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
1. Scope and Applicability
2. Your Consent (PLEASE READ CAREFULLY!)
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.
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
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
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.
6. Lawful Grounds for Collecting Information on our Users.
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;
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.
10. Data Controller / Processor
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.
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.
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.
• 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/.
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].
17. General Information.
18. Have any Questions?