Introduction:

Covered Domains: q88.com, milbros.com, jotunprl.com

Your privacy is very important to Q88 LLC (“Company”, “we” or “us”) and we are committed to protecting it through our compliance with this Privacy Policy. By using any of the websites operated under any of the “Covered Domains” identified above (our “Website(s)”), you consent to the terms of this Privacy Policy.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our Websites or use any of the services offered through any of the Websites (the “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to information that we collect through our Websites.  It does not apply to information we collect through any other means, including through email, text or other electronic messages between you and the Company.

For purposes of this Privacy Policy, “personal data” is any information relating to an identified or identifiable natural person who can be identified directly or indirectly by reference to the information. This definition is intended to comply with applicable privacy and data protection laws, including the General Data Protection Regulations of the European Union (“GDPR”).

Please read this Privacy Policy carefully to understand the Company’s policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use any of the Websites or Services. By accessing or using the Websites or Services, you agree to this Privacy Policy and our Terms of Service. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Websites or Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Information We Collect and How We Collect It:
We collect several types of information from and about users of our Websites, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, any entity or company with which you are affiliated, billing and payment information such as financial and bank account numbers, and any other identifier by which you may be identified or contacted online or offline;
• About vessels and entities and persons related in some manner to identified vessels; and
• About your internet connection, the equipment you use to access our Websites, and usage details.

We do not collect information related to racial/ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, other medical information including biometric and genetic data, or sexual life or criminal allegations or convictions, precise geolocation information.

We collect this information:

• Directly from you when you provide it to us;
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies; and
• From third parties, for example, vessel location information, vessel photos, and information on vessel fixtures.

Information You Provide to Us:
The information we collect on or through our Websites may include:

• Information provided at the time of registering to use our Websites or subscribing to our Services, including personal data;
• Information that you provide by filling in forms on our Websites;
• Documents and records that you upload through the Website;
• Your responses to surveys that we might ask you to complete for research purposes; and
• Your search queries on the Websites.

We may also ask you for information when you report a problem with our Websites;

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Websites, or transmitted to other users of the Websites or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we use reasonable measures to limit access to information we collect and information you provide, including User Contributions, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Websites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies:
As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Websites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website;
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Our cookies help provide additional functionality to the Websites and help us analyze our Websites usage more accurately. On most web browsers, you may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites. Please refer to “help” section on your browser’s toolbar for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites. We recommend that you leave cookies turned on because they allow you to take advantage of some of our Websites’ features.

How We Use Your Information:
We use information that we collect about you or that you provide to us, including any personal data:

• To present our Websites and its contents to you and otherwise to operate our Websites (including by customizing certain features for more personalized use);
• To provide you with information or Services that you request from us;
• To provide you with notices about your account or subscriptions, including expiration and renewal notices, or in connection with the use of any of the Services;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• To notify you about changes to our Websites or Services;
• To allow you to participate in interactive features on our Websites;
• To pool your information with other information to track, for example, the total number of visitors to our Websites, the number of visitors to each page of our Websites, and the domain names of our visitors’ Internet service providers, provided that no personally identifiable information is available or used in this process;
• To fulfill any other purpose for which you provide it;
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.

Disclosure of Personal Data:
We share personal data with others only as described in this statement, or when we believe that the law permits or otherwise requires it.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose your personal data and User Contributions comprising personal data that we collect or you provide as described in this Privacy Policy:

• To our parent company, subsidiaries, and affiliates (and those of our parent company);
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them. Examples of functions performed by contractors, service providers, and other third parties include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by the Company’s about our Websites users is among the assets transferred;
• To fulfill the purpose for which you provide it; and
• For any other purpose disclosed by us when you provide the information.

We may also disclose personal data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes; and
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
• To protect against legal liability.

Some of the Services that are made available through the Websites allow users to store, for use with the Services, User Contributions comprising information, documents and records relating to vessels and crewmembers. We will not access, monitor, use or disclose any such User Contributions, without your authorization, except in the following circumstances: (i) the User Contributions is related to user identification and access authorization; (ii) the User Contributions is to be used to assist you or provide the Services to you; (iii) we are under the good faith belief that we are required to do so pursuant to law, regulation, legal process, governmental demand or other legal obligation; (iv) we are under a good faith belief there is a violation of the Terms of Service, our Acceptable Use Policy , or applicable law, or that a user is engaging in actions which threatens the network, servers or User Contributions, or otherwise threaten users’ property rights, the Websites, the Company and/or other third parties.

Through the Websites, you may authorize us to “publish” certain User Contributions and other data (collectively, “Published Data”), including specific vessel data fields, documents and forms, that you have uploaded through the Websites.  Notwithstanding anything to the contrary herein or in the Terms of Service, if you authorize us to “publish” any Published Data, you grant the Company a perpetual, worldwide, royalty-free, fully paid-up right and license (with the right to sublicense) to publicly display, reproduce, modify for the purpose of formatting for display, and distribute such Published Data, in whole or in part, in any media formats and through any media channels (now known or hereafter developed) including, without limitation, the Websites, and authorize third parties to do the same, without restriction. 

Also, through the Websites or otherwise in writing, you may authorize us to allow specifically identified users to have access to certain User Contributions and other data (collectively, “Shared Data”), including specific vessel data fields, documents and forms some of which may comprise personal data about crew members.  Based on such authorization, we will allow the identified users of the Services to have access to the Shared Data, including associated personal data. As the controller of the personal data that you upload through the Websites, you are responsible for obtaining from associated persons all legally necessary consents for disclosure, as contemplated herein, of personal data incorporated in the Shared Data. By uploading such personal data through our Websites, you represent and warrant to the Company that you have received all necessary consents to disclose such personal data to the Company and authorize the Company to disclose such personal data to our clients/customers using our Services to obtain information about vessels.

The Company considers your personal data to be a vital part of our relationship with you will not sell your personal data without your consent.

If you wish to raise a complaint on how we have handled your personal data, you can contact our Information Security Coordinator at isc@q88.com who will investigate the matter.

Accessing and Correcting Your Information:
If at any point you believe the information we process on you is incorrect, you may request to see this information and even have it corrected or deleted. Requests to access, correct or delete any personal data should be directed to our Information Security Coordinator at isc@q88.com. We cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Websites, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Websites users.

Your California Privacy Rights:
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, reference the CCPA Privacy Notice For California Residents section lower on this page.

We do not use personal data for profiling or automated decision making. We will not sell or rent any personal data to third parties for marketing purposes without your consent.

Nevada Residents’ Rights:
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to our Information Security Coordinator at [nevada-rights@q88.com]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

UK & EU Residents’ Rights:
Notice to UK & EU Residents: If you are an EU or UK resident, you may have certain additional privacy rights. For more information, reference the UK & EU Privacy Rights section lower on this page.

We may we transfer personal data from the European Economic area to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country. By using any Services, you hereby consent to the transfer of your personal data and any other personal data that you submit through the Websites to any country in the world, without regard to whether or not the laws of such country ensure an adequate level of protection as contemplated by your home country. Further, if you have uploaded to the Websites any personal data of any person, you represent and warrant that you have received from such person all necessary consents to allow the transfer of such personal data outside of the European Economic area, as contemplated in this paragraph.

Data Security:
The Company has implemented measures designed to secure your personal information from accidental or unlawful, destruction or loss, and from unauthorized access, use, alteration, and disclosure.

The Company has a data protection regime in place to oversee the effective and secure processing of personal data. It takes reasonable steps to protect the personal data provided via the Websites from accidental or unlawful destruction or loss, and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of Information via the internet is never fully secure or error-free. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to, or stored on our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.  Therefore, you should take special care in deciding what information you send to us via the Websites or otherwise.

With respect to your payment information, please note that Company works to protect the security of all your information during transmission over the Internet by using Transport Security Layer(TLS) to encrypt your credit card number and personal data. The Company will use your credit card information only to process your payment and will not retain or otherwise store your credit card information subsequent to the processing of your payment.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

The Company will only keep personal data for so long as it is being used for the purposes for which we collect it. After it is no longer being used, it will be deleted or destroyed according to generally accepted data destruction standards.

We take reasonable measures to provide that personal data is processed, secured, and transferred according to applicable law. The areas in which any recipients are located will vary from time to time, but may include the United States, Europe, Canada, Asia, Australia, India, and other countries where the Company has a presence or uses contractors. For a list of the Company’s offices, see our Contact page.

External Links:
The Websites may contain links to other websites operated by third parties. Before it engages with third parties, the Company requires that the third parties maintain security measures, that comply with applicable privacy and data protection laws, including the GDPR and agree to the Confidentiality Agreement.

Changes to Our Privacy Policy:
The Websites, Services and our business may change from time to time. As a result, at times it may be necessary for the Company to make changes to this Privacy Policy. The Company reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this Privacy Policy periodically, and especially before you provide any personal data. This Privacy Policy was last updated on the date indicated below. Your continued use of the Websites after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Children’s Privacy:
Our Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.

Contacting Us:
If you have any questions about anything in this Privacy Policy, or about the collection of Personal Data through the Websites, please contact our Information Security Coordinator at isc@q88.com.

Last Updated: June 8, 2022

Your California Privacy Rights

Introduction:
Company: Q88 LLC
Covered Domains: q88.com, milbros.com, jotunprl.com

This notice by the Company to California residents is provided under California law, including the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code 1798.100, et seq. This notice supplements the Company’s Privacy Policy by explaining your privacy rights if you are a California resident, providing our “notice at collection,” and providing certain mandated disclosures about our treatment of California residents’ information, both online and offline.

Notice of Collection of Personal Information:
The Company collects the categories of personal information described in our Privacy Policy when you interact with any website operating under the Covered Domains (“Websites”).

The Company collects this information so that we can best serve you, including to provide services through the Websites (“Services”). A more detailed description of these purposes is in our Privacy Policy.

California residents also have the right to “opt out” of the “sale” of their “personal information” to “third parties” (as those terms are defined in the CCPA and described below).

CCPA Mandatory Disclosures:
We also make the following disclosures for purposes of compliance with the CCPA:

• The Company may have collected the following categories of your personal information in the last 12 months: identifiers/contact information, payment card information associated with you, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.
• The sources of your personal information from whom the Company may have collected are: directly from you, analytics tools, and third-party services that update or supplement information we hold about you.
• The business or commercial purposes of collecting your personal information are as summarized in our “notice at collection” section of this document, and as described in more detail in our Privacy Policy.
• The Company may have disclosed the following categories of your personal information for a business purpose in the last 12 months: identifiers/contact information, payment card information associated with you, commercial information, Internet or other electronic network activity information, geolocation data, or similar information, and inferences drawn from the above. We disclosed each category to third-party business partners and service providers, and other third parties as described in our Privacy Policy.
• The Company does not collect personal information of known minors under 16 years of age.

Your Rights:
Right to Access: If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.

Right to Delete: If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

Right to Opt Out of Sale of Personal Information: If you are a California resident, you have the right to “opt out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA).

Process to Make a CCPA Request:
Making Access and Deletion Requests: To make an access or deletion request, please email us at [CCPA-REQUEST@q88.com]. Before completing your request, we may need to verify your identity. We will may request additional documentation or information solely for the purpose of verifying your identity.

Instructions for Authorized Agents Making Access and Deletion Requests: You may also use an authorized agent to submit an access or deletion request on your behalf. Authorized agents may submit access and deletion requests at [CCPA-REQUEST@q88.com]. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with California probate law. Authorized agents that are business entities must be registered with the California Secretary of State to conduct business in California. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity.

Making Requests to “Opt Out” of the “Sale” of “Personal Information”: We will not sell or rent your personal data to third parties for marketing purposes without your consent.

You have the right not to receive discriminatory treatment for the exercise of your privacy rights conferred by the CCPA.

Shine the Light Act:
We will share your personal data to third parties for the third parties’ direct marketing purposes.

Removal of Content:
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted.

To make such a request, please send an email with a detailed description of the specific content or information to [CCPA-REQUEST@q88.com]. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Contact Information:
If you have a question about our privacy policies, please send an email our Information Security Coordinator at isc@q88.com or write us at:

Q88 LLC
Information Security Coordinator
55 Post Road West, 2^nd floor
Westport, CT 06880
USA

UK & EU Residents’ Rights

Introduction:
Company: Q88 LLC
Covered Domains: q88.com, milbros.com, jotunprl.com

This is a notice to UK and EU residents as required by applicable privacy laws with respect to personal data collected through websites operated under any of the Covered Domains (“Websites”).  This notice supplements and must be read in conjunction with the Company’s Privacy Policy.

Q88 Hellas PC (Agiou Alexandrou 29, Paleo Faliro, 175 61, Greece) and Q88 LLC (55 Post Road West, 2nd floor, Westport, CT 06880, USA) are the data controllers for your personal data collected in connection with use of services offered through the Websites (“Services”) in the European Economic Area, the United Kingdom and Switzerland.

Q88 LLC is the data controller for the personal data collected in connection with use of Services everywhere else.

Your personal data is primarily used to provide you with the Services you request. It may also be used to comply with legal obligations the data controllers are subject to or to fulfill our legitimate interests, such as to personalize your experience, develop and improve our services or to detect illegal activities.

You have a number of rights including the right to request access to, change, or remove your personal data – please see our the Company’s Privacy Policy – to learn more about managing your personal data or deleting your account.

Our Data Protection Officer can be contacted by emailing: GDPR-Request@q88.com

You have a right to lodge a complaint with your local Data Protection Supervisory Authority or  with the UK Information Commissioner’s Office: https://ico.org.uk/for-the-public.

A list of local Data Protection Supervisory Authorities can be found at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

For more information about the Company’s data collection and use practices please reference the data collection section of our Privacy Policy.