Privacy Policy
Information notice pursuant to articles 13-14 and 26 of Regulation (EU) 2016/679 (GDPR) · Last updated: May 20, 2026
1. Who we are
The website corsi.differentsailing.it is operated by Società Sportiva Dilettantistica Different Sail Srl (an Italian amateur sports association), which operates under the “Different Sailing” brand and is dedicated to sailing courses, boating licence courses and training experiences for its members. This notice describes how we collect, use, store and protect your personal data, in compliance with the GDPR.
For sailing holidays, charters and rentals there is a separate website (differentsailing.it), operated by Ecosailing S.r.l., with its own notice.
2. Data Controllers
2.1 Processing for contractual and membership purposes (independent controllership)
For processing relating to registrations, membership, contracts, payments and educational and administrative management, the Data Controller is:
- Società Sportiva Dilettantistica Different Sail Srl
- Registered office: Via A. Graf 51, 00137 Rome (RM), Italy
- VAT / Tax code: 18039551009
- Certified email (PEC): differentsail@pec.it
- Privacy email: privacy@differentsailing.it
2.2 Processing under joint controllership (brand analytics and marketing)
Only for the processing carried out through the shared analytics and marketing tools of the “Different Sailing” brand (Google Analytics 4, Meta Pixel, Meta Conversions API, Google Ads), which operate in a unified way across corsi.differentsailing.it and differentsailing.it, the controllers act jointly as joint controllers under art. 26 GDPR:
- Società Sportiva Dilettantistica Different Sail Srl – operator of the Courses area;
- Ecosailing S.r.l. – operator of the Holidays and Rentals area.
3. Summary of the Joint Controllership Arrangement (art. 26(2) GDPR)
- Lead Joint Controller: Ecosailing S.r.l.
- Single Point of Contact for exercising your rights: privacy@differentsailing.it
You may exercise your rights against any Joint Controller and you have the right to lodge a complaint with the Italian Data Protection Authority (Garante) (www.garanteprivacy.it).
4. Data Collected, Purposes and Legal Bases
4.1 Browsing the website (technical data and cookies)
| Data | Purpose | Legal basis |
|---|---|---|
| IP address, browser, operating system, pages visited | Aggregated brand analytics | Legitimate interest (joint controllers) – subject to consent if not anonymised |
| Technical session cookies | Website operation | Technical necessity |
| Statistical cookies (GA4) | Traffic measurement | Consent |
| Marketing cookies (Meta Pixel, Google Ads) | Advertising and retargeting | Consent |
4.2 Registration for Courses and Experiences
| Data | Purpose | Legal basis |
|---|---|---|
| First name, surname, email, phone | Management of registration, membership and contract | Performance of the contract / membership relationship (art. 6(1)(b) GDPR) |
| Health data relevant to safety | Safety at sea and insurance obligations | Explicit consent (art. 9(2)(a) GDPR) / legal obligations |
| Tax code | Tax and sports compliance (membership) | Legal obligation (art. 6(1)(c) GDPR) |
| Digital signature (Yousign) | Conclusion and proof of the contract | Performance of the contract |
| Images/videos during the activity | Brand promotion | Consent (art. 6(1)(a) GDPR) – revocable |
4.3 Marketing and profiling
| Purpose | Legal basis | Tool |
|---|---|---|
| Newsletter and brand offers | Consent (art. 6(1)(a) GDPR) | CRM + email marketing |
| Retargeting and online advertising | Consent | Meta Pixel, Google Ads |
| Behavioural profiling | Explicit consent | GA4 Audiences |
5. Cookies
The complete list of cookies, their durations and consent management are described in the Cookie Policy.
6. Third-Party Services and Providers (Processors under art. 28 GDPR)
| Service | Provider | Data category | Transfer outside the EU |
|---|---|---|---|
| Digital signature | Yousign SAS | Identification data + signature | EU (France) |
| Online payments (card, Apple Pay, Google Pay) | Stripe, Inc. | Payment data | USA (SCC) |
| Instalment payments (BNPL) | Klarna Bank AB | Payment data | EU (Sweden) |
| Analytics | Google LLC (GA4) | Browsing data | USA (SCC) |
| Advertising and retargeting | Meta Platforms, Inc. | Browsing data + profiling | USA (SCC) |
| Advertising (Google Ads) | Google LLC | Browsing data + conversions | USA (SCC) |
| CMP (cookies) | CookieYes Ltd | Consents | EU (Ireland) |
| Email marketing | Acumbamail SL | EU (Spain) | |
| CRM, chatbot and live chat | Kommo (Kommo Inc.) | Contact data and conversation content | USA (SCC) |
| DNS and anti-spam protection (Turnstile) | Cloudflare, Inc. | IP and technical request data | USA (SCC) |
| Hosting / server | Hetzner Online GmbH | All website data | EU (Germany) |
| Domains and PEC | Aruba S.p.A. | Contact data | EU (Italy) |
| Business email | Google Workspace (Google Ireland Ltd) | Email content | EU / USA (SCC) |
7. Data Retention
| Category | Retention period |
|---|---|
| Contractual data (registrations, contracts) | 10 years from performance of the contract (civil and tax obligations) |
| Payment data | 10 years |
| Medical certificates and sports membership | For the duration of the membership + 5 years |
| Marketing data (subject to consent) | Until consent is withdrawn |
| Statistical cookies (GA4) | 13 months |
| Marketing cookies | 90 days (average) |
| Security data and system logs | 12 months |
8. Your Rights
Under articles 15-22 GDPR you have the right to access, rectify, erase, restrict and port your data, to object to processing for marketing, and to withdraw consent at any time (without affecting the lawfulness of processing carried out beforehand).
How to exercise your rights: send a request to privacy@differentsailing.it. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante) (www.garanteprivacy.it).
9. Use of Images and Videos
During courses and experiences, the Company or its collaborators may collect images and videos for promotional purposes. Consent is part of the document signed at registration (Yousign) and is revocable at any time by writing to privacy@differentsailing.it. Publishing recognisable images of minors without the written authorisation of parents or legal guardians is prohibited.
