Your Data Rights

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You have rights over the information SailCoach holds about you. This page is a how-to, not a recital of the law: what each right actually gets you here, what its real limits are, and exactly how to ask.

One address does all of it: [email protected].

Innovology Ltd, trading as SailCoach and registered in England and Wales, is the data controller. What we hold and why is in the Privacy Policy. How long we keep it is in the Data Retention Schedule, which is unusually blunt about what is automated and what is not — worth reading before you ask, because it tells you what we will actually be able to do.

Three groups of people should skip ahead:

• Parents and carers — see "Parents and children" below.
• People who never signed up but whose name is in race results we collected — see "If you are not a SailCoach user" below.
• Anyone who wants to complain — see "Complaining" at the end.

Your rights, one at a time

The right to be told what we hold, and to get a copy

What it means. You can ask for confirmation that we hold information about you, a copy of it, and an explanation of where it came from, who we share it with and how long we keep it. This is often called a subject access request.

What it gets you here. A copy of your account and profile, your training sessions, coach notes about you, session feedback and assessments, your own notes, goals and reflections, your messages, photos and video of you, any health or emergency-contact information on your record, your weight entries, your analytics and audit trail, and any race results, GPS tracks or ratings we hold about you.

Two things called "private", and only one of them is hidden from you. A coach note marked private is private from the other sailors on the session, not from you — you can already open it in the app. A coach's session feedback marked private is different: it is written for coaches and is not shown to you at all. That is still your personal data and you can ask us for it, so if that is the part you want, say "the private feedback" and we will know what you mean.

The real limits.

• We have no automated export. A person assembles your copy by hand from the stores listed in the Data Retention Schedule. We are building a self-service export; until then, expect us to use the full month.
• A copy of your data must not hand over someone else's. Where a coach note, a message thread or a report names another person, we remove or summarise the parts that are about them. We will tell you where we have done that.
• We may withhold material that would prejudice a live safeguarding enquiry or a criminal investigation. If we do, we say so unless saying so would itself cause the harm.

The right to have things corrected

What it means. If something we hold is wrong or incomplete, you can have it put right.

What it gets you here. Most of your profile — name, contact details, medical notes, emergency contact — you can edit yourself in the app, which is faster than asking us. For everything else, tell us what is wrong and what it should say, and we will change it and tell anyone we have shared it with.

Date of birth is a special case. You can edit it yourself today, and you should not be able to: it is the field that decides whether a guardian can see a sailor's account, so a sailor can currently switch their own parent off by changing it. We are locking it, so that a change for a sailor under 18 needs a guardian or us. Until then, if it is wrong or you changed it by accident, email [email protected].

The real limit worth knowing. A coach's assessment is an opinion, and an opinion is not wrong just because you disagree with it. We will correct a factual error inside it without argument — a wrong date, a wrong boat, a wrong race. Where you dispute the judgement rather than the facts, we will not rewrite the coach's view, but we will record on the file that you dispute it and attach your account, so anyone reading it reads both. That is what the law asks of us and it is also the fairer outcome.

The right to have things deleted

What it means. Often called the right to be forgotten. You can ask us to erase your information.

What it gets you here. Ask and we will close your account and delete your records across every store in the Data Retention Schedule, including photos, video and files, within 30 days. You can also ask for something narrower — just the video, just the weight history, just the race results — without closing your account.

The real limits.

• It is manual. There is no "delete my account" button and no automatic cascade. A person does the work against a written checklist. We are building the automated version; it is the top item on our list.
• Backups. A snapshot taken before your deletion may still contain your data. We put that data beyond use, never use it, and re-apply your deletion immediately if we ever restore. It goes for good when the snapshot is destroyed. Every organisation with backups has this limitation; ours is described in full in the Data Retention Schedule.
• Safeguarding records survive. If something we hold forms part of a concern about a child's welfare, we keep it — see Safeguarding. Protecting a child outranks a deletion request.
• Other people's copies. Messages you sent stay in the other person's conversation. Deleting your account does not reach into their record of a conversation you both had.
• Published results elsewhere. We can remove a result from SailCoach. We cannot remove it from the club website or results archive it was published on. We will tell you who to ask.

The right to have us pause

What it means. The right to restriction. You can tell us to stop using information while something is being sorted out — while you are challenging its accuracy, for example, or while we are considering an objection.

What it gets you here. We take the record out of active use: it stops feeding ratings, analysis and any coaching view, and it is not shared further. We keep it, but we do not act on it, until the matter is settled.

The real limit. There is no "restricted" switch in the product. We do this by hand — removing the record from the surfaces that use it and recording the restriction in writing — and we lift it in writing too. It works, but it depends on us, so ask us to confirm in writing when we have applied it.

The right to take your data elsewhere

What it means. Portability. Where you gave us information and we process it because you agreed or because we need it to provide the service, you can have it in a machine-readable format, or have us send it to another provider.

What it gets you here. A structured file — JSON, or CSV where that is more useful — containing your profile, your own notes, goals, reflections and self-entered results, the sessions you took part in, and messages you sent.

The real limits.

• We assemble it by hand today. Same one-month timescale.
• It covers information you provided. It does not cover our analysis of it — your competitive rating, for example, is something we worked out, not something you gave us. You can still ask for a copy of it under the access right above; it just is not portable.
• It does not cover information a coach wrote about you, or race results we collected from elsewhere, for the same reason. Again, access still gets you a copy.
• Sending directly to another provider is only possible where that is technically feasible. In practice it means we give you the file.

The right to object

What it means. You can object to processing we do because it is in our legitimate interests, and we must stop unless we can show compelling grounds that override your interests. For direct marketing the right is absolute — no argument, we simply stop.

What it gets you here. The processing we do on legitimate-interests grounds is: the signup-journey reconstruction built from product analytics; the race-results corpus, identity matching and competitive ratings; security, audit and abuse-prevention logging; the automatic check on private messages and the message audit log that goes with it; linking a guardian to a child; recording and verifying coach qualifications and DBS checks; and sending coaching text about you to our AI provider. You can object to any of them.

• Analytics and the journey reconstruction: we stop and delete the events we hold about you. Collection itself is consent-based, so the faster route is the cookie panel — see "The right to withdraw consent" below.
• Race results, identity matching and ratings: we remove you. In practice we treat this the same as a deletion request, because keeping a record we cannot use is worse for you than removing it.
• Message checking and the message audit log: for a sailor under 18 we will usually decline, because the log is how a report gets investigated. For an adult account we will look at it on its merits. Either way we explain the reasoning. Be clear about what you would be objecting to: the automatic check is a short list of offensive words, not a grooming detector.
• Guardian links, coach qualifications and DBS records: we will look at each on its facts. A guardian link exists to protect a child and we will not usually remove it while the sailor is under 18; a coach can withdraw their own qualification records and we will delete them.
• The AI processing: there is no per-person switch for this in the product. Nobody's name is sent, but the coaching prose is, so we will accept the objection and stop using the feature on the sessions you are in. That is an instruction to your coaches rather than a setting, and we will confirm it in writing.
• Security and audit logs: we will usually decline, because keeping a record of who accessed what is how we protect everyone else's children's data. We will explain our reasoning to you rather than just refusing.

We do not send marketing email today. If we start, you will be able to refuse it in one click and objecting will be absolute.

The right to withdraw consent

What it means. Where we asked for your agreement, you can take it back at any time, and it must be as easy to withdraw as it was to give. Withdrawing does not make what we did before it unlawful.

What it gets you here. Consent is what we rely on for non-essential cookies and similar storage, and for sharing choices you made — which coaches can see your data, which parent is linked to your account.

• Sharing choices: you can change or revoke a connection or a data-sharing setting in the app at any time.
• Cookies and analytics: we ask before we store anything optional, and you can change your answer at any time from the panel on the Cookie Policy page. Withdrawing takes one tap, stops collection immediately, and deletes the keys that category had stored in your browser. Signing out clears the analytics identifier too, and if your browser sends a Global Privacy Control signal we treat that as a refusal without asking you at all. If you also want the events we have already collected deleted, email [email protected] and we will remove them — we do that by hand, because we have no list that keeps you out of collection on the server.

Rights about automated decisions and profiling

What it means. You have the right not to be subject to a decision based solely on automated processing that has a legal effect on you or something similarly significant, and to be told when we are profiling you.

What it gets you here. We do profile. Specifically:

• We calculate a competitive rating from race results using a statistical model.
• We match names and sail numbers across events to work out that two results are the same person.
• We check messages automatically against a short list of offensive words and flag a match for a human to look at. That check does not detect grooming. A pattern-based grooming check exists in our code but is not applied to messages — do not rely on it as though it were. The Safeguarding Policy says what we are building and by when.
• We send coach feedback text to an AI service to summarise it and gauge its tone. No sailor is named in what we send. What that involves, and what it is not allowed to decide, is set out in How we use AI.

None of these makes a decision about you on its own. Nothing here decides whether you can use the platform, whether you are selected for anything, or what a coach does. A flagged message is reviewed by a person. A rating is information, not a gate.

What you can ask for anyway. If a rating, a match or a flag affects you and you think it is wrong, ask us at [email protected]. A person will look at it, explain how it was reached, and change it if it is wrong. We will not hide behind "the system did it".

How to make a request

Email [email protected].

You do not need to use any particular words, cite any article, or fill in a form. "What do you have about my daughter?" is a valid request and we will treat it as one. A request made in a message to a coach or in an ordinary email to [email protected] still counts — but the privacy address gets it to the right person fastest.

It helps if you tell us:

• Which right you are exercising, or just what you want to happen.
• Who the request is about — you, or a child you are responsible for.
• The email address on the account, if there is one.
• How much you want, if you only want part of it. "Just the video from the July sessions" is far quicker for both of us than everything.

Proving who you are

We have to be sure we are not handing a child's coaching record, medical notes or private messages to the wrong person. But the Information Commissioner's Office is clear that we must not use identity checks as an obstacle, and we do not.

• Normally, replying from the email address on the account is enough. That is the whole check.
• If you cannot use that address, we will ask for something proportionate — enough detail about the account that only its owner would know, or confirmation from the linked parent or club.
• We will not routinely demand a passport, driving licence or photo ID, and we will not ask for a document simply because it is a convenient hurdle. If a case ever genuinely needs stronger proof, we will explain precisely why.
• The clock starts when we have what we need to identify you. If we ask for more, we ask quickly.

How long we take

• We acknowledge within five working days.
• We complete within one month of receiving your request, or of receiving the information we needed to identify you.
• We can extend by up to two further months where a request is genuinely complex, or where you have made several requests together. If we need the extension we will tell you within the first month, and we will say why. We will not use an extension as a way of putting you off, and "we are a small team" is not on its own a good enough reason.
• A narrow request is usually done in days. Ask for the part you want.

What it costs

Nothing. Handling your request is free.

The law lets us charge a reasonable fee, or refuse, where a request is manifestly unfounded or excessive — for example, a request made only to harass, or the same broad request repeated over and over with no interval. We expect never to use this. If we ever do, we will explain in writing exactly why we think the test is met and tell you how to challenge it.

If we say no

If we refuse a request, wholly or partly, we will, within one month:

1. Tell you what we are refusing and what we are doing.
2. Tell you why, in plain terms, naming the exemption or ground we rely on.
3. Tell you how to ask us to look again, through Complaints.
4. Tell you that you can complain to the Information Commissioner's Office and that you can go to court.

We will not refuse by silence. If you have heard nothing from us after a month, that is a failure on our part and it is itself something the ICO will want to know about.

Parents and children

Most of the people whose data we hold are under 18, so this section matters more here than on most services.

When a parent can act for a child

A person with parental responsibility can exercise these rights on behalf of a child who is not yet able to exercise them for themselves. Email [email protected], say which child, and use the email address linked to their account where you can. We may need to check the guardian link on the account before we act.

If your child has no SailCoach account — for example, they are on a club squad list, or their name is in race results we collected — you can still ask. See the next section.

When it stops

Parental oversight inside the product ends automatically on your child's 18th birthday. That is built into the platform, not a policy we remember to apply: the guardian link survives so they still appear on your dashboard, but the access it granted ends. From 18 they exercise their own rights and we deal with them directly, not with you.

An older child's own wishes count

This is the part people are most often surprised by, so we want to be plain about it.

A child's data protection rights are their own. A parent exercises them for the child when the child cannot — not instead of the child when the child can.

• With a younger child, we deal with the parent and expect that to be right.
• As a child gets older, we will normally want to know their view, and from around the age of 12 we may ask them directly before we hand over a coaching record, their private notes or their messages. In Scotland, a child of 12 or over is presumed to be able to exercise their own rights; elsewhere in the UK it is judged case by case, on whether this particular child understands what is being asked.
• By 16, we will generally treat the young person as the one whose decision governs a request made to us, and we will not send their private material to a parent over their objection without a good reason.
• We may decline to give a parent a child's information where doing so would put the child at risk — most obviously where the concern is about someone at home. Where that happens we follow Safeguarding.

What that last point does not change. Inside the product, a linked guardian can read everything their under-18 child can read, including coach notes and message history, and there is no setting that turns that off before the eighteenth birthday. We think continuous read access is the wrong shape for an older teenager and we are reviewing it. Until we change it, this section governs what we send you when you ask — not what a parent can already see on screen.

None of this is us taking sides against parents. Parental oversight is a genuine safeguarding control and this platform is built around it. But a 16-year-old sailor's private reflections are theirs, and a policy that pretends otherwise would be wrong both legally and practically.

A parent's own information

Your own data — your account, your contact details, your name as a child's emergency contact — is yours, and you exercise your rights over it in your own right, regardless of your child's age.

If you are not a SailCoach user

This section is for you if you have never heard of us until now.

SailCoach collects published race results from club websites, results archives and race-tracking providers, and uses them to analyse sailing performance. Those results contain names. If you have sailed a race whose results were published online — or if your child has — it is entirely possible that we hold a record about you that you never gave us and were never told about.

You have the same rights as anyone else, and you are very welcome to use them. You do not need an account, you do not need to create one, and we will not ask you to.

What we are likely to hold

From published results: finishing position, sail number, helm name, crew name, club, nationality, age group, gender, race-by-race scores and penalty codes, and a copy of the original page. From race-tracking providers: a GPS track of a boat through a race, with the boat name, sail number and sometimes the sailor's name. From both: a cross-event record of every event a sail number appears in, a link between names we believe belong to the same person, and a calculated competitive rating.

Most of this is Optimist-class sailing, which means most of the people in it are children.

How to find out what we hold about you

Email [email protected] and tell us:

• Your name, or your child's name, as it appears in results.
• Any sail numbers you have used — this is the fastest way for us to find you.
• The class you sail, and roughly which years.
• Whether you are asking about yourself or about your child.

We will search and reply within one month with what we found, including where each record came from. If we hold nothing, we will say so — that is a perfectly good answer and it costs you nothing to ask.

How to have it removed

Say so in the same email. You do not have to give a reason.

We will delete the results rows, the cross-event record, the identity link and any rating derived from them. We will confirm in writing what was removed.

Two honest limitations:

1. We cannot change the original. The result on the club's website, on the results archive, or in the tracking provider's replay is theirs, not ours. Removing it there means asking them, and we will tell you who they are and what we know about where the record came from.
2. A later collection could re-import you. We do not yet keep a technical suppression list, so a scheduled crawl of the same club page could pick your name up again. Until we build one, we keep a written list of everyone who has asked to be removed and we re-check and re-apply those removals. If you ever see yourself back, tell us and we will remove you again and treat it as our failure, not your inconvenience.

If you would rather we simply stopped using your data than deleted it, say that instead and we will restrict it.

Complaining

Tell us first if you can. Email [email protected], or use Complaints if you want it handled as a formal complaint with a written outcome. We would genuinely rather hear it directly — it is faster for you, and it is the only way we find out what we got wrong.

You do not have to come to us first. You can go straight to the regulator.

Information Commissioner's Office Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Helpline: 0303 123 1113 ico.org.uk/make-a-complaint

Complaining to the ICO is free and does not stop you taking your own legal action.

If you are in the EU. You can complain to the supervisory authority in your country. We have not yet appointed a representative in the EU under Article 27 of the EU GDPR, and we do need one: the exemption in Article 27(2) is for occasional, low-risk processing, and ours is neither. This is an overdue step, not an open question, and it is on the register in our DPIA with a date. In the meantime, EU requests come to [email protected] and are handled the same way as every other.

If you are in the US, Canada or Australia, you have rights under your own laws as well. Send the request to [email protected] and tell us where you are, and we will handle it under whichever regime gives you more.

Who to contact

We have not appointed a Data Protection Officer. We are not a public authority and our processing does not currently meet the threshold in Article 37 of the UK GDPR for requiring one — but we keep that under review as we grow, and [email protected] is monitored either way.