Privacy policy

The IT systems operating the website record, for each access, the IP address, the date and time, the page requested and the browser type. These data are used solely to ensure the operation of the website and to protect it from cyber attacks; they are not used to identify the Data Subject and are not combined with other data.

In order to prevent automated form submissions, the Controller counts for a few minutes the submissions coming from the same IP address and the same email address; after that interval the count is reset.

If a form fails to be sent, the date, the form, the page, the type of error, the language and the browser family are recorded, excluding the content of the form, the name, the email address, the phone number and the IP address. If the request is subsequently received, an internal code links it to that record.

When the Data Subject uses the quote, support, the chat or the “Careers” section, the website stores a random code in the browser (the thandosa_dispositivo cookie) and keeps, together with the code, the device type, operating system, browser and language, in order to link together the requests and messages sent from the same device. The relevant information is set out in the Cookie policy.

The following are processed: first and last name, email address, phone number, number of guests (adults and children), the dates requested and whether they are flexible, the destination chosen or described, the water toys and services requested, the occasion and any notes entered, and the channel through which the Data Subject came to know the Controller. The website language, the page from which the request originated and, where the Data Subject comes from an external website, only the name of that website, for example a search engine, are also recorded.

A quote may also be requested by phone, by email or via WhatsApp; in that case the Controller's staff records it in the panel with the same data and the same rules of this notice apply.

Until submission, the data entered remain stored only in the Data Subject's browser and are not transmitted to the Controller; they are deleted automatically after 24 hours, on submission or with the “Delete and start again” command (Cookie policy).

On submission of a form the Controller records the declaration that this notice has been read and, in the quote, the acceptance of the confidentiality terms, with date and time, version of the text and its digital fingerprint. Such record does not constitute consent to processing but proof that the information was provided, under article 5, paragraph 2, of the GDPR.

The following are processed: first and last name, email address, phone number, the topics selected, the text of the message and, where given, the reference of a request. The phone number is used to contact the Data Subject again: support requests are handled by phone and what is agreed is confirmed by email. To exercise the rights referred to in section 8 the email address is sufficient.

Emails sent directly to the Controller, even without using a form, are recorded in the panel: in the Data Subject's file, where one exists, or among the support messages, together with the sender's name and address. The Controller replies from the panel.

The following are processed: the messages written, the attachments sent, the page from which the Data Subject writes and, where no operator is online and the Data Subject asks to be notified of the reply, the name and the email address or phone number. Any reports and the rating given to the conversation are also recorded. Attachments are checked by an antivirus on the Controller's server before they are opened. A technical cookie (thandosa_chat) keeps the conversation active and the browser keeps an indication of its existence (thandosa:chat), in order to show replies not yet read.

During the conversation the operator sees whether the Data Subject is connected and whether they are typing; this information is not stored. For each message the time of delivery and the time of reading are recorded, and are also visible to the Data Subject. Messages written in a language other than Italian are translated automatically by a program installed on the Controller's server, without the use of external services; the original text is always kept next to the translation.

Where the Data Subject has left an email address or phone number in order to be notified of the reply, the notification is sent by the means indicated: by email or by a WhatsApp message (section 3.12).

The proposal can be consulted through a personal link sent by email. On opening, the date and time, the device type, the IP address and the approximate city derived from the IP address using a database installed on the Controller's server (DB-IP) are recorded, without the address being disclosed to third parties. These data are processed to establish that the proposal has been received and to protect access to it.

When the Data Subject replies to the proposal (“Interested”, “Request changes” or “Not interested”), the reply, the note and the reason optionally given are recorded, together with the same data collected on opening: date and time, device type, IP address and approximate city.

Access to the client panel is by means of the credentials sent by email; the password is stored only in the form of a cryptographic fingerprint. The panel stores the devices used for access (device name, IP address, approximate city, date of first and last access), so that credentials are requested only once per device. The Data Subject may disconnect a device with the “Sign out of this device” command. For the client area an access code of limited validity is sent by email.

On first access the Data Subject accepts the confidentiality terms relating to the information made available, such as the bank details; the acceptance is recorded together with the version of the text.

Where the proposal is accepted, the following are also processed:

• billing data: for a natural person, name, address, country and tax code; for a legal person, company name, VAT number, recipient code or certified email address;
• amounts, payments and the bank-transfer receipts uploaded by the Data Subject;
• the signed contract, uploaded to the panel or sent via WhatsApp;
• the list of persons on board: first and last name of each guest and date of birth of minors;
• a copy of the identity document of the person signing the contract, accessible only to the Controller and authorised operators, to the exclusion of the crew;
• the preferences given for the day, such as boarding, destinations and stops, preferred food and drinks, music, occasions to celebrate, the age of children, any susceptibility to seasickness or first experience on a boat of any guest, the request for photographs on board;
• the email correspondence exchanged, kept in the file together with the panel messages;
• the automatic notifications sent by email about the steps still to be completed.

The list of persons on board is processed in order to know with certainty who is on board, for the safety of navigation and for checks by the maritime authority; the signatory's document is processed in order to identify the contracting party with certainty.

Guests' data are provided to the Controller by the person signing the contract, who is asked to bring this notice to the attention of the persons named, under article 14 of the GDPR.

In the preferences form the Data Subject may indicate, for themselves and for the guests, allergies (among the fourteen allergens listed in Regulation (EU) No 1169/2011 or others), intolerances, whether an allergy is severe and the diets followed, such as a vegetarian, vegan, gluten-free, halal or kosher diet.

Allergies, intolerances and diets followed for health reasons constitute health data; diets followed for religious reasons may reveal religious beliefs. These are special categories of data under article 9 of the GDPR, processed only with explicit consent, given by ticking the box next to the answer, and solely in order to prepare safe and suitable food and drinks on board.

Such data are accessible only to the persons preparing the charter, to the chef where requested, and to the crew. They are deleted automatically the day after the charter ends, together with the consent. Consent may be withdrawn at any time by removing the relevant answers from the form and saving, or by notifying the Controller; withdrawal does not affect the lawfulness of processing carried out beforehand. Without consent the other services of the charter remain unchanged, but the Controller cannot take those requirements into account.

In the other forms the Data Subject is asked not to enter health data concerning themselves or others. Should this occur, the Controller's staff deletes the data from the note or requests it separately, explaining its purpose and obtaining explicit consent.

Where the Data Subject answers yes to “Photos on board” in the preferences form, the crew takes photographs during the charter and makes them available in the client panel. The Data Subject may also upload their own photographs to the panel. The photographs depict the Data Subject and the guests: the person signing the contract shall inform the guests, as provided for the list of persons on board (section 3.6).

Subject to consent given in the client panel, the Controller may publish the photographs of the charter on the website and on its social media channels. The consent is separate from any other, optional and revocable at any time from the panel; withdrawal takes effect for the future.

After the charter the Data Subject may leave a review in the panel, including the rating, the text, the aspects appreciated and those to be improved. The Controller may also invite the Data Subject to leave a review on Google, where Google's privacy notice applies.

At present reviews are not published on the website. Before publishing them the Controller will update this notice, stating how it verifies that reviews come from clients who actually took the charter, as required by article 22, paragraph 4-bis, of the Italian Consumer Code.

The following are processed: the role, first and last name, email address, phone number, languages spoken, years of experience, professional qualifications, knowledge of the Gulf, availability, the message and the CV in PDF format, checked by an antivirus. These data are processed solely to assess the application. Subject to consent, the application is also kept for subsequent selections.

Until submission, the draft application remains stored only in the Data Subject's browser; the CV is not included in it.

Where the date requested is already reserved, or has previously been requested by another client, the Data Subject's request is placed on the waiting list for that date and the Data Subject is informed by email, with a personal link. Through that link the Data Subject may choose a nearby free date, stay on the list or leave it. Should the date become available, the Controller informs the Data Subject. Other clients on the list do not see the Data Subject's name, nor does the Data Subject see theirs.

Where the Data Subject contacts the Controller via WhatsApp, the phone number, profile name and messages are processed solely in order to reply. The Controller also contacts the Data Subject via WhatsApp at their request, for example to notify them of a reply in the chat, or where the Data Subject has provided their number for a request or a charter. Documents sent via WhatsApp, such as the signed contract, are stored in the Data Subject's file. The service is provided by WhatsApp Ireland Limited, which processes the messages as an independent controller under its own privacy policy.