Privacy Policy

The Company processes data under the following legal bases pursuant to Article 6 of the GDPR:

• Performance of a Contract: To provide Platform services and customer support.
• Legal Obligation: To comply with maritime regulations (EU ETS, IMO DCS, etc.) and related reporting obligations.
• Legitimate Interests: To maintain service security, prevent fraudulent use, and optimize Platform performance (e.g., AWS log analysis).
• Consent: Where you have given separate consent, such as for receiving marketing communications.

• Required information: Name, email address, phone number, company affiliation, account password.
• Operational and technical data: Vessel identification reports, emissions data, market/asset-related input values, IP address, browser type, device identifiers.
• Collection methods: Website forms, automatically generated logs during Platform use, and cookies.

Some services on the Platform (e.g., MarinaValue) provide outputs through AI-based automated processing, such as market data analysis, asset value estimation, and predictive modeling. Other services (e.g., MarinaDocs) use AI models to assist with drafting and reviewing internal documents.

• These analysis, prediction, and document-assistance features are intended for user reference or work support; their outputs are not used as legally binding decisions or as sole automated decisions about an individual.
• Analysis results are provided for informational purposes only and may differ from actual market conditions. Responsibility for final decisions rests with the user, and the Company assumes no legal liability in connection with such decisions.
• If you wish to exercise your rights under GDPR Article 22 (automated individual decision-making, including profiling) in relation to the above processing, please contact us using the details in Section 10.
• For the specific AI processor and data scope used by each service, see Section 4-1, “Service-Specific Addendum,” below.

The Company uses Amazon Web Services (AWS) to operate its global services, and data may be transferred as follows:

• Storage locations: AWS regions (including Seoul and Singapore, our primary service locations).
• AI processing subcontracting: Certain features are processed using third-party AI models such as Google Gemini and OpenAI. Input data processed this way is subject to the relevant provider’s data retention policy (a minimal-retention principle) and is not used for any purpose beyond improving the Company’s own services. (The exact retention period will be specified once contract terms with each provider are confirmed — currently undetermined.)
• Safeguards: Where personal data of EU residents is transferred outside the EU, the Company relies on Standard Contractual Clauses (SCCs) approved by the European Commission to maintain an adequate level of protection.
• The above processing is carried out to improve the Platform’s performance, functionality, and user experience.

This table is updated whenever a service is added or an AI processor changes.

• Retention period: The Company retains users’ personal data for the duration of their use of the service and deletes it without delay upon account deletion request or termination of the service agreement.
• Backup data management: Database snapshots (backups) created for disaster recovery and data protection purposes are retained for up to 7 days, after which they are permanently deleted using automated technical methods.
• Legal exceptions: Data required to be retained under applicable law (e.g., commercial law, e-commerce law) or maritime regulations is stored separately in a dedicated database for the period required by that law.

You may exercise the following rights at any time (submit requests to info@marinachain.io):

• Right of access: Request confirmation of how your data is being processed.
• Right to rectification and erasure: Correct inaccurate information and exercise the “right to be forgotten.”
• Right to restriction and objection: Request that processing of your personal data be restricted in certain circumstances.
• Right to data portability: Receive your personal data in a structured, machine-readable format.

The Company’s staff adhere to strict security protocols, including the following measures:

• 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 personnel who require it for their duties.
• Monitoring: Security threats and access logs are monitored in real time via AWS CloudTrail and Security Hub.

The Company uses cookies to enhance the user experience. You may decline cookies through your browser settings, though this may limit certain Platform functionality. Third-party links within the Platform (e.g., payment providers, regulatory agency sites) are governed by those parties’ own policies.

We may update this Privacy Policy from time to time. In the event of material changes, we will post the updated policy on the Platform and update the “Effective Date” at the top of this document to notify you. Continued use of the Platform after such changes constitutes acceptance of the revised policy.

For inquiries or to exercise your rights, please contact us via:

• Address: MarinaChain Pte Ltd (Singapore HQ)
• Email: info@marinachain.io