PRIVACY POLICY
Effective Date: June 1st, 2022
Introduction
This Privacy Policy describes how VesselMan AS, (“VesselMan,” “we,”
“our” or “us”) collects, uses, and shares information about you through
websites or mobile apps operated by us from which you are accessing this
Privacy Policy (the "Websites"), through our social media pages (our
"Social Media Pages") as well as through email messages that we may
send to you that link to this Privacy Policy (collectively, including the Websites
and our Social Media Pages, the "Services").
This Privacy Policy does not apply to our data collection activities
offline or otherwise outside of our Services (unless otherwise stated below or
at the time of collection). By using our Services, you agree to our Terms of
Use. By consenting to this Privacy Policy you consent to our collection, use
and disclosure practices, and other activities described in this Privacy
Policy. If you do not agree and consent, discontinue use of the Services, and
uninstall Service downloads and applications. The Privacy Policy may be found
here: https://www.VesselMan.com/resources.
“Personal Information” is information, whether true or not, that can be
used to identify you (whether alone or in combination), which may include:
·
Name
·
E-mail address
·
Postal Address (including billing and
shipping address)
·
Geolocation information
·
Telephone number
·
Fax number
·
Bank information and credit references (if
applicable)
·
VesselMan Account Number
·
Credit or debit card number.
1. CHANGES
TO THIS PRIVACY POLICY
We reserve the right to revise and reissue this Privacy Policy at any time. Any
changes will be effective immediately upon posting of the revised Privacy
Policy. Subject to applicable law, your continued use of our Services indicates
your consent to the privacy policy posted. If the changes are material, we may
provide you additional notice, to your e-mail address.
2. HOW
WE COLLECT INFORMATION
A. Information
You Give Us
We may collect Personal Information you provide directly to us via the
Services. For example, Personal Information may be collected when you use or
register for our Services, subscribe to our notifications, post on our
Services, participate in promotional activities, apply for a job, communicate
with us through the Services, or use an app installed on a device. You may
choose to voluntarily submit certain other information to us through the
Services, including Personal Information, but you are solely responsible for
your own Personal Information in instances where we have not collected such
information or requested that you submit such information to us. De-Identified
Data Personal Information once “de-identified” may not be subject to this
Privacy Policy and we and our Service Providers (defined below) may treat it as
non-Personal Information and use it without obligation to you except as
prohibited by applicable law.
B. Information
We Collect Automatically From Your Use of Our
Services
We and our Service Providers collect information about the Services that you
use and how you use them. Certain information is collected automatically
through your device, such as your IP address; device identifier, Ad ID, browser
type; operating system characteristics; information about your use of our
Services; and data regarding network connected hardware (e.g., computer or
mobile device) (“Usage Information”). To the extent that Usage Information is
Personal Information under applicable law or is combined with Personal
Information, we will treat that information as Personal Information under this
Privacy Policy.
The methods that we and our Service Providers may use to collect Usage
Information include:
o
Log Information: We
collect information about your use of our Services, such as IP address, browser
type, Internet service provider, referring/exit pages, operating system,
cookies that may uniquely identify your browser or your account, and related
data, and store it in log files.
o
Information Collected by Cookies and Other
Tracking Technologies: We and our Service Providers may use
cookies or other tracking technologies (“Tracking Technologies”) to collect and
store information about interactions with our Services, including information
about your browsing and purchasing behavior.
o
We are giving you notice of the Tracking
Technologies and your choices regarding them explained in Section 13 so that
your consent to encountering them is meaningfully informed.
C. Personal
Information Collected from Other Sources
We may receive your Personal Information from other sources, such as public
databases, joint marketing partners, and social media platforms, and combine
that with information we collect about you. To the extent we combine such third
party sourced information with Personal Information we collect directly from
you, we will treat the combined information as Personal Information. We are not
responsible for the accuracy of the information obtained from third parties or
third party practices.
3. HOW
WE USE INFORMATION WE COLLECT
We and our Service Providers may use information about you for the following
purposes:
A. To
provide, maintain, protect and improve our Services, develop new services, and
protect VesselMan and our users;
B. To
facilitate, manage, personalize and improve your online experience;
C. To
respond to your inquiries and fulfill your requests, such as to send you
newsletters, brochures, catalogs and e-mails;
D. For
our business purposes, such as data analysis, audits, fraud monitoring and
prevention, enhancing, improving, or modifying our Services, identifying usage
trends, and operating and expanding our business activities; and
E. To
send you advertisements and communicate with you about products, services,
offers, promotions, rewards and events we believe may be of interest to you
(for information about how to manage these communications, see Section
13).
Marketing Purposes
If you are a user from the United States, we may use your Personal Information
for direct marketing purposes. If you are a user from outside the U.S., we will
not use your Personal Information for direct marketing purposes unless we have
received your express consent. As a Non-U.S. User, you have the right to
opt-out from direct marketing and can require us to cease using the data at any
time for direct marketing purpose at no cost to you
4. HOW
WE SHARE INFORMATION
Our agents, vendors, consultants, marketing service providers, and other
service providers (collectively “Service Providers”) may receive, or be given
access to your information, including Personal Information and Usage
Information, in connection with their work on our behalf. These Service
Providers may be located in countries other than your country of residence.
These Service Providers are prohibited from using your Personal Information for
any purpose other than to provide this assistance, although we may permit them
to use de-identified data or aggregate information which does not personally
identify you or any other user of the Services (for example, we may aggregated
Personal Information to calculate the percentage of our users who have a
particular telephone area code). We may also share information about you as
follows:
A. As
necessary, for the following purposes: (a) to comply with legal process; (b) to
respond to requests from public and government authorities, including public
and government authorities outside your country of residence to meet national
security or law enforcement requirements; (c) to enforce our terms and
conditions; (d) to protect our operations and protect our rights, privacy,
safety or property, and/or that of you or others; and (e) to allow us to pursue
available remedies or limit the damages that we may sustain;
B. With
our affiliates for internal business purposes. For example, processing your
orders, fulfilling your requests, providing customer service, and improving our
products;
C. With
our subsidiaries, affiliates, business partners, and other third parties for
their own business purposes. For example, improving their products and
services; and
D. To
a third party in connection with or during negotiations of any reorganization,
merger, sale, joint venture, assignment, transfer or other disposition of all
or any portion of our business, assets or stock (including in connection with
any bankruptcy or similar proceedings).
When
VesselMan engages third-party service providers and when disclosure of Personal
Information to such providers is necessary for the provision of such service, VesselMan
ensures that such providers protect Personal Information in a manner consistent
with this Privacy Policy and, where applicable, is responsible for ensuring
that such third parties process EU Personal Information in a manner consistent
with the Privacy Shield Principles discussed below (see Section 15).
Aggregated Information
Without limiting the forgoing, in our sole discretion, we may share aggregated information,
which does not identify you or de-identified information about you with third
parties or affiliates for any purpose.
Sharing for Marketing Purposes
If you are a user from the U.S., we may share your Personal Information with
third parties for direct marketing purposes. California residents have further
rights, as set out in Section 14. If you are a user from outside the U.S., we
will not share your Personal Information with third parties for direct
marketing purposes unless we have received your express consent. Users from
outside the U.S. have the right to opt-out from direct marketing and can
require us to cease to use the data at any time for direct marketing purpose at
no cost to you.
Please note that by using our Services you agree to share your Personal
Information and Usage Information, as described in this section.
5. SWEEPSTAKES,
CONTESTS, AND PROMOTIONS
We may offer sweepstakes, contests, and other promotions (each, a “Promotion”)
jointly sponsored or offered by third parties that may require submitting
Personal Information. If you voluntarily choose to enter a Promotion, your
Personal Information may be disclosed to third parties for administrative
purposes and as required by law (e.g., on a winners list). By entering a
Promotion, you are agreeing to the official rules that govern that particular
Promotion, and may, except where prohibited by applicable law, allow the
sponsor and/or other parties to use your name, voice and/or likeness in
advertising or marketing materials.
6. INFORMATION
YOU DISCLOSE PUBLICLY OR TO OTHERS
The Services may permit you to post or submit written content, user profiles,
audio or visual recordings, computer graphics, pictures, data, or other
content, including Personal Information (collectively, “User Content”).
If you choose to submit User Content to any public area of our Services, your
User Content will be considered “public” and will be accessible by anyone,
including us, not subject to this Privacy Policy and may be used to the fullest
extent permitted by applicable law. We encourage you to exercise caution when
making decisions about what you disclose in such public areas. California
minors should see Section 11 regarding potential removal of certain posted
content.
7. THIRD
PARTY SERVICES AND SOCIAL FEATURES
Our Services may include hyperlinks to websites, locations, platforms, or
services operated by third parties ("Third Party Service(s)").
These Third Party Services may use their own cookies, web beacons and other
Tracking Technology to independently collect information about you and may
solicit Personal Information from you. Certain functionalities on the Services
permit interactions that you initiate between the Services and certain Third
Party Services, such as third party social networks (“Social Features”).
Examples of Social Features include “liking” or “sharing” our content and
otherwise connecting our Service to a Third Party Service. If you use Social
Features, and potentially other Third Party Services,
information you post or provide access to may be publicly displayed on our
Services or by the Third Party Service that you use. Similarly, if you post
information on a Third Party Service that references
our Services (for example, by using a hashtag associated with VesselMan in a
tweet or status update), your post may be used on or in connection with our
Services. Also, both VesselMan and the third party may have access to certain
information about you and your use of our Services and the Third Party Service.
To the extent we combine information from Third Party Services with Personal
Information we collect directly from you on the Services, we will treat the
combined information as Personal Information under this Privacy Policy.
Third Party Responsibility
The information collected and stored by third parties remains subject to their
privacy practices, including whether they continue to share information with
us, the types of information shared, and your choices on what is visible to
others on Third Party Services. We are not responsible for the collection,
usage, and disclosure policies and practices (including the data security
practices) of any other organization, including any Personal Information you
disclose to other organizations through or in connection with our Social Media
Pages. We make no representations regarding the policies or business practices
of any third parties or Third Party Services and encourage you to familiarize
yourself with and consult their privacy policies and terms of use.
8. ADVERTISING,
ANALYTICS SERVICES, AND ONLINE TRACKING
We may use third party advertising companies to serve advertisements on our
behalf on the Services and/or on Third Party Services and to provide analytics
services about the use of our Services and the performance of our ads and
content on Third Party Services. In addition, we may participate in online
advertising networks and exchanges that display relevant advertisements to our
Service visitors, on our Services and on Third Party Services and off of our
Services, based on your interests as reflected in your browsing of the Services
and certain Third Party Services. These entities may use cookies and other
Tracking Technologies to automatically collect information about you and your
activities, such as registering a unique identifier for your device and tying
that to your online activities on and off of our Services. We may use this
information to analyze and track data, determine the popularity of certain
content, deliver advertising and content targeted to your interests on the
Services and Third Party Services and better understand your online
activity.
Online Behavioral Advertising
Some information about your browsing of the Services and certain Third Party
Services may be collected across time and services and shared with third
parties to deliver ads and/or other content to you on the Services and certain
Third Party Services. VesselMan may receive information about Third Party
Services that you have visited and use it for marketing purposes—a practice
sometimes termed “(re)-targeting,” “interest-based advertising,” and “online
behavioral advertising.”
Third Parties
We are not responsible for third parties or Third Party Services associated
with advertising and analytics services, and related tracking activities. We
encourage you to consult their privacy policies and notices for information on
their practices and see Section 13 regarding certain choices some of them may
offer you. Your browser settings may allow you to automatically transmit a “Do
Not Track” signal to online services you visit. Note there is no consensus
among industry participants as to what “Do Not Track” means in this context.
Like many online services, we currently do not alter our practices when we
receive a “Do Not Track” signal from a visitor’s browser. To find out more
about “Do Not Track,” visit http://www.allaboutdnt.com.
9. DATA
SECURITY
We seek to use reasonable measures to help protect information about you from
loss, theft, misuse and unauthorized access, disclosure, alteration and
destruction. In addition, VesselMan will not keep your Personal Information for
longer than necessary for the purposes set out in this policy. Unfortunately,
no data transmission or storage system is completely secure and we cannot
guarantee the security of your information collected through our Services. Your
Personal Information is stored on servers in Ireland /EU and Norway maintained
with the assistance of a third party data storage provider.
10. INTERNATIONAL
TRANSFER
VesselMan complies with the Privacy Shield Framework, as set forth by the U.S.
Department of Commerce in consultation with the European Commission, regarding
the collection, use and retention of Personal Information received from the
European Union. To learn more about the EU – U.S. Privacy Shield Framework,
please visit https://www.privacyshield.gov/EU-US-Framework.
11. CHILDREN’S
PRIVACY
Our Services are not intended for children and are not targeted to children
under the age of thirteen (13). If you are a child under the age of thirteen
(13), you are not permitted to use the Services and should not send any
information about yourself to us through the Services.
COPPA
We do not knowingly collect any personal information from children under the
age of 13 and, if we learn that we have received information from a user under
the age of 13, we will delete this information in accordance with the
Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or
guardian and you believe that your child under the age of thirteen (13) has
provided us with personal information without COPPA-required consent, please
contact us at info@VesselMan.com.
12. ACCESSING
AND CHANGING INFORMATION
VesselMan will provide web pages or other mechanisms allowing you to correct or
update some of the Personal Information you have provided us.
Access Rights
Users from the European Union, Singapore, Hong Kong, Japan, New Zealand,
Mexico, and Australia have a right to access their Personal Information,
request corrections and/or deletions, and oppose the use of their Personal
Information for specific purposes, subject to exceptions allowed by law. Such
users are also entitled to request information on the origin of their Personal
Information, the recipients or types of recipients to whom their Personal
Information is provided, the reason for which their Personal Information is
being stored, and the ways in which their Personal Information has been or may have
been used or disclosed by us within a year before the date of the request. If
you would like to do so, please send your request in writing by sending an
email to info@VesselMan.com. For all requests, we will need evidence of you
identification to carry out your requests. To protect your privacy and the
privacy of others, we will need evidence of your identity before we can grant
you access to information about you or change it. You will not be charged for
compliance with such a request.
Changes and Deletions
We will make good faith efforts to make requested changes in our then-active
databases as soon as practicable (but may retain prior information for records
to the extent not prohibited by applicable law). Please note that it is not
always possible to completely remove or delete all of your information or
public postings from our databases and that residual data may remain on backup
media or for other reasons. We also may retain cached or archived copies of
information about you for a certain period of time.
13. CHOICES:
TRACKING AND COMMUNICATIONS OPTIONS
A. Tracking
Technologies Generally.
Regular cookies may generally be disabled or removed by tools available as part
of most commercial browsers, and in some instances blocked in the future by
selecting certain settings. Browsers offer different functionalities and
options so you may need to set them separately. Please be aware that if you
disable or remove cookies some parts of our Services may not work and that when
you revisit our Services your ability to limit browser-based Tracking
Technologies is subject to your browser settings and limitations. With respect
to our mobile applications, you can stop all collection of information by
uninstalling the app. Also, you may be able to exercise specific privacy
choices, such as enabling or disabling location identifying services, by
adjusting the permissions in your mobile device.
B. Analytics
and Interest-Based Advertising.
Certain companies may participate in the Digital Advertising Alliance
("DAA") AdChoices Program and may display
an Advertising Option Icon for interest-based ads that links to an opt-out tool
which allows you to exercise certain choices regarding targeting. You can learn
more about the DAA AdChoices Program at http://www.youradchoices.com/ and
its opt-out program for mobile applications at http://www.aboutads.info/appchoices.
In addition, certain advertising networks and exchanges may participate in the
Network Advertising Initiative (“NAI”). NAI has developed a tool that allows
consumers to opt-out of certain targeted advertising delivered by NAI members'
ad networks. To learn more about opting out of targeted advertising or to use
the NAI tool, visit http://www.networkadvertising.org/choices/.
Please be aware that, even if you are able to opt-out of certain kinds of
targeted advertising, you will continue to receive non-targeted ads. We are not
responsible for effectiveness of, or compliance with,
any third-parties’ opt-out options or programs or the
accuracy of their statements regarding their programs. However, we support the
ad industry’s 2009
Self-regulatory Principles for Online Behavioral Advertising (http://www.iab.net/media/file/ven-principles-07-01-09.pdf). and
expect that ad networks we directly engage to serve you interest-based ads will
do so as well, though we cannot guaranty their compliance.
C. Communications.
You may opt-out of receiving promotional communications (e-mails or text
messages) from us at any time by (i) for promotional
e-mails, following the instructions as provided in e-mails to click on the
unsubscribe link or changing your communication preferences by logging onto
your account; and (ii) for text messages, following the instructions as
provided in text messages from us to text the word, “STOP”. Please note that
your opt-out is limited to the e-mail address or phone number used and will not
affect subsequent subscriptions. If you opt-out of only certain communications,
other subscriptions may continue. Even if you opt-out of receiving promotional
communications, we may, subject to applicable law, continue to send you
non-promotional communications, such as those about your account, transactions,
servicing, or our ongoing business relations.
D. Mobile
Applications.
Our mobile applications may send you notifications that may include alerts,
sounds, and icon badges. These push notifications or in-app messages may
include both operational messages and promotional messages regarding products,
services and offers that may be of interest to you. These can be configured in
Settings. As with e-mails, even if you opt-out of receiving promotional
communications, we may continue to send you non-promotional push notifications,
such as those about your use of the applications or our ongoing business
relations.
14. YOUR
CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law permits customers in California to request
certain details about how certain types of their information are shared with
third parties and, in some cases, affiliates, for those third parties’ and
affiliates’ own direct marketing purposes. For our U.S. users, we may from time
to time elect to share certain information about you collected by us on the
Service with third parties or affiliates for those third parties’ or
affiliates’ own direct marketing purposes. If you are a California resident,
you may opt-out of such future sharing by contacting us at info@VesselMan.com Requests
must include "California Privacy Rights Request" in the first line of
the description and include your name, street address, city, state, and ZIP
code. Please note that we are only required to respond to one request per
customer each year, and we are not required to respond to requests made by
means other than through this e-mail address.
15. PRIVACY
RIGHTS IN NON-U.S. JURISDICTIONS
Accuracy and Access to Personal Information
EU persons may request access to their Personal Information under this policy
to the full extent required by applicable law in the home country of the person
making the request. Such persons may request the correction, amendment, or
deletion their Personal Information that is inaccurate or has been processed in
violation of the Privacy Shield Principles. VesselMan will reasonably fulfill
such requests to the extent required by applicable law.
Users from outside the U.S. have the right to ask us not to process their
Personal Information for marketing purposes. We will inform you (before
collecting your information) if we intend to use your information for such
purposes or if we intend to disclose your information to any third party for
such purposes. You can exercise your right to prevent such processing by
checking certain boxes on the forms we use to collect your information.
You can exercise these rights at any time by contacting us at info@VesselMan.com
or by sending a letter to the addresses set forth in Section 16 below.
Revocation of Consent
Users from outside the U.S. also have the right to revoke their given consent
regarding the use and sharing of their Personal Information. However, it is
important to note that in some cases such request may not be immediately or
fully executed because it is possible that we have a legal obligation to keep
using your Personal Information. Also, you must consider that for certain
purposes, the revocation of consent means that we cannot continue providing the
services you requested. You can revoke your consent at any time by contacting
us at info@VesselMan.com or by sending a letter to the addresses set forth in
Section 16 below.
Accountability and Inquiries
Any EU person who is not satisfied with VesselMans´
compliance with the EU – U.S. Privacy Shield may contact the VesselMan to
resolve such complaints at info@VesselMan.com or
by sending a letter to the addresses set forth in Section 16 below. If any EU
person believes that such a complaint has not been resolved, he or she agrees
first to try and settle the dispute by mediation, administered by the
International Centre for Dispute Resolution under its Mediation Rules, before
resorting to arbitration, litigation, or some other dispute resolution procedure.
The rules governing these procedures and information regarding how to file a
claim free of charge can be found here: http://info.adr.org/safeharbor/.
Any EU person who remains dissatisfied may contact his or her national Data
Protection Authority in the country where the person resides. VesselMan has
agreed to cooperate and comply with appropriate EU Data Protection Authorities
and the Department of Commerce in resolving such disputes. If an EU person
remains dissatisfied and meets the pre-arbitration requirements of Annex I Part
C of the EU – U.S. Privacy Shield Framework, the person may invoke binding
arbitration pursuant to procedures in Annex I of the EU – U.S. Privacy Shield
Framework Principles found here:
https://www.privacyshield.gov/EU-US-Framework.
16. CONTACT
US
For any requests relating to your Personal Information, or if you have any
questions about this Privacy Policy, please contact us at:
VesselMan AS
Anna Quams Vei 9, 2201 Kongsvinger
Norway
(Attention: Legal Counsel)
info@VesselMan.com