Policy version: 18/07/2023

Services under this Privacy Policy are provided by IM MARITIME PRACTICE INTERNATIONAL LTD, a company incorporated in the Republic of Cyprus, registered number HE 432938, with its registered address at Akropoleos 82, 2nd Floor, Akropoli, 2012, Nicosia Cyprus (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained within the context of the provision of the requested services under Public offer, meaning we are the organisation legally responsible for deciding how and for what purposes it is used. We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA) and all local legislation and regulations (Law 125(I)2018, as subsequently amended).

Given the nature of our services, we do not expect to collect the personal data of anyone under 12 years old. If you are aware that any personal data of anyone under 12 years old has been shared with us please let us know so that we can delete that data.

This privacy policy is divided into the following sections:

• What this policy applies to
• Personal data we collect about you
• How your personal data is collected
• How and why we use your personal data
• Marketing
• Who we share your personal data with
• How long your personal data will be kept
• Transferring your personal data out of the EEA
• Cookies
• Your rights
• Keeping your personal data secure
• How to complain
• Changes to this privacy policy
• How to contact us
• Do you need extra help?

This privacy policy relates to your use of our website only.

Throughout our Platform we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.

What this policy applies to

The personal data we collect about you depends on the particular activities carried out through our website as well as programs you are singing in to participate. We will ask you to provide us with some personal data by filling in questionnaires before the programs as well. We will collect and use the following personal data about you:

• your name, address and contact information, including email address and telephone number
• information to check and verify your identity, e.g date of birth
• your gender, if you choose to give this to us
• location data (including IP location)
• Photo and video material generated within the context of the provision of our services
• bank account and payment details
• details of any information, feedback or other matters you give to us by phone, email, post or via social media
• your activities on, and use of, our website
• any other personal data you provided to us (including but not restricted to medical information).

You must provide this personal data in order to be able to use our services. Any data that is optional will be clearly indicated as such.
Sometimes you can choose if you want to give us your personal data and let us use it. Where this is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on efficient use of the Platform.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

We collect personal data from you:

• directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase services via our website, and complete customer surveys or participate in competitions via our website, and
• indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies’ below

We also collect personal data about you from other sources as follows:

• from data received from you in the course of communication, including from your messages by phone, email, WhatsApp, Telegram or social networks;
• from these questionnaires that you provide to us in order to prepare for educational/programs.

Personal data we collect about you

How your personal data is collected

Under data protection law, we can only use your personal data if we have a proper reason and legal basis:

• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or
• for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

How and why we use your personal data

What we use your personal data for

Our reasons

Creating and managing your account with us

Providing services to you

To perform our contract with you or to take steps at your request before entering into a contract

Enforcing legal rights or defend or undertake legal proceedings

Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests, i.e. to protect our business, interests and rights

Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website

Depending on the circumstances:

—your consent as gathered by the separate cookies tool on our website
— see ‘Cookies’ below
—where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

If you have provided such a consent, you may withdraw it at any time by sending us a message at moretime.expeditions@gmail.com with the topic "Withdrawal of consent data processing" (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)

Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended

Depending on the circumstances:

—your consent as gathered by the separate cookies tool on our website
— see ‘Cookies’ below
—where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

If you have provided such a consent, you may withdraw it at any time by sending us a message at moretime.expeditions@gmail.com with the topic "Withdrawal of consent to data processing"To] (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)

Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices

Depending on the circumstances:

—to comply with our legal and regulatory obligations
—establishing feedback with the user, including, but not limited to: sending mailings, notifications in the form of SMS messages, emails, oral and written requests, processing requests and applications from the user;
—in other cases, for our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service to you at the best value

Protecting the security of systems and data used to provide the services

To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Statistical analysis to help us understand our customer base

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Updating and enhancing customer records

Depending on the circumstances:

—to perform our contract with you or to take steps at your request before entering into a contract
—to comply with our legal and regulatory obligations
—where neither of the above apply, for our legitimate interests, e.g. making sure that we can keep in touch with our customers about new products

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant

To comply with our legal and regulatory obligations

Marketing our services to existing and former customers

For our legitimate interests, i.e. to promote our business to existing and former customers;

Identification of the user in order to provide the user with information support about Educational programs;

providing the user with access to the Sites or services of the Partners of the Company in order to obtain information, updates and services of both the Company and the Partners of the Company. Partners may also receive (directly) the data of the user when the latter visits or uses their services, or through third parties with whom they cooperate;

See ‘Marketing’ below for further information

Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us

More details about how we use your personal data and why are set out in the table below.

How and why we use your personal data—in more detail

Purpose

Processing operation

Lawful basis relied on under the EU GDPR

Relevant categories of personal data

Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices

Addressing and sending communications to you as required by data protection laws, i.e.:
— regulations and legislation applicable in Cyprus, (Law 125(I)2018, as subsequently amended)
— the EU GDPR

Processing is necessary for compliance with a legal obligation to which we are subject

—your name, address and contact information, including email address and telephone number 
—your account details (username)

Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above)

Our legitimate interests which is to be as efficient as we can so we can deliver the best service to you

—your name, address and contact information, including email address and telephone number
—your account details (username)

Addressing and sending communications to you

Processing is necessary for compliance with a legal obligation to which we are subject

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:

• data concerning health.

Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws and inform you accordingly at the time of collection of the said data.

How and why we use your personal data—Special category personal data

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

How and why we use your personal data—sharing

We will use your personal data to send you updates (by email, text message, telephone) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us at moretime.expeditions@gmail.com, indicating in the subject "Refusal to receive marketing information"
using the ‘unsubscribe’ link in emails

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.

We may use any photographs and/or videos produced within the context of the provision of our services for advertising services subject to your consent.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Marketing

We routinely share personal data with:

• third parties we use to help deliver our services to you, e.g. payment service providers etc.
• other third parties we use to help us run our business, e.g. marketing agencies, website hosts and website analytics providers
• state and regulatory authorities, if necessary, issue permits for your participation in programs held in places with limited access
• ship owners for registration of ship roles (in case of the program on board the ship)

We only allow those organisations to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

We will not share your personal data with any other third party.

Who we share your personal data with

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Who we share your personal data with—further information

We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you stop using our services we will delete or anonymise your account data after seven years, from the termination of our professional relationship with you, always subject to the above considerations.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

How long your personal data will be kept

Countries outside the EEA have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the EEA. In those cases we will comply with applicable EEA laws designed to ensure the privacy of your personal data.

We may transfer your personal data to:

• our service providers located outside the EEA, and
• state and regulatory authorities, if necessary, issue permits for your participation in programs held in places with limited access
• ship owners for registration of ship roles (in case of the program on board the ship)

Under data protection laws, we can only transfer your personal data to a country outside the EEA where:

• the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
• a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

Transferring your personal data out of the EEA

If you would like further information about data transferred outside the EEA, please contact our Data Protection Officer (see ‘How to contact us’ below).

Transferring your personal data out of the EEA—further information

A cookie is a small text file which is placed onto your device (for example computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies our use of ‘cookies’, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.

Cookies

You generally have the following rights, which you can usually exercise free of charge:

Your rights

Access to a copy of your personal data

The right to be provided with a copy of your personal data

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of use

Data portability

The right to require us to restrict use of your personal data in certain circumstances, i.e. if you contest the accuracy of the data

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object to use

The right to object:

—at any time to your personal data being used for direct marketing (including profiling)
—in certain other situations to our continued use of your personal data, i.e. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

The right to withdraw consents

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

You may withdraw consents by sending us a message at moretime.expeditions@gmail.com with the topic "Withdrawal of consent to data processing"Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We have developed and implemented local procedures on the processing of personal data, as well as local policies and organizational measures establishing procedures aimed at preventing and detecting any breaches and minimizing the consequences of such breaches;

Employees of the Company who are directly involved in the processing of personal data must be familiar with the provisions of all applicable legislation and regulations on the processing of personal data, including the requirements for the protection of personal data, documents defining our policies in relation to the processing of personal data.

We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Keeping your personal data secure

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:

• the Commissioner for the Protection of Personal Data in Cyprus

The Commissioner for the Protection of Personal Data in Cyprus may be contacted using the details https://www.dataprotection.gov.cy/dataprotection/
dataprotection.nsf/contact_en/contact_en?opendocument.

How to complain

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.

Changes to this privacy policy

You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details: moretime.expeditions@gmail.com

How to contact us

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).

Do you need extra help?

For further information on each of those rights, including the circumstances in which they do and do not apply, please follow this link or contact us (see ‘How to contact us’ below).

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself (full name, address and subscriber or matter reference number) and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates to