Pulse App Privacy Notice

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General Information

1. This Pulse App Privacy Policy (Pulse App Privacy Notice) explains what personal data may be collected by us through the Pulse App, the purposes for which such data is collected, and how it will be processed. It also explains your rights in relation to your personal data and how you may contact us in the event of any questions or complaints.

2. By accessing or using the Pulse App, you acknowledge that you have read and understood this Pulse App Privacy Notice. Fleet Management Group may update this Pulse App Privacy Notice from time to time. Any such changes will be effective prospectively upon being made available on the Pulse App or by otherwise notifying you. Your continued access and use of the Pulse App after such changes have been notified will constitute your acceptance of the updated Pulse App Privacy Notice.

3. ‍The Pulse App is developed to enable seafarers to interact with other seafarers, create and manage their profiles, and submit or update personal and professional information. The Pulse App is integrated with Fleet Management Group’s internal systems (including PARIS), and personal data processed through the Pulse App may be used for both user interaction purposes and operational or crewing purposes.

4. This Pulse App Privacy Notice is separate from, and does not replace or modify, the Operational Personal Data Processing Statement that you have already reviewed and, as applicable under relevant laws, acknowledged or consented to during your onboarding.

5. The Operational Personal Data Processing Statement governs employment related and other operational data processing. To the extent that personal data collected, submitted, or updated through the Pulse App is used for the purposes described in the Operational Personal Data Processing Statement, including deployment on a vessel, administration of entitlements and benefits, training and competency management, compliance obligations, obtaining licences and travel documents, and compliance with applicable laws and regulatory requirements, such processing shall be governed by the Operational Personal Data Processing Statement.
6. Documents submitted by you through any features within the Pulse App including those containing your Personal Data flow into Fleet Management Group systems (including PARIS) and are processed in accordance with the Operational Personal Data Processing Statement. Personal data processed through the Pulse App for Pulse App related purposes shall be governed by this Pulse App Privacy Notice.

Definitions

7. For the purposes of this Pulse App Privacy Notice, the following terms shall have the meanings set out below:

“Data Protection Laws” means applicable laws, rules, regulations, directives and governmental requirements related to protection of personal data, including: (i) the EU General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the EU Privacy Directive 2002/58/EC, together with any EU Member State national implementing legislation; (ii) the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong); (iii) the Digital Personal Data Protection Act, 2023 (India) (the “DPDPA”), (iv) the Philippines Data Privacy Act of 2012 and its implementing rules and regulations (the “DPA”) , (v) the Personal Information Protection Law of the People’s Republic of China (“PIPL”) and (vi) the Personal Data Protection Act 2012 of Singapore (“PDPA”), in each case` together with any rules, regulations, notifications, guidelines, and any successor or replacement data protection legislation, as amended, consolidated, re-enacted, replaced, or brought into force in phases from time to time.

“Fleet Management Group” means Fleet Ship Management Inc and its such subsidiaries and affiliated companies who are engaged in the business of providing ship management or crew management services to their clients. Address of Fleet Ship Management Inc. is Vistra Corporate Services Centre, Wickhams Cay II, Road Town Tortola, VG1110, British Virgin Islands 

“Operational Personal Data Processing Statement” means the privacy statement issued by the Fleet Management Group that governs the collection, use, storage, sharing, and retention of personal data of seafarer for employment related and other operational purposes. Seafarers review, acknowledge, and consent to such privacy statement as part of their pre joining formalities prior to joining the vessel.

“PARIS” means Fleet Management Group’s internal operational ship-management and crewing platform.

“Pulse App” means digital platform branded as “Pulse by Fleet Management”, designed to facilitate engagement, communication, and connectivity among seafarers.

“Personal Data” means any information that relates to an identified or identifiable individual.

“User” / “You” means any seafarer using the Pulse App.

“User-Generated Content” means any content submitted, uploaded, or otherwise provided by you through the Pulse App, including but not limited to personal profile picture, self-introduction, interests, comments, or other information voluntarily shared for the purpose of using features within Pulse App.

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The Controller & its Business

8. Fleet Management Group is the data controller (or equivalent) in respect of personal data processed through the Pulse App and determines how such personal data is collected and the purposes for which it is used. Members of the Fleet Management Group will comply with their respective obligations under applicable Data Protection Laws.

Categories of Personal Data Processed

9. The categories of personal data that may be collected and processed through the Pulse App include:

• profile information (such as name, photograph, interests, and introduction);
• User-Generated Content (such as posts, comments, messages, and interactions);
• personal and professional information submitted or updated through the Pulse App;
• information synchronised with PARIS or other Fleet Management Group systems;
• technical data including application logs, usage data, and device information.

Purpose of Data Processing

10. Personal data is processed through the Pulse App for the following purposes:

a. verifying account creation and authentication;

b. assessing and validating privacy settings, consent prompts, and data visibility controls;

c. validating features within Pulse App and User-Generated Content;

d. ensuring that user interface/user experience (UI/UX), workflows, navigation, and data flows operate as intended;

e. ensuring system stability, security, access controls, and error handling;

f. identifying bugs or issues and implementing fixes;

g. enabling interaction and communication among seafarers;

h. creating, maintaining, and updating user profiles;

i. facilitating the submission and updating of personal and professional information;

j. enabling synchronisation of data with PARIS and other Fleet Management Group systems;

k. managing and responding to enquiries submitted through the Pulse App in relation to the Pulse App, its content;

l. supporting the functionality, performance, security, and improvement of the Pulse App.

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Legal Basis for Processing

11. The legal basis relied upon by members of the Fleet Management Group for processing personal data through the Pulse App are, to the extent relevant under applicable Data Protection Laws: 

a. for legitimate business interests (including operating, maintaining, and improving the Pulse App, ensuring system security, enabling interaction and communication among users, and supporting Pulse App-related functionalities), provided that such interests are not overridden by your rights under applicable Data Protection Laws; and 

b. based on your consent (including where you voluntarily provide personal data through the Pulse App, such as creating a profile, sharing content, or participating in community and engagement features). Where required under applicable Data Protection Laws, we will obtain your consent prior to collecting and processing your personal data.

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Sources of Collection

12. Personal data processed through the Pulse App may be collected from:

• information provided directly by you;
• Fleet Management Group systems and databases (including PARIS);
• data generated through your use of the Pulse App.

Transfer of Data

13. Personal data processed through the Pulse App may be shared with:

• members of Fleet Management Group;
• IT vendors and technology partners supporting the Pulse App, including hosting services;
• regulatory or governmental authorities where required by applicable law.

14. Where personal data is transferred internationally, appropriate safeguards will be implemented in accordance with applicable Data Protection Laws.

Failure to Provide Personal Information

15. Members of the Fleet Management Group may require certain personal data to enable access to and use of the Pulse App. However, you may choose not to provide your personal data. In such cases, you may not be able to access or use certain features of the Pulse App, and the Pulse App or certain functionalities may not be available to you.

Retention

16. The Fleet Management Group will only retain personal data for as long as necessary to fulfil the purposes for which it was collected for. The Fleet Management Group will only store data for as long as is required to fulfil that purpose, or for the purpose of satisfying legal, tax, accounting or reporting requirements and as per the local laws of the country we operate in. To determine the appropriate retention period for personal data, the Fleet Management Group consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use and/or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and also the applicable legal requirements.

Security of Your Data

17. Fleet Management Group takes the security of your information seriously and will take all practicable steps, including the implementation of technical and physical security measures, to ensure that all personal data held by members of the Fleet Management Group is kept secure and safe from any loss or unauthorised disclosure, use and modification.

18. The security practices adopted by members of the Fleet Management Group include regular review of permissions and account access, as well as change, incident, risk, and problem processes to prevent and resolve issues. Security frameworks used by the Fleet Management Group for guidance are ISO27001 and National Institute of Standards and Technology.

19. Members of Fleet Management Group also check from their Cloud and IT vendors if they have the appropriate security certifications. 

Your Rights

20. You may have certain rights as a data subject relating to your personal data that we process depending on the applicable Data Protection Laws. These rights may or may not be available in all jurisdictions and will be subject to limitations, conditions and requirements under applicable Data Protection Laws. The scope and manner of exercising these rights may vary depending on the Data Protection Laws applicable to the processing of your personal data. 

To the extent under the applicable Data Protection Laws, you may exercise following rights

• Right of access: right to request a copy of the information the organisation holds
• Right of rectification: individuals have the right to correct data that is inaccurate or incomplete.
• Right to be forgotten: in certain circumstances, individuals can ask the organisation to erase any personal data that’s stored by them.
• Right of portability: the right, in certain circumstances, to transfer individuals’ personal data to another organization.
• Right to restrict processing: individuals can request that an organisation limits the way it uses personal data.
• Right to object: individuals have the right to challenge certain types of processing, such as direct marketing.
• Rights not to be subject to automated decision-making including profiling.
• Right to withdraw consent: withdrawal, however, will not affect the lawfulness of the processing before the consent withdrawal.
• Right to lodge a complaint: the right to raise concerns or complaints with a competent supervisory or regulatory authority.
• Right to seek redress: in certain circumstances, to seek compensation or remedies for damage resulting from unlawful processing of personal data.
• Right to know and make decisions on the processing of his/her personal information.

For further details on your rights, please refer to the relevant Data Protection Laws applicable to you.

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Subject Access Requests

21. If you have questions in relation to your personal data (including any complaints that you may have in relation to the Fleet Management Group’s handling of your personal data) or would like to exercise any of the abovementioned rights or where the data processing is based on your consent, if you want to withdraw your consent to the processing of any personal data at any time, please write to privacy@fleetship.com along with the necessary proof of identity requirements that we may require prior to processing such request from you. Withdrawal of consent will not affect the lawfulness of any processing carried out prior to such withdrawal or where processing is based on a legal basis other than consent. If you withdraw your consent, you may not be able to access the Pulse App or related services, however it shall not affect your engagement, deployment, or any operational or employment-related processes, which will continue to be governed by the Operational Personal Data Processing Statement.

22. Access to this Pulse App Privacy Notice - The current version of this Notice is made available to you at www.fleetship.com.

23. Questions, comments and requests regarding this Pulse App Privacy Notice or the privacy aspect of the Pulse App, are welcomed and should be sent to privacy@fleetship.com.

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