This Privacy Policy outlines how MarinaChain Pte Ltd (the "Company") collects, uses, and protects the personal information of customers using the MarinaNet platform. This policy complies with global standards, including GDPR (EU), PDPA (Singapore), and PIPA (South Korea).
Effective Date: October 1, 2023
1. Legal Basis for Data Processing (GDPR Compliance)
In accordance with Article 6 of the GDPR, the Company processes data based on the following legal grounds:
- Performance of Contract: To provide MarinaNet services and customer support.
- Legal Obligations: To comply with maritime regulations (e.g., EU ETS, IMO DCS) and reporting requirements.
- Legitimate Interests: To maintain service security, prevent fraudulent use, and optimize platform performance (e.g., AWS log analysis).
- Consent: When the user has provided explicit consent for specific purposes, such as receiving marketing information.
2. Information Collected and Collection Methods
- Required Information: Name, email address, phone number, company affiliation, and account password.
- Operational & Technical Data: Vessel Noon Reports, emission data, IP addresses, browser types, and device identifiers.
- Collection Methods: Website forms, automated logs generated during platform use, and cookies.
3. International Data Transfer
The Company utilizes Amazon Web Services (AWS) for global operations. Data may be transferred as follows:
- Storage Location: AWS Regions (including service hubs in Seoul and Singapore).
- Safeguards: When transferring the data of EU citizens outside the EEA, we ensure a high level of protection by implementing Standard Contractual Clauses (SCCs) approved by the European Commission.
4. Data Retention and Destruction
- Retention Period: The Company retains personal data for the duration of the service use. Upon request for account deletion or termination of the service agreement, the data will be destroyed without delay.
- Backup Data Management: To ensure system recovery and data integrity, database snapshots (backups) are retained for a maximum of 7 days. After this period, the snapshots are permanently deleted through automated technical means. This short retention period is strictly enforced to adhere to the principle of data minimization and to prevent potential data misuse.
- Legal Exceptions: Data required to be stored by applicable laws (e.g., commercial law) or maritime regulations will be stored separately for the period prescribed by such statutes.
5. Data Subject Rights (EU & South Korea)
Users may exercise the following rights at any time by contacting info@marinachain.io:
- Right of Access: Request to confirm the status of your data processing.
- Right to Rectification & Erasure: Request to correct inaccurate data or exercise the "Right to be Forgotten."
- Right to Restriction & Objection: Request to stop or limit data processing under specific circumstances.
- Right to Data Portability: Receive your personal data in a structured, machine-readable format.
6. Technical and Administrative Security Measures
Our team of 21 employees adheres to strict security protocols, including:
- Encryption: All data is encrypted at rest (AES-256) and in transit (TLS/SSL).
- Access Control: Multi-Factor Authentication (MFA) is mandatory, and access is limited to the minimum necessary personnel.
- Monitoring: Real-time monitoring of security threats and access logs via AWS CloudTrail and Security Hub.
7. Cookies and Third-Party Services
The Company uses cookies to enhance user experience. Users can manage cookie preferences via browser settings, though some services may be limited. Third-party links within the platform (e.g., payment gateways, regulatory agencies) are governed by their respective privacy policies.
8. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on our platform and updating the "Effective Date" at the top. Your continued use of the platform after the changes have been made constitutes your acceptance of the revised policy.
9. Contact Information & Data Protection Officer (DPO)
For inquiries or to exercise your rights, please contact us via:
- Address: MarinaChain Pte Ltd (Singapore HQ)
- Email: info@marinachain.io
