Privacy Policy

1. Introduction

The Red Sky ("we", "our", "us") is operated by Changzhou Jingtu International Trade Co., Ltd. (Business Registration Number: 91320411MADH337131), located at Xinbei District, Longhu Tower Street, Longye Road and Fengwan 3rd Building, Unit 06009, Changzhou, Jiangsu.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website, utilise our yacht club services, or interact with us in any capacity. We are committed to protecting the privacy and security of our members and visitors.

2. Information We Collect

We may collect and process the following categories of personal data:

• Identity Data: Full name, title, date of birth, and identification documents provided during the membership application process.
• Contact Data: Email address, telephone number, postal address.
• Financial Data: Payment card details, bank account information, billing address, and transaction history related to membership fees and charter bookings.
• Membership Data: Application details, membership tier, preferences, vessel usage history, and voyage records.
• Technical Data: IP address, browser type and version, device information, operating system, time zone settings, and browsing actions on our website.
• Usage Data: Information about how you use our website, services, and facilities.
• Communications Data: Records of correspondence between you and The Red Sky, including emails, messages, and call notes.
• Cookie Data: Data collected through cookies and similar tracking technologies (see our Cookie Policy).

3. How We Use Your Information

We use the information we collect for the following purposes:

• Processing and managing your membership application and account.
• Facilitating yacht charters, voyage bookings, and concierge services.
• Processing payments, invoices, and financial transactions.
• Communicating with you about your membership, bookings, events, and club updates.
• Personalising your experience and providing tailored recommendations.
• Improving our website, services, and member facilities.
• Complying with legal and regulatory obligations.
• Protecting the safety and security of our members, staff, and vessels.
• Conducting internal analytics and business planning.

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contractual Necessity: Processing necessary for the performance of your membership agreement or charter contracts.
• Consent: Where you have given explicit consent to processing for specific purposes, such as receiving marketing communications or event invitations.
• Legitimate Interest: Processing necessary for our legitimate business interests, provided these are not overridden by your rights and freedoms. This includes service improvement, security, and fraud prevention.
• Legal Obligation: Processing required to comply with applicable laws, regulations, or court orders.

5. Information Sharing

We do not sell your personal data. We may share your information with:

• Service Providers: Third-party companies that assist us in operating our services, such as payment processors, marina operators, catering partners, and IT service providers. These parties process data only on our behalf and are bound by contractual obligations to protect your information.
• Legal Requirements: Government authorities, regulators, or law enforcement when required by applicable law, regulation, or legal process.
• Business Transfers: In connection with a merger, acquisition, restructuring, or sale of assets, your data may be transferred as part of that transaction.
• Professional Advisors: Lawyers, accountants, auditors, and insurers who provide professional services to us.

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

For active members, data is retained throughout the duration of membership and for a period of seven (7) years following termination, unless a longer retention period is required by law. Website usage data is typically retained for twenty-four (24) months. You may request deletion of your data at any time, subject to our legal obligations.

7. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your personal data under certain circumstances.
• Right to Data Portability: Request transfer of your data to another organisation in a structured, machine-readable format.
• Right to Restrict Processing: Request limitation of processing in certain circumstances.
• Right to Object: Object to processing based on legitimate interest or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at info@theredsky.xyz. We will respond to your request within thirty (30) days.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols.
• Secure storage of data with access controls and authentication requirements.
• Regular security assessments and vulnerability testing.
• Staff training on data protection and confidentiality.
• Incident response procedures for data breach management.

While we strive to protect your personal data, no method of transmission or storage is completely secure. We cannot guarantee absolute security.

9. International Transfers

As The Red Sky operates internationally, your personal data may be transferred to and processed in countries outside your country of residence. When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by relevant authorities.
• Adequacy decisions recognising equivalent levels of data protection.
• Binding corporate rules where applicable.

If you would like more information about the specific safeguards applied to your data, please contact us.

10. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete that information promptly. If you believe we may have collected data from a minor, please contact us immediately.

11. Client Engagement & Project Data

In the course of providing yacht club services, we may collect and process additional data specific to your engagement with The Red Sky:

• Voyage and Charter Records: Details of bookings, itineraries, vessel selections, and special requests.
• Professional Communication Records: Records of discussions, correspondence, and instructions related to your charter and concierge arrangements.
• Service Delivery Data: Performance reports, feedback, and satisfaction surveys.
• Billing and Invoicing Information: Detailed financial records of all transactions, including membership fees, charter costs, and ancillary service charges.

This data is processed on the basis of contractual necessity and legitimate business interest, and is subject to the same security and retention standards outlined in this policy.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will notify you by updating the "Last updated" date at the top of this page and, where appropriate, by sending a direct notification to active members. We encourage you to review this policy periodically.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Changzhou Jingtu International Trade Co., Ltd.
Xinbei District, Longhu Tower Street, Longye Road and Fengwan 3rd Building, Unit 06009
Changzhou, Jiangsu
Business Registration Number: 91320411MADH337131

Email: info@theredsky.xyz
Phone: +31 730400344