Privacy Policy 100CAPTAINS
GENERAL PROVISIONS

1.1. This Privacy Policy (hereinafter referred to as the Policy) governs the processing and use of personal data that 100 CAPTAINS S.R.L. (VAT number 06206390822) (hereinafter referred to as the Operator) receives from clients using the services of the site https://100captains.com and consuming the services provided by the Operator (hereinafter referred to as the User/Users).

1.2. The operator sets as its most important goal and condition the implementation of its activities in compliance with the rights and freedoms of man and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

1.3. By transferring personal data to the Operator through the Site, the User confirms his consent to the use of the specified data under the conditions set out in this Policy. If the User does not agree with the terms of this Policy, he is obliged to immediately stop any use of the Site and the services provided by the Operator. Unconditional acceptance of this Policy is the start of using the Site and the services provided by the User.

1.4. In the Policy, concepts are used with the following meanings:

1.4.1. Website is a collection of information, texts, graphic elements, design, graphics, images, audiovisual works (photos and video materials) and other results of intellectual activity belonging to the Operator, as well as computer programs contained in an information system that ensures the availability of such information on the Internet via network address: https://100captains.com, including all its sections, pages (subdomains), file structure and any other structural elements, source and object code. The transfer of exclusive rights to the User is not the subject of this Policy.

1.4.2. User - a person using the Site and/or consuming services provided by the Operator.

1.4.3. Personal data is any information relating directly or indirectly to a specific or identifiable individual - the User, which the User provides about himself independently during registration or in the process of using the functionality of the Site, as well as in the process of ordering and consuming services provided by the Operator.

1.4.4. Registration - completion by the User of the Registration form/questionnaire located on the Site, as well as provided by the Operator by indicating the necessary information.

1.4.5. Registration form/questionnaire - a form located on the Site or provided by the Operator, which the User must fill out in order to register on the Site and consume the Services provided by the User.

1.4.6. Service(s) - services provided by the Operator on the basis of an agreement (offer) concluded with the User.

1.4.7. The operator is the 100 CAPTAINS S.R.L., Italy, Via Maggiore 143, Baronissi (SA) CAP 84081

1.4.8. Processing of personal data is any action or set of actions with personal data performed using automation tools or without their use. Processing of personal data includes, but is not limited to: collection, recording, systematization, accumulation, storage, clarification (updating, changing ), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.4.9. Automated processing of personal data is the processing of personal data using computer technology.

1.4.10. Dissemination of personal data is actions aimed at disclosing personal data to an indefinite number of persons.

1.4.11. Providing personal data is actions aimed at disclosing personal data to a certain person or a certain circle of persons.

1.4.12. Blocking of personal data is a temporary cessation of the processing of personal data (except for cases where processing is necessary to clarify personal data).

1.4.13. The use of personal data is actions (operations) with personal data performed by the Operator for the purpose of making decisions or performing other actions that give rise to legal consequences in relation to the subject of personal data or other persons or otherwise affecting the rights and freedoms of personal data subjects or other persons.

1.4.14. Destruction of personal data is actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material media of personal data are destroyed.

1.4.15. Depersonalization of personal data is an action as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information.

1.4.16. A personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.

1.4.17. Cookies are User data that is automatically transferred to the Operator during the use of the Site using the software installed on the User’s device. Cookies include IP address, information about the browser and type of operating system of the User’s device, technical characteristics of the equipment and software used by the User, date and time of access to the Site, and other actions performed on the Site.

Using cookies, the server on which the Site is located recognizes the browser used by the User, providing, for example, the registered User with access to areas and services without having to register each time he visits and remembering his settings preferences (language, font size, etc.) for future visits, so there is no need to re-configure them when you visit the Site again or when moving between pages. This means that the Operator may only use statistical data relating to groups of individuals, but will in no way be able to identify any individual person, or information or activities on the website associated with any individual person.

2. PURPOSES OF PROCESSING PERSONAL DATA

2.1. The processing of personal data is limited to the achievement of specific, pre-defined and legitimate purposes.

2.2. The Operator collects and stores only those Personal Data that are necessary for the provision of Services by the Operator and interaction with the User.

2.3. The Operator may process Users’ personal data for the following purposes:

2.3.1. Fulfillment by the Operator of obligations to the User under contracts/agreements concluded with the Operator. Fulfillment of obligations, in particular, includes informing about the date and time of events (including by calling and sending SMS messages, messages in instant messengers and email); sending documents and other information and information necessary for the execution of contracts/agreements concluded between the User and the Operator. Including providing the User with access to services, information and/or materials contained on the Site or other resource used by the Operator to provide Services to the User. As well as posting in the User’s personal account a recording of an online event held with his participation for the purpose of viewing by other participants (Users) of the group in case of missing/lateness or for the purpose of reviewing the recording of an online event to eliminate gaps in understanding the topic/information raised during the online event -event.

2.3.2. Identification of the User for the provision of Services under concluded contracts/agreements.

2.3.3. Sending advertising and informational messages to the User; targeting advertising materials, providing information about the Services, as well as new Services and products of the Operator, special offers/promotions and various events, about gifts due to the User; Happy Birthday. The User may at any time withdraw his consent to the processing of Personal Data for the purposes of processing specified in this paragraph by contacting the Operator in the manner provided for in clause 3.3. of this Policy.

2.3.4. Posting on the Site, in official groups of social networks and other communities of the Operator on the Internet, other advertising and information sources - comments and reviews left by the User about the Services provided by the Operator. The User may at any time withdraw his consent to the processing of Personal Data for the purposes of processing specified in this paragraph by contacting the Operator in the manner provided for in clause 3.3. of this Policy.

2.3.5. Improving the quality of service for Users and modernizing the Operator’s Website by processing requests and applications from the User (anonymized User data).

2.3.6. Statistical and other studies based on anonymized information provided by the User (anonymized User data).

2.4. Cookies may be used to:

1) Settings for the content of web pages, in accordance with the preferences of Users, as well as for User recognition.

2) Creating statistics that help to understand exactly how Users use the Site.

3) Maintaining the Site User session (after authorization on the Site), so that Users do not have to re-enter their login and password on each page of the Site. Some operations on the pages of the Site cannot be performed without the use of cookies, which are technically necessary for the functioning of the Site.
Cookies are also used to calculate audience and traffic parameters, track progress and number of visits to the Site.
Cookies contain data in anonymized form without identifying a specific User.

2.5. When using the Operator's Website, Users confirm their consent to the use of cookies.
In many cases, browsers and mobile devices allow cookies to be stored by default. The user has the right and opportunity, at his own discretion, at any time to configure his browser and mobile device so that the function of installing cookies is disabled, and the user can at any time delete cookies previously installed on his device used to visit the Operator’s Website . By deleting and/or disabling the storage of cookies, the User is deprived of access to some functions of the Site, and his experience of the operation of this Site may be less satisfactory.

2.6. The specific scope of Personal Data processed for the above purposes is defined in Section 4 of this Policy.

3. CONDITIONS AND PROCEDURE FOR PROVIDING CONSENT TO THE PROCESSING OF PERSONAL DATA BY THE OPERATOR

3.1. The Operator receives Personal Data directly from the subjects of personal data. The Operator does not check the Personal Data provided by the User. In this regard, the Operator assumes that when providing personal data the User:

3.1.1. Is a capable person.

3.1.2. Indicates reliable information about himself to the extent necessary to use the Site and consume the Services provided by the Operator, within the framework of concluded contracts/agreements. The User independently keeps the provided Personal Data up to date.

3.1.3. Understands that information on the Site posted by the User about himself may become available to other Users of the Site and may be copied and distributed by such Users.

3.2. The Operator processes the User’s personal data if it is filled out and/or sent by the User independently through special forms located on the Site and/or other resources used by the Operator to provide services to the User. By filling out the appropriate forms and/or sending his Personal data to the Operator, the User expresses his consent to this Policy. The User accepts the terms of the Policy and gives the Operator informed and conscious consent to the processing of his personal data in the following order:

3.2.1. During any use of the Site - for Cookies.

3.2.2. When registering on the Site and/or other resources used by the Operator to provide Services to the User - for Personal Data that the User provides to the Operator:

— by filling out a form to place an order for the Services provided by the Operator, located on the Internet on the Contractor’s Website;

— by authorization using Personal data specified by the User on social networks or electronic services;

— providing the Operator with documents and other information containing Personal Data that the User provides for the conclusion and proper execution by the Operator of the agreement/contract concluded with the User.

3.2.3. When entering or changing Personal Data - for Personal Data that the User provides when editing or adding information.

3.2.4. When using any other method of transferring Personal Data (including through a message in a telephone conversation, correspondence with the Operator, filling out questionnaires provided by the Operator, etc.) - for all Personal Data transferred to the Operator, as well as for Personal Data that the User provides when editing or adding information.

3.3. After the User expresses consent to this Policy and provides consent to the processing of Personal Data, a confirmation letter is sent to the User by email, by replying to which the User confirms consent to the processing of Personal Data and agreement with the Policy.

3.4. The User’s consent to the processing of his Personal data by the Operator is valid indefinitely. The period for processing personal data is unlimited, and the User may at any time withdraw his consent to the processing of Personal Data by sending a notification to the Operator via email to the Operator's email address 100captains@100pec.it with the note “Withdrawal of consent to the processing of Personal Data.”

3.5. All information that is collected by third-party services, including payment systems, communications and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy (Personal Data Processing Policy). The user is obliged to familiarize himself with these documents in a timely manner. The operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

4. PERSONAL DATA PROCESSED BY THE OPERATOR

4.1. The content and scope of the Personal Data processed correspond to the stated purposes of processing.

4.2. The User’s personal data processed by the Operator includes: last name, first name, patronymic (if any); telephone, email address; data specified in the account of any social network; photo and video image of the User; Date of Birth; floor; place of residence; passport details; passport details; information on clothing size (for polo and long sleeve); information about the place of residence during the period of participation in events organized by the Operator (regattas); information about the sport that the User is interested in; information about readiness to become a leader in sports activities at events (regattas) organized by the Operator; information about the purpose of the User’s participation in events organized and conducted by the Operator (regatta); information about allergies and the presence of serious diseases; information about the date/time of arrival/departure from the venue of events organized by the Operator; information about the airport of arrival/departure; arrival/departure flight number; information about yachting experience; preferred topics for communication; expectations from participation in the community organized by the Operator; information that the User can give to the community organized by the Operator, information and copies of any documents provided by the User; User nickname, information for cookies.

4.3. Processing of Personal Data not specified in clause 4.2. of this Policy is permitted if the User has consented to the processing of such Personal Data.

4.4. Some of the Personal Data processed by the Operator are disclosed to him at the User’s request. In this case, the Operator processes such Personal Data of the User only if it is provided.

5. PRINCIPLES, PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL AND OTHER DATA

5.1. The processing of Personal Data is carried out on a legal and fair basis.

5.2. Processing of Personal Data is carried out in compliance with the principles and rules provided for by the Federal Law.

5.3. The processing of Personal Data by the Operator is limited to the achievement of specific, predetermined and legitimate purposes. Only Personal Data that meet the purposes of their processing are subject to processing. The content and volume of Personal Data processed must correspond to the stated purposes of processing. Processing of Personal Data is carried out with the User’s consent to the processing of his Personal Data.

5.4. The processing of the User's Personal Data is carried out by the Operator using databases on the territory of the European Union.

5.5. Personal data is processed using automated systems, except in cases where non-automated processing of Personal data occurs.

5.6. The Operator has the right to entrust the processing of Personal Data to another person on the basis of an agreement concluded with this person, including a state or municipal contract. The person processing Personal Data on behalf of the Operator is obliged to comply with the principles and rules for processing Personal Data provided for by the Law on Personal Data.

5.7. Processing of the User's Personal Data includes the following actions by the Operator: collection, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.

5.8. Storage of Users' Personal Data is carried out on electronic and tangible media. Confidentiality is maintained with respect to the User's Personal Data, except in cases where the specified data is publicly available.

5.9. The Operator has the right to retain an archived copy of Personal Data, including after deleting the User’s account.

5.10. The Operator has the right to transfer the User’s Personal Data without the User’s consent in cases directly provided for by the current legislation of the European Union.

5.11. The Operator has the right to transfer Personal Data to third parties only with the User’s consent, in the following cases:

5.11.1. the transfer is necessary as part of the User’s use of the Site or the provision of Services to the User;

5.11.2. the transfer occurs as part of the sale or other transfer of a business (in whole or in part), and all obligations to comply with the terms of this Policy are transferred to the acquirer.

5.12. Distribution of Personal Data (nickname, photo/video) of the User can be carried out by the User or on his behalf by the Operator at the request of the User only in the following cases:

5.12.1. When processing Personal Data for the purpose of displaying the User’s profile for other Users of the Site and/or other resources used by the Operator to provide Services to the User, to maintain communication, including when providing Services remotely.

5.12.2. When the User leaves comments or reviews about the Services provided by the Operator within the framework of the contract/agreement concluded between them.

5.12.3. Posting a video recording of events of this group in the Users’ personal account for the purpose of viewing a recording of an event held and missed, organized and conducted by the Operator as part of the provision of Services in the event of a missed event or being late for it.

5.12.4. Posting video recordings of events of this group in the Users’ personal account for the purpose of reviewing the recording of the event organized and conducted by the Operator as part of the provision of Services to eliminate gaps in understanding the topic discussed at the event.

5.13. The User’s personal data and cases of their use specified in clause 5.12. of this Policy may be available to other Users of the Site and/or other resources used by the Operator to provide Services to the User.

6. MEASURES TAKEN BY THE OPERATOR TO PROTECT PERSONAL DATA

6.1. The Operator takes necessary and sufficient legal, organizational and technical measures to protect information provided by Users from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties. Such measures include in particular the following:

6.1.1. provides unlimited access to the Policy, which is posted on the Operator’s Website;

6.1.2. establishes rules for access to Personal Data processed in the Operator’s information system, and also ensures registration and accounting of all actions with it;

6.1.3. assesses the harm that may be caused to Users in case of violation of the Law on Personal Data;

6.1.4. identifies threats to the security of Personal Data during their processing in the Operator’s information system;

6.1.5. evaluates the effectiveness of measures taken to ensure the security of Personal Data before putting the Operator’s information system into operation.

6.2. The Operator ensures the confidentiality of Personal Data, ensures its safety and takes all possible measures to prevent access to Personal Data by unauthorized persons.

6.3. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the User has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract/agreement.

6.4. Databases of information containing Personal data of citizens of the European Union are located on the territory of the European Union.

7. RIGHTS AND OBLIGATIONS OF USERS

7.1. The user has the right:

7.1.1. At its discretion, provide the Operator with Personal Data for processing under the conditions specified in the Policy;

7.1.2. Independently make changes and corrections to your Personal Data, provided that such changes and corrections contain current and reliable information;

7.1.3. To withdraw consent to the processing of Personal Data;

7.1.4. Contact the Operator with requirements, including clarification of Personal Data; on blocking or destruction of Personal data if such data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights.

7.1.5. The User has the right to receive information regarding the processing of his Personal Data, including containing:

1) confirmation of the fact of processing of Personal Data by the Operator;

2) legal grounds and purposes of processing Personal Data;

3) the purposes and methods of processing Personal Data used by the Operator;

4) name and location of the Operator, information about persons (except for the Operator’s employees) who have access to Personal Data or to whom Personal Data may be disclosed on the basis of a contract/agreement with the Operator or on the basis of the Law on Personal Data;

5) processed Personal data related to the relevant User, the source of their receipt, unless a different procedure for presenting such data is provided for by the Law on Personal Data;

6) terms of processing of Personal data, including periods of their storage;

7) the procedure for the User to exercise these rights provided for by the Law on Personal Data;

8) information about completed or intended cross-border data transfer;

9) name or surname, first name, patronymic and address of the person processing Personal Data on behalf of the Operator, if the processing has been or will be assigned to such a person;

10) information on how the Operator fulfills the obligations established by Art. 18.1. Personal Data Law;

11) other information provided for by the Law on Personal Data or other federal laws. The User has the right to contact the Operator to obtain the information specified in this paragraph in the manner prescribed by the Law on Personal Data.

7.2. The user is obliged:

7.2.1. provide the Operator with reliable information about yourself;

7.2.2. inform the Operator about clarification (updating, changing) of your Personal data;

7.3. Users who provided the Operator with false information about themselves are liable in accordance with the legislation of the European Union.

8. RIGHTS AND OBLIGATIONS OF THE OPERATOR

8.1. The operator has the right:

8.1.1. receive from the User reliable information and/or documents containing personal data;

8.1.2. if the User withdraws consent to the processing of Personal Data, the Operator has the right to continue processing Personal Data without the User’s consent if there are grounds specified in the Personal Data Law;

8.1.3. independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and regulations adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws; 8.1.4. defend your interests in court.

8.2. The operator is obliged:

8.2.1. provide the User, at his request, with information regarding the processing of his Personal Data;

8.2.2. organize the processing of Personal Data in the manner established by the current legislation of the European Union;

8.2.3. respond to requests and requests from Users in accordance with the requirements of the Personal Data Law;

8.2.4. report to the authorized body for the protection of the rights of personal data subjects, at the request of this body, the necessary information within 10 working days from the date of receipt of such a request. This period may be extended, but not more than by 5 working days if the Operator sends a motivated notification to the authorized body for the protection of the rights of personal data subjects indicating the reasons for extending the period for providing the requested information;

8.2.5. publish this Policy on the Site or otherwise provide unrestricted access to this Policy regarding the processing of Personal Data;

8.2.6. take legal, organizational and technical measures to protect Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of Personal Data, as well as from other unlawful actions in relation to Personal Data;

8.2.7. stop transfer (distribution, provision, access) of Personal Data, stop processing and destroy Personal Data in the manner and cases provided for by the Law on Personal Data;

8.2.8. When collecting Personal Data, including through the information and telecommunications network "Internet", the Operator is obliged to ensure recording, systematization, accumulation, storage, clarification (updating, changing), retrieving personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation. Federation, except for the cases specified in paragraphs 2, 3, 4, 8 of part 1 of article 6 of the Law on Personal Data;

8.2.9. perform other duties provided for by the Personal Data Law.

9. POLICY CHANGE

9.1. The Operator reserves the right to make changes to the Policy at its own discretion, including in cases where this is caused by changes in legislation or conditions of use of the Site services and/or other resources used by the Operator to provide Services to the User.

9.2. The new version of the Policy comes into force from the moment it is posted in the appropriate section of the Operator’s Website. The User undertakes to independently monitor changes to the Policy by familiarizing himself with the current edition. Continued use of the Site or its services and/or other resources used by the Operator to provide Services to the User after the publication of a new version of the Policy means acceptance of the Policy and its terms by the User. In case of disagreement with the terms of the Policy, the User must immediately stop using the Site and its services, as well as other resources used by the Operator to provide Services to the User.

10. FINAL PROVISIONS

10.1. The User can receive any clarification on issues of interest regarding the processing of his Personal Data by contacting the Operator via email 100captains@100pec.it.

10.2. This Policy and the relationship between the User and the Operator arising in connection with the application of the Policy are subject to the law of the Russian Federation.

11. OPERATOR CONTACT INFORMATION

11.1. Phone: +374 91 145159

11.2. E-mail: 100captains@pec.it

11.3. Address: Italy, Via Maggiore 143, Baronissi (SA) CAP 84081