Privacy Policy

This Privacy Policy is effective as of 01/19/2024.

OCEAN OF EXPERIENCES  and its affiliates (alternatively, “NAUTIC OCEAN”, “we”, “us” or “our”) respect your privacy and are committed to abiding by this privacy policy (“Privacy Policy”), which describes the information we collect about you, including how we collect it, how we use it and with whom we may share it.

This Privacy Policy applies to information collected on our websites www.seastarlight.com, (the “Websites”), as well as on the mobile applications  Evasión” (the “Mobile Applications” and, together with the “Websites”, the “System”).

It also covers the use of personal data of visitors and users of our aforementioned websites, visitors and users of our mobile applications, users of the System, as well as owners and providers or suppliers of services or goods. It also covers the use of personal data of all those who interact with us in any other way, through our relationship programs, loyalty programs, recruitment and human resources interactions and even on social networks.

The Privacy Policy is an integral part of the contractual relationship that OCÉANO DE EXPERIENCIAS may have with its users, customers and partners.

Concerned with respecting the rights and freedoms of individuals, OCÉANO DE EXPERIENCIAS is committed to protecting personal data.

I. PERSONAL DATA COLLECTED

Sea Starlight collects certain information from or about you that can be used to identify you (“Personal Information”). We collect Personal Information from a variety of sources, including information you provide directly and information we collect automatically when you access and use the System.

Information you provide to us: You may provide information about yourself to us and our third party service providers through the System, including your contact information, such as your name, email address, telephone number, address and similar information, as well as your user names and passwords and any personal information you enter when communicating with Sea Starlight  (telephony, open comment areas, email).

Please note that the information you enter in the free comment areas must be objective, never excessive or insulting, and must not contain data considered sensitive (racial or ethnic origin, political, philosophical or religious opinions, trade union membership, data concerning health or sex life, crimes, convictions or security measures).

If you have any questions, you may contact Sea Starlight by e-mail: privacy@SeaStarlight .com, to ensure that you are not infringing on the rights of the company or its employees.

We may also collect your gender, date of birth, boating license and other forms of identification, such as your driver’s license. Finally, we and our third party service providers may collect transaction data, such as payment card, bank account information and billing address.

Information Collected Automatically: We and our third party service providers may automatically collect information about you when you visit and use the System. This information includes the following:
Usage information: We may collect information about how you interact with the System. This may include information such as the dates and times you visit the System, the page you view, referring/exit URLs, browser type, and the domain name of your Internet service provider.

In some cases, we may collect this information using cookies and similar technologies. For more information about these technologies, please see our Cookie Policy.

Device Information: We may collect information about the devices you use to access the System, including the make and model of your device, IP address, suspected geolocation information, operating system and unique device identifiers.

II. INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA

Sea Starlight  implements all its processing of personal data in accordance with the relevant regulations and, in particular:

  • General Personal Data Protection Regulation n°2016/679 which came into force on May 25, 2018 (hereinafter, “GDPR”), as well as, The Spanish Data Protection Law ………………………..

In the context of the activity carried out through the System, Sea Starlight  acts as a data controller in the sense that the company determines the purposes and means of the Processing carried out in the context of the System as described below in this Policy.

The processing of personal data carried out within the framework of the operation of the System respects the principles of fairness, lawfulness and transparency. Therefore, Sea Starlight   is committed to providing clear, complete and easily accessible information on how these treatments are carried out.

Sea Starlight  only collects your personal information when strictly necessary and lawful. We undertake to collect only the minimum amount of personal information necessary for the purposes contemplated in this Privacy Policy.

In the event that we need to use your personal data for purposes not covered by this Privacy Policy, you will be asked for additional consent. However, please note that your consent will not be required if the processing of your personal data is justified for a legitimate reason, provided that such use does not adversely affect your own rights and interests.

You may refuse to provide us with your personal information. However, if the information is necessary to respond to your request and you do not provide it, your request may not be considered or its analysis may be delayed.

In the event that you communicate the personal data of a third party to us, you must inform them in advance of your request and ensure that you have their authorization and consent to do so.

The System is intended for a general audience of adults. The System is intended to exclude children under the age of 16. We do not knowingly collect information from children and do not intend to knowingly sell products to children. In accordance with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 16.

Sea Starlight  undertakes not to process sensitive personal data revealing racial or ethnic origin, political opinions, religious or philosophical convictions or trade union membership, nor to process genetic data, biometric data intended to uniquely identify a natural person, or data concerning the health, life or sexual orientation of a natural person.

If, during the exchanges with the client/prospect or user of the System, one of the parties communicates such information, it will not be registered by Sea Starlight  in its database.

The scope of the use and management of the System, as well as relations with end-user customers, associated merchants and service providers/suppliers of services or goods, or with applicants leads Sea Starlight  to process the personal data detailed below:

  • Personal data transmitted to Sea Starlight : Surname, first name, postal address, e-mail address, gender, date of birth, as well as possible data relating to the user’s areas of interest.
  • Legal basis for processing: Consent.
  • Purpose of processing: Management of the invoicing of reservations and payments on the Sea Starlight platform.
  • Personal data transmitted to Sea Starlight : Last name, first name, customer account, e-mail address, postal address.
  • Legal basis for processing: Contract for the provision of services.
    Purpose of processing: Management of customer opinions and comments.
  • Personal data transmitted to Sea Starlight : Last name, first name, any data that the customer may have transmitted in the free comments area.
  • Legal basis for processing: Legitimate interest.
  • Purpose of processing: Customer relationship management (oral or written exchanges).
  • Personal data transmitted to Sea Starlight : Surname, first name, telephone records, e-mail addresses, customer’s free text.
    Legal basis for processing: Legitimate interest.
  • Purpose of processing: Creation and management of marketing campaigns (push notifications).
  • Personal data transmitted to Sea Starlight : Last name, first name, telephone number, e-mail addresses.
  • Legal basis for processing: Consent
  • Purpose of processing: Creation and management of marketing campaigns (targeted advertising).
  • Personal data transmitted to Sea Starlight : User profiles.
  • Legal basis for processing: Legitimate interest.
  • Purpose of processing: Creation and management of marketing campaigns (newsletter).
  • Personal data transmitted to Sea Starlight : Last name, first name, e-mail address.
  • Legal basis for processing: Legitimate interest.
  • Purpose of processing: Dispute management.
  • Personal data transmitted to Sea Starlight : Last name, first name, postal address, e-mail address, telephone number, date of birth, gender, navigation license, customer invoice.
  • Legal basis for processing: Legitimate interest.
  • Purpose of processing: Application management
  • Personal data sent to Sea Starlight : last name, first name, postal address, e-mail address, telephone number, photograph, CV, cover letter.
  • For candidates who do not have French nationality: visa allowing them to work in France.
  • For interviewees: possibility of recording telephone interviews.
  • Legal basis for processing: Consent and legitimate interest (specifically for recording telephone interviews).
  • OCÉANO DE EXPERIENCIAS keeps your data for the time we consider necessary for the purposes for which they were collected, or for a longer period to comply with legal and regulatory obligations.

III. HOW DO WE USE THE INFORMATION WE COLLECT?

Sea Starlight  and our third party service providers collect and use Personal Data for the following purposes, including:

  • To provide you with our products and services,
  • To operate and provide the System,
  • Improve our products and services, the System, the user experience and our business,
  • Security purposes, including monitoring, risk assessment, resolving System integrity and security issues, and preventing or deterring fraud and crime,
  • Sending information requested by you, including responding to requests or inquiries about or from Sea Starlight,
  • Sending promotional or marketing material about Sea Starlight ,
  • Other business purposes, including, but not limited to, verifying your identity, age and/or payment information, investigating complaints about the System, research and analysis, marketing, advertising, customer preferences and buying trends, and dispute resolution,
  • In connection with a merger or similar consolidation of Sea Starlight  into or with another entity,
  • To comply with law enforcement, agency or government mandate,
  • Comply with Sea Starlight policies  and all applicable legal requirements or comply with them to the extent permitted,
  • Engage in other activities contemplated by this Privacy Policy or by Sea Starlight  at its discretion.

IV. PRESERVATION OF YOUR DATA

Sea Starlight  retains your personal data in order to enable you to use the System on an ongoing basis, for the period necessary to achieve the purposes described above.

The data collected by Sea Starlight  is stored on the servers of a service provider located in the European Economic Area,  undertakes to take all necessary measures to ensure the security and confidentiality of the data you have provided to us.

You can close your space at any time by sending a request to Sea Starlight support at the following e-mail address: privacy@SeaStarlight.com or by accessing the “my info” page of your account and clicking on the “delete my account” button.

At your request, Sea Starlight will delete all personal data stored in your personal space, with the exception of data that is necessary to fulfill its contractual or legal obligations, in particular accounting obligations. The data will be deleted once the applicable statute of limitations has expired.

V. COMMUNICATION AND RECIPIENTS OF YOUR DATA

Sea Starlight undertakes to retain all personal data collected through the System and only shares it under certain circumstances and in accordance with the provisions of Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms, as amended by Law No. 2018-493 of June 20, 2018.

Sea Starlight  does not sell any of your personal information and only shares it in the ways set out in this Privacy Policy or if required by law. We do not rent, distribute or sell your personal data to third parties unless you have expressly authorized us to do so in advance. We ensure that your data is only accessible to the authorized internal or external recipients listed below.

Sea Starlight may give access to your personal data to service providers to carry out services related to the System, in particular maintenance, analysis, marketing, communication, data processing, payment, distribution of e-mails or postcards, management of promotions or contests, etc. These service providers will only have access to your data to perform these services and will be subject to the same security and confidentiality obligations as Sea Starlight , which will remain responsible for the processing of your data.

Sea Starlight  may share your data to prevent, detect, investigate and take action against any potentially prohibited and illegal activity, any situation that threatens the security or any other rights and interests of users or any person, any violation of its terms and conditions of use, if authorized or required by law and if Sea Starlight  believes in good faith that it is necessary to share them. OCÉANO DE EXPERIENCIAS may also transmit your personal data to respond to legal proceedings of any kind, court orders, legal process or law enforcement actions requested by the relevant authorities.

Sea Starlight  may share your data to prevent, detect, investigate and take action against any potentially prohibited and illegal activity, any situation that threatens the safety or other rights and interests of users or any person, any violation of its terms and conditions of use, if authorized or required by law and if Sea Starlight  believes in good faith that such sharing is necessary.

Sea Starlight  may also share your personal data to respond to legal proceedings of any kind, court orders, legal process or law enforcement actions requested by the relevant authorities.
Sea Starlight  may share your data for other purposes and may allow its partners to send you information when you use the System (and to enable us to fulfill our contractual obligations to them), subject to your express consent.

We may share Personal Information with our affiliates or other third parties, such as business partners and trusted service providers, to help us provide the System, deliver our services, provide advertising or marketing, process payments, perform statistical analysis, send you correspondence, provide customer service, protect against fraud or investigate fraudulent or illegal activities, or perform any other function related to the operation of the System and our services.

We may also share Personal Data with professional advisors, such as lawyers, auditors, bankers and insurers, in connection with the professional services they provide to us. These third parties have agreed to comply with the relevant data protection and confidentiality provisions.

For strategic or other business reasons Sea Starlight  may decide to sell or transfer part or all of its business. As part of such a sale or transfer, we may transfer the information we have collected and maintain (including personal data) to any person or entity involved in the transaction. In the event of a merger, acquisition, sale or transfer of all or part of our business, your data may be communicated to the persons or entities involved.

VI. STORAGE OF YOUR PERSONAL DATA

Sea Starlight may store your personal data (and transfer it to subcontractors) for the following purposes:

  • System hosting management
  • IT resource management and system maintenance

In this context, Sea Starlight  undertakes to verify their compliance with personal data protection rules and to apply a specific contractual framework, under the conditions required by these rules.

Sea Starlight  may also transmit certain information to authorized persons and entities internally (employees, officers and agents of the company) and externally, in particular to third parties authorized under legal, administrative or judicial prerogatives.

Apart from these cases, OCEANO DE EXPERIENCIAS will not transmit your personal data to third parties without your prior consent.

VII. TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN UNION

Transfer of personal data outside the European Union

Sea Starlight  may transfer personal data outside the European Union.

In case of transfer of personal data outside the European Union, Sea Starlight  will apply the necessary regulatory framework appropriate to the situation of such transfer, ensuring:

  • The transfer of your personal data to a country that offers an adequate level of protection, or,
  • The signature of the standard contractual clauses (STCs) proposed by the European Commission, or
  • Any other assurance deemed appropriate within the meaning of Article 46 of the GDPR.

Transfer of personal data to the United States

Following the European Commission’s Adequacy Decision of July 10, 2023, which found that the United States offers a substantially equivalent level of protection for personal data as the EU, organizations subject to the GDPR are now allowed to transfer personal data to certified organizations.

In this context, it is not mandatory for such organizations to establish a transfer tool in accordance with Article 46 of the GDPR, nor to make use of an exception under Article 49 of the GDPR.

Sea Starlight  may transfer your personal data to certified organizations that have made a public commitment to comply with personal data protection standards, in accordance with the list of organizations on the U.S. Department of Commerce website, available at this link:

https://www.dataprivacyframework.gov/s/participant-search

Sea Starlight  will handle any other transfers to the United States using the standard mechanisms mentioned above.

VIII. SECURITY OF YOUR DATA

Sea Starlight undertakes, by obligation of means, to implement all those actions aimed at ensuring the security of your Personal Data.
To this end, Sea Starlight  undertakes to implement all technical and organizational measures, within the meaning of Article 32 of the GDPR, to ensure the confidentiality, integrity and availability of personal data and, therefore, a sufficient level of protection thereof.

Sea Starlight  and its employees have been trained and made aware of personal data protection issues, including the consideration and application of such measures.

IX. AUTOMATED DECISION MAKING

We do not perform any automated decision making as part of our services.

X. EXERCISE OF YOUR RIGHTS

Pursuant to Law no. 78-17 of 6 January 1978 on data processing, files and freedoms, as amended by Law no. 2018-493 of 20 June 2018, you may, at any time, request the exercise of your individual rights and, in particular, request:

  • Access to your personal data in a clear and understandable format so that you know what information Sea Starlight  processes about you,
  • The rectification leading to the modification of incomplete or incorrect personal data processed by Sea Starlight ,
  • The deletion of your personal data under the conditions predetermined by the applicable regulations,
  • Limitation of the processing of personal data under the conditions predetermined by the applicable regulations,
  • The possibility to object to the processing of personal data for legitimate reasons,
  • Portability of personal data in a clear and easily machine-readable format, with the possibility of transmitting such data to another organization,
  • The determination of the destination of your personal data in the event of its disappearance, with the transmission of specific directives to Sea Starlight.

You are informed that the exercise of the rights of opposition, deletion and portability of data, as well as the right to limitation of processing, is subject to conditions and may be denied by Sea Starlight  if the requests to exercise these rights do not correspond to the situations provided for in the regulations on personal data.

It should also be noted that if you opt out of receiving commercial prospecting, we will continue to send you communications related to the operations for which you have registered (games, contests, surveys, analysis, etc.).
Applications should be addressed to Sea Starlight :

By e-mail to: privacy@SeaStarlight .com, or By mail to the following address: Sea Starlight  – Direction………………………

After verifying that you are the person to whom the requested data refers or your duly authorized representative (identity verification), Sea Starlight  will endeavor to respond to your request as soon as possible.

Sea Starlight  undertakes to process any request relating to the exercise of your individual rights within thirty (30) days of receipt; this period may be extended by sixty (60) days in particular in case of complexity in the investigation of the request. In this case, OCEANO DE EXPERIENCIAS undertakes to keep you informed and to follow up on these requests.

XI. LINKED WEBSITES

For your convenience, hyperlinks to other websites that are not under our control may be posted on the System. We are not responsible for the privacy practices of those websites or pages that are not under our control or of any company that we do not own or control, and this Privacy Policy does not apply to them. We do not endorse any such websites or pages, the services or products described or offered on such websites or pages, or any content appearing on such websites or pages.

XII. CHANGES TO OUR PRIVACY POLICY

We may modify this Privacy Policy at any time. The most recent version of this Privacy Policy is indicated by the effective date at the top of this Privacy Policy. All modifications to this Privacy Policy will be effective immediately upon notice to you, which we may provide by any means, including posting a revised Privacy Policy or other notice on the System.

XIII. CORRESPONDENCE

We welcome your questions and comments about the System and invite you to send your messages to us at privacy@SeaStarlight .com or through our “Help Center” or our “Contact Us” page. If you correspond with Sea Starlight , we may collect information, including content and metadata about any correspondence you send us. We may share your messages with those in our organization who are best able to address the issues contained in your message.

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