1. Introduction and Scope
Sortsycompss Maritime Publishing Ltd. ("Sortsycompss", "we", "us", or "our") operates the web platform sortsycompss.skin. This Privacy Policy sets forth the principles governing our collection, processing, storage, and protection of personal data belonging to users, visitors, and subscribers ("you", "your").
We are fully committed to compliance with the Regulation (EU) 2016/679 (General Data Protection Regulation or GDPR), the UK Data Protection Act 2018, and relevant international data privacy laws including the California Consumer Privacy Act (CCPA/CPRA).
2. Data Controller Information
For the purposes of the GDPR and European data protection laws, the designated Data Controller responsible for your personal data is:
- Legal Entity: Sortsycompss Maritime Publishing Ltd.
- Company Registration Number: MT-9842104
- Registered Office: 48 Mediterranean Wharf, St. Julian's Bay, STJ 3140, Malta
- Designated Data Protection Officer (DPO): [email protected]
3. Categories of Data Collected
Depending on how you interact with our guides, quiz calculators, and inquiry channels, we may collect the following classifications of information:
- Directly Provided Information: Full name, email address, country of residence, and inquiry details submitted when filling out our contact or newsletter forms.
- Technical & Device Data: IP address (anonymized at the subnet level where possible), browser classification, operating system, referrer URL, and interaction logs with specific island route articles.
- Interactive Preference Data: Island filter selections, preferred travel season, and calculated ferry route parameters stored locally within your browser storage.
4. Lawful Bases for Processing
Under Article 6 of the GDPR, we only process personal information where an established lawful basis exists:
- Consent (Art. 6(1)(a)): Explicit consent given when subscribing to island advisories or accepting non-essential analytics cookies.
- Contractual Performance (Art. 6(1)(b)): Responding to specific travel planning inquiries or consulting service requests requested by you.
- Legitimate Interests (Art. 6(1)(f)): Maintaining server network security, detecting bot traffic, preventing malicious form spam, and optimizing travel guide site performance.
- Legal Obligation (Art. 6(1)(c)): Compliance with statutory financial, tax, and regulatory requirements in Malta and the European Union.
5. Third-Party Processors & Data Sharing
We do not sell, rent, or trade your personal information. We only disclose data to vetted third-party data processors bound by strict Data Processing Agreements (DPAs):
- Cloud Infrastructure: Cloudflare Inc. (CDN caching, DDoS mitigation, DNS resolution).
- Privacy-Friendly Analytics: Anonymized server telemetry providers operating exclusively within EU data centers.
- Email Dispatch: Secure SMTP transactional delivery servers adhering to ISO 27001 certifications.
6. International Data Transfers
Where personal data is transferred outside the European Economic Area (EEA), Sortsycompss ensures adequate safeguards are enforced, utilizing the European Commission's Standard Contractual Clauses (SCCs) and verifying compliance with data sovereignty regulations.
7. Data Retention Guidelines
We retain contact inquiries for a maximum duration of 24 months to address ongoing travel planning follow-ups, after which correspondence records are permanently purged. Server access logs are held in encrypted partitions and rotated automatically every 30 days.
8. Your Statutory Rights (GDPR / CCPA)
As a data subject, you hold comprehensive rights regarding your personal information, including:
- Right of Access (Art. 15): Request a copy of all personal data held about you.
- Right to Rectification (Art. 16): Correct inaccurate or incomplete travel profile details.
- Right to Erasure ('Right to be Forgotten' - Art. 17): Request deletion of your personal records.
- Right to Restriction of Processing (Art. 18): Restrict the scope of data analysis.
- Right to Data Portability (Art. 20): Receive your information in a structured, machine-readable JSON/CSV format.
- Right to Object (Art. 21): Object to any processing based upon our legitimate interests.
To exercise any of these rights, please email our Data Protection Officer at [email protected]. We respond to all verified requests within thirty (30) calendar days free of charge.
9. Lodging a Regulatory Complaint
If you believe our data processing breaches European data protection regulations, you possess the right to file a formal complaint with our lead supervisory authority:
Office of the Information and Data Protection Commissioner (IDPC)
Floor 2, Airways House, High Street, Sliema SLM 1549, Malta
Website: https://idpc.org.mt/