This   Privacy   Policy   defines   the   general   requirements   for   the   processing   and protection of Personal Data of the subjects of personal data processed using the automated   means   of   the -  "INTERNATIONAL   SEAFARER'S   CABINET"   mobile application (hereinafter referred to as the Service), and as well as Personal data contained in the database of the Service or intended to be entered into databases using automated means.

In order to ensure proper access and use of the Service and its applications, the Service collects and processes Users' Personal Data.

The Service acts as the owner and administrator of Users' Personal Data, depending on the circumstances under which such data was collected.

The Service does not collect or process Personal Data provided by persons under the age of 16.

The Service does not collect or process such categories of Personal Data as data on political, religious or ideological beliefs, membership in political parties and trade unions, criminal convictions, as well as sex life, biometric or genetic data User data.

The Service undertakes to ensure the implementation of all available measures to protect Users' Personal Data, taking into account the provisions of current legislation on the protection of personal data and the peculiarities of the Service's sphere of activity.


In this document, the following terms are used as follows:

  • personal data base - a named set of ordered personal data in electronic form and/or in the form of personal data files;
  • the owner of personal data – a legal entity that determines the purpose of processing personal data, establishes the composition of this data and the procedures for its processing, unless otherwise specified by law;
  • consent of the subject of personal data - a voluntary expression of the will of a natural person (provided that he is informed) regarding the granting of permission for the processing of his personal data in accordance with the stated purpose of their processing, expressed in writing or in a form that makes it possible to conclude that consent has been given;
  • depersonalization of personal data - removal of information that enables direct or indirect identification of a person;
  • database - any structured personal data accessible according to defined criteria, regardless of whether such data is centralized, decentralized or separated according to functional or geographical principles;
  • processing of personal data - any action or set of actions, such as collection, registration, accumulation, storage, adaptation, change, renewal, use and dissemination (distribution, realization, transfer), depersonalization, destruction of personal data, including using information (automated) systems;
  • recipient - a natural or legal entity to which personal data is provided, including a third party;
  • personal data - information or a set of information about a natural person who is identified or can be specifically identified;
  • administrator of personal data - a legal entity that is authorized by the owner of personal data or by law to process this data on behalf of the owner;
  • subject of personal data - a natural person whose personal data is processed;
  • third party - any person, with the exception of the subject of personal data, the owner or manager of personal data, to whom the owner or manager of personal data transfers personal data.

User is a natural or legal person who has entered into a License Agreement for the right to use the Service and has registered on the Service in the manner specified by this Agreement.


Depending on how the Users use the Service, as well as on the use of which Service functions are requested, the scope, method, purpose and legal grounds for the collection and processing of Personal Data may change.

The Service collects and processes the following categories of Users' Personal Data:

  • Full Name;
  • registration data of a legal entity, including permits, licenses and other documents related to its type of activity;
  • passport data;
  • registration number of the taxpayer's account card;
  • personal information (age, gender, etc.);
  • place of residence according to state registration and/or actual place of residence;
  • profession, specialty, qualification;
  • electronic identification data (IP-address, phone numbers, e-mail addresses, etc.);
  • image recording;
  • login data of Users to the mobile applications (logins, passwords);
  • technical data for mobile applications.

In relation to personal data regarding bank payment cards (name of the owner, number, expiration date and CVV code) carried out using software tools, the Service acts exclusively as the personal data, determining the purpose and methods of personal data processing. In order to process such categories of personal data, the Service engages specialized payment service providers who act as personal data managers who have exclusive access to the processing of such personal data.

The Service also collects anonymized data that is not personal data (the Service cannot independently identify Users). The collection and processing of anonymized data takes place in a consolidated form and is used for marketing research.

The Service has the right to receive and process personal data from open registers and on the basis of requests and/or direct access to databases and any registers, including, but not limited to, on the basis of information exchange agreements between the Service and state organizations, enterprises of any form of ownership for the purpose of forming the database of the Service and providing the User with the opportunity to make maximum use of the functionality of the Service.

The Service collects and processes Personal Data of Service Users on the following legal grounds:

  • consent to the collection and processing of personal data;
  • fulfillment of contractual obligations of the Service;
  • fulfillment of legal requirements that apply to the Service;
  • legitimate interest of the Service.

The Service collects and processes Personal Data of Service Users in accordance with the following purpose:

  • creating an account on the Mobile Application of the Service;
  • providing Users with access to the Mobile Application of the Service;
  • ordering and providing Users with the appropriate functionality of the Service;
  • providing answers to search and information requests of Service Users;
  • managing the subscription to the newsletter regarding the functionality of the Service;
  • use of feedback forms on the Mobile Application of the Service;
  • provision of information exchange from the Mobile Application of the Service;
  • conducting marketing research and analyzing trends to improve the Service;
  • improving the operation of the Mobile Application of the Service.

Provision of Personal data by Users is necessary for using the functionality of the Mobile Application Service.


The controller and processor of personal data is private enterprise «Digital media management INC.»

  • address: 360 Bloomfield Avenue, Suite 301. Windsor, Connecticut. 06095 USA
  • email: [email protected]
  • phone number: +15852095367


Users of the Service have the right to:

  • to access their Personal Data or the data of third parties who have given their consent;
  • to make changes to Personal Data;
  • to receive information on methods of processing Personal Data;
  • to inform about violations of the integrity of Personal Data;
  • require the transfer of their Personal Data to third parties in the amount requested by Users;
  • to withdraw consent to the collection and processing of Personal Data;
  • to suspend the processing of Personal Data;
  • request deletion of Personal Data.


The Service transfers Personal Data to third parties (including cross-border transfers) exclusively to the extent necessary to fulfill the purpose of collecting and processing Personal Data, for which such collection and processing were previously carried out directly by the Service.

In order to properly provide access to the relevant functions of the Service, as well as to improve the functionality of the Service, Personal Data may be transferred to the following persons:

  • state, authorities, enterprises, institutions and organizations belonging to the sphere of their management, whose activities are related to the sphere of the transport sector of the country's economy;
  • organizations engaged in the provision of services, including intermediary services, in the field of testing, diagnostics, certification, conversion, technical operation of wheeled vehicles, passenger and cargo transportation; transportation of dangerous goods; safety in transport;
  • other legal entities based on the decision of the authorized person to make such a decision or the provision of separate consent by the subject of personal data to such a legal and/or natural person;
  • participants/members of world payment systems that ensure the authorization and transfer of funds by subjects of personal data, and to whom the processed personal data is transferred to ensure the transfer of such funds;
  • other legal entities and individuals legally requesting access to processed personal data.

Processed personal data is transferred to third parties with the consent of the subject of personal data. The transfer of processed personal data to third parties without the consent of the subject of personal data or a person authorized by him is allowed in cases defined by law and only (if necessary) in the interests of national security, economic well-being and human rights.


The period of storage of personal data is not longer than is necessary in accordance with their legal purpose and the purpose of their processing, unless otherwise provided by legislation in the field of archival affairs and record keeping.

The Service processes each category of Personal Data for the period necessary to fulfill each of the above-mentioned purposes. In any case, the Service has the right to store Personal Data for the period necessary to fulfill obligations to Users, as well as to fulfill obligations stipulated by current legislation.


The service takes measures to ensure the protection of personal data at all stages of their processing, including with the help of organizational and technical measures. Protection of personal data involves measures aimed at preventing their accidental loss or destruction, illegal processing, including illegal destruction or access to personal data. In order to ensure the security of personal data processing, special technical protection measures are taken, including the exclusion of unauthorized access to processed personal data and the operation of the technical and software complex, which is used to process personal data.

When transferring Personal Data of Users to third parties, the Service takes all available measures of a legal, organizational and technical nature to guarantee the protection of Personal Data.


Processing of personal data is carried out by the Service only with the consent of the subject of personal data, except when such consent is not required by the Law. The subject's consent to the processing of his personal data must be voluntary and informed. Consent can be given by the subject in electronic form, which makes it possible to conclude that it has been given.

The service, except for the cases provided for by the legislation of USA, informs the subject of personal data about the composition and content of the collected personal data, his rights defined by the Law, the purpose of collecting personal data and third parties to whom his personal data is transferred - during registration on Services. In other cases, when the User's personal data is sent to the Service from third parties, the latter guarantees that such data are received and processed in accordance with the consent of the subject of personal data, taking into account the requirements of general and local Consumer Privacy Act.

In case of detection of information about a person that does not correspond to reality, such information must be changed or destroyed immediately.

Regarding any issues related to Personal Data, Users can send a request or complaint to the representative of the Service on data protection issues at the company’s e-mail address.

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