General Terms of Use & Privacy Policy

This website/platform belongs and is operated by the company under the name LEARNING PATH SA (hereinafter referred to as “Learning Seaman”), which has its registered seat at 3-5 Mantos Mavrogenous Street, 15238 Chalandri, Greece, VAT 802286517, General Commercial Register No. 173659503000. In order to use our website, you should read and accept the General Terms of Use and the Privacy Policy (https://www.learningseaman.com/privacy-policy/).

The present document constitutes a binding legal document for the ship owners/ship managers/individual seafarers to whom the services of the Learning Seaman platform are provided in order to be used by the crew of their vessel or seafarers individually. Please read carefully these terms. In case you disagree either with the present terms or with the General Terms of Use or with the Privacy Policy, you must stop using our services. Otherwise, it is presumed that you explicitly and unconditionally accept the present terms and you consent thereto. The following General Terms of Service are applicable to all the content of our website/platform.

Learning Seaman is entitled to modify these “General Terms of Service” and/or the “General Terms of Use” and/or the “Privacy Policy”. Once such a modification occurs, we shall notify you accordingly, e.g. via a clear notification (banner) on our website. You should check this page regularly to make sure that you are satisfied with any modifications to these terms and to read carefully any relevant notification. By continuing to use our website, you consent to these specific terms.

If you have any queries or require any clarifications, please contact our customer service via email at info@learningseaman.com.

 

Definitions

“Visitor/User”: any person that navigates the Learning Seaman website

“Registered User”: the user who registers and creates an account on the Learning Seaman platform for the attendance of courses offered through our platform

“Employer”: the ship owner and/or ship manager (natural or legal person) who owns and/or manages the vessel and for whom the seafarers visiting the Learning Seaman website and using the services of the Learning Seaman are working on board, in case seafarers visit the Learning Seaman website through registration of a vessel.

“Individual seafarer”: the natural person who registers in the Learning Seaman website individually, without a prior vessel’s subscription.

The services of Learning Seaman

Being aware of the unique living and working conditions of seafarers and their demanding working environment, as well as the opportunities offered by technology, we created the Learning Seaman platform in order to accommodate your needs in the best possible way. Learning Seaman is the first mental health and wellbeing platform dedicated to seafarers.

Browsing topics offered through the Learning Seaman platform has many advantages. Learning Seaman is an “all-in-one” platform, which offers concise and intelligible videos from a wide variety of topics, which are constantly being updated. Our goal is to provide seafarers with a tool to support their mental health, spend creatively their leisure time on board, to develop new skills and to self-develop themselves. The Learning Seaman platform is fully adjusted to the connectivity limitations on board as well as to seafarers’ living and working conditions on board.

Information on the navigation to our website and the use of our services

  1. Subscription of vessels

Once the vessel of the Employer is subscribed, the subscription fee is paid by the Employer and the IP address of the vessel is whitelisted, we shall invite the vessel’s crew to register in the Learning Seaman platform. The (non-registered) Visitors/Users can freely navigate the Learning Seaman website (provided that they accept the General Terms of Use – https://www.learningseaman.com/privacy-policy/).

If the Visitors/Users wish to use Learning Seaman, they have to register in our platform and create an account. To register in the services of the e-learning platform of Learning Seaman, the users will be requested to provide the following personal data: first name, last name, email address, nationality, rank.

  1. Subscription of seafarers individually

If a seafarer wishes to subscribe directly to our website, they can do so by paying directly the subscription fee, without the need of a prior vessel’s subscription. To register in the services of the e-learning platform of Learning Seaman, the users will be requested to provide the following personal data: first name, last name, email address, nationality, rank.

How the Learning Seaman platform works

The Learning Seaman platform offers registered users the possibility to watch psychoeducational videos suited to their preferences and interests while on board. On our home page you can be informed about the topics offered through the Learning Seaman platform. Once registered users have completed their registration in the Learning Seaman platform and log in to their account, they can select their preferred topic from a wide variety of categories, including but not limited to Mental Health Awareness, Wellness & Development, In a nutshell, Sleep, Meditation, For work and Music. We reserve the right to modify, rearrange and enrich the content of the service and its topics at any time. We reserve the right to make unavailable in the future certain modules previously available on the service.

In addition, on our website users are given the opportunity to contact us for any questions they may have while navigating our website, as well as in case they have questions about using the Learning Seaman platform services or they experience technical difficulties in their attempt to use our platform.

 

Equipment and Access

Access to the Learning Seaman platform is controlled through the IP address of the vessel, in case a seafarer is visiting the website through a vessel’s subscription, or through their personal static IP address, or in case a seafarer is visiting the website individually. To be able to access the services of the Learning Seaman platform and attend the courses offered online, all registered users must have the necessary equipment (laptop, PC, tablet, mobile phone) as well as an internet connection suitable to be used for such operations and suitable to connect to the Learning Seaman platform and to comply with the terms of the applicable legislation. Users may also download the Learning Seaman content via the mobile applications and watch the videos without internet connection.

 

Intellectual property rights

By accepting the terms hereof, you are granted a strictly personal, non-exclusive, non-transferable, and revocable license for the use of our services, whether you are a company owing/managing a vessel, the crew of which is going to use our platform (B2B), or a seafarer who wishes to use our platform individually (B2C), for non-commercial use only, subject to the limited uses listed as permitted herein and in the “General Terms of Use”.

The entire content of the “Learning Seaman” website and platform, including but not limited to information material of any form, texts, graphics, photographs, drawings/designs, “look and feel”, illustrations, services and products provided, and in general any kind of files is the intellectual property of Learning Seaman and is protected by the relevant provisions of Greek law, European law and applicable international conventions on intellectual property. Any reproduction, republication, copying, distribution, transfer, transformation, translation, arrangement, adaptation, rental, resale, transmission, communication to the public, public performance, storage, linking, downloading, creation of derivative works or exploitation in any other way, in whole or in part, partially or in summary, of the content of the Learning Seaman website and platform, and the intellectual property rights thereon, is prohibited. Misleading the public about the real provider of the website content is strictly prohibited. Any use of the content of the Learning Seaman website and platform in any way or by any means for commercial or other purposes is permitted only upon the prior written permission of Learning Seaman.

The names, images, logos and distinctive features included in this website are exclusive trademarks and distinctive features of Learning Seaman or third parties and are protected by the relevant trademark, industrial and intellectual property and unfair competition laws. Any use of Learning Seaman’s trademarks and distinctive features without the prior written consent of Learning Seaman is prohibited.

In case of infringement of the aforementioned rights, Learning Seaman reserves the right to claim any direct or indirect, positive or consequential, damage incurred by it, in accordance with the provisions of the applicable legislation.

 

Hyperlinks to third-party websites

There may be references to third party websites in the form of links / hyperlinks, for the purpose of facilitating the users of the Learning Seaman platform and website. We highlight that the websites to which reference is made are subject to their own terms of use. The appearance of these links on Learning Seaman’s website does not constitute an indication of approval or acceptance of the content of the corresponding websites by Learning Seaman, which is not responsible for their content and services, nor for the terms of management and protection of personal data used by them, nor does it guarantee their availability or the accuracy of the materials contained therein. The visitor/user of the linked websites is solely responsible for any problem that may arise due to their content and/or services.

 

Payment

  1. In order to navigate our website, Visitors/Users do not have to pay any fee.
  2. In case Registered Users are visiting the website through a vessel’s subscription, the Employer of the Registered Users of the platform assumes the payment of the subscription fee for the use of the services of the Learning Seaman platform. Registered Users can register and attend online courses and use the services of the Learning Seaman platform without having to pay any fee themselves. The subscription for the use of the services of the Learning Seaman platform is annual and is billed in advance. The invoices are sent via email to the email address provided by the Employer during the registration of its vessel. Hence, the Employer is responsible for the accuracy of the email address provided. In the event of termination of the services provided to you as the Employer (such as in the event of non-payment of the subscription fee, breach of the terms of use by the Employer, or any other termination, such as a decision by the Employer to delete its account), our services will cease to be available to Registered Users. In this case, we do not bear or accept any liability whatsoever for any damage incurred by the User as a result of the termination of the services offered to him/her.
  3. In case of Individual users, they assume individually the payment of the subscription fee for the use of the services of the Learning Seaman platform, in order to register and attend online courses and use the services of the Learning Seaman platform. The subscription for the use of the services of the Learning Seaman platform is monthly or annual and is billed in advance. The invoices are sent via email to the email address provided by the Individual user during their registration. Hence, the Individual users themselves are responsible for the accuracy of the email address provided. In the event of termination of the services provided to you as an Individual user without Learning Seaman’s responsibility (such as in the event of non-payment of the subscription fee, breach of the terms of use, or any other termination from your side, such as a decision to delete your account), our services will cease to be available to you. In this case, we do not bear or accept any liability whatsoever for any damage incurred as a result of the termination of the services offered to you.

 

Obligations of the Employer

The Employer using the Learning Seaman website must comply with the provisions of Greek, European and international laws and the relevant legislation. Furthermore, it must refrain from any illegal and abusive use of the content and services of this website. The Employer is liable for any damage caused to Learning Seaman by the Visitor/User and/or the Registered User due to the illegal, unfair or abusive use of the platform, the website or its content. In such cases, Learning Seaman shall cease the infringement and prevent its continuation and claim damages.

In the event of any legal action, administrative or judicial claim against the Learning Seaman website, arising from any form of infringement by the user, the Employer undertakes the obligation both to intervene in the relevant legal proceedings and to indemnify Learning Seaman in the event that the latter is obliged to pay compensation or other costs.

In order to identify the crew that is permitted to use our services, and for their invitation to use our services, the Employer may be requested to send to Learning Seaman the following details of the crew members: first name, last name, email address, nationality, rank.

The Employer represents and warrants that it has received the explicit consent of its crew members in writing in order to transfer the information described above, in compliance with all the requirements of the applicable data protection legislation. The Employer is obliged to indemnify any damage incurred by Learning Seaman due to breach of its aforementioned obligation.

Obligations of the individual seafarer

The Individual seafarer using the Learning Seaman website must comply with the provisions of Greek, European and international laws and the relevant legislation. Furthermore, they must refrain from any illegal and abusive use of the content and services of this website. The Individual seafarer is liable for any damage caused to Learning Seaman due to their illegal, unfair or abusive use of the platform, the website or its content. In such cases, Learning Seaman shall cease the infringement and prevent its continuation and claim damages.

In the event of any legal action, administrative or judicial claim against the Learning Seaman website, arising from any form of infringement by the user, the Individual seafarer undertakes the obligation both to intervene in the relevant legal proceedings and to indemnify Learning Seaman in the event that the latter is obliged to pay compensation or other costs.

 

Limitation of liability

The content and information provided through this website and the Learning Seaman platform are intended for general information purposes. The Learning Seaman website is for information and entertainment purposes only and does not provide specialist knowledge or support. Also, the website is not a substitute for the provision of psychological or other types of specialized support, which can only be provided by specialists. The content may under no circumstances be construed as providing medical advice or advice to undertake or abstain from specific actions.

Learning Seaman makes its best efforts to create a friendly environment for visitors/users and registered users, to provide the best possible services for its users and to maintain and make available the Learning Seaman website. However, it does not warrant that the operations of the website will be uninterrupted or free from bugs and viruses and is not liable for any loss or corruption of data or other damage to the visitor/user or registered user or third party from the use of the platform or its related services, due to either use/copying/downloading or alteration or infection with viruses or other unauthorized third-party interference with files and information made available through the website. Each visitor and registered user should take its own protective measures (daily backing up system of their software, files and data, use of antivirus programs, virus scanner or other protection systems) before using the Learning Seaman website, or storing its information, software or content on their terminal devices. The cost of corrections is borne by the Employer and/or visitor and/or registered user and/or the Individual seafarer and in no case by Learning Seaman.

The quality of the image and generally the flow of information depends on your equipment and your connection, i.e. the telecommunications network you use. Therefore Learning Seaman cannot guarantee the quality of the transmitted information. Similarly, we are not responsible for any communication network error affecting access to the platform or for the total or partial unavailability of the platform, including but not limited to that caused by the telecommunications or mobile network operator or by the large number of visitors trying to use the website at the same time, or for transmission errors or problems related to the security of transmission or for an error involving your device or mobile services.

It is possible to interrupt and/or modify all or parts of the Website, temporarily or permanently, for purposes of maintenance or upgrades to the Platform or the Website or for any reason.

 

Termination

Breach of the terms of this agreement and any interruption/termination of the services provided to you as the Employer (and through which Registered Users gain access to and use our services) or directly as an Individual seafarer will result in the termination of access to our services in general.

 

Applicable law and jurisdiction

Any disputes arising from the application of these General Terms of Service shall be governed by the provisions of Greek law and shall be subject to the exclusive jurisdiction of the Courts of Athens.

 

Other terms

In the event that any of the provisions of these General Terms of Service is found to be invalid, the remaining provisions shall remain in force as if the invalid provision had not existed in the first place.

Learning Seaman may transfer its rights without the consent of third parties.

The parties have agreed to all the terms and conditions contained in this agreement.

The content provided through this website cannot be construed as advice, encouragement, suggestion, instruction or guidance to users to act or refrain from acting in a particular way but it is at their discretion to do as they wish, provided that in doing so Learning Seaman is not liable.

If you need to contact us, you can call us at +30 210 6081192 or email us at info@learningseaman.com.

Please read and accept the General Terms of Use and the Privacy Policy (https://www.learningseaman.com/privacy-policy/).

 

PRIVACY POLICY

 

This Privacy Policy (hereinafter “Policy”) aims to inform you about the information collected from you when you visit and use this website, how it may be used, how you can control the use and disclosure of the information related to you and the measures taken to protect this information. This Policy forms an integral part of the General Terms of Use, which are incorporated by reference (https://www.learningseaman.com/privacy-policy).

This website belongs to the company under the name “LEARNING PATH SA” (hereinafter “Learning Seaman”), which has its registered seat at Athens, 3-5 Mantos Mavrogenous Street, 15238 Chalandri, Greece, VAT 802286517, General Commercial Register No. 173659503000, and provides lifelong e-learning services dedicated to the wellbeing of seafarers. Learning Seaman, acting as the controller of your personal data, informs the person to whom the personal data relates who visits/uses the website/platform https://www.learningseaman.com/ (hereinafter “Website”) that the processing of personal data is governed by the applicable national and EU legislation applicable to the collection, use and disclosure of your personal data by us, including Regulation (EU) 2016/679 of the European Parliament and of the Council, and Law 4624/2019, as well as respective decisions, guidelines and regulatory acts of the Hellenic Data Protection Authority.

 

Information about this Policy

Unless otherwise defined in this Policy, the terms used in this Policy have the same meaning as in the General Terms of Use [http://www.learningseaman.com/privacy-policy/].

By accepting the Privacy Policy upon registration or by visiting the Website and/or using the Services, you expressly consent to the collection, use and disclosure of your Personal Data (as defined below) in accordance with this Policy.

In the future, the Website may provide additional uses and increased functionality. If this involves any change in the way we collect and process your Personal Data, further details and additional terms will be provided to you in this Policy. Unless otherwise stated, any new use/service of the Website introduced will be subject to this Policy.

Where the use of any service of the Website is governed by a more specific privacy policy, such specific policy will apply jointly with this Policy. In the event of a conflict, the more specific privacy policy of each service shall prevail.

The purpose of this Policy is:

  1. To ensure that you know what personal data we collect about you, the reasons why we collect and process it, and to whom we disclose it.
  2. To make clear how we use the personal data that you have shared with us.
  3. To explain your rights and choices in relation to your personal data collected and processed when you visit and use the website.

By accepting this Policy by visiting and using the Website, you expressly consent to the collection, use and processing of your Personal Data (as defined below) in accordance with this Policy.

 

Definitions

PERSONAL DATA” means any information relating to an identified or identifiable natural person (hereinafter the “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier (such as IP address, e-mail address, etc. ) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

APPLICABLE DATA PROTECTION LEGISLATION”: The General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council adopted on 27 April 2016 and implemented as of 25 May 2018, and the EU and national legislation on the protection of personal data and privacy in the field of electronic communications, currently in force, as well as the relevant decisions, guidelines and regulatory acts of the Hellenic Data Protection Authority.

SPECIAL CATEGORIES OF PERSONAL DATA/SENSITIVE PERSONAL DATA”: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life of or sexual orientation.

 

How personal data are collected

Certain personal data are provided directly by users of the website, for example, when a user registers for a service on the website, and certain data are recorded automatically when visitors and users navigate the website.

 

Personal data we collect and process

Learning Seaman ensures the fair and lawful collection and processing of personal data. The personal data collected are those strictly necessary for the implementation of the action requested by the Data Subject.

The Data Subject ensures that the personal data provided is correct and accurate and undertakes to notify Learning Seaman of any change or modification to it. Any loss or damage caused to Learning Seaman or any third party through the communication of incorrect, inaccurate or incomplete information on the registration form is the sole responsibility of the Data Subject.

Specifically, we collect the following personal data:

(a) Visitors/Users of the Website: 

Data that we collect and process when you visit and navigate our website are your IP address, the date and time of your visit, the exact page you visited, the webpage from which you reached our website. We process these data for the purposes of improving the services provided to you.

We collect and process data about your use of our website and services (“usage data”) for the purposes of analysing the use of the website and monitoring and improving our website and services. Usage data may include the IP address, the geographic location, the browser type and version, the operating system, the referral source, the length of visit, the page views and the website navigation paths, as well as information regarding the timing, frequency and mode of use of our services and website on your part.

Learning Seaman collects and processes data solely for the purposes of the legitimate and proper operation of the Website and to provide visitors/users of this Website with the best possible user experience.

(b) Registered Users of the Platform: During the registration of users to use the Learning Seaman Platform Services, we process the following data of registered users of our services:

Specifically, for the registration of the user to the Learning Seaman e-learning platform services, we collect and process the following data: first name, last name, email address, nationality, rank.

Learning Seaman collects and processes the aforementioned data in order to provide the user with the services requested thereby and in particular the attendance of distance learning courses.

During the use and browsing of registered users on the platform, we also collect data recorded under (a) above, as well as further usage data, such as IP, anonymous information about the user’s device and browser, and platform usage data such as time of entry/exit, pages visited, time spent on a specific page-section. 

Furthermore, specifically in the case where (i) our services are provided to crew members of vessels and (ii) access and use of our services by the aforementioned persons takes place after registration of the Vessel/Employer on our platform and after payment by the Employer of the relevant subscription fee, and thus you are not navigating through our website as an Individual seafarer, it is possible that prior to your registration we may request and receive from the Employer the following personal data of yours:

first name, last name, email address, nationality, rank.

These data are transmitted to us with your explicit consent which you have given to the Employer. The purpose of collection and processing of this data by us is as follows:

(a) to enable us to identify Registered Users with the crew members of the vessel to whom the licence to use our services applies and to exclude the possibility of unauthorised users using our services.

(b) to enable us to carry out introductory communication – invitation to use our services to persons who (following registration of the Vessel, by the Employer, on our Platform) acquire the right to register and use our service.

In accordance with the specific provisions of Article 8 par. 1 (a) of the General Data Protection Regulation (EU) 2016/679 in conjunction with Article 21 of Law 4624/2019, minors under the age of fifteen (15) years old are prohibited from disclosing their personal data to us through the Website, without the consent of the persons having parental care and custody of the minor. Learning Seaman makes reasonable efforts to verify in such cases that consent is provided or approved by the person having parental care and custody for the child, taking into account available technology.

 

Purposes of processing/grounds of lawfulness

The personal data of the Visitors/Users of the website and Registered Users of the Learning Seaman platform are limited to the information required to serve the purposes specified above.

Learning Seaman guarantees that it will not transfer, disclose, make available, distribute, lease, etc. your personal data to third parties, unless we have your permission or are required by law to do so. However, Learning Seaman reserves the right to disclose information relating to the Data Subject if the law introduces a corresponding obligation to do so or if such disclosure is required by a court judgment, prosecutor’s order or order or decision of another person or administrative body with statutory authority to compel disclosure of such information.

Specifically, Learning Seaman uses the personal data it collects solely for the following purposes and on the following legitimate grounds:

(a) for the conduct of its business activities and the provision (including improvement) and services it offers and for the performance of the contract with you,

(b) to send communications, including but not limited to confirmations & reminders of participation in platform’s online courses, service announcements and management messages, including promotional material (marketing, offers etc.) and newsletters via email with your express consent,

(c) for the improvement of the services provided,

(d) for compliance with its legal obligations.

(e) for its legal protection and for purposes related to its legal interests.

(f) for statistical purposes.

 

Potential Recipients of the Data

Recipients of your data may be the following:

– Third parties who provide technical services (e.g. Cloud Service Providers), communications services (e.g. email service providers), accounting services (e.g. external accountants) or legal services (e.g. external legal advisors) to Learning Seaman, and who act as processors under written contracts that meet the terms of the applicable data protection legislation.

– Public Authorities where it is necessary for us to comply with a legal obligation, and/or in the event of a judicial investigation or other proceedings by a Public or Judicial Authority to which we have a duty to comply and provide information.

Furthermore, specifically in the case where (i) our services are provided to crew members of vessels and (ii) access and use of our services by the aforementioned persons takes place after registration of the Vessel/Employer on our platform and after payment by the Employer of the relevant subscription fee, and thus you are not navigating through our website as an Individual seafarer, Learning Seaman may disclose to the Employer of registered users (ship owner or ship manager), upon request, fully anonymised data relating to participants and participation in the online courses on our platform for statistical purposes. The data communicated to the Employer of the registered users is anonymous and does not contain any personal data of the registered users.

Learning Seaman may also contact you to confirm, remind, cancel or postpone your participation in our platform’s online courses, to communicate service announcements and management messages between you and Learning Seaman, for communications in the context of our platform course ratings and to receive certificates of completion of our platform’s courses. By providing your contact information and agreeing to this Policy, you consent to Learning Seaman communicating with you or third parties at the email address provided by you. If you wish to opt out of such communications, you can either follow the unsubscription link, that will always be sent to you at the end of every email you receive from Learning Seaman, or contact customer service at info@learningseaman.com to request to opt out of any email communications and your reasonable requests will be accommodated.

 

Data security

For us at Learning Seaman, protecting the Personal Data of Visitors/Users of our website and Registered Users of our platform services and respecting privacy of individuals online is a self-evident commitment. Learning Seaman takes all appropriate technical and organizational measures necessary to ensure the security of our users’ and customers’ data and to protect it from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access and any other form of unlawful processing.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we collect about you.

 

Time period for processing Personal Data

The storage and processing of the data of Visitors/Users of our website and Registered Users of our platform services is only done for as long as necessary to meet the purposes of the processing (as defined above) or until the user objects to the use of the Personal Data by Learning Seaman or (where the legal basis for processing is consent) until the user withdraws consent, and in any case for a maximum period of two years since the data’s storage. Where required by law or where it is necessary for Learning Seaman’s legal claim or defence against legal claims to retain the Personal Data for a longer period of time, Learning Seaman will retain the Personal Data for a longer period of time.

 

Transfer to third countries

We use a server and data centre located in Europe and therefore we have to comply with the provisions of applicable data protection legislation. In the event of any transfer of your data to a processor who may be based outside the EEA, we ensure that such processor complies with the GDPR by applying and concluding, among other measures, the standard contractual clauses for international data transfers issued by the European Commission.

Finally, the website may display advertisements from third party websites and contain links (links, hyperlinks, banners) which refer to third party websites. Any interconnection of our website and platform with any other third-party website does not imply that Learning Seaman assumes any responsibility for the policy followed on that website regarding the protection and management of personal data. When you access those websites, this Policy does not apply, and we recommend that you read the respective privacy policies in order to be aware of the collection and processing of your personal data by the aforementioned websites.

 

Cookies and Similar Technologies

We will ask you to consent to the use of cookies in accordance with the terms of this Policy on your first visit to our website.

What are cookies?

Cookies are small text files that a website stores on your computer, tablet or mobile device when you visit that website; more specifically they are files sent from a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies help analyse web traffic or inform us when you visit a particular website. They also allow us to, among others, store your preferences and settings, allow you to connect to our services, help fight fraud, and analyse the performance of our website and online services. We use cookies to identify you when you visit and as you browse our website and to identify which pages are used, helping us to analyse data about web traffic and to improve our website.

Cookies are only stored on your device if you give your consent. It is at your discretion to control and/or refuse to accept cookies. You have the right to withdraw your consent to the use of these cookies at any time for all cookies except for those necessary for the operation of the website. When you visit our website, you can choose via the pop up window whether you accept or reject the cookies we use. If you do not accept cookies, the performance and functionality of the website may be affected.

We use cookies on our website to manage login sessions, to provide personalised web pages to reflect your special needs and interests. In this way, the website remembers your actions and preferences for a period of time, so you do not have to enter these preferences each time you visit the website or browse its pages. Overall, cookies help us to provide you with a better experience of our website by allowing us to keep track of which pages you find useful and which you don’t.

In any case, we cannot identify your personal identity from cookies. Cookies are stored exclusively on your own device (PC, tablet, mobile phone) and under no circumstances do they give us access to your device or any information about you, other than the data you choose to share with us.

We use Google Analytics (1600 Amphitheater Parkway, Mountain View, CA 94043, USA “Google”) to analyse the use of our website. Google Analytics collects information about the use of the website through cookies. The information collected about our website is used to generate reports on the use of our website. The collection and processing of data by Google Analytics is available here: www.google.com/policies/privacy/partners/.

 

The cookies we use

  1. Strictly necessary cookies

Strictly necessary cookies help make a website usable, by enabling basic functions such as navigation and access to secure areas of the website. The website cannot function properly without these cookies. These cookies do not recognise your personal identity. Without them we cannot provide effective operation of our Website so they are considered strictly necessary.

  1. Performance Cookies

We use these types of cookies to monitor the performance of our Website and how users can use them. These cookies give us the information that helps us to improve and maximise the features of our Website and provide better services to users. They also help us to identify areas of our website that are not working properly or that need maintenance.

  1. Functionality cookies

Functionality cookies help to improve your experience by, among others, remembering preferences, choices you make while visiting the website or previous actions. They allow our website to remember information that changes the way the website behaves or looks, such as your preferred language or the region you are in.

  1. Statistics Cookies

Statistics Cookies help website owners understand how visitors interact with pages by collecting and reporting information anonymously.

  1. Marketing Cookies

Marketing Cookies are used to share certain information with third-party advertisers so that we know how you have approached our website. These cookies record your visit to our website, the parts of our website you have visited and are interested in, and the links you followed to identify you as a previous visitor and to track your activity on our website and other websites you visit. These cookies are used to provide content that best suits you and your interests. This information is used to show you advertisements that we think may be of interest to you, to customize how we communicate with you, or to customize the content of the communications we send you.

  1. Unclassified Cookies

Unclassified cookies are cookies that are in the process of being classified, together with the providers of individual cookies.

 

How to control cookies

Cookies are stored on your computer after you have been informed and accepted their collection. It is at your discretion to control and/or not accept cookies. You have the right to withdraw your consent to the use of these cookies at any time for all cookies except for those necessary for the operation of the website. However, this may result in difficulties in navigating the website and some website functions may not be available. In addition, not accepting a cookie or a category of cookies will not delete existing cookies from the browser – this will have to be done separately, within the browser. You can find further information on how to delete cookies or adjust the cookie settings for the browser you are using from the list below:

  • Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
  • Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
  • Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
  • Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471
  • A useful guide to deleting and managing cookies in browsers: http://www.aboutcookies.org

Web browsers are usually set by default to accept cookies. Today more and more browsers, although not all of them, have a pop-up message for user consent installed. In any case, if you want to modify the function of your web browser to warn you about the use of cookies or to prevent you from accepting their use, you can refer to the settings of your browser.

Useful links about cookies:

  • Management of cookies of advertising agencies for the US: http://www.aboutads.info/choices
  • Management of cookies of advertising agencies for the EU: http://www.youronlinechoices.com/uk/your-ad-choices

This website may contain links or references to other websites. You should be aware that we do not control the cookies and/or tracking technologies of other websites and this Cookie Policy does not apply to those websites.

 

How we access and control your Personal Data

Upon request, you will be provided with information about whether and what personal data is collected and processed in relation to you (“right of access”).

In the event that your Personal Data is incorrect, you have the right:

  • To request the rectification of your personal data to the extent that it is inaccurate and/or incomplete (“right to rectification”).
  • To request their erasure (“right to erasure” / “right to be forgotten”). Learning Seaman will erase without undue delay your personal data under the terms and conditions of applicable law. Learning Seaman may only delete the data if there is no legal obligation or if it has no other legal right to retain it. Of course, if the data of a visitor/user of the website is deleted, then Learning Seaman is not able to continue to provide its services to that user when they require the use of that data.
  • To request the restriction of the processing of your personal data under the terms and conditions of applicable law and be informed before the restriction of processing is lifted (“right to restriction of processing”).
  • To communicate any rectification or erasure or restriction of processing of your personal data to each recipient to whom the data in question have been disclosed, unless this proves impossible or involves a disproportionate effort; and to be informed about those recipients.
  • To receive your personal data in a structured, commonly used and machine-readable format, i.e. in electronic form, as well as the right to transmit it to another controller (‘ right to data portability ‘).
  • To object at any time to the processing of your personal data on grounds relating to your particular situation (“right to object”).
  • Not to be subject to a decision based solely on an automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
  • To withdraw your consent to your personal data being used in the future, in whole or in part. Withdrawal of your consent does not affect the lawfulness of the processing based on the consent prior to its withdrawal.

Finally, in accordance with the applicable data protection legislation, you have the right to lodge a complaint with the Hellenic Data Protection Authority at the following details:

Hellenic Data Protection Authority

1-3 Kifisias Ave., ZIP Code 115 23, Athens

Tel.: (+30) 210 6475600

www.dpa.gr   

Please communicate such requests or other questions and comments regarding this Policy or Learning Seaman’s privacy practices via email to the following email address: info@learningseaman.com

Learning Seaman is committed to protecting your personal data. If you have questions or comments about Learning Seaman’s handling of your personal data, please contact us at the email address and details listed above. You may also use this email address to communicate any concerns you may have about compliance with this Policy.

If you exercise any of the rights set out above, Learning Seaman will process your request and provide you with information about actions taken in response to your request without delay and in any event within one month of receipt of the request.

 

Modifications to this Policy

We reserve the right to update this Policy at any time without prior notice from time to time by posting a new version on the website. We will process the data in accordance with the Policy in force at the time you provided your consent to the processing of your personal data in accordance with this Policy. When a significant modification to this Policy takes place, we will notify you appropriately, e.g. via a clear notification (banner) on the website. You should check this page regularly to ensure that you are satisfied with any modifications to this Policy and read carefully any relevant notice you receive. By continuing to use the website you consent to the updated Policy. Use the “Last Updated” date on this Policy to find out when it was last modified.

 

 

PRIVACY POLICY

 

This Privacy Policy (hereinafter “Policy”) aims to inform you about the information collected from you when you visit and use this website, how it may be used, how you can control the use and disclosure of the information related to you and the measures taken to protect this information. This Policy forms an integral part of the General Terms of Use, which are incorporated by reference (https://www.learningseaman.com/privacy-policy).

This website belongs to the company under the name “LEARNING PATH SA” (hereinafter “Learning Seaman”), which has its registered seat at Athens, Greece, VAT 802286517 and provides lifelong e-learning services dedicated to the wellbeing of seafarers. Learning Seaman, acting as the controller of your personal data, informs the person to whom the personal data relates who visits/uses the website/platform https://www.learningseaman.com/ (hereinafter “Website”) that the processing of personal data is governed by the applicable national and EU legislation applicable to the collection, use and disclosure of your personal data by us, including Regulation (EU) 2016/679 of the European Parliament and of the Council, and Law 4624/2019, as well as respective decisions, guidelines and regulatory acts of the Hellenic Data Protection Authority.

 

Information about this Policy

Unless otherwise defined in this Policy, the terms used in this Policy have the same meaning as in the General Terms of Use [http://www.learningseaman.com/privacy-policy/].

By accepting the Privacy Policy upon registration or by visiting the Website and/or using the Services, you expressly consent to the collection, use and disclosure of your Personal Data (as defined below) in accordance with this Policy.

In the future, the Website may provide additional uses and increased functionality. If this involves any change in the way we collect and process your Personal Data, further details and additional terms will be provided to you in this Policy. Unless otherwise stated, any new use/service of the Website introduced will be subject to this Policy.

Where the use of any service of the Website is governed by a more specific privacy policy, such specific policy will apply jointly with this Policy. In the event of a conflict, the more specific privacy policy of each service shall prevail.

The purpose of this Policy is:

  1. To ensure that you know what personal data we collect about you, the reasons why we collect and process it, and to whom we disclose it.
  2. To make clear how we use the personal data that you have shared with us.
  3. To explain your rights and choices in relation to your personal data collected and processed when you visit and use the website.

By accepting this Policy by visiting and using the Website, you expressly consent to the collection, use and processing of your Personal Data (as defined below) in accordance with this Policy.

 

Definitions

PERSONAL DATA” means any information relating to an identified or identifiable natural person (hereinafter the “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier (such as IP address, e-mail address, etc. ) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

APPLICABLE DATA PROTECTION LEGISLATION”: The General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council adopted on 27 April 2016 and implemented as of 25 May 2018, and the EU and national legislation on the protection of personal data and privacy in the field of electronic communications, currently in force, as well as the relevant decisions, guidelines and regulatory acts of the Hellenic Data Protection Authority.

SPECIAL CATEGORIES OF PERSONAL DATA/SENSITIVE PERSONAL DATA”: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life of or sexual orientation.

 

How personal data are collected

Certain personal data are provided directly by users of the website, for example, when a user registers for a service on the website, and certain data are recorded automatically when visitors and users navigate the website.

 

Personal data we collect and process

Learning Seaman ensures the fair and lawful collection and processing of personal data. The personal data collected are those strictly necessary for the implementation of the action requested by the Data Subject.

The Data Subject ensures that the personal data provided is correct and accurate and undertakes to notify Learning Seaman of any change or modification to it. Any loss or damage caused to Learning Seaman or any third party through the communication of incorrect, inaccurate or incomplete information on the registration form is the sole responsibility of the Data Subject.

Specifically, we collect the following personal data:

(a) Visitors/Users of the Website: 

Data that we collect and process when you visit and navigate our website are your IP address, the date and time of your visit, the exact page you visited, the webpage from which you reached our website. We process these data for the purposes of improving the services provided to you.

We collect and process data about your use of our website and services (“usage data”) for the purposes of analysing the use of the website and monitoring and improving our website and services. Usage data may include the IP address, the geographic location, the browser type and version, the operating system, the referral source, the length of visit, the page views and the website navigation paths, as well as information regarding the timing, frequency and mode of use of our services and website on your part.

Learning Seaman collects and processes data solely for the purposes of the legitimate and proper operation of the Website and to provide visitors/users of this Website with the best possible user experience.

(b) Registered Users of the Platform: During the registration of users to use the Learning Seaman Platform Services, we process the following data of registered users of our services:

Specifically, for the registration of the user to the Learning Seaman e-learning platform services, we collect and process the following data: first name, last name, email address, nationality, rank.

Learning Seaman collects and processes the aforementioned data in order to provide the user with the services requested thereby and in particular the attendance of distance learning courses.

During the use and browsing of registered users on the platform, we also collect data recorded under (a) above, as well as further usage data, such as IP, anonymous information about the user’s device and browser, and platform usage data such as time of entry/exit, pages visited, time spent on a specific page-section. 

Furthermore, and given that (i) our services are addressed to crew members of vessels and (ii) the possibility of access and use of our services by the aforementioned persons takes place after registration of the Vessel/Employer on our platform and after payment by the Employer of the relevant subscription fee, it is possible that prior to your registration we may request and receive from the Employer the following personal data of yours:

first name, last name, email address, nationality, rank.

These data are transmitted to us with your explicit consent which you have given to the Employer. The purpose of collection and processing of this data by us is as follows:

(a) to enable us to identify Registered Users with the crew members of the vessel to whom the licence to use our services applies and to exclude the possibility of unauthorised users using our services.

(b) to enable us to carry out introductory communication – invitation to use our services to persons who (following registration of the Vessel, by the Employer, on our Platform) acquire the right to register and use our service.

In accordance with the specific provisions of Article 8 par. 1 (a) of the General Data Protection Regulation (EU) 2016/679 in conjunction with Article 21 of Law 4624/2019, minors under the age of fifteen (15) years old are prohibited from disclosing their personal data to us through the Website, without the consent of the persons having parental care and custody of the minor. Learning Seaman makes reasonable efforts to verify in such cases that consent is provided or approved by the person having parental care and custody for the child, taking into account available technology.

 

Purposes of processing/grounds of lawfulness

The personal data of the Visitors/Users of the website and Registered Users of the Learning Seaman platform are limited to the information required to serve the purposes specified above.

Learning Seaman guarantees that it will not transfer, disclose, make available, distribute, lease, etc. your personal data to third parties, unless we have your permission or are required by law to do so. However, Learning Seaman reserves the right to disclose information relating to the Data Subject if the law introduces a corresponding obligation to do so or if such disclosure is required by a court judgment, prosecutor’s order or order or decision of another person or administrative body with statutory authority to compel disclosure of such information.

Specifically, Learning Seaman uses the personal data it collects solely for the following purposes and on the following legitimate grounds:

(a) for the conduct of its business activities and the provision (including improvement) and services it offers and for the performance of the contract between you,

(b) to send communications, including but not limited to confirmations & reminders of participation in platform’s online courses, service announcements and management messages, including promotional material (marketing, offers etc.) and newsletters via email with your express consent,

(c) for the improvement of the services provided,

(d) for compliance with its legal obligations.

(e) for its legal protection and for purposes related to its legal interests.

 

Potential Recipients of the Data

Recipients of your data may be the following:

– Third parties who provide technical services (e.g. Cloud Service Providers), communications services (e.g. email service providers), accounting services (e.g. external accountants) or legal services (e.g. external legal advisors) to Learning Seaman, and who act as processors under written contracts that meet the terms of the applicable data protection legislation.

– Public Authorities where it is necessary for us to comply with a legal obligation, and/or in the event of a judicial investigation or other proceedings by a Public or Judicial Authority to which we have a duty to comply and provide information.

Furthermore, Learning Seaman may disclose to the Employer of registered users (ship owner or ship manager), upon request, fully anonymised statistical data relating to participants and participation in the online courses on our platform. The data communicated to the Employer of the registered users is anonymous and does not contain any personal data of the registered users.

Learning Seaman may also contact you to confirm, remind, cancel or postpone your participation in our platform’s online courses, to communicate service announcements and management messages between you and Learning Seaman, for communications in the context of our platform course ratings and to receive certificates of completion of our platform’s courses. By providing your contact information and agreeing to this Policy, you consent to Learning Seaman communicating with you or third parties at the email address provided by you. If you wish to opt out of such communications, please contact customer service at info@learningseaman.com to request to opt out of any email communications and your reasonable requests will be accommodated.

 

Data security

For us at Learning Seaman, protecting the Personal Data of Visitors/Users of our website and Registered Users of our platform services and respecting privacy of individuals online is a self-evident commitment. Learning Seaman takes all appropriate technical and organizational measures necessary to ensure the security of our users’ and customers’ data and to protect it from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access and any other form of unlawful processing.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we collect about you.

 

Time period for processing Personal Data

The storage and processing of the data of Visitors/Users of our website and Registered Users of our platform services is only done for as long as necessary to meet the purposes of the processing (as defined above) or until the user objects to the use of the Personal Data by Learning Seaman or (where the legal basis for processing is consent) until the user withdraws consent. Where required by law or where it is necessary for Learning Seaman’s legal claim or defence against legal claims to retain the Personal Data for a longer period of time, Learning Seaman will retain the Personal Data for a longer period of time.

 

Transfer to third countries

We use a server and data centre located in Europe and therefore we have to comply with the provisions of applicable data protection legislation. In the event of any transfer of your data to a processor who may be based outside the EEA, we ensure that such processor complies with the GDPR by applying and concluding, among other measures, the standard contractual clauses for international data transfers issued by the European Commission.

Finally, the website may display advertisements from third party websites and contain links (links, hyperlinks, banners) which refer to third party websites. Any interconnection of our website and platform with any other third-party website does not imply that Learning Seaman assumes any responsibility for the policy followed on that website regarding the protection and management of personal data. When you access those websites, this Policy does not apply, and we recommend that you read the respective privacy policies in order to be aware of the collection and processing of your personal data by the aforementioned websites.

 

Cookies and Similar Technologies

We will ask you to consent to the use of cookies in accordance with the terms of this Policy on your first visit to our website.

What are cookies?

Cookies are small text files that a website stores on your computer, tablet or mobile device when you visit that website; more specifically they are files sent from a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies help analyse web traffic or inform us when you visit a particular website. They also allow us to, among others, store your preferences and settings, allow you to connect to our services, help fight fraud, and analyse the performance of our website and online services. We use cookies to identify you when you visit and as you browse our website and to identify which pages are used, helping us to analyse data about web traffic and to improve our website.

Cookies are only stored on your device if you give your consent. It is at your discretion to control and/or refuse to accept cookies. You have the right to withdraw your consent to the use of these cookies at any time for all cookies except for those necessary for the operation of the website. When you visit our website, you can choose via the pop up window whether you accept or reject the cookies we use. If you do not accept cookies, the performance and functionality of the website may be affected.

We use cookies on our website to manage login sessions, to provide personalised web pages to reflect your special needs and interests. In this way, the website remembers your actions and preferences for a period of time, so you do not have to enter these preferences each time you visit the website or browse its pages. Overall, cookies help us to provide you with a better experience of our website by allowing us to keep track of which pages you find useful and which you don’t.

In any case, we cannot identify your personal identity from cookies. Cookies are stored exclusively on your own device (PC, tablet, mobile phone) and under no circumstances do they give us access to your device or any information about you, other than the data you choose to share with us.

We use Google Analytics (1600 Amphitheater Parkway, Mountain View, CA 94043, USA “Google”) to analyse the use of our website. Google Analytics collects information about the use of the website through cookies. The information collected about our website is used to generate reports on the use of our website. The collection and processing of data by Google Analytics is available here: www.google.com/policies/privacy/partners/.

 

The cookies we use

  1. Strictly necessary cookies

Strictly necessary cookies help make a website usable, by enabling basic functions such as navigation and access to secure areas of the website. The website cannot function properly without these cookies. These cookies do not recognise your personal identity. Without them we cannot provide effective operation of our Website so they are considered strictly necessary.

  1. Performance Cookies

We use these types of cookies to monitor the performance of our Website and how users can use them. These cookies give us the information that helps us to improve and maximise the features of our Website and provide better services to users. They also help us to identify areas of our website that are not working properly or that need maintenance.

  1. Functionality cookies

Functionality cookies help to improve your experience by, among others, remembering preferences, choices you make while visiting the website or previous actions. They allow our website to remember information that changes the way the website behaves or looks, such as your preferred language or the region you are in.

  1. Statistics Cookies

Statistics Cookies help website owners understand how visitors interact with pages by collecting and reporting information anonymously.

  1. Marketing Cookies

Marketing Cookies are used to share certain information with third-party advertisers so that we know how you have approached our website. These cookies record your visit to our website, the parts of our website you have visited and are interested in, and the links you followed to identify you as a previous visitor and to track your activity on our website and other websites you visit. These cookies are used to provide content that best suits you and your interests. This information is used to show you advertisements that we think may be of interest to you, to customize how we communicate with you, or to customize the content of the communications we send you.

  1. Unclassified Cookies

Unclassified cookies are cookies that are in the process of being classified, together with the providers of individual cookies.

 

How to control cookies

Cookies are stored on your computer after you have been informed and accepted their collection. It is at your discretion to control and/or not accept cookies. You have the right to withdraw your consent to the use of these cookies at any time for all cookies except for those necessary for the operation of the website. However, this may result in difficulties in navigating the website and some website functions may not be available. In addition, not accepting a cookie or a category of cookies will not delete existing cookies from the browser – this will have to be done separately, within the browser. You can find further information on how to delete cookies or adjust the cookie settings for the browser you are using from the list below:

  • Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
  • Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
  • Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
  • Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471
  • A useful guide to deleting and managing cookies in browsers: http://www.aboutcookies.org

Web browsers are usually set by default to accept cookies. Today more and more browsers, although not all of them, have a pop-up message for user consent installed. In any case, if you want to modify the function of your web browser to warn you about the use of cookies or to prevent you from accepting their use, you can refer to the settings of your browser.

Useful links about cookies:

  • Management of cookies of advertising agencies for the US: http://www.aboutads.info/choices
  • Management of cookies of advertising agencies for the EU: http://www.youronlinechoices.com/uk/your-ad-choices

This website may contain links or references to other websites. You should be aware that we do not control the cookies and/or tracking technologies of other websites and this Cookie Policy does not apply to those websites.

 

How we access and control your Personal Data

Upon request, you will be provided with information about whether and what personal data is collected and processed in relation to you (“right of access”).

In the event that your Personal Data is incorrect, you have the right:

  • To request the rectification of your personal data to the extent that it is inaccurate and/or incomplete (“right to rectification”).
  • To request their erasure (“right to erasure” / “right to be forgotten”). Learning Seaman will erase without undue delay your personal data under the terms and conditions of applicable law. Learning Seaman may only delete the data if there is no legal obligation or if it has no other legal right to retain it. Of course, if the data of a visitor/user of the website is deleted, then Learning Seaman is not able to continue to provide its services to that user when they require the use of that data.
  • To request the restriction of the processing of your personal data under the terms and conditions of applicable law and be informed before the restriction of processing is lifted (“right to restriction of processing”).
  • To communicate any rectification or erasure or restriction of processing of your personal data to each recipient to whom the data in question have been disclosed, unless this proves impossible or involves a disproportionate effort; and to be informed about those recipients.
  • To receive your personal data in a structured, commonly used and machine-readable format, i.e. in electronic form, as well as the right to transmit it to another controller (‘ right to data portability ‘).
  • To object at any time to the processing of your personal data on grounds relating to your particular situation (“right to object”).
  • Not to be subject to a decision based solely on an automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
  • To withdraw your consent to your personal data being used in the future, in whole or in part. Withdrawal of your consent does not affect the lawfulness of the processing based on the consent prior to its withdrawal.

Finally, in accordance with the applicable data protection legislation, you have the right to lodge a complaint with the Hellenic Data Protection Authority at the following details:

Hellenic Data Protection Authority

1-3 Kifisias Ave., ZIP Code 115 23, Athens

Tel.: (+30) 210 6475600

www.dpa.gr   

Please communicate such requests or other questions and comments regarding this Policy or Learning Seaman’s privacy practices via email to the following email address: info@learningseaman.com

Learning Seaman is committed to protecting your personal data. If you have questions or comments about Learning Seaman’s handling of your personal data, please contact us at the email address and details listed above. You may also use this email address to communicate any concerns you may have about compliance with this Policy.

If you exercise any of the rights set out above, Learning Seaman will process your request and provide you with information about actions taken in response to your request without delay and in any event within one month of receipt of the request.

 

Modifications to this Policy

We reserve the right to update this Policy at any time without prior notice from time to time by posting a new version on the website. We will process the data in accordance with the Policy in force at the time you provided your consent to the processing of your personal data in accordance with this Policy. When a significant modification to this Policy takes place, we will notify you appropriately, e.g. via a clear notification (banner) on the website. You should check this page regularly to ensure that you are satisfied with any modifications to this Policy and read carefully any relevant notice you receive. By continuing to use the website you consent to the updated Policy. Use the “Last Updated” date on this Policy to find out when it was last modified.