This Privacy Policy (“Policy”) sets forth how Erne S&P - FZE LLC, a company established and existing under the laws of the UAE (Ajman Free Zone), license number 43012 (“w
This Privacy Policy (“Policy”) sets forth how Erne S&P - FZE LLC, a company established and existing under the laws of the UAE (Ajman Free Zone), license number 43012 (“we”, “us”, “our”), processes personal data of: Users of the Service available at the: https://e-shipsale.com, our contractors, vendors, vendors' employees and other representatives, inbounds. This Policy is posted and is constantly available at https://e-shipsale.com/p/privacy-policy. The Policy may be updated time to time, and you may access any version (see at the end the available versions). In the event of any major changes, we will let you know in advance. Some technical terms used in this Policy are given without explanation. If you do not know a term, please contact us (see contact details in Section 7). 1. WHAT DATA WE COLLECT AND FOR WHAT PURPOSES We do not collect any special categories of personal data about you (i.e. details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We also don't use your data for profiling and making automated decisions concerning you. You are not obliged to provide your personal data to us. However, if we need personal data to enter and perform the contract with you and you do not provide this data, we may not be able to perform the contract we have or are entering into with you. Should this be the case we will notify you at the time. For each scenario of processing, we have set out below, in a table format, a description of all the ways we plan to use your personal data, and which legal bases we rely on to do so. When you use our Service What are the purposes What data we collect What is the legal basis For how long we store data Providing the Service, including: conclusion, performance and cancellation of Agreement for the use of the Service, the ability to register and manage an account, providing the functionality of the Service, verifying the account details and authenticity, sending transactional messages within the framework of the Service functionality, processing payments within the Service, refunds, support of the Service users, processing of complaints and claims, ensuring the operability and security of the Service (prevention of fraud, as well as investigation of such cases). Users: Full name Contact details Date of birth Photo Country Government ID Authentication data System role (seller, broker, observer, buyer, etc.) Information about devices Information about the Service usage Information about the history of orders and payments using the Service (subscription, etc.) Payment details IMO number Other information contained in the chats Other information contained in supporting documents (ISM management certificate, ownership certificates, power of attorney, etc.) System IDs Performance of the contract with you During the term of the contract, but in any case, not more than 1 year from the date of account deactivation (at your initiative or our initiative, if the account has been inactive for 3 years). Within 7 years from the account closure or 7 years from the year following the year in which the respective financial transactions were performed, whichever is shorter, for data processed for accounting/tax purposes. Analysing, controlling and improving the user experience and quality of Services provided using the Service. See more information on cookies in Section 4 All Service visitors: Information about the Service usage Information from the cookies and pixels (IP, MAC-address, other device information) Consent Performance of the contract with you Up to 1 year after the last visit Sending promotional messages over email, analysing the effectiveness of marketing campaigns Subscribers and users: Full name Contact details Information about the Service usage Consent details Consent Up to 3 years after the last interaction When you are our vendor or an employee or other representative of our vendors What are the purposes What data we collect What is the legal basis For how long we store data Vendor management, including: due diligence procedures, conclusion, execution and cancellation of contracts, ensuring communication and co-operation within the framework of the contracts, accounting of counterparties and contracts, payments fulfillment. Contractors: Full name, Date of birth Address Government ID Bank account details Place of work, position and division Contact details Information on tax status Services information (contract details, performance, payments, etc.) Representatives and other employees of vendors: Full name Place of work, position Contact details Services information (contract details, performance, payments, etc.) Performance of the contract with you or your employer During the term of the contract and for 7 years after for tax/accounting and legal hold purposes When you contact us for inquiries What are the purposes What data we collect What is the legal basis For how long we store data Managing your inquiries and responding to them Full name Contact details Content of the inquiry Consent Up to 1 month after your inquiry has been closed, unless further required for legal claims. 2. HOW WE SHARE YOUR DATA We share your data only in limited cases with the following recipients: affiliates and other companies of our group to efficiently perform our business activities, SaaS, hosting, payment, and mailing Service providers that support the operation of our SaaS software and other tools, and host the IT systems used to deliver our Service, new business owner if we ever sell our business, governmental agencies and courts, if required by law or court order, professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional Services that they render to us. 3. HOW WE TRANSFER DATA OUTSIDE OF THE UAE We do our best to keep your data inside the UAE. With that, some processes require the transfer of your personal data in other countries, specifically with our affiliates. The countries to which we transfer your data don't always have the same protections as your jurisdiction. We take reasonable measures to ensure your data is adequately protected when outside of the UAE, for example, we implement specific contractual clauses with our vendors and affiliates, assess the risks of the international data transfers to adopt suitable safeguards, etc. To learn more contact us, as specified in Section 7 (Contacts). 4. COOKIES AND OTHER TECHNOLOGIES We use cookies (small text files that are stored on your browser or device) and other web-analytics technologies (local storage, session storage, pixels) (all referred to as "cookies" for being simpler) for a number of purposes, including: remembering user preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, analysing site traffic and trends, ensuring security of our Service and combatting fraud, and generally understanding the online behaviours and interests of people who we interact with. In general, cookies may be stored on your device from 1 day to up to 14 months. Some technologies (local storage) place the information on your device persistently due to their nature and it's up to you to delete them from your device. We process personal data collected via cookies based on your consent (with regards to non-essential cookies) and our legitimate interest (with regards to essential cookies) to provide and secure our website, allow for the high-quality user experience, and remember your cookie choices to not ask you again any time you visit our website. Cookies allow us to obtain information from your device, such as your device type or operating system, IP address, time of visit and other technical details which allow us to learn how you interact with our websites. You can set in your browser to remove or reject browser cookies. To do so, please follow the instructions provided by your browser which are usually located within the ‘Help’ or ‘Preferences’ menu. Please also click below for detailed information on how to disable and delete cookies in some commonly used browsers: Mozilla Firefox® Microsoft® Internet Explorer Google Chrome™ Safari® 5. WHAT ARE YOUR RIGHTS Under the applicable laws you have certain rights, which are briefly summarised below, in relation to any personal data about you which we hold: Accessing data You have the right to ask us to provide information on whether we process your data and how we do it. As well you can request a copy of your personal data we hold about you. In some cases, we may need to ask for additional information before we are able to disclose any data to you to protect the privacy of third parties. Data portability You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances. Changing or updating data You have the right to rectify data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. Deleting data You have the right to ask us to delete your data in certain circumstances. In some cases, we may be required to continue processing your data for other purposes even though you ask us to delete it. Should this be the case, we will provide you with further information. Objecting, restricting processing You have the right to request that we stop using all or some of your personal data, or that we limit (restrict) our use of their data. This includes objecting to use of personal data that is based on legitimate interests. If we process your personal data for direct marketing purposes, we will stop such processing without any exceptions after we receive such a request from you. But, in other cases we may continue to process data after such objection or request to the extent required or permitted by law. Revoking consent You have the right to withdraw your consent at any time after which we will stop any processing of your data for such purposes. Specifically, you can withdraw your consent to direct marketing by following the “unsubscribe” link or contacting us in accordance with Section 7 (Contacts) below. Complaints If you believe we have violated your rights you may lodge a complaint with the data protection authority in the country you reside in or work. Nevertheless, we kindly ask to contact us first to see if we can resolve your issue amicably. You can also access, delete, and correct some of your personal data directly in your account settings. If you would like to exercise the rights above, please contact us, as specified in Section 7 (Contacts). 6. THE SAFETY AND SECURITY OF DATA No IT system or online service is 100% safe. But we do our best to ensure security of your personal data. We take technical, organisational, and administrative measures, including, where relevant, access management, encryption, logging, etc., to ensure that your personal data are protected from unauthorised or accidental access, deletion, modification, blocking, copying and dissemination. Access to your account is authorised using your login (e-mail address) and password. You are responsible for keeping the credentials confidential. If you suspect any misuse or loss of, or unauthorised access to your data, you should let us know immediately. We also have procedures in place to deal with any suspected data breach. We will notify you and any applicable authority of a suspected data breach where we are legally required to do so. 7. CONTACTS If you have any questions regarding this Policy or how we process your personal data, please contact us: by email: support@e-shipsale.com; or by mail: AMC-BLA-B.C-6010809, AMC - Boulevard-A Building, Ajman Media City Version 2.0 Last update: 24 April 2026
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