This Privacy Policy explains how Richstone Consulting FZCO ("we", "us", "our") collects, uses, and protects information when you visit burntheboatsnetwork.com (the "Website") or submit an application through it. Richstone Consulting FZCO is a free zone company established in the United Arab Emirates and is the operator of the Burn the Boats Network ("BTB").
This Policy applies to website visitors and applicants. If you become a Member of the BTB platform, a separate, more detailed Privacy Policy and App Usage Agreement applies to your use of the BTB iOS app and member services.
This Policy complies with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL). Where these regimes differ, we apply the highest applicable standard.
1. WHO WE ARE
Data controller: Richstone Consulting FZCO, a free zone company established in the United Arab Emirates.
Contact for any privacy-related question or request: support@thebtbtribe.com
2. WHAT DATA WE COLLECT
2.1 Information you give us via the signup form
When you submit an application or enquiry through the Website, we typically collect:
Full name
Email address
Phone number
Country of residence
Professional background and information you provide in answer to application questions
Any other information you choose to share with us
2.2 Information collected automatically when you visit
When you visit the Website, we and our service providers may automatically collect:
IP address and approximate location (country/city level)
Device type, operating system, and browser type
Pages visited, time spent on pages, referral source
Interactions with the Website (clicks, scrolls, form interactions)
Cookie and similar tracking data (see our separate Cookie Policy)
2.3 What we do not collect
We do not collect special category data (such as health, religion, ethnicity) on the Website. If a future application form ever requests such information, that section will clearly explain why and request explicit consent.
3. HOW WE USE YOUR DATA
We use the data we collect to:
Process your application or enquiry and respond to you
Assess whether the BTB network is a fit for you and you for it
Communicate with you about your application, including by phone, email, and SMS
Send you marketing and promotional content where you have opted in
Operate and improve the Website, including analytics and bug fixing
Detect, prevent, and respond to fraud, security incidents, and abuse
Comply with legal obligations and respond to lawful requests
4. LAWFUL BASIS FOR PROCESSING
Under UK GDPR Article 6, we rely on the following lawful bases:
Legitimate interests: assessing applications, responding to enquiries, securing the Website, and managing our business
Consent: marketing communications and non-essential cookies. You can withdraw consent at any time.
Performance of pre-contractual steps: where you have requested information or applied with a view to potentially entering into a contract with us
Legal obligation: where we are required by law to retain or disclose data
5. WE DO NOT SELL YOUR DATA
We do not, and will never, sell your Personal Data to any third party. Submitting an enquiry or application to BTB does not put you on a list that gets sold, traded, or shared with advertisers or data brokers. This is a foundational principle, not a marketing line.
6. WHO WE SHARE YOUR DATA WITH
We share Personal Data only with:
Service providers acting as our processors: hosting providers, email and CRM tools (such as Klaviyo or equivalent), form processors, analytics providers, and customer support tools. Each is bound by a written agreement that meets UK GDPR Article 28 standards.
Professional advisers: our lawyers, accountants, and auditors, bound by professional confidentiality
Authorities: where required by law, court order, or formal request from law enforcement, tax, or regulatory bodies
Successors in business: in the event of a merger, acquisition, or restructure, your data may transfer to the successor entity, subject to the same protections as in this Policy
If your application progresses and you become a Member of the BTB platform, your data will be transferred into the member systems and the separate Member Privacy Policy will apply.
7. WHERE YOUR DATA IS STORED
We use service providers based in the European Economic Area, the United Kingdom, the United States, and the United Arab Emirates. Where data is transferred outside the UK or EEA, we rely on appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission and the UK Information Commissioner's Office, plus supplementary technical and organisational measures.
8. HOW LONG WE KEEP YOUR DATA
We retain Personal Data only for as long as necessary:
Application data where the applicant is not admitted: up to 12 months from submission, then deleted or anonymised
Application data where the applicant is admitted as a Member: transferred to the member systems, retained per the Member Privacy Policy
General enquiry data: up to 24 months from last contact, then deleted or anonymised
Marketing data where consent has been given: until consent is withdrawn or 3 years of inactivity, whichever is sooner
Website analytics: aggregated and anonymised after 14 months
Records required for legal or accounting compliance: as required by applicable law
9. YOUR RIGHTS
Under UK GDPR, EU GDPR, and (where applicable) UAE PDPL, you have the right to:
Access the Personal Data we hold about you
Request correction of inaccurate or incomplete data
Request deletion of your data, subject to our legal retention obligations
Restrict processing in certain circumstances
Receive your data in a structured, commonly used, machine-readable format (data portability)
Object to processing based on legitimate interests, including profiling
Withdraw consent where processing is based on consent
Lodge a complaint with a supervisory authority (in the UK: ico.org.uk)
To exercise any of these rights, email support@thebtbtribe.com. We will respond within one calendar month, with the option to extend by a further two months for complex requests. We may need to verify your identity before processing the request.
10. MARKETING COMMUNICATIONS
If you have opted in to marketing communications, we may contact you about new BTB events, trips, content, and updates. You can unsubscribe at any time using the link in any marketing email, or by emailing support@thebtbtribe.com. Unsubscribing from marketing does not affect operational communications about an active application or service request.
11. DATA SECURITY
We take appropriate technical and organisational measures to protect your data, including encryption, access controls, monitoring, and regular review of our security practices. No system is perfectly secure, but we treat protecting your data as a core responsibility.
12. BREACH NOTIFICATION
In the event of a Personal Data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours where required by UK GDPR Article 33, and we will notify affected individuals directly where the breach is likely to result in a high risk to their rights and freedoms.
13. CHILDREN
The Website and the BTB network are intended for adults aged 18 and over. We do not knowingly collect Personal Data from anyone under 18. If you believe we have collected data from someone under 18, please contact us at support@thebtbtribe.com and we will delete it.
14. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The effective date at the top of this page reflects when it was last updated. Material changes will be communicated via the Website and, where appropriate, by email.
15. CONTACT
For any question, request, or concern about this Privacy Policy or your data, contact us at support@thebtbtribe.com.
