PRIVACY POLICY

Last updated November 01, 2024

 

This Privacy Notice for Sailorfy Pvt Ltd (doing business as Sailorfy) ('we', 'us', or 'our'), describes how and whywe might access, collect, store, use, and/or share ('process') your personal information when you use our services

('Services'), including when you:

Download and use our mobile application (Sailorfy), or any other application of ours that links to this Privacy Notice

Use Sailorfy. Sailorfy is the community platform for seafarers globally. Sailorfy empowers seafarers by simplifying

complex documentation, providing seamless digital identities, managing verifications and offering various services such

as expert financial advice - all in one platform

Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are

responsible for making decisions about how your personal information is processed. If you do not agree with our policies and

practices, please do not use our Services. If you still have any questions or concerns, please contact us at contactus@sailorfy.com

 

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these

topics by clicking the link following each key point or by using our table of contents below to find the section you

are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process

personal information depending on how you interact with us and the Services, the choices you make, and the products and

features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered 'special' or

'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may

process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn

more about sensitive information we process.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our

Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your

information for other purposes with your consent. We process your information only when we have a valid legal reason to do

so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in

specific situations and with specific third parties. Learn more about when and with whom we share your personal information

 

How do we keep your information safe? We have adequate organisational and technical processes and procedures

in place to protect your personal information. However, no electronic transmission over the internet or information storage

technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other

unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your

information. Learn more about how we keep your information safe

 

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you

have certain rights regarding your personal information. Learn more about your privacy rights.

 

How do you exercise your rights? The easiest way to exercise your rights is by visiting support@sailorfy.com, or by

contacting us. We will consider and act upon any request in accordance with applicable data protection laws

 

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full


Permissions Required

Our app requires certain permissions to function as intended:

Internet Access (android.permission.INTERNET):

This allows our app to access the internet for features such as data synchronization, API calls, and in-app updates.

External Storage Access (android.permission.WRITE_EXTERNAL_STORAGE, android.permission.READ_EXTERNAL_STORAGE, android.permission.MANAGE_EXTERNAL_STORAGE):

These permissions allow our app to store and access files on your device. This is necessary for saving app data, caching, and other storage-related features.

Fingerprint and Biometric Authentication (android.permission.USE_FINGERPRINT, android.permission.USE_BIOMETRIC):

If your device supports biometric or fingerprint authentication, these permissions enable secure login features in our app.

Network State Access (android.permission.ACCESS_NETWORK_STATE):

This permission helps us check your internet connectivity status to improve app performance and data usage efficiency.

 

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS NOTICE?

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

 

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in

obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise

when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your

interactions with us and the Services, the choices you make, and the products and features you use. The personal

information we collect may include the following:

names

phone numbers

email addresses

mailing addresses

job titles

contact preferences

contact or authentication data

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the

following categories of sensitive information:

biometric data

information revealing race or ethnic origin

social security numbers or other government identifiers

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us

with access or permission:

If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, contacts, sms messages, storage, and other features. If you wish to change our access

or permissions, you may do so in your device's settings.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the

application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your

device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for

our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes

to such personal information.

 

 

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security

and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may

process your information so you can create and log in to your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user. We may process your information to provide

you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your

inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our

products and services, changes to our terms and policies, and other similar information.

To fulfil and manage your orders. We may process your information to fulfil and manage your orders,

payments, returns, and exchanges made through the Services.

To enable user-to-user communications. We may process your information if you choose to use any of our

offerings that allow for communication with another user.

To request feedback. We may process your information when necessary to request feedback and to contact you

about your use of our Services.

 

To send you marketing and promotional communications. We may process the personal information you

send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our

marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.

To deliver targeted advertising to you. We may process your information to develop and display personalised

content and advertising tailored to your interests, location, and more.

To protect our Services. We may process your information as part of our efforts to keep our Services safe and

secure, including fraud monitoring and prevention.

To identify usage trends. We may process information about how you use our Services to better understand how

they are being used so we can improve them.

To determine the effectiveness of our marketing and promotional campaigns. We may process your

information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

To save or protect an individual's vital interest. We may process your information when necessary to save

or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e.

legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter

into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in

order to process your personal information. As such, we may rely on the following legal bases to process your personal

information:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal

information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your

consent.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil

our contractual obligations to you, including providing our Services or at your request prior to entering into a contract

with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve

our legitimate business interests and those interests do not outweigh your interests and fundamental rights and

freedoms. For example, we may process your personal information for some of the purposes described in order to:

Send users information about special offers and discounts on our products and services

Develop and display personalised and relevant advertising content for our users

 

Analyse how our Services are used so we can improve them to engage and retain users

Support our marketing activities

Diagnose problems and/or prevent fraudulent activities

Understand how our users use our products and services so we can improve user experience

Legal Obligations. We may process your information where we believe it is necessary for compliance with our

legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal

rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or

the vital interests of a third party, such as situations involving potential threats to the safety of any person.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any

merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour

this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other

companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products,

services, or promotions.

Other Users. When you share personal information (for example, by posting comments, contributions, or other

content to the Services) or otherwise interact with public areas of the Services, such personal information may be

viewed by all users and may be publicly made available outside the Services in perpetuity. Similarly, other users will

be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

 

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from

third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do

not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use

of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or

application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any

third-party websites. Any data collected by third parties is not covered by this Privacy Notice. We are not responsible for the

content or privacy and security practices and policies of any third parties, including other websites, services, or applications

that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to

respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact

with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent

crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and

advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send

abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers

use their technology to provide advertising about products and services tailored to your interests which may appear either on

our Services or on other websites.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie

Notice.

 

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless

otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice,

unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No

purpose in this notice will require us keeping your personal information for longer than the period of time in which users have

an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup

archives), then we will securely store your personal information and isolate it from any further processing until deletion is

possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the

security of any personal information we process. However, despite our safeguards and efforts to secure your information, no

electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we

cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our

security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your

personal information, transmission of personal information to and from our Services is at your own risk. You should only

access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such

personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of

such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users

less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly

delete such data from our records. If you become aware of any data we may have collected from children under age 18,

please contact us at contactus@sailorfy.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have

rights that allow you greater access to and control over your personal information. You may review, change, or terminate

your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These

may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or

erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be

subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of

your personal information. You can make such a request by contacting us by using the contact details provided in the section

'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

 

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have

the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right

to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact

details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the

processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and

promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us

using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be

removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related

messages that are necessary for the administration and use of your account, to respond to service requests, or for other nonmarketing

purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Log in to your account settings and update your user account.

Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active

databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any

investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can

usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject

cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by

advertisers on our Services.

If you have questions or comments about your privacy rights, you may email us at contactus@sailorfy.com.

 

11. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or

setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored

and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been

finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically

communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the

future, we will inform you about that practice in a revised version of this Privacy Notice.

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988

(Privacy Act).

This Privacy Notice satisfies the notice requirements defined in the Privacy Act, in particular: what personal information we

collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to

provide our services, in particular:

offer you the products or services that you want

respond to or help with your requests

manage your account with us

confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request

by contacting us by using the contact details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE THE

DATA WE COLLECT FROM YOU?'

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a

breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner.

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

 

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at

the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently

posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice

frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at contactus@sailorfy.com or contact us by post at:

Sailorfy Pvt Ltd

33-A Umang

Mahanagar

Bareilly, Uttar Pradesh 243006

India

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we

collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may

also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in

some circumstances by applicable law. To request to review, update, or delete your personal information, please visit:

support@sailorfy.com.