Privacy statement

1. Introduction

This privacy statement (“Statement”) applies to Mano Maritime Ltd. (the "Company" "we," or "us") which operates this website and markets its products and services including cruise plans and vacations (the “Website” and “Services”).  

The security and privacy of your information are very important to us. Whether you purchase one of our Services (“Customer”) or just visiting the Website, we want you to trust us with managing and protecting the information that you provide us with. We have prepared this statement to explain more about who we are and how we collect and manage your information.

This Website is a general audience website which is neither designed nor intended for the use of, or collection of personal information from, children and/or minors. 

This Statement forms part of our General Terms. By using any of our Services or the Website and/or by agreeing to this Statement, e.g., in the context of purchasing any of our Services, using our website or by any other means, you understand and acknowledge that we will collect and use Personal Data as described in this Statement.

1. Who are we and how you can contact Us?

Mano Maritime Ltd.

2 Pal-Yam Avenue,

PO Box 1400 Haifa,

33031 Israel

Phone: +972-4-8606677

Mail: manocruise@mano.co.il

The Data Protection Representative (DPR) under Article 27 to the GDPR

Questions, comments, requests and complaints regarding this Statement and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently.

1. Data Controller  under the GDPR

Under the European General Data Protection Regulation (”GDPR”), we are the Data Controller of our Customers’ and Website’s visitors Personal Data (to the extent such data is being collected). "Personal Data", or personal information, means any information about an individual from which that person can be identified. 

1. Collection of Personal Data

We collect Personal Data from you voluntarily when you provide such Personal Data to us, when you Purchase any of our Services or using the Website with which you voluntarily interact. 

You do not have to provide us with your information, but in some cases, if you do not, it may mean that you are unable to use our services.  For example, we may be unable to complete a requested order or purchase on our Website, unless you will provide us with a method of payment and shipping address. Similarly, we cannot allow provide you with any Customer’s service and cannot treat any inquiry unless you will provide us with the relevant information for contacting you and responding to your inquiry. 

When you use our Website or any of our Services we might collect and process the following information:

• Identity and Contact Data - including full name, title, gender, date of birth, phone number, email, address, and any other information provided by you upon your sole discretion. 

• Order Data – requested trip or cruise dates, number of people in your party, family members information, number of rooms, staying and food preferences, prices and rates, additional or personal requests, billing and payment information, etc.

• Usage Data - includes information about how you use the Website and Services, including a record of your use in some cases.

• CCTV Data – footage of our cruise ships premises, during your stay or visit.

• Technical Data - includes internet protocol (IP) address, the device you are using, browser type and version, screen resolution, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Customer inquiries data – data which is being collected when you contact our customer service with any inquiry or request. 

• Marketing and Communications Data - includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but does not reveal your identity. 

1. How is your Personal Data is being Collected?

We use different methods to collect data from and about you, including through:

• Direct interactions - You may give us your Identity, Contact, Order and other Personal Data by filling in forms or making a purchase through the Website (e.g. "Contact Us" or "Subscription", “Order Form”, “Mailing List”, etc.) or by corresponding with us by phone, email or otherwise. 

• Automated technologies or interactions - As you interact through our Website, we may automatically collect Personal Data through the use features and tools or Cookies (please refer to the description below, under "Cookies Usage").

• Third parties or publicly available sources – In our Website we may receive Personal Data about you from various third parties and public sources, e.g.: advertising and social networks, analytics providers, search information providers.

1. Cookies Usage

Like many other websites, the Website uses cookies to improve your experience while you navigate through the Website. We may use various types of Cookies:

Essential Cookies – which are necessary for the site to work properly (usually appears under our name/cookie tag);

Functional Cookies – designated to save your settings on the site - your language preference or other view preferences (also, under our name/cookie tag);

Session Cookies – used to support the functionality of the website – such Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser.

Targeting Cookies - these cookies are used to collect information from you to help us to improve our products and services as well as serve you with targeted advertisements that we believe will be relevant to you (e.g. Google’s Cookies). 

Social networks Cookies - Social Plug-In Cookies (e.g. Facebook, Twitter, LinkedIn Cookies, or pixels etc.) enabling the sharing of your usage information with your social network’s accounts.

Analytics Cookies - give us aggregated information which enables us to improve the way our website works, e.g. Google analytics. 

Third party services used by us – for example, an external service supporting our career and recruiting options through the website (e.g. Com     eet or Workday), or an external service which allows us to screen short videos in our website (e.g. YouTube or Vimeo).

Please note that the data collected by use of Cookies may be linked to and combined with any other data, including Personal Data.

Managing cookies and opting out: aside from the Essential Cookies described above, you can always configure your browser or use the “cookies bar” installed in the Website to reject all cookies or notify you when a cookie is set, but sometimes in that case, certain services, features, and functionality in our website may not be available to you. 

1. The purposes of the processing

We might use your data in order to: enable you to use our Services, complete and deliver an order made by you, use the Website in the most effective way, including the personalization of your experience by presenting content tailored to your interests; Provide you as our Customer with Services which you have purchased from us; meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory body; assess or evaluate the effectiveness of our services, as well as any technical and organizational measures designated for the protection of your Personal Data; Improve and secure our services and systems; protect our rights and legitimate interests, as well as defend against any lawsuit, legal claim or complaint; to conduct any other activities that are required to provide our services.

1. The Legal Basis for the processing of your Personal Data

We will only process and use your Personal Data when the law allows us to, i.e. when we have a Lawful Basis for such usage. Such lawful and legal basis can be any of the following:

• Processing actions which are allowed to us as part of a contract we have between us and you, as our Customer – any action required for the fulfillment of an order or completion of any purchase, or contacting you per "Contact" form filled by you;

• Our use of your information is necessary to meet responsibilities we have to our regulators, tax officials, Customs and Border controls, law enforcement, or otherwise meet our legal responsibilities;

• Our use of your information is in our legitimate interest as a commercial organization. For example, to operate and improve our services and to keep people informed about our products and services. In these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights, making sure our legitimate interest is not overridden by your interests or fundamental rights and freedoms;

In general, and as detailed above, we do not rely on consent as a legal basis for processing your Personal Data.  Yet, in any case in which you have provided your consent to our processing of your information, you can withdraw this consent at any time by contacting us through the contact details provided above.

1. Processing of anonymized or statistical data

In some circumstances we may anonymize the Personal Data which is being collected and managed using our Services and Website, so that it can no longer be associated with any identified person. Such anonymized or aggregated data, might be used by us as part of our Services, including for research or statistical purposes, without further notice to you.

1. Data Recipients

We may disclose your Personal Data to third parties in a variety of circumstances in the ordinary course of operating our business, such as: 

• Disclosure of Personal Data to persons authorized to process personal data, in our organization, or third-party service providers, qualified as data processors or sub-processors, providing us with services supporting our services and ordinary course of business, e.g. system, storage and computing services, as well as marketing efforts, in accordance with applicable law; 

• Indirectly, and in connection with the use of Cookies through a third-party service as explained above;

• When we have a legal obligation to do so, or when where can do so under our legitimate interests.

In any such communication we will take steps to make sure such transfer is carefully managed to protect your privacy rights:

• transfers within our group and affiliates, will be subject to an agreement / policies and procedures made to ensure that your data receives an adequate and consistent level of protection as required by applicable law;

• transfers to any subcontractor or processor will be subject to contractual terms ensuring the security and protection of any Personal Data under any such sub-processor, in accordance with applicable law provisions;

any requests for information we receive from law enforcement or regulators will be carefully validated before the disclosure of any Personal Data.

1. Data Processing Location

Any transfer of data which originates in the European Union ("EU") to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR. Such transfer can be made to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights, e.g. signing a Standard Contractual Clauses which were published and authorized by the relevant EU authorities.

It is important to note that we are headquartered in Israel, a country which is considered by the European Data Protection Board to be offering adequate level of Personal Data protection regulation.   

1. Links to other sites

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

1. How we secure your information

We are committed to protecting the security of your Personal Data. We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access and use. However, the collection, transmission and storage of information can never be guaranteed to be completely secure. Yet, we take steps to ensure that appropriate security safeguards are in place to protect your information, and we will continue to revise our policies and implement additional security features.

1. Retention Periods for Storage of Personal data

We will only store your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. As part of that we might store and keep record of data which might be required for us for our legal protection. We have defined data retention periods for any data item in our systems, ensuring minimization of retention periods.

As explained before, in some circumstances we may anonymize your Personal Data, in which case we may save and use this anonymized information indefinitely.

1. Data Subjects' rights under Privacy Protection laws 

Under EU law, EU residents and individuals, have certain rights to apply to us to provide information or make amendments to how we process data relating them. Those rights might include:

•  right to access your Personal Data - you can ask us to confirm whether or not we have and use your Personal Data, and if so, you can ask for a copy of your data;

• right to correct your Personal Data - you can ask us to correct any of your Personal Data which is incorrect, after verifying the accuracy of the data first;

• right to erase your Personal Data - you can ask us to erase your Personal Data if you think we no longer need to use it for the purpose we collected it from you. you can also ask for such erasure in any case in which the process of your data was based on your consent, or where we have used it unlawfully or where we are subjsect to a legal obligation to erase your Personal Data. any request for such erasure will be subject to our obligations under the law (e.g. our obligation to keep some records for tax or customs purposes);

• right to restrict our use in your Personal Data - you can ask us to restrict our use of your Personal Data in certain circumstances;

• right to object to how we use your Personal Data - you can object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information;

• you can always require us to refrain from using your data for direct marketing purposes;

• you can ask us to transfer your information to another organization and/or provide you with a copy of your Personal Data (Portability Right);

• You have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. however, we will appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact us in the first instance. 

We may not always be able to do what you have asked. In addition, not all those rights apply in every jurisdiction. However, we encourage you to contact us with any such request, and we will be happy to assist you.

1. Changes to this Privacy Statement

We reserve the right to change this statement from time to time at our sole discretion. If we make any changes, we will post those changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our site or our services or otherwise provide data after we post any such changes, you accept and agree to this statement as modified.

Effective as for September 2020