Privacy Policy

Who we are

Morvargh Sailing Project is a Community Interest Company (Click here to find out more about CIC's) registered in England and Wales (Company No. 7132688). We are the data controller responsible for the personal information processed through this website and in connection with our voyages, events, and volunteering opportunities.

At a glance

• We only collect the information we need to respond to enquiries, deliver our services, meet legal obligations, and keep everyone who sails with us safe.
• We do not use Google Analytics, Facebook Pixel, or any other third-party tracking tags. We rely solely on essential, privacy-first analytics generated by our own systems.
• We never sell personal information and only share it with trusted partners when it is strictly necessary and lawful.
• You remain in control of your information and can request access, updates, or deletion at any time.

Information we collect

Depending on how you interact with us, we may collect (the list below is indicative):

• Contact details:
  Such as name, email address, telephone number, and postal address.
• Voyage participation details:
  Including date of birth, medical information, emergency contacts, and relevant qualifications needed to manage risk and ensure safeguarding.
• Payment and donation records:
  Processed securely through approved providers.
• Volunteer and safeguarding information:
  Required to complete background checks and meet regulatory standards.
• Technical information:
  Like anonymised server logs that help us maintain the website's security and reliability.

How we use your information

We use personal data to:

• Respond to enquiries, provide voyage details, and manage bookings.
• Deliver safeguarding, welfare, and health & safety obligations for everyone on board.
• Administer donations and supporter communications where you have asked us to.
• Run volunteering programmes, including collecting references and Disclosure and Barring Service checks (you can read more about DBS here).
• Maintain secure systems, detect fraud, and comply with legal or insurance requirements.
• Send updates about voyages, opportunities, and the work of Morvargh Sailing Project, where you have requested this, or where we have an existing relationship, and it is reasonable to do so. You can opt out of these communications at any time.

Lawful basis for processing

Our legal basis under UK data protection law includes consent, contractual necessity, legitimate interests, and compliance with legal obligations (for example, safeguarding regulations, maritime requirements, and governance requirements).

Where we send email communications about our voyages and related activities, we rely on either your consent or, where applicable, our legitimate interests under the “soft opt-in” rule. This applies where you have previously booked a voyage, made a donation, or otherwise engaged with us, and the communication relates to similar services. In all cases, you will be given a clear opportunity to opt out at the point your data is collected and in every subsequent communication.

Cookies and analytics

Our website uses only first-party cookies that are necessary for security, logged-in functionality, and basic performance insights. We do not set optional cookies, run behavioural advertising, or load any third-party tracking scripts, such as Google Analytics, Google Tag Manager, Facebook Pixel, or similar tags.

We currently set the following cookies:

• PHPSESSID (session cookie) — created automatically when you sign in to secure areas or submit certain forms. It keeps you logged in during a visit and expires when you close your browser.
• an_session (30 minutes) — a short-lived identifier generated by our self-hosted analytics so that we can understand high-level page usage and keep the site running smoothly.
• an_user (12 months) — a long-lived identifier used by the same analytics tool to recognise returning visits in an aggregated, pseudonymised way.
• an_optout (12 months, only if you create it) — an optional cookie you can set to the value 1 to prevent our analytics from recording your visit. Contact us if you would like help setting this cookie.

The analytics cookies above are first-party, do not collect personal identifiers such as names or email addresses, and are only used to generate aggregated statistics (for example, total page views and general device types). IP addresses are hashed with a secret salt before storage, and we never build individual visitor profiles.

Who we share information with

We only share personal data when it is essential. Recipients include:

• Qualified crew, safeguarding leads, and medical professionals to keep participants safe.
• Emergency services, but only when we have a legal obligation or vital interest to do so.
• Accredited regulators: We only share the specific information listed below with accredited regulators, and only where it is necessary and lawful to do so:
  • Association of Sail Training Organisations (ASTO)
    What we share: Anonymised participant data and statistics, photos. videos, and testimonials/quotes
  • Sail Training International (STI)
    What we share: Anonymised participant data and statistics, photos. videos, and testimonials/quotes
  • The Royal Yachting Association (RYA)
    What we share: Safety management system; risk assessments; volunteer qualifications; and accident statistics. Where we deliver RYA training and qualifications, we may also share relevant participant information required to register and process certifications. This may include name, date of birth, and contact details such as address. The exact information shared will depend on the specific qualification and RYA requirements.
  • Marine Accident Investigation Branch (MAIB) & Maritime & Coastguard Agency (MCA)
    What we share: If required due to an incident, Full participant data, Full volunteer data, Safety management system, Risk assessments etc, to report on the casualty
• Payment processors and cloud service providers that help us deliver our services securely.
• We use EmailOctopus to manage and send bulk email communications, including updates on voyages, opportunities, and our work. When you receive these types of emails from us, your name and email address may be securely stored and processed by EmailOctopus on our behalf. EmailOctopus acts as a data processor and only processes your data in accordance with our instructions and applicable data protection law. You may unsubscribe at any time.

We never sell or lease your personal data.

International data transfers

We occasionally operate voyages that visit countries within the European Union and further afield. To secure the necessary permissions for crew and participants to enter or leave these countries, we may be required to share relevant personal information with customs, immigration, or border enforcement authorities.

This information may include full participant and volunteer details such as passport data, nationality, date of birth, and voyage-related travel information. In some cases, where required by law or regulation (for example, under the EU Entry/Exit System), this may also include biometric identifiers such as facial images or fingerprints.

We only share this information when it is legally required and proportionate to the purpose of border clearance. Data is transmitted through secure, approved systems; however, once shared, it becomes subject to the data protection laws and practices of the receiving country, which may differ from those in the United Kingdom.

How long do we keep information

We retain personal data only for as long as needed to fulfil the purpose for which it was collected and to meet legal, accounting, or reporting requirements. 

How do we keep information secure

We implement technical and organisational measures to protect your data, including encrypted communications, access controls, staff training, and regular security reviews of our systems and third-party suppliers.

Your rights

You have the right to:

• Request access to the personal data we hold about you.
• Ask for inaccuracies to be corrected or for incomplete information to be completed.
• Request deletion or restriction of your data in certain circumstances.
• Object to processing based on legitimate interests or withdraw consent where we rely on it.
• Receive your data in a portable format, where applicable.
• Lodge a complaint with the Information Commissioner's Office (ICO) if you are unhappy with how we handle your data.

Contact us

To exercise your rights or ask any questions about this policy, please contact:

Matt Barraud
Morvargh Sailing Project
Willow Barn, Lower Bodwen, Redmoor, Cornwall, PL30 5AT
matt@sailadventure.co.uk 

You can also contact the Information Commissioner's Office at ico.org.uk or call 0303 123 1113.