Privacy

TABLE OF CONTENTS

1. INTRODUCTION

2. SCOPE AND AIM

3. DEFINITIONS

4. HOW WE COLLECT YOUR DATA

5. OUR PRINCIPLES RELATING TO PROCESSING OF YOUR PERSONAL DATA

6. DATA CONTROLLER

7. DATA - LAWFULNESS OF PROCESSING - PURPOSES - STORAGE PERIOD

8. PROCESSING OF CHILDREN’ S DATA

9. CONSENT

10. DATA PROVISION – RETREIVABLE INFORMATION

11. PROCESSORS & RECIPIENTS

12. TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY

13. YOUR RIGHTS

14. STORAGE & SECURITY OF PERSONAL DATA

15. EMPLOYERS’ INFORMATION

16. DISPUTE RESOLUTION

17. UPDATES TO THE PRIVACY POLICY

18. DRAFTING – EDITING

1. INTRODUCTION

The platform www.liveseas.com is owned and operated by the company SEASLIVE LTD, with registered offices at 128 City Road, London EC1V 2NX, United Kingdom, Company number 14547639, e-mail: privacy@liveseas.com.

The Company has taken the appropriate technical and organisational measures which ensure that processing of your personal data complies with the General Data Protection Regulation (EU) 2016/679 (GDPR). Especially, Liveseas.com adopts internal policies and implements measures which meet the principles of data protection by design and data protection by default.

This Privacy Policy applies to the Platform’s Users. Therefore, the words "you", "your" and generally the use of the second plural form refers to any User. Throughout the Privacy Policy, the use of first plural form (terms “we”, “us”, “our” etc.), refer to the Company. Users and Visitors should comply with the Privacy Policy, while browsing the Platform. By using this Platform, you agree to be bound by this Privacy Policy. In case you disagree with the Privacy Policy, you must refrain from any action, interaction, access and use of the Platform.

The Privacy Policy binds the Employers who collect your Data through the Platform. The Employers should collect and process your data only for the purposes they were disclosed to them and not further process them in a manner that is incompatible with those purposes. The Company performs no audits of this processing; therefore, we do not guarantee that the Employers process your data lawfully, fairly and in a transparent manner that ensures appropriate security.

2. SCOPE AND AIM

While browsing through different webpages of the Platform, we may ask you to disclose some personal data in order to provide you with our Services. The present Privacy Policy (hereafter Privacy Policy) describes the type of your personal data which are subject to the processing, the way and the context in which your personal data are collected, the purposes and means of the processing of your personal data , the lawfulness of processing, the entities to which your personal data may be disclosed, the purpose limitations, the storage period, the measures we take to ensure lawful and fair processing and the principles relating to processing of your personal data. It also includes information about your rights and data protection. The Privacy Policy applies only to processing of personal data by the Company for purposes of the Platform’s Services and operation.

This Privacy Policy does not apply to the processing of your Personal Data by the Employers (Recipients) for any purposes and by any means that they determine, after the disclosure of your Data to them. Read more at the chapter PROCESSORS & RECIPIENTS.

3. DEFINITIONS

Personal data or Data: Any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Processing : Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Data controller : The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the Controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Processor : A natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller;

Consent of the data subject: Any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Recipient : A natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

Third party : A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

Supervisory authority An independent public authority which is established by a Member State pursuant to Article 51 G.D.P.R.

Restriction of processing : The marking of stored personal data with the aim of limiting their processing in the future;

Profiling : Any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;

For any other term please read the Terms of use.

4. HOW WE COLLECT YOUR DATA

We collect your personal data either directly from you, or through other sources. We collect your data through this Platform and / or in other ways (social media, cookies, analytics tools, e-mails etc.). In this case data processing may also be subject to another privacy policy (e.g. Google / Facebook privacy policy).

5. OUR PRINCIPLES RELATING TO PROCESSING OF YOUR PERSONAL DATA

On this Platform we process your personal data lawfully, fairly and in a transparent manner (‘lawfulness, fairness and transparency’). We collect your personal data for specified, explicit and legitimate purposes. Your data are not further processed in a manner that is incompatible with those purposes (‘purpose limitation’). Furthermore, your personal data that we process are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’). Your personal data are also accurate and, where necessary, kept up to date. We take every reasonable step to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’). Your personal data are kept in a form which permits identification of you for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’). Your personal data are processed in a manner that ensures appropriate security of them, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

6. DATA CONTROLLER

For any processing of personal data carried out by the Company, solely for the following purposes, the company “SEASLIVE LTD” is the Data Controller (e-mail: privacy@liveseas.com). The Data Controller determines the purposes and means of the processing of your personal data.

7. DATA - LAWFULNESS OF PROCESSING - PURPOSES - STORAGE PERIOD

In this section you can retrieve information about the categories of your Personal Data we process, the Processing of such data in relation to the purpose we pursue on a case-by-case basis, the legal basis for each processing activity and the storage period.

PROCESS

DATA

PURPOSE

LEGAL BASIS

STORAGE PERIOD

Registration (collecting essential data for an account creation)

E-mail, first name, last name, position (industry, department), title, job preferences (industry, ship type/size, role)

We will process your data to create and retain a personal account for you and provide you with the Services

Processing is necessary for the performance of a contract to which you are party

Your Personal Data are stored for as long as you retain your account*

You may edit these data at any time, except for your e-mail

Registration (collecting optional account information / profile completion)

CV **, current location, work experience (seatime, sea service record)

1. We will process your data to create and retain a personal account for you and provide you with the Services.

2. Providing of your CV, work experience & current location adds a percentage of completion to your profile which unlocks extra Services

Processing is necessary for the performance of a contract to which you are party

Your Personal Data are stored for as long as you retain your account*

You may delete / edit these data at any time

Registration (collecting optional account information)

Information about your documents & certifications: Passport (issuing country, expiry date), Seaman’s Book (issuing country, expiry date), Certificate of competency (license) (issuing country, expiry date, details), profile photo, phone, selected companies, short bio

We will process your data to create and retain a personal account for you and provide you with the Services

Processing is necessary for the performance of a contract to which you are party

Your Personal Data are stored for as long as you retain your account*

You may delete / edit these data at any time

Registration (collecting optional account information)

1. Nationality

2. Information about the validity (expiry date) of your Medical Fitness Document

1. We will process your data to create and retain a personal account for you and provide you with the Services.

2. Providing of your Nationality adds a percentage of completion to your profile which unlocks extra Services

Consent

Your Personal Data are stored for as long as you retain your account*

You may delete / edit these data at any time

Contacting Users

E-mail

We may use your Data to send you improvements and / or updates to our Services’ specifications.

1. Processing is necessary for the performance of a contract to which you are party


2. Legitimate Interests (to inform Users)

Your Personal Data are stored for as long as you retain your account*

Responding to questions / requests / complaints

Name, e-mail, messages, requests etc.

We process your personal data to answer your questions / respond to your requests etc./ provide you with information / support / solve a problem / handle a complaint you have submitted

1. When you seek information about the Services, we process your Data in order to take steps at your request, prior to entering into a contract.

2. Processing is necessary for the performance of Liveseas Agreement

3. Legitimate Interests (to communicate with Users)

Unless you are already a User, we will store your Personal Data for one year from the last time you have contacted us. Otherwise, we will keep your Data for as long as you retain your account*

Newsletter Subscription

E-mail

We will process your e-mail to send you free of charge e-mails with advertising content, promotions, events, discounts, special offers, actions, contests, Company’s news & plans etc.

Consent

We will store your e-mail for this purpose until you unsubscribe. You may unsubscribe at any time. In this case, if there is another legal basis for keeping your e-mail, we will also store it to an unsubscribe list to fulfil our legal obligation, otherwise we will completely erase it.

Social Media Accounts management

Fans’ / Followers’ profile name, comments, reviews, contact details, messages, reactions / likes / shares / comments on Social Media Platforms (Company’s accounts / pages on Facebook/Instagram/Twitter)

1. Respond to users’ messages / reviews.

2. Communicate with the users.

3. Review comments etc.

1. Consent

2. Legitimate Interests (to communicate with fans/followers)

Your personal data will be retained for as long as you remain a fan / follower / member / subscriber of our pages / accounts or for as long as your activity (posts, comments, reactions, reviews etc.) remains on our social media accounts / pages

Contests

1. Participant information from Social Media platforms (profile name, likes/shares/comments) where the contest is hosted.

2. Winners’ full name, phone number, e-mail will be also collected

We will process this information to run the contest, communicate with the winners and award the prizes

Consent

Until the contest is completed and the prizes are awarded to the winners

Cookies

Analytics

Web Beacons

Pixels

Information collected through Cookies, User ID, activity data, visits to the Platform, Platform usage statistics, IP, browser type and log files

Collection of information through Cookies, contributes to the smooth and efficient operation of the Platform, to the recording and retention of your preferences while browsing the Platform and to improvement of your experience while using the Platform. It also allows statistical analysis of your activity on the Platform; improves the way it operates, enhances its security, and helps in personalizing the content of the Platform and the ads displayed on the Platform or in other places on the internet (remarketing / retargeting, etc.), as well as in measuring and analyzing the effectiveness of the ads. The exact purpose of each cookie is described in the Cookies Policy.

1. Legitimate Interests (Smooth, proper and efficient operation of the Platform) (Functionality / Essential Cookies)

2. Consent

(Analytics / Marketing / tracking / third party Cookies)

Cookies’ storage time depends on the type of each cookie. Cookies are either temporary or persistent. Cookies can be deleted: 1) automatically at the time of expiration, 2) manually through your browser, 3) through the Cookie Consent Manager.

* If your account remains inactive and there is no other legal basis for the processing of your personal data, or no obligation to retain them exists, they will be deleted two years after your last login on the Website. In case of deletion of your account by the Company, your personal data will be kept for one month after the deletion of the account (unless there is another legal reason or obligation to maintain them) and you will be notified so that you can ask the Company to keep your profile active or to provide you with a copy of your data, then they will be permanently deleted.

** You shall refrain from including special categories of Personal Data in your CV, unless necessary. The Company shall not be liable for any damage incurred to you or a third party due to an illegal act performed by you, regarding special categories of Data. In case you send us Special Categories of Personal Data you consent to the processing of your personal data in accordance with this Privacy Policy.

The Company cooperates with advertising / promotional businesses, statistical analysis businesses, suppliers and service providers who process personal data on our behalf. We disclose to our partners your personal data, solely for the processing purposes referred to in this Privacy Policy.

We collect and process your personal data only for legal purposes, as the above-mentioned. We may process your personal data for purposes other than those for which your personal data were initially collected, only where the processing is compatible with the purposes for which your personal data were initially collected. We may also process your personal data, if processing is necessary for compliance with a legal obligation to which the Company is subject.

The time that your Personal Data may be retained by the Company is also determined by our legal obligations in the applicable Legislation. If there is a dispute, pursuant to our contract, we may keep your personal data for as long as the law stipulates.

8. PROCESSING OF CHILDREN’ S DATA

Only adults shall use the Platform’ s Services. Therefore, we do not collect or process children’s Data. The Company will erase any children’s Data that a User discloses to us through the Platform. The Company shall not be liable for any and all damages arising from any use of the Platform by a child.

9. CONSENT

We may ask for your consent to the processing of personal data relating to you. This may include ticking a box or expressing your understanding while browsing through different webpages of the Platform. Ticking that box or the expression of your understanding, is a clear affirmative action, which is considered as a freely given, specific, informed and unambiguous indication of your agreement to the processing of your personal data for the above-mentioned purposes, where the processing of your data is based on your consent. You may withdraw your consent at any time, without affecting the lawfulness of processing based on your consent before your withdrawal.

We will provide you all the information you need to express your agreement (consent) to the processing of personal data relating to you, where processing is based on your consent. You may retrieve this information through this Privacy Policy.

10. DATA PROVISION – RETREIVABLE INFORMATION

If you refuse to disclose your Personal Data to the Company, we may not be able to provide you with some of our Platform’s Services, send you newsletters, show you personalized search results (companies that meet your preferences / experience) and advertising, or you may not be able to participate in a contest, etc. In the context of the Liveseas Agreement, the provision of your essential data is a contractual requirement while the provision of some optional data is critical to reach the percentage of profile completion needed to be visible to Employers.

The information that you disclose to the Platform (work experience, position, title, job preferences etc.) effects the available Employers you may select as well as your profile’s inclusion in the Employer’s search results. These options are incorporated into the Services which you can use in the context of the Liveseas Agreement’s performance. You can change your information at any time, except for your e-mail. The information you retrieve from the Platform and the Employers you can reach may depend on the data you share with us. For more information, please read the Terms of Use. You can decide which information relating to you may the Selected Employers retrieve from the Platform (by adding or removing data to your profile). After you make your profile visible to the Selected Employers, they can review and collect all information included in it.

For your convenience, you may download an auto CV based on the information you have disclosed to us. Note that this document does not constitute an official document and is available only for personal use.

11. PROCESSORS & RECIPIENTS

We may need to disclose your Personal Data to authorized processors for (i) the maintenance / repair of our equipment (PCs, servers, hardware) that support the operation of the Platform, (ii) the development of the Platform and for other purposes (advertising etc.).

Where processing is to be carried out on behalf of the Company, we use only processors providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of the GDPR and ensure the protection of your rights. Some of the recipients and/or processors: i) Google LLC, ii) Meta Platforms Ireland Limited (Instagram & Facebook).

Facebook Privacy Policy: https://www.facebook.com/about/privacy.

Instagram Privacy Policy: https://help.instagram.com/519522125107875/?maybe_redirect_pol=0

The Company and Meta Platforms Ireland Limited are joint controllers for the collection and disclosure by transferring to Facebook/Instagram of the data collected through embedded Facebook/Instagram plugins (Share or Like button).

The Company uses Google Analytics. The Company and Google LLC. are Joint Controllers for some of the processing activities, while for other processing activities Google and the Company are sole Controllers.

Google determines some of the purposes and means of the processing of personal data collected through its technology. For each processing activity for purposes and means determined by Google, Google is the sole Controller. Google may use your personal data for its own purposes, such as profiling and combination with other data from user accounts in other services. The processing of your Personal Data under the Google Analytics service, either by the Company or by Google, is carried out on the basis of your prior consent.

Google Privacy Policy: https://www.google.com/intl/en/policies/privacy/.

Employers: Where you make your profile visible to specific Employers, we disclose your data to them as provided for in the Liveseas Agreement. The Employers may have full and immediate (live) access to your profile’s information as recipients of these data. You may at any time check which Employers have access to your data. You may ask the Company to which Employers your data have been disclosed. Any change to your data will be automatically visible to the Selected Employers. If you choose to deny access to your profile to a previously Selected Employer, we will immediately hide your profile from that Employer.

Upon accessing your Data, any Selected Employer becomes the Data Controller for any processing of your Data for any purposes and by any means that this Employer determines. The Company does not bear any responsibility for any processing of your Data by the Employers.

12. TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY

A transfer of your personal data to a third country (outside European Economic Area (EEA)) may take place where the Commission has decided that the third country ensures an adequate level of protection. In the absence of a decision, we may transfer personal data to a third country only if the processor has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available. Otherwise, any data transfer from the Company to you may take place if the transfer is necessary for the performance of the Liveseas Agreement between you and the Company.

13. YOUR RIGHTS

The Company protects your personal data and respects your rights and freedoms. As Data Subject you can exercise:

1. the right to be informed on the processing of your personal data,

2. the right of access to your personal data and to information relevant to processing. You have the right to obtain from the Company confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and relevant information,

3. the right of rectification of your personal data. You have the right to obtain from the Company without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement,

4. the right to erasure of your personal data. You have the right to obtain from the Company the erasure of personal data concerning you without undue delay and the Company will have the obligation to erase personal data without undue delay where one of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) you withdraw consent on which the processing is based, and where there is no other legal ground for the processing, (c) you object to the processing and there are no overriding legitimate grounds for the processing; (d) the personal data have been unlawfully processed; (e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Company is subject; (f) the personal data have been collected in relation to the offer of information society services,

5. the right to restriction of processing. You have the right to obtain from the Company restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by you, for a period enabling the Company to verify the accuracy of the personal data; (b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; (c) the Company no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; (d) you have objected to processing, pending the verification whether the legitimate grounds of the Company override those of you,

6. the right to data portability. You have the right to receive the personal data concerning you, which you have provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the Company to which the personal data have been provided, where: (a) the processing is based on consent or on a contract and (b) the processing is carried out by automated means,

7. the right to object to the processing of your personal data, the right not to be subject to a decision based solely on automated processing, including profiling and the right to withdraw your consent at any time,

8. the right to withdraw your consent at any time, without affecting the lawfulness of processing based on your consent before withdrawal, where the processing is based on consent.

To be informed about or exercise the above rights, you need to apply by writing to the Company with registered offices at 128 City Road, London EC1V 2NX, United Kingdom, or via e-mail: privacy@liveseas.com. We are ready to handle your request with respect to your rights and privacy. Otherwise, if the Data Controller does not take action on your request, you could lodge a complaint to a supervisory authority.

If you request the deletion of your account, we will deactivate your account without undue delay and we will delete your data within one month from the receipt and approval of your request. You may also use the Platform’s services to change/edit/complete your personal data.

Where you communicate us your decision to terminate the Liveseas Agreement, we will deactivate your account without undue delay, and we will delete your data within one month from the receipt and approval of your request.

We take all efforts to facilitate the exercise of your rights. We will not refuse to act on any request of yours for exercising your rights, which are described above, unless we are not in a position to identify the Data Subject.

We will respond in writing to such requests from you, without undue delay and in any event within one month of receipt of your request. In this case we will provide you with information on action taken on behalf of your request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

We will communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

The selected Employers who had access to your profile will immediately lose access to it upon deletion or any other form of denial of access by you, so they will have to delete your data if they have no other legal basis for keeping them. We do not bear any responsibility for the processing and storage of your Data by the Employers. Any requests for exercising your rights concerning the processing of your data by an Employer shall be sent directly to that Employer.

Otherwise, if we do not intend to act on your request, we will inform you without undue delay and at the latest within one month of receipt of the request, of the reasons for not taking action.

Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the Company may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested, or (b) refuse to act on the request.

14. STORAGE & SECURITY OF PERSONAL DATA

Taking into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, the Company implements appropriate technical and organisational measures to ensure that processing is performed in accordance with the GDPR. The Company reviews and updates those measures, where necessary.

Personal data collected through Liveseas.com are stored at the Company’ s computer systems and at the Platform’s server, within the European Union. Liveseas.com uses SSL certificate for secure encryption and transmission of your information. We do not disclose your data to other Users or non-selected Employers.

The Company shall not be liable for any damage caused by risks appearing in websites of entities advertised in this website or collaborating companies even if users are referred to said websites by hyperlinks, banners etc. placed on the Platform. Liability for the content, information, visitors’ safety and protection of their personal data, as well as the quality of services provided, lies with owners and administrators of said websites, which users visit at their own risk.

15. EMPLOYERS’ INFORMATION

We collect and process the first/last name, the position and a phone number of a natural person (legal representative, authorized employee, contact person), that the Employer discloses to us, to facilitate the registration and verification of the Employer’s account and the communication between the Company and the Employer. These Personal Data will be stored for as long the Employer’s account remains active. The Employer is responsible to confirm that consent of the Data Subject is given or to that there is another legal basis for disclosing these data to us.

16. DISPUTE RESOLUTION

Any dispute between the Company, Users, Employers and third parties will be resolved through friendly negotiations between them. If any dispute cannot be resolved through friendly negotiations within a maximum of two (2) months, the Company, the Users and the Employers also agree to participate in any other arbitration, mediation, or other alternative dispute resolution proceedings available for such disputes. If any dispute cannot be resolved by these procedures within a maximum of three (3) months, any lawsuit, action, or proceeding arising out of [or related to] the processing of personal data for the above - mentioned purposes, shall be heard exclusively in the courts of London, United Kingdom and you irrevocably submit to the jurisdiction of such courts in any such lawsuit, action, or proceeding, without prejudice to any exclusive jurisdiction provided by the mandatory law of your country of residence.

17. UPDATES TO THE PRIVACY POLICY

The Company reserves the right to amend this Privacy policy. Any changes will be post on this web page. You should periodically check whether changes have been made by the Company. Last update: 01.03.2023.

18. DRAFTING – EDITING

This Privacy policy was written by Attorney at Law Stefanos Andriakopoulos https://www.internetlaw.gr/.