IMSKIPPER PRIVACY POLICY

Version from 10.10.2022. Previous versions.

The present Privacy Policy discloses to Users, Partners (also referred to as "You") what personal data IMSKIPPER collects, for what purposes, as well as what protection measures are taken to ensure confidentiality, in what cases and for what purposes such data may be transferred to other individuals.

By using IMSKIPPER Website, the Platform, You agree to the present Policy without any reservations.

Please read the present terms carefully. If you need any clarification, you can send a request at any time to the email address specified in Contact Information section.

TABLE OF CONTENTS

1. TERMS AND DEFINITIONS

2. POLICY ACCEPTANCE

3. DATA COLLECTION

4. HOW IMSKIPPER USES PERSONAL DATA

5. DATA STORAGE

6. DISCLOSURE AND TRANSFER OF INFORMATION TO THIRD PARTIES

7. SECURITY

8. DATA PROTECTION FOR MINORS

9. POLICY CHANGES

10. RIGHTS OF DATA SUBJECT

11. CONTACT INFORMATION

Appendix A to IMSKIPPER Privacy Policy

Appendix B to IMSKIPPER Privacy Policy

1. TERMS AND DEFINITIONS

IMSKIPPER – D.O.O. company IMORE, Montenegro, PIB 03400921, developer and owner of exclusive rights to the Platform.

The Account – a user account in the Platform accessed with a user name (login) and a password.

The Partner is an individual or a legal entity that uses the Platform to sell its Services.

Personal data is information that, by itself or together with another information, can be used to identify a specific individual.

The Policy – the text of the present Policy with all appendixes and other documents referenced.

The User – an individual or a legal entity that uses the Platform to search for and order the Services.

IMSKIPPER website is a site on the internet united by the address space of imskipper.net domain and its subdomains.

The Platform is a software product hosted on IMSKIPPER servers, and the access to its functional part is granted to the User or the Partner on IMSKIPPER Website or in IMSKIPPER mobile device application.

The Service – a service in accordance with an Advertisment that is available for sale and ordering using the Platform.

Advertisment – information created and maintained by a Partner related to booking places on yachts, booking participation in events, etc., their price, cancellation procedure and conditions, as well as other essential provisions.

2. POLICY ACCEPTANCE

You accept the Policy without any reservations when you:

• Visit IMSKIPPER Website and/or create an Account.
• Send a message to IMSKIPPER using feedback form, online chat, by e-mail, in messengers or on social networks, as well as otherwise provide IMSKIPPER with your personal data.
• Use the Platform

3. DATA COLLECTION

IMSKIPPER collects information mainly as a result of direct or indirect interaction with you.

IMSKIPPER may collect directly both Personal Data and other data that is not Personal Data as is (i.e. cannot be used to identify a specific individual).

IMSKIPPER takes necessary administrative, physical and technical measures to protect all the information received from you. For more information about such measures, see the section "Security".

IMSKIPPER may process your data without obtaining consent if such processing is carried out to conclude and execute contracts (based on paragraph 1 (b) of Article 6 of GDPR). In other cases, processing is performed solely on the basis of your explicit consent in accordance with paragraph 1 (a) of Article 6 of GDPR.

In exceptional cases IMSKIPPER has the right to process data on the basis of legitimate interests, as specified in paragraph 1 (f) of Article 6 of GDPR, however, each such legitimate interest must be specified in the present Policy.

IMSKIPPER does not process special categories of data: biometric data, information about political, religious beliefs, criminal records, health status and other similar data. However, in some cases for ordering Services, you need to meet certain level of health and have no contraindications. In this case, only your assurance about the circumstances will be processed, the accuracy of which is your sole responsibility, but no diagnoses, medical history or any other similar data, is subject to processing.

IMSKIPPER strongly recommends not to provide personal data on forums and other public sections of IMSKIPPER Platform and website. IMSKIPPER does not perform mandatory moderation of entered data and does not bear responsibility in case of its public disclosure.

IMSKIPPER receives information from the following sources:

A) Information that IMSKIPPER receives directly from you.

IMSKIPPER collects and processes information that you provide directly to IMSKIPPER while:

• Using IMSKIPPER Website, the Platform;
• Creating and using the Account;
• Bying and providing Services.

IMSKIPPER collects and processes information only to the extent that corresponds to the purposes of its collection.

The content of the data collected and processed may differ depending on whether you are the User or the Partner. In particular, you provide the follwing to IMSKIPPER:

• First name, last name, gender, address, phone number, email address, date of birth
• Data on purchased (sold) services
• Searches
• Authorization data
• License Information
• Information about ownership of water crafts
• Addresses of routes (places of departure, arrival, route)
• Data of identity documents
• Information about insurance
• Place of work, position
• Social Media profile
• Geolocation data.

In case you provide Personal Data of third parties for the purpose of purchasing the Service, you confirm that you are authorized to act on behalf of such persons, have received their consent to provide personal data and can provide appropriate confirmation at the first request of IMSKIPPER, but in any case no later than within 48 hours.

IMSKIPPER does not collect nor process payment card data. All payment card data is processed by the corresponding payment services. Payment service provides IMSKIPPER only with transaction ID, and in some cases the last 4 digits of the card that can be displayed in payment information in the Account.

B) Data collected automatically

IMSKIPPER can automatically collect and process information about how you use IMSKIPPER website and the Platform. This may also include anonymized IP addresses, browser type, screen resolution, software or hardware environment, searches and other data that allow IMSKIPPER to improve performance of IMSKIPPER Website and the Platform.

As a rule, such information is not Personal Data. However, if automatically collected data will have the characteristics of Personal Data, they will be subject to immediate anonymization before or simultaneously with their storage.

Automatically collected data includes:

• Log-data (log data). IMSKIPPER servers automatically record technical information about access to them. It happens when you open IMSKIPPER Website, perform actions in your Account, use the Platform. Log data may contain IP address, browser characteristics, date, time, duration, and sequence of actions.
• Usage data. IMSKIPPER collects information about how you used IMSKIPPER Website, the Platform to make them more convenient. Such data may include device type, version of operating system, technical error reports, quantitative usage parameters.
• Cookies. IMSKIPPER uses cookie (and similar) data collecting technology. For more information, see relevant section of the Policy.
• Data provided to IMSKIPPER by third parties. In most cases you have a right to independently allow, prohibit or restrict disclosure of information by a third party. For example, you can log in using social networks. At the same time, this is up to you to a social network to provide IMSKIPPER with your email address, name or another information. IMSKIPPER cannot get any information on its own if you have not allowed this in the settings of social network and have not provided consent.

4. HOW IMSKIPPER USES PERSONAL DATA

IMSKIPPER uses personal data strictly in accordance with applicable law and purposes of data is collection.

When processing personal data, IMSKIPPER acts based on the following principles:

• Processing of personal data is carried out onlegal and fair basis;
• Processing of personal data is limited to achieving specific, predetermined and legitimate goals, and the content and volume of processed data should not be excessive. Processing of personal data incompatible with the purposes of its collection is not allowed;
• It is not allowed to unite databases containing personal data, processing of which is carried out for purposes incompatible between each other;
• Only personal data that meet purposes of their processing are subject to processing;
• When processing personal data, accuracy of personal data is provided, its sufficiency and relevance in relation to the purposes of processing of personal data, and, if necessary the necessary measures are taken to delete or clarify incomplete or inaccurate data;
• Storage of personal data for no longer than it is required for the purposes of personal data processing;
• Ensuring security against unauthorized or illegal processing, as well as against accidental loss, damage or destruction.

Personal data is used by IMSKIPPER for:

• Fulfillment of IMSKIPPER's obligations on the basis of contracts.
• Compliance with legal requirements. For example, in order to comply with legislation on payment of taxes.
• Payments, account management and administration, payment control.
• Protection against copyright infringement, fraud and other unfair behavior.
• Improvements, support, modernization of the Platform. Such processing is necessary to prevent and eliminate errors, ensure security, correct technical problems, analyze and monitor usage.
• Interactions with Users and Partners, for example, replies to requests.
• Mailing and other types of communication. At the same time IMSKIPPER can send several types of messages (including email, SMS, messages in the Account): a) systemic messages are required for timely fulfillment of IMSKIPPER's obligations to the User or Partner. Such notifications include messages about the status of services, payments, password changes and other similar issues; b) marketing and advertising messages are sent only if you provided explicit consent to receive them. You can always refuse to receive such messages, at the bottom of each email you have corresponding instructions.
• Conducting research using depersonalized data.

When processing data for purposes specified in paragraphs 4-8, with an exception of marketing and advertising messages — IMSKIPPER proceeds from reasonable legitimate interest, as indicated in paragraph 1 (f) of Article 6 of the GDPR.

5. DATA STORAGE

IMSKIPPER stores data for the time necessary for the purposes of its collection.

After processing goals are achieved or in case there is no need to achieve these goals, as well as in case of receipt of a corresponding request, the data is subject to destruction or depersonalization.

Despite user's request to delete information, IMSKIPPER has the right to store the information if it is necessary for legitimate business interests, fulfillment of obligations and dispute resolution.

IMSKIPPER provides for collection of personal data and its processing using databases located in Germany.

Collection of personal data of residents of the Russian Federation is carried out using databases located on the territory of the Russian Federation.

6. DISCLOSURE AND TRANSFER OF INFORMATION TO THIRD PARTIES

In order to fulfill its obligations to Users and Partners, IMSKIPPER may required to transfer some Personal Data to third parties. In such cases, IMSKIPPER reduces the amount of data transmitted to the maximum possible minimum. In any case IMSKIPPER enters into agreement with each such third party (including as part of general agreement) to ensure confidentiality of transmitted data.

IMSKIPPER transfers Personal Data:

• of Users to Partners, provided such Users purchased (or intend to purchase) Partner's Services;
• of the Partner to Users to the extent necessary to select the Partner and provide Services;
• of Users and Partners to payment services, messaging services, analytic services and other third parties whose services are necessary to ensure operation, development and improvement of the Platform, error handling. The list of categories of individuals to whom Personal Data can be transferred to a limited extent is specified in Appendix A;
• When receiving instructions from the User or the Partner;
• To state, judicial and other authorities in order to comply with applicable legislation, prevent illegal actions, protect rights and security of IMSKIPPER and other individuals, protect against claims and lawsuits. So, the data may be disclosed in case of request from a competent authority or in order to bring to justice for fraud;
• In other cases upon receipt of your consent.

By placing an order to purchase a Service, the User provides IMSKIPPER with an order and consent to transfer his Personal Data to the Partner, as well as Personal Data of other individuals whose data the User specifies when purchasing the Service.

By placing an Ad in the Platform, the Partner provides an order for collection and transfer of Personal Data necessary for provision of the Service.

The Partner undertakes to ensure confidentiality of Personal Data on the terms not less defined by the Policy.

In order to exclude doubts the User and the Partner are notified and agree that it is the Partner who is the controller (as interpreted in accordance with GDPR norms) with respect to Personal Data collected and transferred when purchasing the Service, since it is the Partner who initiates the sale of the Service and collection of Personal Data, and the Partner also performs further processing of Personal Data during direct provision of the Service. IMSKIPPER only provides the Platform, the functions of which allow the Partner to request certain Personal Data, and the User to transfer them, i.e. in this case IMSKIPPER is a processor, as defined in GDPR.

The Partner may have own policy regarding confidentiality of Personal Data.

IMSKIPPER in accordance with Article 30 of GDPR records transmitted data.

In case of data transfer to countries beyond IMSKIPPER location, such transfer will be carried out in full compliance with Chapter 5 of GDPR, ensuring a level of protection not less than that established by the present Policy.

7. SECURITY

IMSKIPPER took necessary technical and organizational measures to ensure protection of Personal Data fromviolations of privacy or loss.

In particular:

• All data is processed in secure information systems, to which there is no public access;
• Any data is transmitted in encrypted form using SSL;
• Confidentiality agreement was concluded with all contractors (to whom personal data is transferred or who may have access to it), an NDA or similar conditions are otherwise contained in the documents regulating the relationship;
• Periodic checks of personal data processing conditions are carried out;
• The employees directly engaged in processing of Personal Data are familiarized with provisions of legislation on personal data, including requirements for protection of personal data, documents, and other internal documents on processing of personal data.

Despite all security measures applied, IMSKIPPER cannot guarantee that Personal Data during its transmission on the Internet or storage will be absolutely restricted from intrusion. At the same time IMSKIPPER uses pseudonymization and data encryption wherever possible.

8. DATA PROTECTION FOR MINORS

IMSKIPPER website and the Platform are not intended for children or minors. For this reason IMSKIPPER does not assume that the information collected by IMSKIPPER will be Personal Data related to children or minors.

However the User can purchase Services in the interests of children and minors. In this case the User, acting as legal representative, gives consent to processing of their Personal Data for the purposes of providing the Service under the terms of the Policy. The User bears all the responsibility for legitimacy of providing Personal Data of children and minors.

IMSKIPPER has the right, at its discretion, to require confirmation of powers to provide Personal Data of a child or a minor.

Any Personal Data that is identified as belonging to a child or a minor is subject to immediate deletion if it is not provided legally, and the provision of Services may be refused.

9. POLICY CHANGES

IMSKIPPER has the right to make changes to this policy taking into account changes in legislation, business processes and other circumstances. All changes are subject to publication on IMSKIPPER Website.

Unless otherwise specified in the text of new versions, they come into effect 10 days after the date of their publication on IMSKIPPER Website.

You accept the obligation to familiarize yourself with the Policy changes.

SKIPPER has the right (but is not obliged) to send additional notifications about the changes by e-mail and/or in the Platform.

10. RIGHTS OF DATA SUBJECT

Users and Partners are guaranteed compliance with their rights in accordance with Applicable legislation and recognized norms of international law.

With respect to Personal Data, Users and Partners have the right to:

• Revoke consent to processing of personal data (if processing is based on consent). For example, by agreeing to receive advertising or marketing information you can always unsubscribe to such messages.
• Obtaining information about processing of personal data. By keeping the present policy in up-to-date version IMSKIPPER ensures that you receive reliable information about the data collected, purposes of processing and other aspects of processing.
• Access to information, its update, modification, clarification and deletion of information. You always have the right to manage information.
• Right to object to processing. The User has the right to object to processing of his personal data for direct marketing purposes.
• The right to restrict processing. Only in strictly defined cases, for example, challenging data accuracy (during data qualification period) such a right allows to establish illegitimate processing. In case of a request to restrict processing, IMSKIPPER is not entitled to perform any type of processing without the User's consent. However, processing may be performed if it is needed to protect against claims and lawsuits without such consent.
• The right to exportand import data if technically executed. Data is exported in CSV format.
• The right to delete Personal Data. IMSKIPPER has the right to continue processing data after receipt of the request, if permitted by applicable legislation.

Other additional rights may be granted by applicable legislation.

If you request to perform any operations on your Personal Data, IMSKIPPER may ask you to provide proof of your identity in order to exclude any errors.

11. CONTACT INFORMATION

The data controller (operator) is: D.O.O. IMORE, Montenegro, PIB 03400921.

Any requests related to data processing should be sent to e-mail address: support@imskipper.net, and also in writing to IMSKIPPER address.

IMSKIPPER will strive to consider incoming requests as soon as possible, but in any case no more than in one month.

Appendix A to IMSKIPPER Privacy Policy

IMSKIPPER PROCESSORS AND INDIVIDUALS TO WHOM DATA CAN BE TRANSMITTED

IMSKIPPER may involve sub–contractors, service providers (hereinafter referred to as Processors) in order to fulfill obligations to Users and Partners, as well as in order to provide for its legitimate legal interests.

Processors are given a strictly limited set of data required to perform their functions. Before involving the processor, IMSKIPPER will take all possible measures to ensure confidentiality of data transmission.

In the present application IMSKIPPER discloses the categories of such individuals.

Depending on the volume of interactions (for example, whether you subscribed to marketing notifications, whether you purchased Services, etc.), data may not be transmitted at all or transferred to some of the following list:

Service category	Purpose of transfer
Services of notification distribution	Distribution of service and marketing messages by means of e-mail, SMS or other types of messages.
Analytical Services	Research on the use of the Service in order to develop it, search for errors (only depersonalized data)
Advertising services	Display of advertising information.
Social networks	Authentication, display of advertising information.
Partners	Provision of Services

Appendix B to IMSKIPPER Privacy Policy

COOKIE POLICY

The present section defines how, when and for what purpose IMSKIPPER uses Cookies and similar technologies.

By continuing to use IMSKIPPER website, the Platform, you agree to use cookies and similar technologies in accordance with the Policy and the present appendix to it. If you do not want these technologies to be used, set the settings as indicated in section "HOW TO DISABLE COOKIES".

WHAT ARE COOKIES

Cookies are small text files stored on a computer or mobile device when using IMSKIPPER website, the Platform. Each Cookie is unique for each account or browser.

WHAT COOKIES IMSKIPPER USES

IMSKIPPER uses cookies and similar technologies, for example, such as "pixel". As a rule, gif file is 1 pixel in size when you open it, you can get information, for example, about technical parameters of the connection.

IMSKIPPER uses both session and persistent cookies. Session cookies are created only while your Internet browser is open, and are subject to automatic deletion when it is closed. Permanent cookies are created for a period until its self-deletion or expiration of the period specified in such Cookies.

IMSKIPPER also uses its own Cookies, as well as third-party Cookies. Third-party cookies are installed on your device by another person through IMSKIPPER website or the Platform, for example, by analytical systems such as Google Analytics. You may find out how such third parties collect and use data on our behalf in their privacy policies.

Some Cookies are related with your Account and allow you to provide your authorization. Other Cookies are not related with the Account, but being unique, they allow you to save settings, interface elements, preferences, and choices.

IMSKIPPER uses the following types of Cookies:

Cookie Type	Description
Necessary	They provide for basic operations of the Platform, such as navigation, access to non-public sections. The Platform cannot function correctly without these Cookies. Such Cookies, in particular, allow you to identify unfair behavior and the use of bots.
Preferences	Allow the Platform to save information about interface settings and usage settings. For example, you can save your selected language, currency settings, region, and others.
Statistical/analytical	Collect information about how you use the Platform so that we can improve the Platform. Such Cookies provide us with aggregated information about performance, number of visits, errors, sources of visits, and track effectiveness of advertising campaigns (including email)
Marketing	They allow you to display advertising information matching your interests, and also prevents the same ads from being shown again. Some Cookies are associated with social networks and may participate in the authorization process in social networks.

Cookies allow you to use all the features of IMSKIPPER Website and the Platform.

HOW TO DISABLE COOKIES

Most modern browsers allow to manage security settings. In particular, the user can prohibit storage and use of cookies, set up exceptions for trusted web-sites.

IMSKIPPER is not responsible for your browser settings.

You ma find simple instructions on how to manage cookies in different browsers on the website www.allaboutcookies.org.

Rejection of third-party cookies, for example Google Analytics, can be made on Google website. Also, restrictions to use "pixels", "web beacons", for example, social networks, can be made in security settings of social networks.

If you restrict the use of cookies, normal functioning of IMSKIPPER website and the Platform may be disrupted.

IMSKIPPER assumes no responsibility in case it is impossible to use the Platform or IMSKIPPER website due to restrictions on the use of cookie technology.