Effective September 1, 2022 (Last updated September 1, 2022)
SeaLead (SeaLead Shipping Pte Limited, 78 Shenton Way # 32-00, Singapore 079120), and its subsidiaries (“SeaLead”, “we”, “us” or “our”), respect your preferences concerning the collection and use of your personal data.
This policy reflects our current data protection policies and practices and describes how we collect personal data when you access or use SeaLead websites on which this policy appears (the “Websites”) and how we use such personal data (hereinafter, the “Policy”).
SeaLead operates in more than 10 countries. Unless otherwise stated, this Policy applies to all jurisdictions in which SeaLead operates. Certain regions, countries, and/or individual states may have additional requirements, which are detailed, by jurisdiction, below. We also encourage you to review our table of contents, above, which identifies the portions of this Policy that apply to specific locations.
SeaLead is the primary controller of personal data collected through the websites. This Policy, except as provided below, applies only to the personal data that we collect online from users of our websites
We reserve the right to update it from time to time, in which case the new version will posted on the Website on which it appears. What Personal Data does SeaLead collect through its websites? “Personal data” is information that identifies you personally as a natural person, directly or indirectly, in combination with other information available to us such as an identification number, location data, online identifier or one or more factors specific to your identity as a natural person. For the purposes detailed herein, SeaLead may collect and process the following categories of personal data:
SeaLead also collects and processes personal data it did not collect from you. This is the case where SeaLead receives personal data from your device as part of the electronic communication itself – the standard electronic greeting between your computer, the network, and our servers. At this time, our server will also query your computer to see if there are “cookies” previously set by our websites to facilitate log in or other site navigation procedures.
Our websites may contain applications that allow you to book shipments, in which case you need to provide us with third-party personal data required to arrange for such shipment. In such case, you represent and warrant to SeaLead that you have obtained all necessary third-party consents for the processing of such personal data contemplated by the shipment.
SeaLead may use your personal data in several ways, including:
For pursuing its legitimate interest of improving its business practices, SeaLead will collect and process your personal data for the following purposes:
Lastly SeaLead may be required to collect and process personal data to comply with legally mandated reporting, disclosure, as well as any legal requirements.
In order to pursue the purposes referred to under this Policy, SeaLead may need to share certain personal data with subsidiaries and affiliates in different jurisdictions (which may also act as data controllers), with service providers (e.g., those needed for the operation of the Websites, credit card clearing houses, transport companies, etc.) and other third parties, including Government agencies and marketing entities. We share personal data to the parties referred above only to the extent needed to run our websites and conduct the activities referred to in this Policy.
In certain, limited circumstances, where permitted by applicable law, we may share or transfer personal data to unrelated third parties. For example, we may provide personal data to a third party (i) at your request; (ii) to comply with a legal requirement or court order; (iii) to investigate a possible crime, such as identity theft; (iv) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution; or (v) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal data.
SeaLead takes appropriate steps to ensure that its personnel, its affiliates and third-party vendors are bound by duties of confidentiality and that, if applicable, SeaLead implements measures such as EU standard contractual clauses to ensure that any transferred personal data remains protected and secure.
We do conduct e-mail marketing activities. If in the use of our websites you have provided us with e-mail or other personal data, we will ask your consent to send you e-mail marketing material, except if you are an existing customer, and such permission is not required according to law. We will include an “unsubscribe” link in each electronic communication so that you can advise us whether you wish to continue receiving such communications going forward.
SeaLead implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk and has in place generally accepted information security techniques to prevent unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data we collect. These measures include policies, procedures, firewalls, access control procedures and cryptography, and technical elements relating to personal data access controls. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our websites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.
The website is not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13. If you are under 13, do not access or use the website.
The inclusion of any external link on our websites does not imply our endorsement of the website or the company (including such company’s products) to which the link leads. Linked websites are not under our control. Except as stated below, this Policy applies solely to personal data that is acquired on our websites. We do not accept any responsibility or liability in connection with these other websites.
If you are an individual in a country in the European Economic Area or the United Kingdom, you are entitled to the following additional disclosures regarding your personal data.
SeaLead will retain your personal data for no longer than is necessary for the purposes specified under this Policy, except as otherwise agreed to by you in a contract or as provided by applicable law.
The legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it, which is discussed below.
The provision of your personal data is voluntary and is therefore based on your consent. However, if you do not provide such personal data, you may not be able to receive the requested information from us. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
We may process your personal data if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. For example, personal data may be necessary to fulfil our legitimate interests of knowing you as a user of our websites or to offer you, as a potential customer, products or services that fulfil your needs.
Personal data may be needed for the purpose of entering to or providing services pursuant to a contract with you.
We may process your personal data to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.
If you bring a claim against us or we bring a claim against you, we may process your personal data in relation to that claim
You are entitled to: (i) request access to your personal data processed by SeaLead; (ii) request the rectification of your personal data; (iii) request the erasure of your personal data; (iv) request the restriction of processing or object thereto; (v) receive your personal data in a structured and standard format as part of your right to portability; and (vi) lodge a complaint with a local supervisory authority.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
The CCPA contains an exception that is relevant to us. Some of the CCPA’s privacy rights explained below do not apply to personal information reflecting a written or verbal communication or a transaction between us and a consumer, where the consumer is acting as an employee, owner, director, officer, or contractor of another entity and when the communication or transaction occur solely within the context of us conducting due diligence regarding or providing or receiving a product or service to or from such entity.
If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all the following:
As discussed, some of the CCPA’s privacy rights discussed herein do not apply to the Personal Information listed above because of the CCPA’s business-to-business exemption.
We do not knowingly collect or sell the Personal Information of minors under 16 years of age.
If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a relationship and/or account with SeaLead (i.e., a password-protected account).
If you maintain a relationship and/or account with SeaLead, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account.
If you do not maintain a password-protected account, or if you are an accountholder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion, as applicable.
For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
If you are a California resident, you have the right to direct businesses to stop selling your Personal Information. We do not sell Personal Information as it is defined in the CCPA.
We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.” As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including with discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.
We do not disclose personal information obtained through our Site or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.
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