Privacy Policy
This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage made by Seazone Smart Management Ltd. (“Company”, “we” or “us”).
This Privacy Policy concerns the data we collect from individuals:
- who access and use our website available at: https://seazone.app/ (respectively “Website” and “Visitors”);
- who are interacting and using our web application as part of using Seazone System - a license software, provided by the Company, that helps Yachts’ Owners to maintain the services of their yachts by opening an Account that support the yacht maintenance services, yacht craw, guests and financials (respectively, “Customer” and “Seazone System” - all together “Services”);
- who are looking for a job on our Website as a yacht crew member, yacht manager or Supplier (“Job Candidate”).
- who are booking a yacht from our System, and using our System as a user of the yacht (“Yacht Guests”).
Each of the Customers and Seazone Gusts using our System, shall be referred together as “User”.
Each of the Visitors, Systems’ Users and Job Candidate, shall also be referred to herein as “you”.
This Privacy Policy constitutes an integral part of the Terms of Use (“Terms”). Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms.
If you have any questions about this Privacy Policy, please contact us at: admin@seazone.app .
AMENDMENTS
We reserve the right to periodically amend or revise the Privacy Policy, which will immediately affect the implementation of the revised Privacy Policy on our Website. The last revision date will be reflected in the “Last Modified” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.
Who are we and Contacting Us
Seazone Smart Management LTD
Ha Zedef 1,
Herzliya, Israel
Phone: +972528336421
Mail: admin@seazone.app
Questions, comments, requests and complaints regarding this Privacy Policy and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently.
Our EU and UK Representative under the GDPR and UK-GDPR
We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative for GDPR and UK-GDPR purposes, to serve as your point of contact.
Prighter group gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, contact us at:
Address:
Schellinggasse 3/10
1010 Vienna
Austria
Website:
https://prighter.com/q/11830860
Data Controller / Data Processor for GDPR purposes
Under the European General Data Protection Regulation (”GDPR”), we are the Data Controller of our direct Customers’ Personal Data, Users and certain types of Job Candidates Personal Data.
The Personal Data of which we are deemed a controller consists of Account data and contact details (Name, Email, login credentials, etc.) and any other Customer data as part of its Owner’s Account. Also, we are the Controller of the Personal Data which is being collected in our promotional Website (usually when you are using the Users Feedback System) and from our Job Candidates.
With respect to such data, we assume the Data Controller's responsibilities (to the extent applicable under the law), as outlined in this Privacy Policy. In such instances, our external suppliers processing such data will assume the role of “Data Processor”.
In other cases, you are using the Seazone System as User under an Account Owner (e.g. a Yacht Guest using Seazone System under a Yacht Owner who is the Account Owner), we are the Processor of any Personal Data processed on behalf of our Customer, the Account owner. The Personal Data processed by us as a Data Processor includes any Personal Data uploaded by the Customer or its Users to the System (including contact details such as Name, Email, login credentials, etc.) and other Data processed on such Customer’s behalf (e.g., System’s usage data, Users credentials, consumption of food and beverages on the yacht, such Yacht Gusset’s budget, etc.) . In such instances, we merely a Data Processor under the Account owner, the Controller of your data. That means that we process such data following the Account Owner’s instructions, subject to our agreements with him. The Account Owner will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control). Therefore, and with any request, you should contact the relevant Account Owner. It should also be noted that, in these instances, our relevant external suppliers shall act as designated Sub-Processors.
Also, note that under this Privacy Policy, we can use any aggregated, statistical, and anonymized data, which can no longer be associated with any individual with no limitation. Such data may be included in our proprietary information and does not deem as Personal Data under the law.
Collection of Non-Personal Data
We may collect aggregated, non-personal and non-identifiable information which may be made available or gathered via your use of our Website or System (“Non-Personal Data“). We are not aware of the identity of the individual from which the Non-Personal Data is collected.
Also, we may sometimes process and anonymize or aggregate personal data and identifiable information in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified person.
Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, without further notice to you.
Collection of Personal Data
During your use of the Website or the System, we will collect individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information” as defined under applicable law). This may include online identifiers, name, emails, etc., subject to applicable law.
If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.
processing of Personal Data – Purposes and Lawful Basis
We have included in the table below information about which data is processed, how we process and use your data and the lawful basis for which we do so subject to the GDPR.
Type of Data | Purpose of Processing | Lawful Basis | Processing Operations |
Becoming a general User of the Seazone System: | |||
If you are or wish to become a user of the Services, you will be required to provide us with certain information such as:
| We will use the identification data to designate your account and allow you to use the System. Further, we will use the demographic data to allow you to use our System, in the best way for your needs and current situation.
Also, your email address will be used to send you needed information related to our System (e.g., notify you regarding any updates to our System, etc.) and promotional and marketing emails.
| Our lawful basis under the GDPR for collecting this information is the performance of a contract (i.e., providing you the Services as per your request).
When we use your email for providing you with further information of marketing nature, i.e., regarding our products and services, we will do that under the necessity of processing for our legitimate interests, after ensuring that your rights and interests are being ensured and protected. | For opening of an Account and subscribing to our Services: Collection of your data, storage, analysis of the data and customizing the System, and Seazon’s Services for your characteristics and needs. We will also archive and save that data to allow the continuity of the Services to you.
For providing you with information we will use your data for email delivery.
We are encrypting the data in our systems for security and confidentiality purposes. |
Through and during the use of the Seazone System: | |||
Data which you will provide:
Data that will be collected automatically by our System:
| We will use this data to adjust the Seazone System for your needs and optimize your benefit from its use.
We also may use this data for upgrading and developing our Services.
Your geolocation data will be used for checking the weather and other relevant indicators in your surroundings. Such collection will be limited to the usage time of the Seazone System. | Our lawful basis under the GDPR for collecting this information is the performance of a contract (i.e., providing you the Services as you requested).
As for improving and developing our services, the lawful basis for using your data for those purposes is the necessity of processing for our legitimate interests. We are using your data for those needs only after ensuring that such use is done in a minimal, secured, and where possible, de-identified manner.
Usage data is being processed: (a) for providing you with the Services in relevant cases, under the contract between us; (b) for our internal needs and for the general management of our Services as part of our legitimate interest, in a minimal manner, mainly aggregated and statistical. | Processing actions – data collection, storage, analysis (including big data analysis), and usage optimization and customization, and record keeping of the data.
As for improving and developing our Services, we are doing so through the further AI and big-data analysis of your data, together with other users’ data. We do so in a manner which is, to the extent possible, minimal and de-identified, in order to ensure that your identity itself is not inherently used for such improvement and development.
Usage data is being stored and recorded, and also analyzed in an aggregative and statistical manner to provide us with general insights regarding the use of our Services.
We may, but won’t be obliged to, encrypt the data in our systems for security and confidentiality purposes. |
Recruitment Data if you are a Job Candidate using the Seazone System for job seeking | |||
Suppose you are looking a job Position through Seazone System and subscribing to the System as Job Candidate. In that case, and in addition to any other we may collect information regarding your job status, education, CV, requested salary, face photo and other information to be collected as part of any recruitment process. In addition, in the system we will process records and reviews data which will be collected in our feedback system, as provided by other users. | We will use such information for presenting you with job opportunities, and allowing other Users to search for relevant recruiters for their yacht crew. Also, we may keep it afterward as part of our business records. | The lawful basis for such processing will be the contract between us - we process your data as per your application to a position within our Company. After the recruitment process, we may keep your information under our legitimate interests as part of our ongoing business records and for future protection from any potential legal suit. | Collection of data, analysis of such data, correspondence with you through the means of contact you have provided us with, record keeping of data.
Also we may provide your details, upon your will as a job seeker, to other Users as potential employers. |
Through and during the use of the Supplier Zone: Data which any Supplier will provide:
| We will use this data to publish your services and allow you to advertise them in the Supplier Zone, to be engaged by other User as potential Customers. | Our lawful basis under the GDPR for collecting this information is the performance of a contract (i.e., providing you the Supplier Zone as you requested).
After and if you will, terminate your Account, we will keep a record of it in our systems as part of our record keeping as a business, under our legitimate business.
| Processing actions – data collection, storage, analysis (including big data analysis), and usage optimization and customization, and record keeping of the data.
|
Ratings and Reviews Data: as described in our Terms, Seazone System include a user’s rating and reviews, provided by Users on different Services of Seazone System, such as Supplier’s services, yacht’s facilities, Yacht crew, etc. When a User share a review the Company may collect certain contact information such as your full name and email address. In addition, you can choose to provide us with additional information as part of your Ratings and Reviews. | We will use this data to adjust the Seazone System for your needs and optimize your benefit from its use.
We also may use this data for upgrading and developing our Services.
| Our lawful basis under the GDPR for collecting this information is the performance of a contract (i.e., providing you the Services as you requested).
However, if you feel that any review or rating given to you by another user is not justified or mis lawful, please contact us through support@seazone.app and we will do our best to assist you. | Processing actions – data collection, storage, analysis (including big data analysis), and usage optimization and customization, and record keeping of the data.
As for improving and developing our Services, we are doing so through the further AI and big-data analysis of your data, together with other users’ data. We do so in a manner which is, to the extent possible, minimal and de-identified, in order to ensure that your identity itself is not inherently used for such improvement and development. |
Seazone’s Website |
| ||
Contact us information: If you voluntarily contact us in any manner, whether for partnering or to submit a request or for other inquiries, whether by sending us an email or through the means of communications on our Website, e.g., any online form available on the Website, such as “Contact us” form, you may be asked to provide us with your contact information such as your full name and email address. In addition, you can choose to provide us with additional information as part of your correspondence with us. | Addressing your inquiries and/or checking the option to provide you with services. | We will collect and process this data, store it in our systems, and check it with our contact history solely to respond to your inquiries and provide you with the support or information you have requested. We will retain our correspondence with you for as long as needed, subject to applicable law. Note that such correspondences can be retained in databases we use for this purposes and which we bought from third parties (i.e., SaaS platform such as CRM). In such cases, your data may be shared and transferred to such third parties. For more information regarding data transfer and sharing see below. | In case you contact us as a Customer or User -the lawful basis for processing your information will be the contract between you and us, meaning we will use the data for addressing your requests and inquiries. After completing any such request, we will retain your information as part of our business records under our legitimate interest. In the event you contacted us as a prospect customer or partner we will also do so under our legitimate interest. In such cases, where we rely on our legitimate interest, you are entitled to object such processing based on our legitimate interests if you believe that your rights are overridden by our interests. |
Online identifiers and other Technical Data | |||
When you access our Website, we may collect certain online identifiers, including your IP address, Advertising ID, and IDFA. We may also collect technical Non-Personal Data transmitted from your device (e.g., actions in the Website, your browser type, language used, type of operating system, type of device, etc.) and approximate geographical location (country).
*** please see the following paragraph regarding Cookie usage | We use this data for our legitimate interests of (I) operating, providing, maintaining, protecting, managing, customizing, and improving the Website and how we offer it; (ii) enhancing your experience; (iii) auditing and tracking usage statistics and traffic flow; (iv) protecting the security of the Website, as well as our and third parties’ rights (subject to applicable law requirements); and (v) advertising purposes
| Such processing is part of our legitimate interests as a commercial business. If we use third-party cookies on the Website or collect online identifiers, we will obtain your consent if required under applicable law. | Collection of data, aggregation and statistical analysis, report generation, record keeping and storage. |
Joining our team – Applying for a position in Seazone via our website | |||
If you apply for any position in our Company through the Website or elsewhere. In that case, we will collect your first and last name, email address, phone number, CVs and additional information at your choice, such as a URL to your LinkedIn profile or a personal note you added. | We will use such information for the recruitment process for checking your suitability for job opportunities in our yachts’ crew. Also, we may keep it afterward as part of our business records. | The lawful basis for such processing will be the contract between us - we process your data as per your application to a position within our Company. After the recruitment process, we may keep your information under our legitimate interests as part of our ongoing business records and for future protection from any potential legal suit. | Collection of data, analysis of such data, correspondence with you through the means of contact you have provided us with, record keeping of data. |
Cookies Usage
Like many other websites, the Website and parts of our System use cookies to improve your experience while you navigate the Website. We may use various types of Cookies:
- Essential Cookies – which are necessary for the site to work properly (usually appears under our name/cookie tag);
- Functional Cookies – designated to save your settings on the site - your language preference or other view preferences (also, under our name/cookie tag);
- Session Cookies – used to support the Website's functionality – such Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser.
- Targeting Cookies - these cookies are used to collect information from you to help us improve our products and services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s Cookies).
- Social networks Cookies - Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts.
- Analytics Cookies - give us aggregated and statistical information to improve the Website and System and further developing it e.g., Google analytics, Google Firebase Catalytic, etc.
- Third-party services used by us – for example, an external service supporting our recruiting options through the Website (e.g., Comet or Workday), or an external service which allows us to screen short videos on our Website (e.g., YouTube or Vimeo).
Please note that the data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data.
Also note, that Cookie’s data is usually collected through third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might use it, as a “joint controller” of the data, meaning that the data is also “owned” and processed by them under their terms and conditions. Under those terms and conditions and the direct accounts or subscriptions you have with those third parties, your Personal Data might be linked to other data collected by the relevant third party and processed in its systems, for its purposes, and under its management. For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies in Our Website might be linked to other data Facebook collects and might be used by Facebook per the independent agreements between you and Facebook.
What Are Your Choices Regarding Cookies?
If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser, or use the designated Cookies Bar in the Website.
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
For the Chrome web browser, please visit this page from Google
For the Internet Explorer web browser, please visit this page from Microsoft
For the Firefox web browser, please visit this page from Mozilla
For the Safari web browser, please visit this page from Apple
For any other web browser, please visit your web browser’s official web pages.
Where Can You Find More Information About Cookies?
You can learn more about cookies and the following third-party websites:
- All About Cookies: http://www.allaboutcookies.org/
- Network Advertising Initiative http://www.networkadvertising.org/
SHARING DATA WITH THIRD PARTIES
We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:
- Sharing you Data with an Account Owner – where you are a User under an Account Owner, your data and usage of the system shall be accessible and visible for the Account Owner and any other User on its behalf (such as the captain).
- Sharing User’s information with any other User of the Seazone System - The system, as part of its purposes and features, allow Users to share their information with other Users. For example, if you open an account in the Seazone System as a Job Candidate, your details will be shared with potential employers and other Users seeking for relevant yacht crew. Similarly, if you are a Supplier advertising your services through the Seazone System, some of the data you have provided will be shared with other Users, including ratings and reviews regarding your services provided by other Users.
- Legal Requirement: We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);
- Policy Enforcement: We will share your information, solely to the extent needed to (I) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;
- Company’s Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims when necessary, subject to applicable law;
- Third Party Rights: We will share your information, solely to the extent needed to prevent harm to the rights of our users, yourself, or any third party’s rights, property, or safety;
- Business Purpose - we may disclose your personal information to a third party for a business purpose, as detailed above.
- Service Providers – we share your information with third parties that perform services on our behalf (e.g. customer service, tracking, servers, service functionality, marketing, and support, etc.) these third parties may be located in different jurisdictions.
- Corporate Transaction - we may share your information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
- Authorized Disclosures -we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices.
It shall be clarified that we will never transfer nor share your payment method (e.g., full credit card details) with any third party other than our payment services providers.
Your Data Subjects' rights under Privacy Protection laws
Under EU law, EU residents and individuals have certain rights to apply to us to provide information or make amendments to how we process data relating to them. Those rights might include:
- right to access your Personal Data - you can ask us to confirm whether or not we have and use your Personal Data, and if so, you can ask for a copy of your data;
- right to correct your Personal Data - you can ask us to correct any of your Personal Data that is incorrect, after verifying the accuracy of the data first;
- right to erase your Personal Data - you can ask us to erase your Personal Data if you think we no longer need to use it for the purpose we collected it from you. You can also ask for such erasure in any case in which the process of your data was based on your consent, or where we have used it unlawfully, or where we are subject to a legal obligation to erase your Personal Data. any request for such erasure will be subject to our obligations under the law (e.g., our obligation to keep some records for tax or customs purposes);
- right to restrict our use in your Personal Data - you can ask us to restrict our use of your Personal Data in certain circumstances;
- right to object to how we use your Personal Data - you can object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information;
- you can always require us to refrain from using your data for direct marketing purposes;
- you can ask us to transfer your information to another organization or provide you with a copy of your Personal Data (Portability Right);
We may not always be able to do what you have asked. Also, not all those rights apply in every jurisdiction. Yet, we encourage you to contact us with any such request, and we will be happy to assist you.
You have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. However, we will appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact us in the first instance.
data retention
Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable. Basically, and as a minimum, that means that your data will be retained as long as you have an Account in our Systems and use our Services.
Also, and after the termination of your Account, we may keep some of your Personal Data as a user of our Services for more extended periods for protecting our legal interests or under any safety or other legal requirements.
As for Cookies data and technical marketing data, usually the data will be retained in an identified manner for periods of 14-36 months, subject to the relevant system. However, note that as explained before, once you delete the Cookies from your computer or otherwise restrict the use of cookies, we will have no linkage between your identity and your Cookies data (yet, the third-party provider may have such data relating to you, under the separate terms between you and any such third party, e.g., Facebook’s terms of use as a user of Facebook).
Recruitment data will be retained up to 7 years after the last recruitment activity, for allowing to protect ourselves from any potential legal suit, in accordance with Israel’s statute of limitations.
Please note that where we act as a Processor on behalf of an Account Owner, the retention periods are under the sole discretion of the Account Owner, as the Data Controller.
SECURITY
We use physical, technical, and administrative security measures for the services that we believe comply with applicable laws and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost.
However, unfortunately, the transmission of information via the internet and online data processing cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the security of data transmitted via the Website, Seazone System and any transmission of your data shall be done at your own risk.
Data Processing Location
We may store or process your Personal Data in a variety of countries, including the United States.
Any transfer of data that originates in the European Union ("EU") to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR, e.g.:
- transfer to a country that is recognized as providing an adequate level of legal protection;
- transfer under a proper agreement containing the Standard Contractual Clauses published and authorized by the relevant EU authorities;
- where we can be satisfied that alternative arrangements are in place to protect your privacy rights through the use of any other mechanism under the GDPR.
It is important to note that we are headquartered in Israel, a country that the European Data Protection Board considers offering an adequate level of Personal Data protection regulation.
Suppose you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent. In that case, your consent to this Privacy Policy includes your express consent for such transfer of your data.
Links to other sites
Our Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every Website you visit.
CHILDREN
Our System and Website are not directed, nor is it intended for use by children (the phrase "child" shall mean an individual that is under age defined by applicable law which concerning the European Economic Area (“EEA “) is under the age of 16 and with respect to the U.S.A, under the age of 13) and we do not knowingly process a child’s information. We will discard any information that we receive from a user who is considered a "child" immediately upon our discovery that such a user shared information. Please contact us if you have reason to believe that a child has shared any information with us.