Interpretation and Definitions
Interpretation
The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application refers to Sail of the Pirate, the software program provided by the Company.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Sailors Connect Ltd, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ. For the purposes of the GDPR, the Company is the Data Controller.
Country refers to: United Kingdom.
Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Application.
Service Provider means any natural or legal person who processes the data on behalf of the Company — third-party companies or individuals employed to facilitate the Service, provide it on Our behalf, perform related services, or assist in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected — Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to, information You choose to provide.
Usage Data
Usage Data is collected automatically when using the Service. It may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased.
- To contact You: by email, telephone, SMS, or push notifications regarding updates or informative communications related to the functionalities, products or contracted services.
- To provide You with news and general information about other goods, services and events similar to those you have already purchased or inquired about, unless You opt out.
- To manage Your requests: to attend and manage Your requests to Us.
- For business transfers: to evaluate or conduct a merger, divestiture, restructuring, reorganization, or sale or transfer of some or all of Our assets.
- For other purposes such as data analysis, identifying usage trends, and evaluating and improving our Service, products, marketing and your experience.
We may share Your Personal Data with Service Providers, for business transfers, with Affiliates, with business partners, with other users (in public areas), or with Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. The retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner.
Account Information
- User Accounts: retained for the duration of your account relationship plus up to 24 months after account closure.
Usage Data
- Application usage statistics: up to 24 months.
- Server logs (IP addresses, access times): up to 24 months for security monitoring and troubleshooting.
Marketing & Financial Data
- Advertising identifiers and profiles: up to 24 months from last interaction or until you opt-out, whichever comes first.
- Payment information: card details are not stored on Our servers; they are processed by our Payment Service Providers. We retain transaction records for up to 10 years to comply with tax laws and financial regulations.
When retention periods expire, We securely delete or anonymize Personal Data. Residual copies may remain in encrypted backups for a limited period and are not restored except where necessary for security, disaster recovery, or legal compliance.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. This information 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 from Your jurisdiction.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account and visiting the account settings section, or by contacting Us. Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law Enforcement & Other Legal Requirements
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities. The Company may also disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing, protect the personal safety of Users or the public, or protect against legal liability.
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.
Analytics, Advertising & Payments
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
Analytics — Unity Analytics
Unity Analytics is provided by Unity Technologies. For more information on what type of information Unity Technologies collects, please visit their Privacy Policy: unity.com/legal/privacy-policy. You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android).
Advertising — Unity Ads
Unity Ads is provided by Unity Technologies, including personalized advertising services. For more information, please visit their Privacy Policy: unity.com/legal/privacy-policy. You may opt-out of personalized advertising via your device's Limit Ad Tracking (iOS) or Opt Out of Ads Personalization (Android) settings.
Payments
We may provide paid products and/or services within the Service. We will not store or collect Your payment card details — that information is provided directly to Our third-party payment processors, whose use is governed by their Privacy Policy. These processors adhere to PCI-DSS standards.
- Apple Store In-App Payments: apple.com/legal/privacy
- Google Play In-App Payments: policies.google.com/privacy
GDPR Privacy
Legal Basis for Processing
We may process Personal Data under the following legal bases: Consent, Performance of a contract, Legal obligations, Vital interests, Public interests, and Legitimate interests.
International Transfers
Where we transfer Personal Data outside the EEA/UK to a country that has not been recognized as providing an adequate level of protection, We rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses ("SCCs") and/or the UK International Data Transfer Agreement ("IDTA"), along with supplementary measures such as encryption in transit and at rest, access controls, data minimisation, and vendor security reviews.
Your Rights under the GDPR
If You are within the EU, You have the right to: request access to Your Personal Data; request restriction of processing; request correction; object to processing; request erasure; request the transfer of Your Personal Data; and withdraw Your consent.
You may exercise these rights by contacting Us. We generally respond within one month, and may extend by two further months where necessary. You also have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data.
CCPA/CPRA Privacy Notice (California)
This section for California residents supplements the information contained in Our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California.
Categories Collected
Within the last twelve (12) months, We may collect the following categories defined in the CCPA/CPRA: Category A (Identifiers), Category B (California Customer Records), Category D (Commercial information), and Category F (Internet or other network activity). We do not collect protected classification characteristics, biometric information, geolocation data, sensory data, professional information, education information, inferences, or sensitive personal information.
Sale or Sharing of Personal Information
We do not "sell" or "share" information as most people would commonly understand these terms — meaning We do not disclose Your Personal Information in direct exchange for money. However, We allow Our Service Providers to use Your personal information for business purposes such as advertising, marketing, and analytics, and these may be deemed a "sale" or "sharing" under CCPA/CPRA (including for "cross-context behavioral advertising").
Your Rights under the CCPA/CPRA
California residents have the right to notice, the right to know/access, the right to opt-out of sale/sharing, the right to correct, the right to limit use of sensitive personal information, the right to delete, and the right not to be discriminated against for exercising these rights.
Do Not Sell or Share / Opt-Out
To opt out of interest-based advertising and potential sales as defined under CCPA/CPRA, you may use your mobile device controls ("Opt out of Ads Personalization" on Android, "Limit Ad Tracking" on iOS), or the following opt-out platforms:
- NAI: optout.networkadvertising.org
- EDAA: youronlinechoices.com
- DAA: optout.aboutads.info
Our Service does not respond to Do Not Track (DNT) signals. To exercise any CCPA/CPRA right, contact Us at ahoy@sailorsconnect.org.
Children's Privacy
Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.
Links to Other Websites
Our Service 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.
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 "Last updated" date at the top. We will let You know via email and/or a prominent notice on Our Service prior to the change becoming effective. You are advised to review this Privacy Policy periodically for any changes.
Contact Us
If you have any questions about this Privacy Policy, You can contact us by email. We're happy to help with any privacy request or concern.
ahoy@sailorsconnect.orgSailors Connect Ltd · 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ