Privacy Policy

Last updated: 12 October 2026

ALMA Sailing Academy (Alma Dogmatica, a brand of Maksym Izmailov, ENI, sole trader, Madeira, Portugal) ("we", "us"), runs sailing courses, yacht charter and sailing trips on the yacht NARAYANA. This policy explains what personal data we handle when you visit almadogmatica.com, talk to us on Telegram, WhatsApp, Instagram, Facebook, YouTube or TikTok, or book with us. We process personal data under the EU General Data Protection Regulation (GDPR).

What we collect

• Bookings and payments: name, contact details, chosen course or trip, dates, number of people, payment status. Card data is handled only by our payment provider Stripe; we never see or store full card numbers.
• Messages: what you write to us on Telegram, WhatsApp, Instagram, Facebook Messenger or in comments, your public profile name and the platform user id, and the time of the message. We keep only the last message and the topic of a conversation, not a full chat archive.
• Website and bot technical data: basic logs (IP address, browser, time) for security and abuse prevention.

What we use it for

• to answer your questions and handle your booking (contract);
• to send you the information you asked for, such as course materials and reminders (contract / legitimate interest);
• to keep the service secure and to meet legal and tax duties (legal obligation).

We do not sell personal data and we do not use it for advertising profiles. We never publish a customer's name, photo or message without permission.

Social platforms and API services

We publish our own sailing content and answer messages and comments on social platforms using their official APIs:

• YouTube: our application uses YouTube API Services. By using it you are bound by the YouTube Terms of Service, and Google's use of data is described in the Google Privacy Policy. We use the channel owner's authorisation only to upload our own videos and to read and reply to comments on our own channel. Authorisation can be revoked at any time at security.google.com/settings/security/permissions. We store only the comment text, author display name and channel id needed to reply.
• TikTok: with the account owner's consent we use TikTok's official Login Kit and Content Posting API only to send our own videos to our own TikTok account. We do not collect data of other TikTok users. The authorisation can be revoked in TikTok under Settings and privacy, Security and permissions, Apps and services, or by writing to us.
• Instagram and Facebook (Meta): we receive messages and comments sent to our Page and professional Instagram account through Meta's official webhooks and reply to them. Meta's own privacy rules apply to its platforms.

Who receives data

Hosting (Railway), payments (Stripe), the messaging platforms you chose to write to us on, and an AI service that helps us draft replies (Anthropic; message text only, never payment data). Every reply that goes to a public place is approved by a person. Data may be processed outside the EU under standard contractual safeguards.

How long we keep it

Booking and accounting records are kept as long as the law requires (normally up to 10 years in Portugal). Conversation records are deleted on request or after 24 months without contact.

Your rights

You may ask for access, correction, deletion, restriction, portability or object to processing, and you may complain to the Portuguese data protection authority (CNPD). To delete your data see Data deletion. Contact: Telegram @alma_sailing_academy_bot or WhatsApp +351 925 521 864.