PRIVACY POLICY

Welcome to the Fidelio Maritime & Trading S.A. website (the “Website”). Fidelio Maritime & Trading S.A., including its subsidiaries and affiliates (“FMT,” “we,” “our,” or “us), is committed to respecting your privacy. FMT has drafted this Privacy Policy to inform you of its policies with respect to information collected from both online and offline users. Your use of this Website, communications, and involvement in our events, constitutes your acceptance of this Privacy Policy, our Terms and Conditions of Use, and your consent to the practices they describe.

INFORMATION WE COLLECT

In general, we collect Personal Information when you communicate with us and when you use the Website. When FMT uses the term “Personal Information,” we mean information that we directly associate with a specific person, or that can reasonably be used to identify a specific person such as a name, address, telephone number, email address, or Internet Protocol (IP) address. The Website collects some information from you that is voluntarily provided by you and other information that is collected by the Website automatically.

Personal Information You Provide to Us

In general, we collect Personal Information when you communicate with us and when you use our Website.

We may collect and process the following categories of Personal Information:

identity and contact details (such as name, surname, email address, and mailing address)
professional information (for example your organization name and title)
job application information (including demographic information, education, work history, and any other relevant information you share with us through your application)
information collected through our use of cookies

Personal Information Automatically Collected Through Your Use of the Site

When you visit the Website, certain information about your visit is automatically logged, which may include information about the type of browser you use, the server name and IP address through which you access the Internet, the date and time you access the site, the pages you access while at the Website, Internet service provider information, device type, and the Internet address of the website, if any, from which you linked directly to, or depart from, the Website.

We may collect information about your location when you access or use the Website. We may also collect information regarding your general location using your IP address. If you access or use the Website from a mobile device, we may collect more precise geolocation information from your mobile device. You can disable geolocation services in the settings on your mobile device.

HOW WE USE AND SHARE PERSONAL INFORMATION

Use of Personal Information

We collect and process Personal Information to respond to your requests and for other business purposes. For example, EBS may use your Personal Information in the following ways:

the provision of FMT services and product according to agreed terms
to accommodate your requests and inquires for services or information
the provision of notifications, including press releases, offered by EBS
for purposes listed in the “Our Use of Cookies and Other Similar Tools” section below

Disclosure of Personal Information

FMT uses third-party vendors to help us maintain and operate our Website and to operate our business and those vendors may receive your Personal Information for those purposes. FMT may also disclose Personal Information about you in connection with legal requirements, such as in response to a subpoena, governmental request, or investigation, or as otherwise required by law. In certain instances, we may agree to allow a vendor to use aggregated data about activity for general improvement or benchmarking purposes, generally in an anonymized or aggregate form.

We also may share your Personal Information with third-parties for any legitimate business purpose, or if we believe that the law requires us to do so, or to protect our property or the property of our affiliates. Additionally, in the event of a corporate restructuring (such as a sale, merger, or other transfer of some or all of our assets), we may share your Personal Information with a third party. We reserve the right to use or disclose any information in aggregate form, for any purpose, in our sole judgment.

OUR USE OF COOKIES AND OTHER SIMILAR TOOLS

The Website or third-party vendors that are used to operate the website may use “cookies” in order to administer the Website. A “cookie” is a small piece of data that can be sent by a Web server to your computer, which then may be stored by your browser on your computer’s hard drive. Cookies are useful in allowing more efficient login for users, tracking transaction histories, preserving information between sessions, and improving the functionality of a website. Some Web browsers such as Microsoft Internet Explorer and Google Chrome may have features that can notify you when you receive a cookie or prevent cookies from being sent. If you disable cookies, however, you may not be able to use certain personalized functions of this Website. To find out more about cookies and how to block them or control their use by configuring your browser, you can visit www.allaboutcookies.org.

In addition to the use of cookies, we may use certain third-party services, such as Google Analytics, to help us analyze how people use the Website. We use this information to evaluate your and other users’ use of the Website, compile reports on Website activity, and provide other services relating to Website activity and Internet usage.

FMT may use this information we collect from you during your visit to the Website in order to analyze trends and administers our Website. For example, we may use information related to

your use of the site to determine fluctuation of visitor numbers, to diagnose problems with our servers, and to improve user web experiences.

DATA RETENTION

FMT retains your Personal Information for as long as you subscribe to receive alerts from FMT and as long as is required to comply with applicable laws and regulations. Commercial and contract data may be retained longer to comply with applicable commercial laws.

CHOICE/OPT-OUT

When you submit your contact information, FMT may send you emails related to new updates and investment related updates. From time to time, FMT may also wish to send you other messages or updates about FMT and its activities. If you do not wish to receive these communications from FMT, please send an email containing your request to info@fidelnav.com with the word “Unsubscribe” in the subject line.

You will also have regular opportunities to opt-out by following the instructions listed on FMT’s solicitation materials. Even if you opt-out of receiving news and related updates from EBS, we will send you transaction-related emails and respond to questions from you.

CHILDREN’S PRIVACY ON OUR WEBSITE

This Website is not directed to children under 13. We do not knowingly attempt to solicit or receive Personal Information from children under 13. If FMT discovers that it has received Personal Information from an individual reasonably believed to be under the age of 13, FMT will delete such information from its systems. If you are the parent or legal guardian and you believe we may have inadvertently collected Personal Information from a child under 13, please contact us to request the child’s information be deleted by contacting us at info@fidelnav.com.

EXTERNAL LINKS

The Website may contain links to other websites, including those of advertising or third-party content providers. Please be aware that FMT is not responsible for the privacy practices or the content of other websites. FMT encourages you to read the privacy statements provided by other websites before you provide personally identifiable information to them.

ACCESSING OR CORRECTING YOUR INFORMATION

We take reasonable steps to keep your Personal Information accurate and complete. If you would like us to consider providing you access to, or making a correction to, your Personal Information maintained in our records, please send your request to us at info@fidelnav.com.

CHANGES TO THE PRIVACY POLICY

FMT reserves the right to modify or supplement this Privacy Policy at any time, in its sole discretion, so please check back frequently. The “Last Updated” date will be updated when changes to this Privacy Policy are made. The terms of our current Privacy Policy supersede all previous notices or statements regarding FMT’s privacy practices. The terms of our current Privacy Policy apply to all information stored in our records, regardless of when that information was collected.

EU BASED USERS AND THE EU GENERAL DATA PROTECTION REGULATION (“GDPR”)

If the processing of your Personal Information is subject to the EU General Data Protection Regulation (“GDPR”), whenever we use or share Personal Information, we ensure that we have identified a legal basis under which such processing may occur. When we use your Personal Information in connection with a request, order, transaction, or to provide you with services that you requested (such as use of the Website or to register for events), we do this because it is necessary for the performance of an agreement with you. Further, to the extent the GDPR is implicated, where we use your Personal Information in relation to improvement, development, or marketing of our products or services, for reasons of safety and security, or to satisfy regulatory requirements, other than in connection with our agreement or request, we do this on the basis of our (or a third party’s) legitimate interests or with your consent, as required.

Access, Modification, Erasure, or Restriction of Personal Information

If the processing of your Personal Information is subject to the GDPR, you may have the right to access or modify your Personal Information, including the right to:

obtain confirmation that we hold Personal Information about you
request access to and receive information about the Personal Information we maintain about you
receive copies of the Personal Information we maintain about you
update and correct inaccuracies in your Personal Information
object to the processing of your Personal Information, request portability
have the information blocked, anonymized or deleted, as appropriate

You may also contact us with the request to withdraw consent for processing or storage of your Personal Information. These rights are only available if you reside in, or access the Website from, certain jurisdictions and may be limited in some circumstances by local laws and regulations.

Exercising Your Rights Under the GDPR

You can exercise these rights under the GDPR by contacting us at info@fidelnav.com. Please put the statement “GDPR Privacy Rights” in the subject line of your request, and include your name, country or region, and enough information to allow us to respond to your request in the body of your e-mail.