Privacy Policy

At Colton Yacht Crew, we manage our employer branding and recruitment processes through our career portal (the “Career Site”), utilizing an integrated applicant tracking system.

This privacy policy outlines how we handle your personal data if:

You visit our Career Site (“Visitor”).

You connect with us through our Career Site to create a profile and receive updates on current or future job openings (“Connecting Candidate”).

You apply for a job via our Career Site or a third-party service (“Applying Candidate”).

We collect your information from external sources because we believe your profile aligns with our recruitment needs (“Sourced Candidate”).

We receive your details through employee or partner referrals (“Referred Candidate”).

You are listed as a reference by a Candidate and we receive your information (“Reference”).

Additionally, this policy explains your rights concerning the processing of your personal data and how you can exercise them.

When we use the term “Candidate,” we are collectively referring to Connecting Candidates, Applying Candidates, Sourced Candidates, and Referred Candidates, unless explicitly stated otherwise.

1. Processing of Personal Data

Personal data includes any information that can directly or indirectly identify an individual, such as name, email, phone number, or IP address. Processing personal data refers to any automated handling of this information, including collection, analysis, storage, and deletion.

CYC process personal data in accordance with all applicable data protection laws and

regulations, including but not limited to the EU General Data Protection Regulation 2016/679

(GDPR).

In accordance with what is established in the current Personal Data Protection legislation, CYC informs the User of its website that the personal data collected by the company will be entered into an automated file held under the responsibility of CYC, in order to facilitate, expedite and fulfil the commitments established between both parties.

As the data controller, Colton Yacht Crew determines how and why your personal data is processed, while we may use data processors who act on our behalf according to our instructions.

2. What Personal Data Do We Process?

For All Individuals:

Device Information – IP address, browser type, session behaviour, traffic source, language preferences, operating system, and device settings.
Technical and Statistical Data – Site navigation, URL visits, and usage analytics.
Communications Data – Emails, messages, video calls, surveys, and social media interactions.
Contact Details – Name, email, phone number, and physical address.
Yacht Details: If you're a yacht owner or employer, we may collect details about the yacht, job requirements, and crew preferences.

For Candidates:

Recruitment Process Data – Interview notes, assessment results, salary expectations, messages and correspondence between you and Colton Yacht Crew, whether through email, phone calls, or our website.
Application Details – CV, cover letters, references, and education history.
Personal Identification Information: Name, contact details (email, phone number), date of birth, nationality, address.
Professional Information: CV/Resume, job history, skills, certifications, references, and other details related to your professional experience.
Publicly Available Information – Data from LinkedIn or employer websites.
Reference Data – Feedback from individuals listed as references.

3. How Do We Collect Your Personal Data?

From the Career Site – Technical and behavioural data collected when you visit our site.
Directly from You – Information provided from you when applying for a job or creating a profile. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to process your application
From Public Sources – Professional profiles on job networks, such as LinkedIn or company sites.
From Employees or Partners – Referrals from internal or external contacts.
From References – If a Candidate lists you as their reference, we will collect your contact details from the candidate to be able to contact you.

4. Purpose of Processing Personal Data

We process your data for the following purposes:

Protect our rights and the interests of others and handle legal claims – Data from all categories may be used.
To match candidates with suitable yacht positions or yachts with suitable crew members.
Analyse Career Site performance – Device and technical data.
Enhance site security – Device and technical data.
Send updates on vacancies to you – Contact and communication data.
Review applications and communicate with Candidates – All categories of candidate data.
Reach out about future vacancies – Candidate contact details.
Conduct interviews and record sessions (with consent) – Communication data.
Survey participation requests – Candidate data.
Reference checks – Reference contact details and communications data.

5. Sharing your Information

We may share your personal information in the following circumstances:

With yacht owners or employers: If you are a candidate, we may share your information with potential employers or yacht owners when applying for job opportunities.
Service Providers – Vendors supporting recruitment functions.
Group Companies – Affiliates assisting with recruitment operations.
With Third-Party Cookie Providers: We may use third-party vendors who assist with our services, such as hosting services, email services, and analytics tools. These service providers are only given access to the information necessary to perform their services and are obligated to maintain its confidentiality.
Legal compliance: We may disclose your information if required by law or in response to valid legal requests, such as subpoenas, court orders, or government investigations.
Business Transfers – In case of mergers, acquisitions, or business restructuring.

6. Legal Basis for Processing

Processing of personal data is justified under the GDPR based on:

Legitimate Interest – To recruit and engage with talent.
Consent – When explicit permission is required (e.g., interview recordings).

7. Data Transfers Outside the EU/EEA

We strive to process data within the EU/EEA but may engage service providers operating internationally. When data is transferred outside the EU/EEA, we ensure appropriate safeguards, such as:

EU Commission Adequacy Decisions (e.g., EU-US Data Privacy Framework).
Standard Contractual Clauses ensuring GDPR compliance.

8. Retention of Personal Data

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. If you no longer wish to be considered for yacht positions or no longer wish to have your information on file, please contact us, and we will promptly remove your information from our records.

Legal Matters – Retained until cases are resolved.
Visitors – Retained for one (1) year.
Candidates –
- If you are a Connecting Candidate (only), we keep your personal data for as long as you remain connected with us.
- For other types of Candidates, we keep your personal data to decide if you are a suitable candidate for the relevant vacancy(ies) with us.
- If you don’t succeed in the initial recruitment process, we keep your personal data for as long as needed to consider, and potentially contact you, for relevant future job openings.
- If you are hired, we will keep your personal data during your employment, for other purposes than those stated above, which you will be informed of.
References – Retained as long as the Candidate’s data is stored.

9. Your Rights

You have the following rights regarding your personal data:

Right to Access – You may request access to the personal information we hold about you.
Right to Correction – You may request corrections to any inaccurate or incomplete personal information.
Right to Deletion – You may request the deletion of your personal information, subject to any legal obligations we may have.
Right to Object – Oppose processing based on legitimate interest.
Right to Restriction – Limit processing under specific conditions.
Right to Data Portability – Request transfer of your data to another provider.
Right to Withdraw Consent – Revoke consent-based processing.
Right to File Complaints – Lodge concerns with data protection authorities.

To exercise these rights, contact us at jenny@coltonyachtcrew.com.

10. Contact Information

For questions, concerns, or rights requests, reach out via email: jenny@coltonyachtcrew.com.

11. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal obligations. We will notify you of any significant changes by posting an updated policy on our website and revising the "Effective Date" at the top of the page.

By using our services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and sharing of your personal information as described.