Privacy Policy

1. Who we are

SAINT NICHOLAS S.R.L., operating under the Saint Nicholas Yacht brand, is the controller of the personal data described in this policy.

Registered office: Via Fratelli d’Italia 5, 21052 Busto Arsizio, VA, Italy
Italian tax code and VAT number: 04124210123
Privacy contact: info@saintnicholasyacht.com

We have not appointed a Data Protection Officer. You may send all privacy enquiries and requests to the address above.

2. Who this policy is for

This policy applies to visitors and people who use the interest form.

3. Data we collect

Information you provide

• full name, email address and, if you provide it, telephone number;
• country;
• your declared area of interest, which may be Private, Charter or Institutional;
• the request or enquiry details you optionally provide;
• your consent to receive email updates about our boats and website launch;
• your separate, optional newsletter choice.

Information generated when you interact with us

• the source and version of the privacy text and each choice;
• the server date and time of a form submission;
• limited technical and security information, such as IP address, browser information and signals used to prevent abuse;
• website pages and interactions linked to a contact only if you consent through the website settings and the feature is active.

We collect contact data from you and from your interactions with our website and communications. We do not purchase or import marketing lists. Please do not send health, biometric, political, religious or other sensitive information through this form.

4. Why we use data

Email updates about our boats and website launch

By successfully submitting the form using “Send your request”, you subscribe to email updates from Saint Nicholas Yacht announcing boat model news and the website launch. These updates can include promotional information about our boat models and are not limited to a single launch notice. The editorial updates on development, construction, shipyard activity and events described below are reserved for the optional newsletter. We use the details you provide to record this subscription and deliver the updates you request. The legal basis is your consent under Article 6(1)(a) of the General Data Protection Regulation and Article 130 of the Italian Privacy Code. Opening the form does not subscribe you.

Optional newsletter

If you also select the newsletter checkbox and successfully submit the form, you subscribe to the Saint Nicholas Yacht newsletter, featuring boat development and construction updates, shipyard news and events. Newsletter content may be selected according to your country and declared interest. The legal basis is your separate consent under Article 6(1)(a) of the General Data Protection Regulation and Article 130 of the Italian Privacy Code. Leaving this checkbox unselected does not subscribe you to these newsletter updates, but you still receive the model news and website launch communications requested with “Send your request”.

Responding to a separate enquiry

You can contact us at info@saintnicholasyacht.com without subscribing to either email stream. When you ask us about a possible purchase or service, we use the necessary contact and enquiry details to respond and take the steps you request before a possible contract, under Article 6(1)(b) of the General Data Protection Regulation.

We also use the details you optionally enter in “Your request” to handle your enquiry on this basis. Providing a request does not add a newsletter subscription or change the email update choice described above.

Promotional messages will identify Saint Nicholas Yacht and use noreply@saintnicholasyacht.com, which does not accept incoming mail. For questions, replies or privacy requests, write directly to info@saintnicholasyacht.com.

Email delivery and aggregate statistics

Individual reporting of email opens and link clicks is disabled in our Brevo configuration. We do not use individual email activity to personalise communications. Delivery, failure and subscription management records may still identify the recipient because they are needed to operate the requested email service and respect subscription choices.

The configured reporting mode retains aggregate opening and click counts. Tracking pixels and redirected links can remain in messages even though our reports do not associate these interactions with named contacts. This setting does not mean that the messages contain no tracking technologies.

Subscription campaigns are not active at the date of this policy. Before introducing email measurement, we will verify the applicable legal basis and technical safeguards, update this information where necessary and obtain consent where required. The current form does not collect consent for email measurement.

Website measurement linked to a contact

This feature is not active at the date of this policy. If it is activated later, it will operate only after a separate choice in the website privacy settings. It may then allow us to understand pages viewed and website interactions and link them to a known contact for personalised communications. The legal basis would be consent under Article 6(1)(a) of the General Data Protection Regulation and Article 122 of the Italian Privacy Code.

Website and form security

We use limited technical information to deliver the website, prevent spam and abuse, diagnose faults and protect our systems. Netlify processes form submissions using its built in spam filtering and a hidden field designed to detect automated submissions. No Google CAPTCHA service is loaded by this website. The legal basis is our legitimate interest in providing a secure and reliable service under Article 6(1)(f) of the General Data Protection Regulation.

Legal obligations and claims

We may use information where necessary to comply with a legal obligation under Article 6(1)(c), or to establish, exercise or defend legal claims under Article 6(1)(f), of the General Data Protection Regulation.

5. Required and optional information

Full name, email address, country and area of interest are required to submit the form. The form does not ask you to confirm your age or tick an acknowledgement of this policy.

The telephone number is optional and is used only to handle an enquiry you make. You can subscribe to email updates without providing it. We do not use it for promotional calls, text messages, WhatsApp messages or similar marketing.

The “Your request” field is optional and is used to respond to the enquiry you describe. You can submit the form without filling it in.

The form is a voluntary subscription to email updates, including the website launch. The additional newsletter is optional. You can visit the website or contact us without either subscription. Individual email activity is not used for personalisation; optional website measurement is currently inactive and is controlled separately.

6. Your choices

“Send your request” records your subscription to email updates. The newsletter checkbox is optional and starts unselected. Selecting it also records a newsletter subscription when you successfully submit the form. We record these choices separately and do not send a subscription confirmation email.

At the date of this policy, submissions and subscription choices are stored in Netlify Forms for operational collection. Internal notifications are delivered to authorised staff through Microsoft 365. Recovery copies, including submissions classified as spam, are encrypted before upload to a private OneDrive folder. They are not automatically transferred to Brevo, and subscription campaigns are not active. Recording your choice does not send a welcome, confirmation or promotional email.

You can withdraw either subscription, or both, at any time through info@saintnicholasyacht.com. Every promotional email will include a simple unsubscribe method. These new choices do not extend permissions given under an earlier version of the form.

Neither subscription includes consent to measure email opens or link clicks. Website measurement is controlled separately through the privacy settings on this website. A choice in the form never overrides a rejection in the website settings.

You may withdraw consent at any time. Withdrawal does not affect processing carried out before withdrawal.

7. Segmentation and automated processing

With your newsletter consent, we may place you in broad segments based on your declared Private, Charter or Institutional interest and your country. We do not use individual email opens or link clicks for these segments. Website interactions may inform segments only if that separate feature is later authorised and activated.

Segmentation may affect which promotional content you receive. It does not determine prices, eligibility, access to services or contract terms. We do not make decisions covered by Article 22 of the General Data Protection Regulation solely through automated processing.

8. Who receives the data

Within Saint Nicholas Yacht, access is limited to administrators and authorised commercial personnel who need the information for their duties.

Our current service providers for website submissions and correspondence include:

• Netlify, Inc. for website hosting, delivery, security and form collection;
• Microsoft 365, including Exchange Online and OneDrive for internal form notifications, email correspondence, privacy enquiries and encrypted recovery copies.

These providers process the content we entrust to them on our instructions. We have selected Sendinblue SAS, trading as Brevo, for planned subscription email delivery, contact management and newsletter segmentation. The landing form is not yet connected to Brevo. Email measurement is subject to the conditions described in section 4.

Technical, security and professional advisers may receive data where necessary for their services.

We may disclose data to public authorities where required by law or to establish, exercise or defend legal claims. We do not sell, rent or provide contact data to data brokers, commercial partners or other parties for their own marketing.

Fonts and browser software files are served from this website. If the local browser libraries fail to load, the page software may request replacement files from unpkg, which then receives technical connection data. These delivery requests are separate from optional Brevo measurement and are not used by Saint Nicholas Yacht to create a marketing profile.

9. International transfers

Brevo states that its main databases are hosted within the European Union. Netlify, Microsoft and other providers or subprocessors may process personal data outside the European Economic Area. The location of a main database does not by itself exclude access or other processing from another country.

Where a transfer requires safeguards, we use a valid mechanism under Chapter V of the General Data Protection Regulation, such as a European Commission adequacy decision, the EU US Data Privacy Framework where the recipient actively participates, or European Commission Standard Contractual Clauses with supplementary safeguards where required.

You may contact us for information about the transfer mechanism applicable to your data and how to obtain a copy of relevant safeguards.

10. How long we keep data

Encrypted recovery copies are retained for 30 days in the active OneDrive backup folder. Deleted copies may remain in the Microsoft recycle bin according to the applicable retention policy. Restored data remains isolated until later withdrawal and deletion requests have been applied.

• Requests and unsuccessful commercial discussions: up to one year from the last meaningful contact.
• Email updates, newsletter and associated personalisation: up to five years from the form submission in which you give the relevant consent, or until you withdraw it earlier. The two subscriptions are managed separately. Opens, clicks and visits do not restart this period. Continuing after five years requires a new consent.
• Earlier launch notice only registrations: the earlier purpose and retention period continue to apply. These records are not converted into subscriptions to ongoing updates or the newsletter.
• Website navigation linked to a contact: this processing is currently inactive and will not be enabled unless a maximum retention of one year can be enforced.
• Withdrawal and objection records: the minimum information needed to prove and respect the choice may be kept for as long as reasonably necessary for compliance and suppression.
• Legal obligations and claims: for the period required by law or necessary for the relevant claim.

If consent is withdrawn earlier, we stop the consent based processing and delete or irreversibly anonymise data used only for that purpose, unless limited retention is required by law or to prove and respect the withdrawal.

These limits also apply to working exports or correspondence created under our control. Removing a submission from Netlify does not automatically remove a separate working copy if one has been created; every such copy must be included in our retention and deletion process.

If an enquiry develops into a contract, a different retention period and, where appropriate, updated privacy information will apply.

11. Your rights

Subject to the conditions in data protection law, you may ask us to:

• provide access to your personal data;
• correct inaccurate or incomplete data;
• erase data or restrict its use;
• provide portable data where the right to portability applies;
• object to processing based on legitimate interests;
• stop direct marketing and related profiling at any time;
• withdraw a consent at any time;
• provide information about applicable transfer safeguards.

Send requests to info@saintnicholasyacht.com. We may request information reasonably necessary to verify your identity.

You may lodge a complaint with the Garante per la protezione dei dati personali, the Italian supervisory authority.

12. Security

We apply technical and organisational measures designed to protect personal data against accidental or unlawful loss, alteration, unauthorised access or disclosure. No internet transmission or storage system can be guaranteed to be completely secure.

13. Changes to this policy

We may update this policy to reflect changes in our services, providers or legal obligations. The current version and date will be published here. If a change materially affects processing based on consent, we will request a new consent where required.