU customer service, as well as the right to request
correction of any possible incorrect information in the system from the customer service.
The copy can be requested by email at firstname.lastname@example.org
Requesting a copy is free in
principle. However, Glory Yachting OU may charge a reasonable fee for repeated information
requests on the grounds of administrative expenses, or refuse to perform the action
requested by the User if the request is clearly baseless and unreasonable.
11. Other Rights Related to Processing of Personal Information
The User can delete their own user account through the service
settings. The User also has the right to request the Company to delete all the User's
personal information from the Glory Yachting OU database. Information deletion can be
requested by email at email@example.com
All other information apart
from that which is required by official authorities (e.g. payment transaction data for
accounting) and data generated by the use of the service and required for research and
development (e.g. written or recorded answers) can be deleted from the database manually.
Note that data generated by use of the service for exercises cannot, after other information
has been deleted, be connected to the User.
In other words, it becomes anonymous
information as recommended by the applicable data protection legal framework.
Refusing direct marketing
The User can forbid the use of their information for direct
marketing purposes, marketing research and opinion polls. Glory Yachting OU uses the Zoho
Campaigns software for practically all marketing letters and research invitations. The User
can unsubscribe from these by disabling emails in their settings or by clicking the
newsletter unsubscribing link that can be found in the footer of each newsletter.
The Company has the right to save the User's photo if the User has given the
Company the right to use it. The User always retains the right to decide where the picture
can be shown or if it can be shown at all.
User has the right to transfer the information concerning them from one registry
keeper to another. In matters concerning transferring information, please
Right to withdraw consent
User has consented to personal data processing which is not based on performance of
contract, the Company's compliance with legal obligations or the Company's legitimate
interests, the User also has the right to withdraw this consent.
cookies can be disabled from the cookie settings. The User can withdraw
direct marketing by disabling emails in their settings.
Right to file notice of
appeal to authorities If the User is of the opinion that Yacht Travel does not comply with
the requirements of the EU Data Protection Regulation, the User has the right to file notice
of appeal to an authority. 12. Storing of Information
Glory Yachting OU will store User and usage information for a minimum
of one year after the end of the User's last subscription period, unless the User
specifically requests to have the information deleted. After this, the information may be
deleted from the registry during database clean-ups carried out at certain intervals
according to the current practice.
Notwithstanding the above and for the sake
of clarity, it should be noted that information related to purchase events may be stored
even after this time, to the extent and for the time the service provider believes it
necessary to store this information in order to carry out accounting and other legal
In order to monitor the
use of the service and to make it possible, cookies may be introduced to the User's computer
at times. Cookies make it possible for the Company to provide the User with a service that
takes the User's wishes and preferences into account.
Cookies can also be used
to give the User better offers and more personal product recommendations, either directly or
through an external service, such as Google or Facebook.
In addition, cookies
are used to monitor the number of visitors in the service. Parts of the website require
accepting cookies in order to function. Targeting cookies can be disabled from the cookie
Advertisement settings can also be managed in the User's own Facebook
or Google account: https://myaccount.google.com/privacycheckup
Cookies can also be managed on the computer by using a service designed for
purpose, such as Disconnect. https://disconnect.me/disconnect
For more information concerning browser-based online marketing and online
can read information about settings in the most popular web-browser on the following
14. Registry Protection
All persons handling the registry possess
personal user permission (username, password and level of rights) from the registry keeper.
These persons are operating under a non-disclosure agreement or are otherwise legally
obligated to confidentiality.
The personal information of Users is accessible
only by persons who need this information to do their work. These include the customer
service personnel and technical staff of the service.
Glory Yachting OU will,
to the best of its ability, strive to offer the service in such a way that external parties
will not get unlawful access to the User`s information or communications. Other parties
connected to providing the service (e.g. network or mobile operators) are responsible for
their own data security.
Glory Yachting OU strives to offer the service
following the principle of Privacy by Default. Personal information is processed in
pseudonymous or anonymous form whenever possible. The information content of the registry is
technically secured and back-ups are made regularly.
Glory Yachting OU carries
out the appropriate technical and organisational actions in connection to processing
personal information, especially in order to protect personal information from data security
breaches. If, despite this, a data security breach (accidental or illegal destruction, loss,
altering, unlawful transfer or access, which causes a high risk to the Users' rights and
freedoms) should happen, we will inform the Users of the risk, its likely effects, and the
recommended actions for counteracting its harmful effects without delay.