Complaints Policy

Start here: is it a complaint, or something else?

Some things should not wait in a complaints queue. Check this table first — it will get you to the right place faster than we can.

A complaint about the way we handled a safeguarding concern does belong here, at stage 1 — while the independent safeguarding routes stay open to you at the same time. You never have to exhaust our process before going to someone else.

What this policy covers

This is the complaints procedure for Innovology Ltd, trading as SailCoach. It applies to anyone: a sailor, a parent or guardian, a coach, a club administrator, or someone who does not use the service at all but has been affected by it — for example because their race results appear in our records.

SailCoach is free to use today, so most complaints are about how the product behaves or how we have acted, rather than about money. When paid plans exist, billing complaints will follow this same procedure.

How to complain

Email [email protected]. If it is easier to write to us any other way you already have — replying to an email from us is fine — we will pick it up and route it.

Tell us:

• what happened, with dates and, if it involves something on the platform, the page, the session, the message or the account concerned;
• who was involved, as far as you know;
• what has already been said or done about it, and by whom;
• who you are, including the email address on your SailCoach account if you have one;
• what you want — an explanation, an apology, a decision reversed, data corrected, something changed. Telling us this makes it far more likely you get it.

Send what you have. A short complaint is still a complaint; we will come back to you if we need more.

Complaining on behalf of a child

• A parent or guardian may complain for their child. If the child's account is linked to yours in the product, we can see that and will not ask you to prove it again. If it is not, we will need to confirm the relationship before we discuss the child's personal information with you — that check protects the child, and we will keep it proportionate.
• A child can complain for themselves. We will not refuse a complaint from a young sailor because they did not ask a parent first, and we will reply in language they can actually read. Where the complaint suggests a risk to their safety, we will follow the Safeguarding and Child Protection Policy instead — which may mean telling an adult, and if so we will tell the child that we are doing it and why.
• Someone else can complain for you. A club welfare officer, a friend, an advocate. We will ask for your written say-so before we share your personal information with them.

Anonymous complaints

We accept them and we investigate them. We simply cannot acknowledge them, ask you questions, or tell you the outcome. If you want the matter looked at but do not want your name attached to it, say so in the email — we can usually keep who you are away from the person the complaint is about, even when we cannot keep it from ourselves.

The three stages

Working days are Monday to Friday, excluding public holidays in England and Wales.

If we cannot meet one of those dates, we will tell you before it passes, explain why, and give you a new one. That happens occasionally — where a complaint needs an answer from a club, or where a statutory investigation has to run first. What we will not do is let a deadline go by in silence and hope you have forgotten.

We are a small team. A stage 2 review is genuinely done by a different person from the one who answered at stage 1, and if the complaint is about the only person who could otherwise review it, we will say so and arrange an independent reviewer from outside the company rather than pretend.

What we do if we got it wrong

If we have got something wrong, we will:

• say so plainly. Not "we are sorry you feel that way" — a real apology, for the thing we actually did.
• fix it where it can be fixed: reverse the decision, correct the record, restore the account, delete what should not have been kept.
• tell you what changed as a result. A complaint that produces an apology and nothing else has been absorbed, not answered. Where the cause was a design fault, we will tell you what we are changing and when; where the cause was a policy, we will change the policy, publish a new version of it with an effective date, and leave the old wording published so you can compare them.
• record it. Every complaint, its outcome and any change it produced goes into a log the Safeguarding Lead and the directors review, so that a pattern shows up as a pattern rather than as five separate one-offs.

We will not punish anyone for complaining. Raising a complaint, in good faith, will never cost you your account, your connections or your data.

Complaints about your personal data

Raise it with us first at [email protected] — most data complaints are quicker to fix than to escalate, and Your Data Rights explains what you can ask for and how.

You do not have to come to us first, and you can go to the regulator at any point, including while we are still looking at it.

• In the UK, the supervisory authority is the Information Commissioner's Office. Complain at ico.org.uk/make-a-complaint or call the ICO helpline on 0303 123 1113.
• In the EU or EEA, you may complain to the data protection authority in the country where you live or work. We have not yet appointed an Article 27 representative in the EU. We do need one — the exemption in Article 27(2) is for occasional, low-risk processing, and ours is neither — so this is an overdue step rather than an open question. We will name the representative in our Privacy Policy once appointed. Its absence does not affect your right to complain to your own authority.
• In other countries — we have users in the United States, Canada and Australia — you can complain to your national privacy regulator, and you can always complain to the ICO as well, because that is where we are established.

Complaints about a club or a coach

If your complaint is about how an adult behaved at a club, at an event or on the water — as opposed to what they did on this platform — it usually belongs with the club or with the RYA, not with us.

• The club. Every RYA-affiliated club and recognised training centre should have its own complaints procedure and a named welfare officer. Start there, unless the complaint is about that person or about the club's leadership.
• The RYA. The RYA can act on a club's affiliation, a centre's recognition and an instructor's qualification — none of which we can do. For a safeguarding matter, contact the RYA safeguarding team at [email protected]; see rya.org.uk, under Safeguarding, for the current phone number and the RYA's own reporting form.
• The Local Authority Designated Officer (LADO). If an adult who works or volunteers with children has behaved in a way that may have harmed a child, call your local council and ask for the LADO. This route exists so that the adult's own organisation is not the only body deciding.

We will still help. Tell us anyway at [email protected], and we will say clearly who we think should handle it, help you get it to them, and take whatever action is properly ours — restricting an account, preserving message records, or reporting the matter ourselves where our Safeguarding and Child Protection Policy requires it. What we will not do is pass you between us and a club with neither taking it on.

Where things stand if we cannot agree

If you have been through stage 2 and are still unhappy, and no regulator above covers the subject:

• You retain any legal rights you have. Nothing in this policy limits them, and our Terms of Service set out the governing law: England and Wales.
• There is no ombudsman or alternative dispute resolution scheme covering a free platform of this kind, and we are not going to name a body that would not take your case. If that changes — in particular when paid plans launch — we will say so here.

Complaints we may handle differently

Rarely, we will limit how we deal with a complaint. We will always tell you if we do, and why, and you keep the right to go to an external body.

• Abusive or threatening contact. We will deal with the substance of the complaint and restrict the channel for the behaviour.
• The same complaint, again. Where a matter has been through stage 2 and nothing new has been raised, we will tell you it is closed rather than repeat the process. New evidence reopens it.
• Where a statutory investigation is running. If the police or children's social care are involved, their process takes precedence and ours pauses until they tell us we may continue. We will keep you informed of the pause.

Keeping the record

We keep complaint correspondence and the outcome so that we can spot patterns and show a regulator what we did. Retention periods are in our Data Retention Schedule; a complaint connected to a safeguarding matter concerning a child is kept until that child turns 25, as set out there.

Review

This policy is reviewed every year, and after any complaint that shows the procedure itself is not working. Every version stays published with its effective date.

Tell us if this page is hard to follow, or if the process did not work the way it is described here: [email protected].