MOORIO PRIVACY POLICY

I.   GENERAL

One of our main goals is to make trade at ports as transparent as possible. It is important for us that we are transparent about the data we collect on Moorio users and what we do with such data. 

Moorio users and website visitors use our platform to compare and book services for their vessels at ports or to provide those services. This Privacy Policy applies to any Visitor or User of Moorio Services.

The transactions using our platform involve sharing information between vessel operators (Customers), marine service providers (Suppliers) and ship agents (Agents) regarding services, business information and business needs.

This Privacy Policy, including Cookie Policy set out below in Section VII, applies to your use of our Services as defined below.

This Privacy Policy applies to moorio.com, its subdomains, Moorio apps and other Moorio-related sites, apps, communications and services by Moorio (Services), including off-site Services, such as our support staff, but excluding services that state that they are offered under a different privacy policy.

Moorio Ltd Pte, a Singapore company (Moorio) will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.

As a Moorio Visitor or User, the collection, use and sharing of your personal business data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.

This Privacy Policy applies to your use of our Services on or after the date in the header.

We can modify this Privacy Policy and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may choose to close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

II.   DATA COLLECTED

a.   Data you provide to us

Registration data

To create an account you need to provide data including, but not limited to your company name, email address, mobile number, a password, data of SNS Account, country, company or vessel information, accounting data (including data related to payment methods) as well as services provided or ports serviced if you are a Supplier. Upon booking a service, you also provide a payment method. We will collect data about your preferences such as language, time zone and currency.

Search data

You ask for quotes, book services and upload relevant commercial details to process the booking.

When you ask for a quote, we retain the parameters that you used for that. We also retain information about services booked, on-site and emailed messages with both our team and the selected Supplier, Customer or Agent, as well as payment information. For services to be provided, you might also need to upload commercial documents, like your terms of sale, quality certificates, delivery notes, proof of address, commercial invoice, power of attorney, hazardous material statements and other booking related documentation. These documents in turn may contain other personal or business data. We use this information to help streamline your bookings and they are only accessible to relevant Moorio employees and the relevant Supplier, Customer or Agent.

Posting and uploading data

We collect data from you when you provide, post or upload it to our platform, or when you communicate with our staff or your Supplier, Customer or Agent using Moorio Messenger. You almost never have to post or upload personal data, as Moorio is a commercial platform and in general we recommend using business email address, phone number, address where possible on Moorio.

Login data

We log your visits and use of our Services. We use log-ins, cookies, device information and internet protocol (IP) addresses to identify you and log your use.

Cookies data

We use cookies and similar technologies, such as pixels, ad tags and device identifiers, to recognize you and/or your devices. You can control cookies’ settings through your browser settings and other tools. However, some cookies are necessary to use Moorio Services through our platform and disabling them will impede your use of Moorio Services. Our website and our services are intended for business users.

Device and location data

When you visit our website or use Moorio Services, we receive the URL of the site you came from. Our third party technologies also may get information about your IP address, proxy server, operating system, web browser, device identifier and features, and/or ISP. For specific, location-related tools, we will ask your consent before we use GPS or other tools to identify your precise location.

We may also ask you to consent to receive push notifications to your device.

Communication data

If you communicate using Moorio platform, we learn about that. We collect information about your messages when you send, receive, or engage with messages in connection with our Services. We may also use automatic scanning technology on messages.

We may receive data about your company when you use the services of Moorio. If you provided any of our partners with relevant personal data, they may share it with us if we or they have legal grounds to do so. We may also collect and share your company’s credit rating within our platform.

III.   DATA USED

We use the data that we have about your business account to provide and personalize our services, including with the help of automated systems and inferences we make, our services so that they can be more relevant and useful to your company. The following are the purposes for data processing carried out by Moorio:

a.   Services

Moorio is used to compare and book marine goods and services for your vessel from trusted partner network around the world and find customers for those goods and services if you are a Supplier. In order to provide you with Moorio Services we shall process personal data of the representatives of our Customers, Suppliers and Agents.

For this purpose we may process the following data of the representatives of our Customers, Suppliers and Agents: registration data, search data, posting and uploading data, login data and communication data. We process this data on the basis of our legitimate interest to conclude an agreement with the company you represent and properly perform it. 

b.   Communications

Moorio is here to help your company communicate with our support staff and between Suppliers, Customers and Agents both through Moorio messenger, as well as offline channels.

We will contact your business through email, phone, or messages on our websites, and other ways through our Services, including text messages and push notifications. We will also use these channels to let you know about the availability of our Services, security, and other service-related issues. We will also send messages about how to use Moorio, various useful reminders, and promotional messages from us and partners that we like. You may change your communication preferences at any time in your profile settings . There are some notifications we can’t let you opt out of, like service messages from us, including security and legal notices.

For this purpose we may process the following data of the representatives of our Customers, Suppliers and Agents: registration data, search data, posting and uploading data, and communication data. We process this data on the basis of our legitimate interest to facilitate communications between us and provide you with important information about Moorio Services, or upon your consent (e.g. for marketing communications). 

c.   Marketing

We use data and content about how businesses use Moorio to promote our Services. For example, we may use the logos or names of companies that have used Moorio. We will not process personal data for this purpose.

d.   Research

Ordering goods and services for vessels sometimes lack transparency. Moorio platform is a tool that empowers business users with data they need, but it involves conducting research on platform engagement, booking patterns and more, to help disseminate marine knowledge back to our users.

For this purpose we may process the following data of the representatives of our Customers, Suppliers and Agents: registration data, search data, posting and uploading data, device and location data, cookies data, and communication data. We process this data on the basis of our legitimate interest to conduct such research and provide you with its results. 

e.   Customer Support

We use the data (which can include your communications) to investigate, respond to and resolve complaints and system issues (such as bugs). 

For this purpose we may process all personal data listed in Section II as necessary. We process this data on the basis of our legitimate interest to investigate, respond to and resolve complaints and system issues.

f.   Aggregated Insights

We use your data to produce and share aggregated insights that do not identify you. For example, we may use your data to generate statistics about the businesses using Moorio or for creating aggregate market insights. We always anonymize such insights.

g.   Security and Investigations

We use your data (including your communications) if it’s necessary in our view for security purposes or to investigate possible fraud or other violations of our Terms of Use and/or this Privacy Policy and/or attempts to harm our Users or Visitors.

For this purpose we may process all personal data listed in Section II as necessary. We process this data on the basis of our legitimate interest to investigate possible fraud or other violations of our Terms of Use and/or this Privacy Policy and/or attempts to harm our Users or Visitors.

IV.   INFORMATION SHARED

We may transfer your personal data to the following recipients:

a.   Our Platform

Any booking related data is shared between Moorio employees as well as between contracting parties (i.e. Suppliers, Customers and Agents) where necessary for Moorio Services.

Booking and payment documents are stored on Moorio, where they can be accessed by the relevant internal Moorio employees and all contracting parties. When these documents need to be conveyed to external parties, we will typically use digital communication platforms like email or our application.

b.   Service Providers

We may use third parties to help us provide our Services (e.g., maintenance, analysis, audit, legal, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. 

c.   Legal Disclosures

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Moorio, our users, personnel, or others. We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

d.   Change in Control or Sale

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us, or part of our business will have the right to continue to use your data.

e.   Moorio affiliates

We may share your personal data with Moorio affiliates, i.e. subsidiaries, joint venture partners or parent companies (if needed for proper internal administration of the group (e.g. accountability)).

V.   YOUR CHOICES & OBLIGATIONS

a.   Data Retention

We retain your personal data while your account is in existence or as needed to provide you Services. We may retain your personal data for longer if it is reasonably necessary to finalize open orders, comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from further messages from us.

The abovementioned rules on data retention includes data you provided to us and data generated or inferred from your use of our platform. Even if you only use our Services when asking for quotes every once in a while, we will retain your information and keep your profile open as described above. In some cases, we may choose to retain certain information in a depersonalized or aggregated form.

b.   Rights to Access and Control Your Personal Data

You have the following rights with respect to your personal data:

• Right of access: You have the right to obtain from Moorio a confirmation as to whether your personal data is being processed and to access the information about how Moorio processes your personal data, as well as to receive the copy of your personal data.
• Right to rectification: You have the right to obtain from Moorio the rectification of your inaccurate personal data. You also have the right to have incomplete personal data completed, also by providing a supplementary statement. Please note that Moorio may have to verify such additional or amended information.
• Right to erasure. You have the right to request us to erase or delete your personal data, if there is no reasonable reason why we should continue to process it, if personal data is no longer necessary for the purposes for which it was collected or processed, or due to other circumstances established in applicable laws. 
• Right to restriction of processing. You have the right to require us to restrict processing of your personal data under certain circumstances established in applicable laws.
• Right to data portability. You have the right to receive your personal data, which you have provided to Moorio, in a structured, commonly used, and machine-readable format and have the right to transfer this data to another controller under certain circumstances established in applicable laws.
• Right to object. You have the right to object at any time to processing of your personal data for the purposes of the legitimate interests of Moorio, including profiling based on those provisions. Please note that Moorio will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
• Right to withdraw the consent. If the processing of your personal data is based on your consent, you have the right to withdraw this consent at any time. Your withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with a supervisory authority regarding processing of your personal data. Moorio would recommend and be grateful if you contact us before lodging a complaint to the relevant supervisory authority and express your concerns or questions to us. We will do our best to assist you with all your queries.

c.   Account Closure

If you choose to close your Moorio account, your personal data will be completely removed within 30 days. Until then, you will be able to sign in, but only with limited ability to use our Services. Your company profile, however, will remain visible in historical transactions. The last user of the company will be required to finish or cancel all unfinished orders before initiating the account closure. 

Information you have shared with others will remain visible after you closed your account or deleted the information from your own profile, and we may not control data that other users copied out of our platform.

VI.   IMPORTANT INFORMATION

a.   Security

We implement security safeguards designed to protect your data, such as enforcing the use of HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

b.   Cross-Border Data Transfers

We store and use your data outside your country.

Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country. While transferring your personal data to other countries, we will ensure compliance with legal acts applicable to Moorio, including additional safeguards where necessary. You may receive more information by contacting Moorio via contact details indicated below. 

c.   Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You choose to use our Services and have choices about our use of your data. We will only collect and process personal data about you where we have lawful bases. 
 

VII.   MOORIO COOKIE POLICY

This section describes use of cookies and other technologies.

A cookie is a small text file that is placed on your computer or other smart device when you visit a website or use an app. The cookie helps website providers recognize your device the next time you visit their website. There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, which indicate that a page or email has been viewed), web bugs (similar to pixel tags), and web storage, which are used in desktop software or mobile devices.

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them). We use the following types of cookies for the purposes explained in this chart:

All cookies, except for strictly necessary cookies, will be processed on the basis of your consent. Strictly necessary cookies shall be processed based on our legitimate interest to ensure proper operation of our Site and Services. 

We also use mobile device identifiers and other technologies for the purposes articulated in this Privacy Policy, for example to recognize your device when you return to the Moorio app or otherwise use our platform. 

Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies. You may be able to manage other technologies in the same way that you manage cookies using your browser’s preferences. In addition, when you visit the Moorio website you will be informed that these cookies are in place and will be able to select your cookie preferences.

Please note that if you choose to block cookies with your browser or other tools, it may impair or prevent certain elements of Moorio from functioning.

Please note that due to technical capabilities of Moorio website, we may be unable to receive and process requests regarding our use of the cookies delivered by browser plugins and similar means. Therefore, we recommend you to follow our guidance provided above in order to manage your cookie preferences. 
 

VIII.   CONTACTING US

Should you have any questions regarding Moorio Privacy Policy, you can contact us at support@moorio.com.