This Privacy Policy (hereinafter, the “Policy”) applies to the use of this web portal (hereinafter the “Web Portal”), owned and operated by ShipReality Research Ltd. (hereinafter referred to as “ShipReality”, or just “we”), a registered limited company in Cyprus, registration number HE 408473 with the registered address at Tepeleniou 13, Tepelenio Court, 2nd floor, 8010, Paphos, Cyprus.
When you use our Web Portal, services and/or products, (hereinafter referred to as the “User” or just “you”), you are trusting us with information and data. This Policy includes important information and is meant to help you understand what information and data we collect, why we collect it, how you can update the information and data provided by you, as well as know your rights and choices you have with regard to the processing of information and data by us.
I. Definitions.
For the purposes of this Policy:
“Personal Data” means any information relating to an identified or identifiable natural person, including, indicatively, data provided by you and collected by us, when using the Web Portal, and/or services and/or products;
“processing” means any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
“services and products” means any services and products provided by ShipReality via the Web Portal
“financial partners” are institutions, including but not limited to banks, and other partners such as payment method acquirers, payout providers, and card networks that we partner with to provide the services and products.
II. Personal Data and Information we process.
We strictly limit the collection and processing of your Personal Data, and to the best of our abilities we will work only with other organizations who do the same. In order to access the Web Portal and provide you our services and products we collect the following information:
- User Data
For each individual User, you provide us with, and we securely process the following information:
- Email Address: Used as the primary contact and login identifier.
- First Name and Last Name: To personalize User experience and communication.
- Job Title: To understand your professional role and cater our services accordingly.
- Company Data
For every company registered on the Web Portal, we collect the following billing information, which is utilized when users purchase new products:
- Address: The physical location for billing and service delivery.
- VAT Number: For tax identification and compliance.
- Contact Details: Includes the first name, last name, email, and phone number of the individual responsible for billing and invoice-related communication.
III. Why we use Personal Data and Information.
We only process, collect and use your Personal Data and Information when we have a legitimate reason for doing so. We only collect Personal Data and Information that is reasonably necessary to provide our services to you. Namely, we use your Personal Data and Information to provide you with and deliver our services and products, including access to the Web Portal, support, personalization and communication.
We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
- to enable your access to the Web Portal;
- to administer our Web Portal;
- to provide you with our services and products;
- to enable you to customize or personalize your experience of use of the Web Portal;
- To respond to any communications, queries or requests from you;
- for analytics, market research, and business development, including to operate and improve the Web Portal, and/or services, and/or products;
- for advertising and marketing, including to send you promotional information about our services and products;
- for internal record keeping and administrative purposes;
- to comply with our legal obligations and resolve any disputes that we may have;
We do not and will not use Personal Data and Information that you provide to us in a manner inconsistent with the purposes for which you provided it to us, as set out herein. We do not sell, rent or lease personal data.
All payments and/or money transactions via the Web Portal are executed by our financial partners, which are third party payment processors that collect your data and process the payment and interact with your bank or credit card issuer. Ship Reality does not access, collect or in any manner process any financial data regarding your payment.
IV. Legal bases for processing Personal Data and Information.
For purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and national applicable data protection legislation, we rely on several legal bases to process your Personal Data and Information.
i) Performance of a Contract or Transaction (Pre-Contractual and Contractual). We process Personal Data and Information to enter into business agreements and relationships with Users and to fulfill our respective contractual obligations. These processing activities include:
– Creation and management of Web Portal account, and Web Portal account credentials;
– Accounting, auditing, and billing activities;
-Communications regarding the execution of contractual agreement and fulfillment of our contractual responsibilities towards User.
ii) Consent. Users may be asked to give us their consent to collect and use their Personal Data and Information for a specific purpose (for example, communication through mailing list). In such cases, Users may withdraw their consent at any time via email at support@shipreality.com without affecting the lawfulness of processing based on consent before the withdrawal.
iii) Compliance with law. In order to comply with legal requirements, ShipReality may have a legal obligation to use or keep your Personal Data and Information. Such cases may indicatively include compliance with applicable regulatory obligations, court orders, criminal investigations, government requests, and regulatory obligations.
iv) Legitimate interests. We process Personal Data and Information when necessary for our legitimate interests. We consider our legitimate interests indicatively: (i) to administer the Web Portal, (ii) to carry out research and development. We will only rely on this legal basis merely when we have previously identified the purpose (the legitimate interest), assessed that the processing is necessary for that purpose and conducted a balancing test to ensure that this interest is not overridden by the interests, rights and freedoms of the Users.
V. How we protect Personal Data and Information.
In ShipReality we acknowledge that Personal data an Information shall be subject to additional safeguards to ensure the secure procession. At that end, we work hard to ensure Personal Data and Information provided by Users is encrypted when in storage and/or transit. Access to Personal Data and Information is strictly limited to a minimum number of individuals and subject to confidentiality commitments.
ShipReality takes all steps reasonably necessary to ensure that your Personal Data and Information is treated securely and in accordance with this Policy. Unfortunately, the transmission of information via the internet is not completely secure. ShipReality uses strict procedures and security features to try to prevent unauthorized access.
We never transfer your data outside the European Economic Area (EEA) unless we have your explicit consent for it, or on the basis of specific safeguards in individual circumstances of which we will inform you if they apply to your data. ShipReality ensures that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
ShipReality does not share your Personal Data and Information with third parties.
VI. How long do we keep your Personal Data and Information.
At ShipReality, we ensure that all and any Personal Data and Information is retained only for as long as necessary in accordance with the purposes and applicable laws and to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data and Information, the potential risk of harm from unauthorized use or disclosure of your Personal Data and Information, the purposes for which we process your Personal Data and Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Regarding the provision of our Services and Products based on an agreement with User, ShipReality will retain any data which relates to such agreement for ten years.
VII. User’s Rights and Control of Personal Data and Information
Users have the following rights:
Right to Access: User has the right to request copies of their Personal Data and Information from ShipReality. We may charge you a fee for this service.
Right to Rectification: You have the right to request to correct and/or complete information you believe is inaccurate and/or incomplete.
Right to Erasure: Subject to certain conditions, you have the right to request that we delete the Personal Data and Information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your Personal Data and Information, we will let you know how the deletion affects your use of the Web Portal and/or the provision of products and services. There may be exceptions to this right for specific legal reasons which and, if applicable, we will set out for you in response to your request.
Restrict: You have the right to request that we restrict the processing of your Personal Data and Information if (i) you are concerned about the accuracy of such Personal Data and Information; (ii) you believe your Personal Data and Information has been unlawfully processed; (iii) you need us to maintain the Personal Data and Information solely for the purpose of compliance with law; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Objecting to processing: You have the right to object to the processing of your Personal Data and Information that is based on our legitimate interests or public interest. In such case, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
Data portability: You have the right to request a copy of the Personal Data and Information you have provided to us to be provided to you and/or another data controller. The format of such information will be in a structured, commonly used and machine-readable format.
We have 30 days to respond to you if you make a request. To exercise any of these rights please contact us below with “GDPR Request” in the subject line: support@shipreality.com
VIII. Amendments.
ShipReality, at its discretion, may change this Policy to reflect updates to business processes, current acceptable practices, or legislative or regulatory changes. Any and all amendments and changes will be posted on the Web Portal. If required by law, we will get your permission and/or give you the opportunity to opt in to or opt out of, as applicable, regarding new uses of your Personal Data and/or Information, if any.