Last Updated: January 29, 2025
In order to ensure transparency and give you more control over your Personal Data, this privacy policy (“Privacy Policy”) governs how we, My First Mate Ltd. (“My First Mate”, “we”, “our” or “us”) use, collect and store Personal Data that we collect or receive from or about you (“you”) in connection with our e-commerce Platform (as defined in our Terms and Condition: ).
When we use the term “Personal Data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual.
We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal data when you use the Platform, and the provision of it is solely based on your free will. However without receipt of Personal Data it may not be possible to provide you with our services, so please do not use our Platform if you do not wish to provide us with Personal Data.
Table of contents:
- What personal information we collect, why we collect it, and how it is used
- How we protect and retain your personal information
- How we share your personal information
- Your privacy rights
- International transfers of personal information
- Marketing
- Minors
- Contact us
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement material changes in the way we use your Personal Data, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Platform or by other means and take any additional steps as required by applicable law.
1. WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
1.1. INFORMATION WE COLLECT
We can’t help you plan your sailing vacation without information, so when you use our Platform there are certain types Personal Data we ask for. In addition, we also receive information about you from others and collect information through technologies tools and third parties, all as detail below:
1.1.1.Contact details and General Information, such as full name, email address, shipping address, phone number, passport details, relevant licenses details, passport details, citizenship, date of birth, gender, dietary preferences and payment details. You will also need to provide us with this Personal Data for your crew members. Please note, you are responsible for ensuring that any individuals about whom you have provided Personal Data are aware and understand how we use their Data.
1.1.2.Reservations and Usage of the Services Data such as rental details, sailing dates, rental history and support contact requests.
1.1.3.Personal Data from Other Sources. My First Mate also may obtain Personal Data about you from other sources, including publicly or commercially available information, and through third-party data platforms on which you have been active, including partners, service providers and our affiliate. Personal Data we receive from these third-party may be used together with other Personal Data provided by you. Additionally, we collect information in the regrettable case that we receive a complaint about you from a Service Provider, for example in the case of misconduct.
1.1.4.Technologies Data. We use cookie, pixels, tracking technologies and similar identifiers ("Technologies") to automatically collect data through the Platform, which in certain cases could be considered Personal Data. We use Technologies that are small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Platform. For more information about our Technologies activities please read our Cookie Policy.
1.2. PURPOSES AND LEGAL BASIS
1.2.1.We use your Personal Data as detailed in sections 1.1.1 and 1.1.3 above to process and manage your Rental Order, which is necessary for us to provide you service, this includes: (1) allow you to create an account; (2) to provide you the Services and to process your requests, including to allow you to rent products through our Platform; (3) communicate with you about your use of the Services and for support purposes (including via e-mail, WhatsApp, website, etc); (4) fulfill any instruction and/or request made by you in the context of the Services (e.g., to allow you to rent) and to manage your orders; (5) send you push notifications and/or emails and notifications regarding your account or certain features of the Services, including, updates pertaining to your subscription, and related to the services we provide you with (e.g., rental confirmation, shipping status); (6) to ship the rental items to you; (7) to provide you the mechanisms, information and means to return the rental items, (8) to assist you with any inconvenience that you have with the rental items, in accordance with our terms of use; (9) to collect and receive your feedback of our Services and the rental items; (10) to personalize and customize your experience with our Services; (11) provide you support, customer service and to allow you to administer your account easily and manage your personal settings, including to respond to your questions, comments, and other requests for customer support, or information; (12) to send you marketing communication, provided you have given us your consent to do so (as detailed in section 6 below).
For the purpose above, we rely on the legal basis that processing of Personal Data is necessary for the performance of a contract, specifically to finalize and administer your Rent Order. If the required Personal Data is not provided, My First Mate cannot finalize the Rent Order, nor can we provide customer service.
1.2.2.We use the Personal Data collected through Technologies (as described in Section 1.4 above) in accordance with the purposes outlined in our Cookie Policy. The legal basis for using Personal Data collected through essential cookies is our legitimate interest and the performance of our contract with you, as without these tools, we would be unable to provide you with access to the Platform. The legal basis for processing Personal Data collected through non-essential cookies is your consent.
1.2.3.Please note that we also use all the Personal Data as detailed in sections 1.1 above to:
1.2.3.1. Improving our services. We will anonymize, aggregate and/or de-identify part or all of your Personal Data. This data may be used for both internal and external purposes, such as analyzing and improve My First Mate Services (including through the use of artificial intelligence) and for research purposes. We may also share this aggregated information and/or disclose it to third parties without restrictions.
1.2.3.2. Litigation management. For example to take action against any identified security breach, manage any dispute or litigation and seek advice from lawyers, auditors, and other professional advisers. Regarding EU legal basis, such processing is based on our legitimate interest in defending our rights and interests.
1.2.3.3. Comply with legal and regulatory obligations. For example to perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities; process your requests to exercise your rights; detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights. Regarding EU legal basis, such processing is based on legal and regulatory obligations to which we are subject.
In view of purposes under section 1.2.2, we rely on our (or third parties’) legitimate interest to provide and improve services and to prevent fraud and other illegal acts.
2. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION
2.1. Security. We implement and maintain industry-standard technical, organizational and security measures designed to protect your personal information. However, please note that we cannot guarantee that the personal information will not be compromised as a result of unauthorized penetration of our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information. If you have any questions about the security of your personal information, you can contact us at privacy@myfirstmate.pro.
2.2. Retention of your personal information. Your Personal Data will be stored until we proactively delete it from our records, or until you send a valid deletion request. Please note that in some circumstances we store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
3. HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your personal information as follows:
3.1. Service Providers and Subcontractors. We will share Personal Data to perform services on our behalf or complementary to our own, depending on each of their specific roles and purposes in facilitating and enhancing our Platform, including, without limitation: cloud service providers for hosting purposes; websites and web content creation platforms in order to help us manage our Services; e-commerce platform providers; email providers, marketing, CRM, other similar tool providers; artificial intelligence tools and features; analytic companies, in order to help us understand and analyze information we collect in accordance with this policy; third-party payment processors to facilitate secure transactions; shipping partners and vendors who will deliver the rented;
3.2. Governmental, Administrative or Judiciary Authorities. We will share Personal Data with the police and port police, tax authorities, health authorities and other governmental authorities, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of My First Mate, our Services, customers, employees, property, and the public. We may use or disclose the Personal Data we collect in order to ensure that our users are complying with all applicable aspects of our policies.
3.3. Affiliated companies. Your Personal Data will be shared with our affiliates for internal administrative purposes.
3.4. Private Entities. Such as insurance companies, marina operators, and private entities as part of fulfilling the Services you obtained from us.
3.5. Professional Advisors. We disclose Personal Data with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests; We use or disclose the Personal Data to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;
3.6. Corporate Transactions. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal information in connection with the foregoing events;
4. YOUR PRIVACY RIGHTS
4.1. General Provisions. Please note that you may have certain rights regarding the manner of collection, processing, and usage of your Personal Data pursuant to applicable laws. You may have all or some of the following rights depending on your jurisdiction, and, in most cases, you can exercise them free of charge. At any time, you may contact us at privacy@myfirstmate.pro and request to know what personal data we store about you. We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law).
4.2. When you ask us to exercise any of your rights under this Policy and the applicable laws, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data which is related to others that you are not authorized to receive, and to ask you questions to understand better the nature and scope of data that you request to access.
4.3. We may redact from the data we will make available to you any Personal Data related to others. In addition, we may delete your personal data without further notice if we are required to by Applicable Laws.
4.4. If you are based in the EU/EEA, you are entitled to request us to: (a) access your personal data in order to obtain clear, transparent and understandable Data on how we process your personal data and on your rights (as provided in this Policy), as well as a copy of your Personal Data; (b) rectify your personal data in case your Personal Data are obsolete, inaccurate or incomplete; (c) object the processing of your Personal Data when the processing is based on legitimate interest; (d) in certain circumstances under applicable laws, restrict the processing of some of your personal data during a limited period of time**; (e) withdraw your consent** when it has been obtained and processing is based on consent; (f) request data portability, meaning that you can request the transfer of the Personal Data provided by him or her to another data controller; (g) in certain circumstances you can request to delete your Personal Data; (h) lodge a complaint with your national data protection authority.
If you have a complaint about how we use your Personal Data, we would always prefer you to contact us first. However, you may also make a complaint to your local data protection authority in the EU/EEA. If you are unsure which data protection authority to contact, please contact us at privacy@myfirstmate.pro.
4.5. If you are based in Israel, you are entitled to request us to: review your personal data and/or update, amendment, and deletion of personal data which is incomplete or outdated.
5. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
5.1. General provisions. We may store or process your Personal Data in several jurisdictions other than the country of your jurisdiction. In some jurisdictions, the level of protection of your personal data may be lower than in the country of your jurisdiction.
5.2. EEA Transfers. When we transfer personal data from within the European Economic Area ("EEA") to countries or international organizations that are based outside the EEA, the transfer takes place on the basis of an adequacy decision by the European Commission, or in the absence of an adequacy decision, other legally permitted safeguards under the GDPR, such as standard contractual clauses.
5.3. Israeli Transfers. When we transfer Personal Data from the State of Israel to a third country outside Israel, the transfer takes place on the basis of: (i) a country declared as offering equivalent level of protection by the Israeli privacy protection authority; (ii) another approved transfer mechanism under the Israeli regulations; or (iii) your consent to transfer your Personal Data to other jurisdictions, understanding that in some countries the level of protection may be lower than in Israel.
6. MARKETING. If you have opted in, we will notifying you about offers and services that may be of interest to you and tailor content, advertisements, and offers for you. You may choose not to receive marketing materials using the unsubscribe link included in the marketing material, and we will process your request within a reasonable time after receipt.
7. MINORS. The Platform is not intended for use by minors. If you are a minor, you are required to avoid using the Platform. If for some reason you provide us with Personal Data about minors (for example, as part of crew data) please make sure you have obtained the consent of the guardian before sharing their Personal Data. In the event that we become aware that you provided Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such data, please contact us at privacy@myfirstmate.pro.
8. CONTACT US. For any questions, concerns, or to exercise your privacy rights, please contact us at: privacy@myfirstmate.pro.
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