Siren Marine Inc.
Effective Date: [April 1, 2022]
- IN GENERAL
- Your personal data are processed by Siren Marine, Inc., a Delaware corporation. You can contact us via e-mail at [email protected].
- Where we refer to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.
- TYPES OF PERSONAL DATA WE PROCESS
- Whenever you use our Website, we collect:
- Technical information associated with the device you use, such as the device type and model, system language, browser type, geographical location and operating system;
- Technical identifiers that identify the device you use, such as IP address, IDFA (identifier for advertisers) and other unique identifiers; and
- Information concerning your browsing behavior and engagement information, such as how long you visit, what links you click on, what pages you visit, how many times you visit a page and how long it takes for you to come back.
- When you use a Siren Marine Device, register for our Service, or make use of one of our mobile applications, we collect:
- Information relating to the functionality of the equipment installed on your vessel;
- Information we require in order to provide the Service, including sending alerts of an occurrence onboard detected by an installed Siren Marine Device;
- Basic identity information we require to register you for our Service, including your name, your contact details such as your e-mail address and phone number, and details pertaining to your preferences;
- Information we require to allow you access to our Service, namely, your e-mail address;
- Your interaction with our Service;
- Your location; and
- Other personal data you provide to us.
- When you contact us via e-mail, telephone, or any other way, we collect the information you provide to us. In most cases, this is:
- Your contact information such as your name, e-mail address, phone number, and postal address;
- The content of your communication and the technical details of the communication itself, such as with whom you correspond at our end and the date and time;
- Publicly available information about you; and
- Any other personal data you choose to provide to us.
- When you post publicly available blogs or testimonials on our Website, we collect the information you provide to us.
- PURPOSES FOR PROCESSING
- We process your personal data in order to provide you the Service you request from us. This includes sending alerts of an occurrence onboard detected by an installed Siren Marine Device, presenting the Website and its contents to you, providing you with information, products or services that you request from us, and responding to your correspondence.
- If you are a registered user, we process your personal data to send you relevant communications about your subscription, including to provide you with notices about your account/subscription, expiration and renewal notices, and changes to the Website or any products or services we offer or provide through the Website.
- We process your personal data to send you relevant communications, promotions and offerings about our new products and services.
- We process your personal data to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- We process your personal data to perform statistical analyses for internal market research so that we may improve our Website or to develop new products and services.
- We may be required to collect and transfer your personal data to our financial institution or payment service provider to allow your financial institution and the payment service provider to comply with their legal obligations, such as obligations under applicable anti-money laundering and counter-terrorism financing legislation.
- We may process your personal data for informing any third party in the context of a possible merger with, acquisition from/by or demerger by that third party.
- We process your personal data to comply with our legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, or governmental agencies or bodies, including competent data protection authorities. In the same way, we may transfer your personal data upon our own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of our Website, our Service, or other interaction with us.
- We may also process your personal data to fulfil any other purpose for which you provide your personal data, and for any other purpose we describe when you provide the information.
- LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
- We process your personal data to provide you the Service you requested as set out in clause 3.1, as far as this is necessary for performing the agreement between you and us.
- You can opt in for the communications referred to in clauses 3.2 and 3.3. By opting in, you give us your consent to process your contact information for this purpose.
- When you first use our mobile application, we ask you for consent for processing your location data under the conditions outlined in clause 3.1. You can always change your preferences in the settings on your mobile device.
- The processing of your personal data for the purposes outlined in clauses 3.6 and 3.8 is necessary to allow us to comply with our legal obligations.
- The processing of your personal data for the purposes outlined in clauses 3.1, 3.4, 3.5, 3.7, and 3.9 is necessary for the purpose of the legitimate interests of Siren Marine, which are:
- Continuous improvements of our Website, products and services to ensure that you have the best experience possible;
- Keeping our Website and Service safe from misuse and illegal activity; and
- Marketing and promotion of our products and services, and overall successful commercialization of our products and services.
- We may disclose your personal data to our parent entities, subsidiaries and affiliates for the purposes set out in clause 3.
- You understand that if you use our Website or Service, your personal data is also processed by third parties on our behalf in order to provide you our Website and Service and to improve them. For example, we rely on third parties for sending you alerts of an occurrence detected onboard. We also use a third party to safely store your personal data, as well as to process your subscription payments. Moreover, we rely on third parties to follow certain of your actions on our Website in order to better understand how our Website is used.
- Our third-party processors are only allowed to process your personal data on behalf of Siren Marine upon our written instruction. We warrant that all of our third-party processors are selected with due care and are contractually obliged to observe the safety and integrity of your personal data.
- We do not sell or otherwise provide personal data to third-party advertisers to assist in the marketing of third-party products or services to users.
- LOCATION AND TRANSFER
- The recipient country having legislation in place which is considered essentially equivalent to the protection offered within the European Economic Area and the United Kingdom. The European Commission maintains and publishes a list of such countries: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en; and
- A contractual agreement being in place between us and the third party such as an agreement based on the European Commission’s standard contractual clauses for the transfer of personal data to third countries (Commission Implementing Decision (EU) 2021/914 of 4 June 2021).
- You can request further information about how we safeguard your personal data outside the European Economic Area and the United Kingdom by contacting us at [email protected] .
- QUALITY ASSURANCES
- We do its utmost to process only those personal data which are necessary to achieve the purposes listed under clause 3.
- An overriding interest of Siren Marine or any other third party in keeping your personal data identifiable; or
- A legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.
- We make our best effort to ensure that any personal data we collect are safely kept. We have implemented technical and organizational measures designed to secure your personal data, including a variety of privacy and security policies, processes and procedures and administrative, physical and technical safeguards that we deem to reasonably and appropriately protect the integrity and availability of your personal data. We endeavor to encrypt the transmission of your personal data using secure locket layer technology. Access by personnel of us or our third-party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only that can never be guaranteed.
- If you are registered to receive communications, offerings and other advertisements via e-mail or other person-to-person electronic communications channels, you can change your preferences for receiving such communications by clicking the ‘unsubscribe’ link in our communication, or by sending us your request by e-mail to [email protected].
- The Website may contain links to third-party websites over which we have no control. We are not responsible for the privacy policies or practices of other websites. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use, and share your information.
- YOUR RIGHTS
- You have the right to request access to all personal data processed by us pertaining to you. We reserve the right to charge a reasonable administrative fee, taking into account the administrative costs of providing the communication or taking the action requested, or to refuse to act on your request, when your request is manifestly unfounded or excessive.
- You have the right to ask that any personal data pertaining to you that are inaccurate are corrected free of charge.
- If processing of your personal data is based on your consent, you have the right to withdraw your earlier given consent at any time. Withdrawal of your consent does not affect the legality of personal data processing that we have conducted based on consent given before that withdrawal. You may withdraw your consent through the Service you use, by contacting us at [email protected].
- You have the right to request that your personal data be deleted if they are no longer required in light of the purposes outlined in clause 3, or if you withdraw your consent. This request will be evaluated by Siren Marine against:
- Overriding interests of us or any third party; and
- Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion, you can also ask that we limit the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes listed under clause 3 but you need them to defend yourself in judicial proceedings.
- You have the right to object to the processing of your personal data on grounds relating to your particular situation. However, you can always object to processing for direct marketing purposes free of charge and without justification.
- When we process your personal data based on your consent or in order to perform a contract, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller.
- You have the right not to be subject to a decision solely based on automated processing, which produces legal effects concerning you or when this decision similarly significantly affects you, unless these decisions are made as a consequence of our agreement in order to provide you with the services requested by you or when we have asked your explicit consent for this.
- If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to [email protected]. Such request should clearly state which right you wish to exercise and, if required, the reasons or proof for it. It should also be dated and accompanied by any evidence adequately proving your identity.
We will promptly inform you of having received this request. If the request proves valid, we will honor it as soon as reasonably possible and at the latest one month after we received your request.
You may also contact a supervisory authority to lodge a complaint, in particular, in the EU Member State of your habitual residence, place of work, or of an alleged infringement of applicable data protection law. Where applicable, you may also lodge a complaint with the UK ICO.