Privacy Policy

Cydome Privacy Policy

Last Revised: November 2022
Cydome Ltd., (the “Company”, “Cydome, “we” or “us”) respect the privacy of the users (“User(s)” or “you”) of its website located at the following addresses https://cydome.io/ , cyber-yacht.com (“Site”) and of any services it makes available to User through its Site, including Company’s proprietary platform and technology providing its Users with an end-to-end cyber solution platform for the maritime industry (the “Platform”) including such
services accessible through the Site and is committed to protect the personal information that its Users share with
it. We believe that you have a right to know our practices regarding the information we may collect and use when
you use our Site and/or the Platform. For the purposes of this Privacy Policy (as defined below), the Site and the Platform shall be collectively referred to as the “Services”. Users of our Services may include (i) individuals who use our Platform in their capacity as employees or other personnel of our business customers (our business customers shall be defined herein as “Customer(s)”) including individuals identifying as Customer “admin” users or Customer’s end-users, using or accessing the Services under Customer’s account or on Customer’s behalf (each, a “Customer End-User(s)” and collectively); (ii) visitors of the website (each, a “Visitor”); and (iii) Candidate(s) (as defined below).

1. Scope and Applicability
Other than as expressly agreed in writing between Cydome and any User, This Cydome Privacy Policy (the “Privacy Policy”) applies in connection with your use of the Site and the Platform. IMPORTANT NOTE: where we process Personal Data of or about Customer End-Users’, we do so on behalf of and under the instruction of the respective Customer (which Customer may be your employer or other corporation on behalf of which you access or otherwise use our Service) Cydome does so in our capacity as a “data processor” on behalf of such Customer. For more information about our practices as a data processor and the impact on your Personal Information in our possession, please see below . The provisions of this Privacy Policy as they relate to Cydome’s independent privacy and data processing activities as a “data controller” – with respect to Users who are Visitors or Candidates – do not apply to the processing of Personal Data of Customer Users. If you are using our Services (including the Platform) as a Customer End-User, or if otherwise, you have any questions or requests regarding Customer End-Users’ Personal Data, please contact the Customer on behalf of which you use the Platform (usually this will be your employer or corporation on behalf of which you use our Platform).

2. Your Consent (PLEASE READ CAREFULLY!)
BY ACCESSING AND/OR USING THE SITE OR SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY”), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT USE THE SERVICES. Please note you are not obligated by law to provide us with any Personal Information. You hereby acknowledge and agree that you are providing us with Personal Information at your own free will, and you are under no legal obligation to provide us with such Personal Information. You hereby agree that we may collect and use such Personal Information pursuant to this Privacy Policy and any applicable laws and regulations.

3. Which information we may collect on our Users?
A. First – What is personal information? “Personal information” is individually identifiable information, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of private or sensitive nature information relating to an identified or identifiable natural person. Identification of an individual also includes association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc. Personal information does not include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person.

B. We collect Personal Information from you when you use or interact with our Services We collect Personal Information from you and any devices you use when you use or access our Site or Platform, when you register for a demo to our Services via our website (whether by direct contact with our representatives or through online forms), and when you provide us information on web forms (such as the “contact us” form made available via the Site), or through correspondence you and we conduct with each other. More specifically we collect and use the following categories and types of information:

a. Personal information you actively provide us when you use our Services Generally, this category refers to any information, data or content you actively and voluntarily create or provide through our Services: Contact information such as your full name, email, username, any Candidate Information (as defined below), phone number and any information you choose to provide us in connection with such contact by you (e.g., via the “contact us” form available on the Site or when you contact us on behalf of a Customer in your capacity as a Customer End-User), which may constitute Personal Information.

b. Personal information we collect automatically when you use the Services We collect certain information automatically gathered as a result of your use of or access to Services, such as:

technical information with respect to the devices and software you use to access our Services suchas screen size, operating system, type of end user device, etc.
behavioral information with respect to your use of the Services, such as click stream, and loggedactions.
Information concerning your browsing activity on, to and from our Services, such as http referral, IP,page visits, etc.

We perform such automatic collection through use of cookies, web beacons, SDKs, uniqueidentifiers, and similar technologies which allow us to collect information about the pages andscreens you view, the links you click, and other actions you take when using our Services.

c. Personal information collected from other sources. We may also collect personal information concerning you, from third parties who have assured usthat they have obtained your consent for such provision of information. For avoidance of doubt, any Non-Personal Information connected or linked to any Personal
Information shall be deemed as Personal Information as long as such connection or linkage exists. We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance of Cydome’s End User License Agreement (“EULA”) and this Privacy Policy.

TO THE EXTENT THAT YOU PROVIDE US WITH ANY PERSONAL INFORMATION RELATED TO ANY THIRD PARTY OR ANY OTHER PERSON OR ENTITY WHICH IS NOT
YOU, INCLUDING TO ANY OF YOUR PERSONNEL OR CUSTOMERS, YOU ARE SOLELY RESPONSIBLE TO RECEIVE AND HEREBY REPRESENT THAT YOU HAVE AND
UNDERTAKE THAT YOU SHALL HAVE AT ALL TIMES, MAINTAINED AND RECEIVED, THE CONSENT, AUTHORITY, PERMISSION AND APPROVAL OF SUCH PERSONS AND PROVIDED THEM WITH SUFFICIENT DISCLOSURES, TO ALLOW CYDOME TO ACCESS, STORE, COLLECT, ANALYZE AND PROCESS SUCH PERSONAL INFORMATION AS DETAILED HEREIN.

4. Storing, Transfer and Retention of Users’ Personal Information
Information regarding the Users will be maintained, processed, and stored by us and our authorized affiliates and service providers in the United States. While the data protection laws in the above jurisdictions may be different from the laws of your residence or location, please know that we, our affiliates, and our service providers that store or process your Personal Information on our behalf are each committed to keeping it protected and secured, pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction. Specifically, each of our Service Providers (as defined below) which store or process your Personal Information either: (i) assured us that they provide adequate safeguards to protect your rights to privacy; (ii) where applicable, hold and process such information on our behalf in jurisdictions which have been determined to ensure an adequate level protection by the EU Commission; (iii) perform such processing pursuant to your consent and acceptance of their privacy policy as further detailed in this Privacy Policy. By providing your information, you expressly consent to the place of storage and transfer described above, including transfers outside of the jurisdiction in which the information was provided. We retain the Personal Information we collect only for as long as needed in order to provide you with use of our Services in accordance with the terms of this Privacy Policy and the EULA and to comply with applicable laws and regulations or otherwise as required for us to protect against claims by Users for the relevant statute of
limitations period. We then either delete it from our systems or anonymize it without further notice to you.

5. What are the Purposes of the Collection of Information?
We may use the Personal Information that we collect about you only if and as stated below:

To provide and improve our Services and manage our business;
In order to anonymize it and then after it has been anonymized and cannot be used to identify you, use it for improvement and management of our business, Services and general offerings;
Provide our Users with a better user experience.
Be able to contact Users who requested such contact to be made, for the purpose of providing them with further information on Cydome and its Services;
Be able to provide the Users with updates about the Company’s developments.
To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities;
To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.
To be able to send Users newsletters and information in connection with the Services;
To market our Services to Users or potential Users, and to be able to track and evaluate our marketing activities and their results.
To act upon and comply with requests you may make pursuant to this Privacy Policy and the privacy laws that apply to you.

6. Lawful Grounds for Collecting Information on our Users.
We collect and process your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:

● Performance of a contract: Your information may be processed on the basis that such processing is necessary in order to perform the Services in accordance with the EULA or other agreement entered into between Cydome and you (where such agreement makes a reference to this Privacy Policy). This may include, for example, processing your payment information in order to affect a payment or collecting your email for the purpose of registering you to the Platform.

● Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; Enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfill our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our EULA.

● With your consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. For example, we ask for your consent to send you newsletters or provide you with personalized content and ads through the use of cookies;

7. Sharing Information with Third Parties.
We do not sell, disclose, or share Personal Information about you with third parties except under the following circumstances and for the following purposes.

a. Law enforcement, legal proceedings, and as authorized by law: We may disclose Personal Information to satisfy any applicable law, regulation, legal process, subpoena or governmental request;

b. Protecting Rights and Safety: We may share Personal Information to enforce this Privacy Policy and/or the EULA, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; to respond to claims that any content available on the Site violates the rights of third-parties; to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; and to protect the rights, property, or personal safety of Cydome, any of its Users, or the general public;

c. Our Affiliated Companies: We may share Personal Information internally with our family of companies for the purposes described in this Privacy Policy. In addition, when Cydome or any of our affiliated companies is undergoing any change in control, including by means of merger, acquisition, or purchase of all or substantially all of its assets, we may share Personal Information with the parties involved in such event under strict confidentiality and non-use terms. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or a prominent notice on our Site;

d. Third Party Services: We partner with certain third parties to provide selected services that are used to facilitate and enhance the Site and the Platform and your use thereof (“Service Providers”). Such Service Providers may have access to, or process on our behalf Personal Information which we collect, hold, use, analyze, process and/or manage. These Service Providers include hosting, database, and server co-location services by reputable vendors (e.g., AWS), analytics service providers (e.g., Google Analytics), social media advertising services (e.g., Facebook Pixel) and our business, legal and financial advisors. We remain responsible for any Personal Information processing done by Service Provider on our behalf, except for events outside of our and/or their reasonable control, and except with respect to  Service Providers with which you are contractually engaged, either through a prior separate contractual engagement and/or through acceptance of their privacy policy and terms of use if such are referenced under section 13 below. For avoidance of doubt, subject to the EULA and the terms of this Policy, Cydome may transfer and disclose to third parties, or otherwise use, Non-personal Information at its own discretion.

8. Updating, Obtaining a copy of, or Deleting of Personal Information.
If for any reason you wish to exercise any rights to which you are entitled, under the law applicable to you, such as correction, deletion, access to and notification of the types of your Personal Information processed by us or on our behalf, you may do so by contacting Cydome support at [email protected] When handling these requests, we may ask for additional information to confirm your identity and your request. Subject to limitations pursuant to applicable law and if entitled to the same thereunder, if you wish to exercise your right to access your Personal Information, you may be able to obtain the Personal Information you directly provided us (excluding data we obtained from other sources) in a structured, commonly used, and machinereadable format and may have the right to transmit such data to another party. We may provide such access through the Site. Please note, that upon request to delete your Personal Information, we will delete any such Personal Information pursuant to any applicable privacy laws or otherwise, we may de-identify any such Personal Information and thereby transform it to become non personal information. We may retain such data in whole or in part to comply with any applicable rule or regulation and/or to respond or defend against legal proceedings versus us or our affiliates. The rights available to you in connection with your Personal Information may also include the following:

Right of access. You may have a right to know what information we hold about you and, in some cases, to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.

Right to correct Personal Information. We endeavor to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can.

Data deletion. In some circumstances, you have a right to request that some portions of the Personal Information that we hold about you be deleted or otherwise anonymized.

Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.

Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your Personal Information, such as when you are disputing the accuracy of your information held by us. To find out whether these rights apply to you and on any other privacy related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law.

9. Minors.
To use our Services, and accept the terms of this Privacy Policy and EULA, you must be over the age of eighteen (18). Without relieving you of your responsibility to comply with the EULA and the terms hereof we reserve the right (without obligation) to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using our Site without their parent or legal guardian consent. In the event that it comes to our knowledge that a person under the age of eighteen (18) is using our Services, not in accordance with the abovementioned terms, we will use our best efforts to prohibit and block such User from accessing our Site or utilizing our Platform and will use our best efforts to promptly delete any Personal Information.

10. Data Controller / Processor

Under various privacy, data protection or similar laws, regulations or additional legal frameworks, such as the GDPR, two distinguished main roles for  parties processing Personal Data typically apply: the “data controller”, who determines the purposes and means of processing; and the “data processor”, who processes such data on behalf of the data controller (or business). Below we provide additional information into how these roles apply to our Services, where such laws and regulations apply . Cydome is the “data controller” of its Visitors’ and Candidates’ Personal Data, as detailed above. Accordingly, with respect to such categories of data subjects, we assume the responsibilities of a data controller (solely to the extent applicable under law), as set forth in this Privacy Policy . Cydome is the “data processor” of personal data contained in Customer End-Users’ Personal Data, as submitted or otherwise provided to us by our Customers and/or Customer End Users. We process such data on behalf of our Customer (who, in turn, is the “data controller” of such data) and in accordance with its reasonable instructions, and our commercial agreements with such Customer . Our Customers are solely responsible for determining whether and how they wish to use our Platform, and for ensuring that all individuals using the Platform on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in any Personal data processed through the Platform, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Platform are fully met by the Customer. Our Customers are also responsible for
handling data subject rights requests under applicable law, by their Customer End Users and other individuals whose data they process through the Platform (and accordingly, if you are a Customer End User or another individual whose Personal Data was provided to us in connection with Customer’s use of the Services, other than as instructed by an applicable Customer, Cydome does not provide to you the rights set forth in Section 8 above) . If you would like to make any requests or queries regarding personal data we process as a data processor on our Customer’s behalf, including accessing, correcting or deleting your data, please contact the Customer and/or Customer Admin directly.

11. Security.
We take great care in implementing and maintaining the security of Cydome’s Services and its Users’ Personal Information. Cydome employs industry-standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information. However, we do not guarantee that unauthorized access will never occur.

12. Third Party Sites.
While using the Site you may encounter links to third party websites and/or services. Please be advised that such third-party websites and/or services are independent from Cydome, and may use cookies and other web-tracking technologies, not specified, or otherwise handled in our Cookie Policy, to collect non personal and/or Personal Information about you. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third-party websites and/or services. We encourage you to carefully readthe privacy policies and the terms of use of such third-party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties. Cydome has no control over the use of any information you provide to these third-party services.

13. Local Storage and Third-Party Software/Service, Cookies, and other Tracking Technology.
a. When you access or use the Site, Cydome may use industry-wide monitoring and tracking technologies such as “cookies” or “pixel tags” (or similar technologies), which store certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your service experience much more convenient and effortless. The Local Storage is created per session and may be deleted by you or otherwise you may configure by you to not accept any such local storage. For example, these technologies enable us to: (i) provide you with the Services, (ii) keep track of our users’ preferences and authenticated sessions, (iii) secure our website by detecting abnormal behaviors, (iv) identify technical issues and improve the overall performance of the Site and/or our Services, and (v) deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests and track ad performance (For more information about this practice, click here: http://www.aboutads.info/choices/). Such tracking technologies may include Pixel tags (also commonly known as web beacons), transparent images, iFrames, cookies, or Java script placed on our Site or our advertisements and emails, that are used to understand how you interact with the Site, with such advertisements and emails. It is important to note that some of these tracking technologies are provided to us by our Services Providers who collect and process personal information in the scope of the services that they provide us with.

b. Please note – in certain cases such Services Providers may collect and process Personal Information, in a scope that is broader than the scope of collection and processing required for the purposes set forth above. This means that sometimes these Services Providers have access to more of your Personal Information than we do. In such cases all such excess collection and processing are performed pursuant to and under a direct contractual relationship you have with such Service Providers, as detailed below and any rights you may have with respect to such information, collected by such Services Providers, shall be governed by such contractual relationship. Otherwise, the terms of this Privacy Policy shall fully apply.

c. We may use cookies in connection with our Services. A “Cookie” is a small data file that is downloaded and stored on your computer or mobile device when you visit our Services. We use the following third-party Cookies:

Google Analytics – Google provides anonymized data about the visits made to our Services. For more information, please read here: https://policies.google.com/privacy?hl=en&gl=uk

Facebook Pixel – Facebook pixels are tools that provide assistance to website owners and publishers, developers, advertisers, business partners (and their customers) and other integrate, use and exchange information with Facebook, such as the collection and use of information for ad targeting. For more information please read here: https://www.facebook.com/legal/technology_terms/.

Learn more about your choices and how to opt-out of tracking technologies : In order to delete or block any tracking technologies, please refer to the “Help” area on your internet browser for further instructions, or You may also opt out of third-party tracking technologies by following the instructions provided by each third-party service provider in its privacy policy listed above or visiting www.youronlinechoices.eu or http://www.aboutads.info/choices/. Please note however that deleting any of our  tracking technologies or disabling future tracking technologies may prevent you from accessing certain areas or features of our Site, or may otherwise adversely affect your user experience. Please also note that we do not respond to the ‘Do Not Track’ setting on your browser as the protocol and form for such setting has not yet been generally accepted.

14. Direct Marketing.
If you provide us with your contact details through the Site where we indicate that such details will be used for the purpose of sending You different offers with respect to the Services, you hereby agree that we may use such contact details, in order to contact you, inform you regarding our products and services which may interest you, and send you other marketing material, including news and updates by transmission to the e-mail address or phone number you have provided. You may withdraw your consent by sending us a written notice via email to the following address: [email protected]

15. Job Candidates.
Cydome welcomes all qualified candidates (“Candidates”) to apply to any of the open positions posted on our Site, Facebook, LinkedIn, by sending us their contact details and CV (“Candidates Information”). We are committed to keep Candidates Information private and use it solely for our internal recruitment purposes (including for identifying Candidates, evaluating their applications, making hiring and employment decisions, and contacting Candidates by phone or in writing). Please note that Cydome may retain Candidates Information submitted to it even after the applied position has been filled or closed for a reasonable time period. This is done so we could re-consider Candidates for other positions and opportunities at Cydome; so, we could use their Candidates Information as reference for future applications submitted by them; and in case the Candidate is hired, for additional employment and business purposes related to their work. If you previously submitted your Candidates Information to Cydome, and now wish to access it, update it or have it deleted from our systems as described in Section 8 above, please contact us at [email protected]

16. Changes to the Privacy Policy.
Cydome reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the homepage of the Site and/or we will send you an email regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Site or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

17. General Information.
This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of England and Wales, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in London, England. This Privacy Policy was written in English and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.

18. Have any Questions?
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: [email protected] and we will make an effort to reply within a reasonable timeframe.

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