Privacy Policy

Next Logistics Ventures GmbH

Last updated: February 2022

WHO ARE WE?

We are Next Logistics Ventures GmbH (“Next Logistics”, “Next Logistics Ventures” or “we”). We respect your privacy. This Online Privacy Notice (the “Notice”) applies to personal data we collect on www.seabo.com (the “Website” or the “Site”). The Notice describes the types of personal data we obtain, how we use the personal data, and with whom we share it. We also describe the rights you may have and how you can contact us about our privacy practices. Next Logistics is the data controller in respect of personal data that we collect through the Site or that you provide to us. Our contact details, as well as the contact details of our Data Protection Officer can be found at the end of this Notice.

WHAT IS THIS TEXT ABOUT?

This is a Privacy Policy. In this document, we explain what kind of personal data we collect when you use the services that we offer via our platform seabo on www.seabo.com. We also explain how we store, protect and use your personal data and for which purposes.

WHAT IS PERSONAL DATA?

In this Privacy Policy, "personal data" means: (pieces of) information that could allow you to be identified. This definition is in accordance with the Relevant Legislation.

YOUR CONSENT

Before you can use our Website, we will ask you to accept this privacy policy. This way we make sure we have your consent to process your data as described below.

ARE YOU YOUNGER THAN EIGHTEEN YEARS?

If you are younger than eighteen years, you cannot use our Website or services offered by www.seabo.com.

We act as Data Processor and Data Controller We collect and process most personal data on behalf of the users of our Website (“Users”). Our Users determine the purpose and means of this processing of personal data, which means they act as Data Controller within the meaning of the Relevant Legislation. We process this data strictly in accordance with the instructions of our Users and we don’t process this data for our own purposes. In this respect, we act as “Data Processor” within the meaning of the Relevant Legislation.

Apart from the processing of personal data on behalf of our Users, we do collect and process some personal data for our own purposes. In this respect, we act as “Data Controller” ourselves within the meaning of the Relevant Legislation.

WHICH PERSONAL DATA DO WE PROCESS?
HOW WE OBTAIN DATA FROM YOU

We may collect personal data that you choose to provide to us through the Site, including, but not limited to, your first and last name, physical address, e-mail address, or telephone number, such as when you:

  • Fill out a form on the Site;
  • Sign-up to receive direct marketing communications on the Site;
  • Sign-up to a feature that we offer on the Site and you provide your personal data in connection with that feature;
  • Attend an event that we organised; or
  • Communicate with us (for example, on a social media platform or by sending us an email).

INFORMATION WE OBTAIN
INFORMATION THAT YOU PROVIDE TO US

Personal data that you provide directly to us will be apparent from the context in which you provide it, for example:

  • If you fill out a form on our Site, you will generally provide your name, contact details and any other information requested by the form, such as the reason for your enquiry or your product preferences;
  • If you sign up to receive electronic marketing communications from us, you will generally provide your name, email address and other contact information, and your product preferences;
  • If you sign up to a feature on our Site, you will generally provide your name and contact information and any other information necessary to access the feature.

We may also process non-personal data whenever you interact with our Website. This data may include your browser name, the type of your computer and technical information about your means to connect to our Website (such as the operating system and the utilised internet service providers). To provide the services on our Website, we also ask for (parts of) the following data:

  • Information about your vessel, e.g. name, type, next open port and open dates.
  • Information about your cargo, e.g. type, size, duration, commodity and loading and discharging port.

Each form on our website varies in terms of the information required and collected. In most cases, an asterisk (*) indicates the required information on a form. You may choose to provide additional information in fields that are not required.

INFORMATION WE COLLECT AUTOMATICALLY

Our web servers may log information such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your device is located. The web server logs may also record information such as the address of the website that referred you to our pages and the IP address of the device you use to connect to the Internet. They may also record information about your interaction with the Sites, such as which pages you visit. To control which web servers process information by automated means, we may place tags called "web beacons" - small files that link web pages to specific web servers and their cookies. We may also process information such as your browsing history and use this in conjunction with data from forms and emails to understand and respond to your needs.

We use Piwik PRO Analytics Suite as our website/app analytics software and consent management tool. We collect data about website visitors based on cookies. The collected information may include a visitor’s IP address, operating system, browser ID, browsing activity and other information. See the scope of data collected by Piwik PRO.

We calculate metrics like bounce rate, page views, sessions and the like to understand how our website/app is used. We may also create visitors’ profiles based on browsing history to analyze visitor behavior, show personalized content and run online campaigns.

We host our solution on Microsoft Azure in Germany/Netherlands/United States/Singapore/ElastX in Sweden, and the data is stored for 14/25 months.

The purpose of data processing: analytics and conversion tracking based on consent. Legal basis: Art. 6 (1)(a) GDPR.

Piwik PRO does not send the data about you to any other sub-processors or third parties and does not use it for its own purposes. For more, read Piwik PRO’s privacy policy.

HOW DO WE USE THE PERSONAL DATA

We use above mentioned personal data we process as Data Controllerfor the purposes described below:

  • To verify your identity to access your account;
  • To contact you, to inform you about our products and services and to execute our agreement;
  • To improve communication between different parties in the vessel industry;

As Data Processor, we process the personal data on behalf of our Users solely to provide our services on the Website and App to them.

HOW WE USE INFORMATION THAT WE OBTAIN
INFORMATION THAT YOU PROVIDE TO US

We may use personal data that you provide to us to respond to your inquiry, for example, to contact you about your request, ask a question, provide announcements about products and future events, conduct surveys, consider your application for employment, and contact you for other reasons related to offering and improving our services. We use the personal data for these purposes because we have a legitimate business interest in providing services to our customers and other interested individuals that are not overridden by your interests, rights and freedoms to protect personal data about you. The legal basis for data processing is GDPR sec. 6 para 1 lit. f.
If you register for the use of one of our products, we process your personal data also to provide these. The legal basis for this is GDPR sec. 6 para 1 lit. b, the processing for the fulfilment of our contractual obligations or pre-contractual measures.
In addition to the uses discussed above, we may also use the personal data you provide on our Site to:

  • operate, evaluate, and improve our business;
  • develop new products and services;
  • determine the effectiveness of our advertising and marketing;
  • analyze our products, services, and websites;
  • administer the Site.

We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our business that is not overridden by your interests, rights and freedoms to protect personal data about you. The legal basis for data processing is GDPR sec. 6 para 1 lit. f.
We may also use the information to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law that applies to us.

INFORMATION THAT WE COLLECT AUTOMATICALLY

We use personal data that we collect automatically through cookies, non-cookie-based tokens, web beacons, and other automated means for purposes such as customising and enhancing our visitors’ visits to the Site, facilitating use of the Sites, collecting statistics about your visits to the Site, and understanding the manner in which our visitors browse the Site. We also use the information to help diagnose technical and service problems, administer the Site, and identify visitors to the Site. We use clickstream data to determine how much time visitors spend on web pages of the Site, how visitors navigate through the Site, and how we may tailor the Site to meet the needs of our visitors. We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our Site that is not overridden by your interests, rights and freedoms to protect personal data about you.

HOW LONG WILL WE KEEP THE PERSONAL DATA?

The personal data for which we are the Data Controller will be deleted if they are no longer necessary for the fulfilment of the purposes mentioned above or are inaccurate. In no event will the personal data be kept longer than five years after the date on which the data have been updated for the last time, unless we are legally obliged to keep the data for a longer period.

The personal data collected by us as Data Processor, on behalf of our Users, will be retained as long as the User uses our Website and App and uses the personal data in that context. If the User stops using the Website by cancelling its account, we will keep the data for another period of 90 days – so the User can retrieve its data if requested. After this period, we will delete or destroy all personal and copies thereof, unless we are legally obliged to keep the data for a longer period.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We do not sell or otherwise disclose personal data that you provide to us or that we collect on our Site, except as described here. We may share personal data you provide to us or that we collect on the Site with:

  • service providers that perform services on our behalf.

We may share personal data with our affiliates for a number of reasons, including because:

  • You have requested information about our affiliates products and services.

We may share personal data with service providers that perform services on our behalf such as payment service providers, analytics providers, hosting providers and advisers. All service providers have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf or comply with applicable legal requirements.

In addition, we may disclose personal data about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (c) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganisation, dissolution, or liquidation).

Furthermore it is possible that we use “Sub Data Processors” (with permission of our Users), for example the storage of the data and the hosting of the website. These Sub Data Processors must strictly follow our instructions and the instructions of our Users. Therefore, they will not use personal data for their own purposes. In addition to such storage and hosting providers, we use certain tools to provide our services to our clients. We make sure all of our Sub Data Processors comply with the relevant privacy legislation.

We use Data Processors for the processing of personal data for our own purposes as well.

The (Sub) Data Processors we may use for the processing as Data Controller or, with permission of our Users, as Data Processor are: Amazon Web Services, Mailchimp, Digital Ocean.

Besides the above, we will not share your data with third parties – unless we are legally obliged to do so.

(No) Export of data outside the European Union

We may transfer the personal data outside the EU, if our Users ask us to do so or if one of our (Sub) Data Processors is located outside the EU. In case we transfer data outside the EU, the Data will only be transferred to countries who provide an adequate level of protection that meets the EU-standards. For example, we will verify if that organisation is a Privacy Shield Participant or is listed as third country whose level of protection is approved by the European Commission.1 The transfer of data outside the EU will always comply with the Relevant Legislation (such as article 76 section 1 of the DDPA and - from 25 May 2018 - chapter 5 of the GDPR).

1 The European Commission has made a list of third countries whose level of protection is approved by the European Commission. Data transfers to the U.S. are considered adequate when based on the EU U.S. Privacy Shield. The EU-U.S. Privacy Shield is an agreement between the U.S. Department of Economic Affairs and the European Commission on the exchange of personal data between companies in the EU and the U.S. The Privacy Shield has been in force since 1 August 2016.The Privacy Shield List enables European companies to verify whether data can be transferred to an U.S.-based company under the framework. Generic aggregated (non-personal) data

We may convert personal data into non-personal data and aggregate it with information collected from other Users. In such cases the data will be fully and irreversibly anonymized: they will no longer contain personal data. We use this data to improve the Website and App. We also may share such generic aggregated data with our business partners for industry analysis, demographic profiling, improvement of our services and other purposes.

PROTECTION OF YOUR PERSONAL DATA

We work hard to protect your personal data from unauthorised or unlawful access, alteration, disclosure, use or destruction. We take the following security measures regarding your personal data:

  • We secure our network connection with Secure Socket Layer (SSL) technology;
  • We restrict access to the data to employees who have been designated as administrator;
  • Our cloud services data is encrypted using Transport Layer Security (TLS), Our implementation uses strong ciphers and key-lengths by default.
  • We perform internal and external application security testing

COOKIES

We may use the following types of cookies on our Website:

Functional cookies: these are cookies that are essential for the operation of our Website. They enable you to move around our Website and use our features.

Analytical: we use these cookies to track visitor statistics. We use these statistics to continuously improve the Website, and thus offer you relevant content. These cookies also allow us to recognize and count the number of visitors and to see how visitors navigate when they’re using our Website. This helps us to improve user navigation and to ensure users can find what they need more easily.

You can change your cookie settings in your browser, if you don’t want cookies to be sent to your device. Please note that some features or services of our Website may not function properly without cookies.

MODIFICATIONS TO THIS ONLINE PRIVACY POLICY

We may update our Privacy Policy from time to time. When we change this Privacy Policy in a significant way, we will post a notification on our Website along with the updated Privacy Policy. We will ask you to accept our new privacy policy before you can continue to use our Website, to make sure we still have your consent to process your data.

YOUR RIGHTS AND WHO TO CONTACT

If your personal data are processed based on legitimate interests pursuant to GDPR sec. 6 para. 1 sentence 1 lit. f, you have the right to object to the processing of your personal data pursuant to GDPR sec. 21, provided that there are reasons on grounds relating to your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right of objection, which we will implement without specifying a particular situation. If you would like to make use of your right of revocation or objection, simply send an e-mail to support@seabo.com.

If you have any questions, comments or concerns about how we handle personal data, please contact us at support@seabo.com.. We will respond to such a request within 30 days of receipt by us.

Contact us in writing at:

Next Logistics Ventures GmbH
Zirkusweg 2
20359 Hamburg
Germany

By mail: support@seabo.com

VAT ID: DE 335 875 552
HRB 164725 (Amtsgericht Hamburg)