Privacy Policy

This policy describes the processing of personal data in connection with the KiteDeck service. The controller is Horizon Makers, a sole proprietorship (entreprise individuelle), 104 place du Maréchal Joffre, 62400 Béthune, France.

Two distinct roles

For the data of client organisations (account, commissions), we act as controller. For the data that those organisations enter about their own customers — cruise participants, bookings, payments — we act as processor: the organisation decides what it collects and why. This second role is governed by the Data Processing Agreement annexed to the Terms of Sale.

Data collected

• Account: email address, name of the organisation, members' roles.
• Commissions: connected Stripe account identifier, amounts of the commissions deducted from online payments. We do not store any payment card numbers.
• Operational data entered by the organisation: boats, cruises, cabins, customers, bookings, payments.
• Boarding-related data, where the organisation enters it: travel document number and expiry date, a copy of that document, skill level, equipment, and on-board comfort information such as dietary requirements. Copies of documents are kept in private storage, accessible only to members of the organisation concerned.
• Technical data: access and security logs necessary for the operation and protection of the service.
• Push notifications, if a member enables them on a device: the subscription address provided by their browser, the keys that encrypt the messages, the browser type, and the dates of creation and of the last delivery. The subscription is deleted when the member turns notifications off, when the browser reports it as expired, or together with the member's account.

The email address and the name of the organisation are required to create an account: without them, the service cannot be provided. All other information is optional, and leaving it out only disables the corresponding feature.

Purposes and legal bases

• Providing the service and performing the contract: performance of a contract.
• Sending sign-in emails and notifications relating to the operation of the service: performance of a contract.
• Invoicing the commission and complying with accounting obligations: legal obligation.
• Securing the service and preventing abuse: legitimate interest.
• Sending push notifications to a member who has enabled them: performance of a contract. The member can turn them off at any time from the service or in their browser settings.

No decision based solely on automated processing, including profiling, is made about you.

Passwordless authentication

Sign-in is by means of a magic link sent by email. We therefore do not store any password. The link received is valid for one hour and can only be used once.

Recipients and hosting

The data is accessible only to authorised persons within the client organisation and to the publisher, to the extent required for the operation of the service. The following processors are involved:

• Vercel — application hosting, running in Ireland (dub1 region, Dublin), and visit statistics for the public website;
• Supabase — database, authentication and storage, on infrastructure located in Ireland (eu-west-1 region);
• Stripe — payment processing;
• Resend — email delivery;
• Upstash — caching and rate limiting, on infrastructure located in the European Union (Ireland);
• Sentry — technical monitoring and error logging, on infrastructure located in the European Union (EU region).
• Browser push services (Google, Apple, Mozilla or Microsoft, depending on the device) — delivery of push notifications. They receive the subscription address and an encrypted message they cannot read.
• Anthropic — the help assistant behind the “Help” button: it receives the questions members ask, the page they ask from, and their language, never the organisation's data (bookings, clients, payments). KiteDeck keeps nothing of it.
• OVH (France) and Google — internal tracking of the feature requests the assistant picks up: the text of the question, the page, language and organisation identifier, without email address or name.

A client organisation may also, on its own initiative and with its own credentials, enable a connector to a third-party service — currently Brevo, for managing its contacts. The data transmitted through that connector then falls outside our scope: the third-party service is that organisation's processor, and the organisation alone is responsible for handling erasure requests relating to it.

Your account and operational data is hosted in the European Union. Vercel and Supabase are companies governed by US law, but the infrastructure they use for this service is located in Ireland. Some providers may, however, transfer data outside the European Union, in particular to the United States: Stripe (payments), Resend (emails), Anthropic (help assistant), Google (request tracking), browser push services, and Vercel and Supabase for support access. These transfers rely on the EU–US Data Privacy Framework where the provider is certified under it, and otherwise on the European Commission's standard contractual clauses included in their contracts. A copy of these safeguards can be obtained by writing to contact@kitedeck.fr.

Retention periods

• The organisation's account and operational data: for the entire term of the contract, then deleted thirty days after the request for closure. This period gives you time to export your data or to change your mind; once it has elapsed, erasure is permanent and we cannot restore anything.
• A member's sign-in account: deleted together with the last organisation to which the member belongs. An account still linked to another organisation is not affected.
• An organisation's customer record: three years after the end of the customer's last cruise — or after the record was created if the customer has never sailed. A record to which nothing is linked is then simply deleted. If bookings or accounting entries are linked to it, it is anonymised: identity, contact details, notes, dietary requirements, skill level, equipment and travel document are erased, and only the accounting line remains, which no longer identifies anyone.
• Copy of a travel document (scan or photo): twelve months after the end of the customer's last cruise — or after it was uploaded if no cruise has taken place. The file thus lasts a full season, then disappears: a customer who returns the following year has nothing to send again, and a customer who does not return does not leave their identity document with us.
• Travel document number and expiry date: until the document's expiry date, and at the latest until the customer record is erased (see above). An expired document serves no further purpose: it is erased automatically, together with its copy if one remains. Records without an expiry date are subject only to the record's retention period.
• Accounting documents and invoices: ten years, in accordance with legal obligations. Once the record's retention period has elapsed, they are archived separately, with no usable link to an identified person, and are used solely to respond to an audit or a dispute.
• Technical logs: twelve months at most.
• Database backups: fourteen days, on a rolling basis. Erased data disappears from backups when those backups expire; no backup is restored in order to reinstate data deleted at a person's request.

Cookies

The service sets only the cookies necessary for its operation: maintaining the authenticated session and remembering the language chosen on public pages. No advertising cookies are used, which is why no consent banner is required. The full list, with their duration, is in the cookie policy.

The pages of the kitedeck.fr website (home, guide, sign-up, legal pages) are counted by Vercel Web Analytics, provided by our host: page viewed, referring page, country, device and browser type. It sets no cookies and identifies no one: a visitor is not recognised from one day to the next, nor from one site to another. The application and the operators' booking pages are not measured.

Your rights

You have the right of access, rectification, erasure, restriction of processing, objection and data portability. Write to contact@kitedeck.fr. We respond within one month. If you are a customer of an organisation using KiteDeck, please address your request to that organisation: we will forward it to them if it reaches us directly.

You may also set out instructions regarding the retention, erasure and disclosure of your data after your death (Article 85 of the French Data Protection Act, loi Informatique et Libertés).

If you believe your rights have not been respected, you may lodge a complaint with the CNIL (Commission nationale de l'informatique et des libertés, the French data protection supervisory authority, www.cnil.fr).

Two of these rights do not require you to write to us: from the service's “My account” page, the owner of an organisation can at any time download all of its data in CSV format (customers, cruises, bookings, entries, boats), and request the closure of its account. Closure immediately closes the public pages, and triggers complete erasure thirty days later.

The right to erasure is subject to one exception: entries relating to a payment are retained for ten years under accounting obligations. A request for erasure then applies to the identity and contact information, which is deleted, and not to the invoice itself.

Security

Communications are encrypted in transit, access to each organisation's data is segregated at database level, and the database is backed up by our hosting provider.