Privacy Policy

Pronavia 38 Sailing Limited

Last updated: 20 August 2026

1. Who we are

Pronavia 38 Sailing Limited is a company registered in Malta (company number C115920), with its registered office at 4 Botanic Mans, Flat 4, Triq il-Marokk, Naxxar NXR3161, Malta.

We operate two Pronavia 38 yachts, Bongani and Seawolf, offering sailing activities based in Valletta,Malta.

We are the data controller for the personal data we collect about you. If you have any questions about how we use your data, you can reach us at pronavia38sailing@gmail.com.

2. What data we collect and why

We do not collect data we don’t need, and we do not use your data for purposes other than those listed below.

Data	Why we collect it	Legal basis
Name, email address, contact details	To process and manage your booking and communicate with you about it	Performance of a contract
Names and ages of all guests in your party	To manage your booking and meet our safety obligations as a licensed commercial operator	Performance of a contract; legal obligation
Passport or national ID details	To prepare crew lists and meet port authority and regulatory requirements	Legal obligation
Health information, medical conditions, allergies, dietary requirements	To keep you and others safe aboard; to allow the Skipper to plan appropriately	Vital interests; performance of a contract
Sailing experience and fitness information	To place you appropriately for your activity and meet our duty of care	Performance of a contract
Emergency contact details	To contact someone on your behalf in the event of an emergency	Vital interests
Payment information	To process payment for your booking	Performance of a contract
Photographs and video taken aboard	For use on our website and social media to show our activities	Legitimate interests(see section 5)

3. Health and sensitive data

Some of the information we ask for — such as medical conditions, allergies, and mobility limitations — is classified as special category data under GDPR. We collect this only where it is necessary to protect your safety or that of others aboard, and we handle it with additional care.

This information is shared only with the Skipper of your vessel and is not retained beyond the period set out in section 6.

4. Who we share your data with

We share personal data with third parties only where necessary to deliver your booking or to comply with our legal obligations.

Acuity — our online booking platform for Race Yacht Experience sails. Acuity processes your name, contact details and payment information on our behalf when you book online. Acuity acts as a data processor for us. You can read Acuity’s privacy policy at https://acuityscheduling.com/privacy.php.

Stripe — our payment processor for online bookings. Stripe processes your payment card details securely.We do not store your card details ourselves. You can read Stripe’s privacy policy athttps://stripe.com/gb/privacy.

Xero — our accounting software. Xero holds invoice and payment records which may include your name, contact details and the amount paid. You can read Xero’s privacy policy athttps://www.xero.com/uk/legal/privacy/.

Port authorities and race organisers — we are required to submit crew lists including names and passport details to port authorities and, for offshore races, to race organisers. We share only what is required.

Transport Malta — as our licensing authority, Transport Malta may require access to records related to our commercial operations.

We do not sell your personal data to third parties, and we do not share it for marketing purposes.

5. Photography and video

We take photographs and video during our activities and use some of this on our website and social media.This is part of how we show people what we do, and we believe we have a legitimate interest in doing so.

If you would prefer not to appear in photographs or video, please let us know before your trip or at the safety briefing and we will make sure you are not included. This is straightforward to accommodate and will not affect your booking in any way.

For Business Events, any footage supplied to you as part of your memory video is yours to use as you like. Our use of footage from your event for our own marketing is subject to your agreement, which we will confirm in your booking form.

6. How long we keep your data

Data	Retention period
Booking and contact details	7 years from the date of your booking (for accounting and legal purposes)
Health and medical information	12 months from the date of your activity, then securely deleted
Passport and ID details	12 months from the date of your activity, then securely deleted
Emergency contact details	12 months from the date of your activity, then securely deleted
Payment records	7 years (legal and tax obligation)
Photographs and video	Indefinitely, unless you ask us to remove images of you

7. Marketing

We do not currently send marketing emails. If we introduce a mailing list in the future, we will ask for your explicit consent before adding you to it, and you will always be able to unsubscribe.

8. Your rights

Under GDPR, you have the following rights in relation to your personal data:

Access — you can ask us for a copy of the personal data we hold about you.
Correction — you can ask us to correct inaccurate or incomplete data.
Deletion — you can ask us to delete your data where we no longer have a lawful reason to hold it.
Restriction — you can ask us to restrict how we use your data while a complaint is being resolved.
Objection — you can object to our use of your data where we rely on legitimate interests as our legal basis.
Portability — you can ask us to provide your data in a portable format where technically feasible.

To exercise any of these rights, please write to us at pronavia38sailing@gmail.com. We will respond within one month.

Please note that some rights are subject to limitations — for example, we may need to retain certain records to comply with our legal obligations even if you ask us to delete them. Where that applies, we will explain why.

9. Complaints

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information and Data Protection Commissioner (IDPC), which is the data protection supervisory authority in Malta.

Information and Data Protection Commissioner Level 2, Airways House High Street, Sliema SLM 1549Malta https://idpc.org.mt

We would always prefer to resolve concerns directly — please contact us first atpronavia38sailing@gmail.com and we will do our best to address your concerns promptly.

10. Changes to this policy

We may update this privacy policy from time to time. The current version will always be available on our website, and the date at the top of this page will reflect when it was last updated. For significant changes, we will let you know directly where we hold your contact details.

Pronavia 38 Sailing Limited · Registered in Malta · C115920 · 4 Botanic Mans, Flat 4, Triq il-Marokk, Naxxar, NXR3161, Malta