GDPR PRIVACY POLICY

Introduction
The company under the distinctive title Seanturion ΟΜΟΡΡΥΘΜΗ ΕΤΑΙΡΕΙΑ (hereinafter the “Company”) has created this website and the related platforms (dashboard & mobile app) solely for the purpose of serving its customers. Their use is simple and user-friendly and has been designed to meet the specific needs of each user.

In order to serve you in the best possible way, it is important that you, our customer, understand that we may need you to provide us with certain information related to the processing of your order, which we safeguard.

The processing of your personal data, including location data (geolocation), is carried out in accordance with the provisions of the General Data Protection Regulation (GDPR 2016/679), any specific national and European legislation applicable to related fields, the applicable Greek legislation on the protection of personal data and privacy, and the legislation in the field of electronic communications (Law 3471/2006, as in force).

This Privacy Policy describes what personal information we collect about you, how we collect it, for what purposes we use it and to whom it may be disclosed. This Privacy Statement relates exclusively to the personal data that you provide to us when placing orders on this website.

Data Controller

In its capacity as Data Controller, the Company informs you that, for the purposes of carrying out its business activities, it processes personal data of natural persons, including geolocation data, which may allow their identification. The Company is the Data Controller of your personal data.

For any matter relating to this Policy you may contact us at:
Email: info@seanturion.com
Telephone: +30 698 917 6700
Address: Pipinou 5, 17342 Athens, Greece

What are personal data?

Personal data are any information that identify you directly or indirectly. Indirect identification means in combination with other information, such as, for example, your name, postal address, email address, telephone number, or a unique device identification number.

Which personal data we collect

The Company has designed and operates this website in a way that allows users to visit it without having to disclose their identity, unless they wish to do so. The provision of personal data is requested only when it is necessary for the performance of specific actions, such as submission and processing of product or service orders, registration for a user account or newsletter, as well as communication with the Company via email or contact form.

In particular, the personal data we collect and process during your visit are the following:

• Account and contact data: user’s full name, email address, telephone number, postal address or other contact details.
• Order, billing and invoicing data: order details, payment details, tax/company details (VAT number), transaction history.
• Device and location data: device identifiers (e.g. ID, IMEI), geolocation data (GPS/GNSS), telemetry, operational or maintenance data of equipment.
• Technical and analytical usage data: IP address, browser or device type information, date and time of access, log files, connection data and usage statistics (analytics).
• Optional communication and marketing data: communication preferences, subscription to newsletters, participation in promotional or advertising activities.

Purposes of processing personal data

The Company processes your personal data exclusively for lawful and specified purposes, which are directly related to the provision and improvement of our services. In particular, we use your data for the following purposes:

• To improve the operation of the website and the online store (e-shop), through statistical analysis and evaluation of the user experience, so as to ensure their smooth and secure operation.
• To provide customer support and communication, in order to respond to queries, requests or complaints and to offer effective service.
• To manage and perform orders, including invoicing, payments, shipment or collection of products, and informing you about their progress.
• To send newsletters, offers or other marketing communications only if you have given your explicit consent.

The processing of geolocation data is carried out exclusively if you have provided the relevant consent via your device or browser. Such data are used indicatively for the following purposes:

• Monitoring and tracking of the position of vessels, fleets or equipment in real time.
• Improving the accuracy of the monitoring services provided through the platform’s dashboard and mobile application.
• Identifying the nearest shipping or pickup option for an order, to facilitate the delivery process.
• Optimising the user experience by providing more accurate information about locations, delivery times and service availability.
• Adapting functions and services to the needs and location of the user, in order to provide personalised options and suggestions.
• Preventing and investigating incidents of fraud or suspicious transactions, to ensure the security of users and transactions.

Your consent for the processing of location data may be withdrawn at any time, without affecting the lawfulness of processing carried out before the withdrawal. Revocation may be made through the location settings of the device or browser you use.

Legal basis for processing

In the context of the use of the website and the services provided, the Company processes users’ personal data in accordance with the provisions of the Regulation, based on the following legal grounds:

• Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, e.g. for the creation of an account, the completion of your purchases and subscriptions and for accessing or using the device monitoring and management platform.
• Compliance with a legal obligation: The Company processes personal data when required in order to comply with its legal obligations, such as responding to requests from competent judicial, police or supervisory authorities, handling requests regarding the exercise of data protection rights, as well as keeping accounting and tax records as required by applicable law.
• Legitimate Interest: Processing may be based on the Company’s legitimate interest, where this does not override the rights and freedoms of the data subjects, such as ensuring the proper, safe and uninterrupted operation of the website, preventing, detecting and addressing security incidents or malicious activity, keeping backups, as well as efficient management of communication with users and customers through the Company’s official channels (contact forms, email, telephone requests) for timely response to queries, comments or support requests.
• Consent: Processing is carried out on the basis of the user’s consent where required. Consent is given freely, specifically and explicitly, and relates in particular to: the use of cookies and similar technologies, in accordance with the Company’s Cookies Policy, the collection of information for analysis, personalisation of experience and advertising purposes, as well as the sending of newsletters or promotional communications.

The user has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Revocation may be effected through the Cookies Policy or the communication settings on the website.

Who are the recipients of your data?

The Company shares personal data only to the extent necessary for the proper operation of the online store, the performance of its services and the fulfilment of contractual or legal obligations. Such disclosure is made exclusively to third parties acting as Processors, in accordance with the Regulation, who have assumed obligations of confidentiality and data security.

Indicatively, the categories of third parties to whom personal data may be disclosed include:

• Payment service providers: For completing transactions, processing payments and secure handling of financial data, e.g. Visa, Mastercard, PayPal, Viva, Stripe.
• Hosting and cloud service providers: For the operation, storage and security of the website and electronic services data.
• Email/SMS delivery providers: For sending notifications, order updates and other transactional messages.
• Analytics providers: For collecting technical usage data, connection data and geolocation data solely for the purpose of improving the operation of the website and the Company’s services.
• Courier companies: For the delivery of products and proper execution of orders.
• Accountants, lawyers and other professionals: Where required for compliance with the Company’s legal or tax obligations.
• Banks, insurance companies, public authorities including tax and judicial authorities: Only where provided by law or where there is a legitimate interest. In such cases, these organizations process data in accordance with their own privacy policies and legal obligations.

The Company has taken all necessary measures to ensure that its staff and associates are specifically authorised for the relevant purposes and are fully bound by confidentiality and the obligations laid down by law in relation to the collection and further processing of your data.

In which countries we process personal data

The Company does not transfer personal data to third countries outside the European Union (EU) or the European Economic Area (EEA).

If, in the future, it becomes necessary to transfer personal data to third countries, this will be carried out exclusively under the following conditions:

• The transfer will be made only to countries for which an adequacy decision has been issued by the European Commission, ensuring an adequate level of data protection.
• The transfer will be carried out using appropriate technical and legal safeguards as provided in the Regulation, e.g. standard contractual clauses.
• Users will be informed before any such transfer of their data so that they are aware of the relevant conditions and protection guarantees.

The Company is committed to ensuring that any transfer to third countries will be made in full compliance with the Regulation and with measures that guarantee the security, confidentiality and integrity of your personal data.

Security of your data

Our Company has taken all appropriate technical and organisational measures, in accordance with technological standards and applicable laws and Regulations, to ensure that the processing of personal data, whether carried out by the Company itself or by third parties on its behalf, is lawful, appropriate and has an adequate level of security in order to prevent any unauthorised or accidental access, processing, deletion, alteration or other misuse.

Retention of your data

The Company will retain your personal data only for as long as necessary for the purposes defined in this Privacy Policy. In particular:

• User accounts and subscriptions: Account and subscription details will be retained for as long as the subscription remains active and for an additional twelve (12) months after its expiry, for support and communication purposes.
• Invoicing and accounting records: Order, payment and accounting data are kept in accordance with tax and accounting legislation.
• Logs, telemetry and technical usage data: Such data are retained for twelve (12) months for purposes of security, proper operation, monitoring and business continuity of the website and the Company’s services.

The Company implements appropriate technical and organisational security measures, including encryption during data transmission, access controls and regular backups, in order to ensure the integrity, confidentiality and availability of personal data.

At the end of the above periods, the data will be deleted or anonymised, unless otherwise provided by law or if required for the establishment, exercise or defence of the Company’s legal claims.

With regard to data collected on the basis of consent, such data are retained until you withdraw your consent.

User rights

In any case, we would like to inform you that, in accordance with the Regulation, you have – and may exercise, after verification of your identity – the following rights:

• Right of access: You can obtain full information regarding your personal data processed by us and verify the lawfulness of their processing.
• Right to rectification: You can request the correction, updating or modification of your personal data, by contacting the Data Protection Officer (DPO).
• Right to erasure (“right to be forgotten”): You can request the deletion of your personal data.
• Right to restriction of processing: You can request the restriction of the processing of your personal data in the following cases:
  (a) when you contest the accuracy of the personal data, and until it is verified;
  (b) when you oppose the deletion of personal data and request the restriction of their use instead;
  (c) when the personal data are no longer needed for the purposes of processing but are required for the establishment, exercise or defence of legal claims; and
  (d) when you object to processing and until it is verified whether the legitimate grounds for processing override your reasons.
• Right to object to processing: You may object at any time to the processing of your personal data when such processing is based on the Company’s legitimate interests.
• Right to data portability: You may receive your personal data in a format that allows access, use and processing by commonly used methods. Where technically feasible, you may request that the data be transmitted directly to another controller. This right applies to data you have provided to us and which are processed based on your consent or the performance of a contract.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw it at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise your rights, you may contact us at: info@seanturion.com

Information about minors

The Company does not collect or process personal data relating to children under 16 years of age without the explicit and verifiable consent of a parent or guardian, as required by the Regulation. If a child under 16 provides personal data without the required consent, the Company will not process such data and will request their deletion.

Use of Cookies

Like most websites and platforms, when you use our services (whether you are a registered user or a simple visitor), we collect data through cookies, web beacons and log files, both on our website and in our applications (dashboard & mobile app), as well as through third-party applications that use our API. These technologies are specifically used for the following purposes:

• Ensuring the security of your accounts and data.
• Ensuring the proper and continuous operation of the platform, including the monitoring of vessels, fleets or equipment.
• Analysing usage and monitoring traffic, trends and user behaviour, with the aim of improving service quality and user experience.
• Sending personalised alerts, updates or offers regarding our services, only where you have given the relevant consent.

You may disable or restrict the use of cookies at any time through your browser settings. However, disabling certain cookies may affect the functionality or optimal user experience of our website and applications.

Right to lodge a complaint

If you exercise any of your rights and are not satisfied, you have the right to lodge a complaint with the Hellenic Data Protection Authority via its online portal (https://eservices.dpa.gr/). For more information you can consult the website of the Hellenic Data Protection Authority (www.dpa.gr).

Amendments to this Privacy Notice

This notice reflects the current policy of the Company regarding the processing of personal data, as applied at the time of its publication.

The Company may amend or update this notice if there are substantial changes in its personal data processing activities, changes in the relevant data protection legislation, or changes in its business processes.

In any case, users will be informed of any significant change via the Website or other official communication channels, so that they are aware of the current Privacy Policy.