Privacy Policy
Effective date: 26 July 2025
This Seareviews Privacy Notice (the “Notice”) is issued on behalf of SeaReviews B.V. registered at De Nieuwe Erven 3, 13355, 5431NV Cuijk under registration number 97740993 (“Seareviews”, “we”, “us” or “our”) and applies to Seareviews users using the Seareviews Services (the “Users”, “you”, “your”).
The Services
This Notice is designed to fully inform you about our privacy practices including the collection of any information relating to an identified or identifiable natural person (“Personal Data”), how we use Personal Data, your rights, and how to exercise them.
Who are we?
Seareviews is acting as the controller and is therefore responsible for processing your Personal Data, and determines the purposes and means for processing. Seareviews uses and protects Personal Data you share when visiting a Seareviews website and/or using the products and services offered by Seareviews (collectively “Services” or “Service”). If you are part of the workplace’s management listed on our Services (the “Management”), you may apply for the admin functionality on our Services. Please see our Terms of use for more information.
If you have any questions about this Notice or how we process your Personal Data, please contact us at privacy@seareviews.com.
How we may use your Personal Data
We have set out per purpose for processing, the Personal Data we may process, and the legal basis for processing. All Personal Data is collected from you directly.
| Why we process your Personal Data (purpose) | Types of Personal Data | Legal basis |
|---|---|---|
| To manage and maintain your Seareviews account | Your email address, acceptance to the Terms of Use, date of account creation, and User ID | Necessary for our legitimate interests, namely to manage and maintain your Seareviews account |
| To verify whether you work(ed) on the workplace you review(ed) | Your information included in your seamen’s discharge book (such as the name of the ship, date and place of joining the ship and leaving ship, role (capacity), signature of master (captain) or an authorised person, official yacht/company stamp), and information included in your employment contract (such as employer name and address, your name, date of birth, place of birth, yacht details, ship owner, role (capacity), period of employment, remuneration (salary), annual leave, and your signature). | Necessary for our legitimate interest, namely to enhance authenticity of the reviews on our platform |
| To verify whether you are the Management of a workplace listed on our Services | For Management only, your information included in your email signature (such as your name, your role and yacht details), information included in your discharge book (such as the name of the ship, date and place of joining the ship and leaving ship, role (capacity), signature of master (captain) or an authorised person, official yacht/company stamp), and information included in your employment contract (such as employer name and address, your name, date of birth, place of birth, yacht details, ship owner, role (capacity), period of employment, remuneration (salary), annual leave, and your signature). | Necessary for our legitimate interest, namely to ensure we only provide the admin functionality of our Services to Users that qualify as Management. |
| To manage and maintain your reviews and responses on our Services | Your ratings (of the accommodation, food, perks, compensation, professional development, the culture and leadership, and safety), your role, employment status, work period, date the rating was posted, and any other data you share within your review, including but not limited to your personal experiences. For Management only, any personal data you share in your responses to the reviews related to your workplace. | Necessary for our legitimate interests, namely to provide an overview of workplaces to enable individuals to make informed career decisions |
| To respond to your contact requests, questions, comments, and feedback | Your email address, name, and any other Personal Data you share in your communication with us. | Necessary for our legitimate interests, namely to communicate with you. |
| To improve Seareviews Services (by using surveys, online questionnaires, and pilot testing) | Your email address, name and your responses to our surveys, questionnaires and pilots. | Necessary for our legitimate interests, namely to provide a better user experience |
| To ensure our Services work properly | The Personal Data collected via the Strictly Necessary Cookies, Functional Cookies and Limited Performance Cookies as explained in Section 3 below, including but not limited to your verification token and session token (to keep you logged in), IP-addresses, website visit and use, duration and time of visit to the website. | Necessary for our legitimate interests, namely to provide you with our Services and to ensure our website and Services work properly and smoothly |
| To meet all legal and regulatory requirements applicable to Seareviews, or as otherwise required by law or regulation, or requested by competent authorities | Your email address, name, and any other Personal Data that requires processing to meet our legal and regulatory requirements. | To comply with a legal obligation |
| To participate in an acquisition, merger, restructuring, sale or other transfer involving all or any portion of Seareviews assets or business. | All types of Personal Data listed in this column. | Necessary for our legitimate interests, namely to transfer the Services to a successor, and to ensure continuation of the Services. |
Cookies
A cookie is a text file placed onto your device when you access our Services. We use cookies and other tracking technologies such as web beacons, and flash object storage in the following ways:
| Strictly Necessary Cookies | We or a third party on our behalf set these cookies to enable you to use the basic features of our Services, such as logging you into our Services, and keeping you logged in, technically deleting content, setting your privacy preferences or filling in forms. Without these cookies, the services you have asked for cannot be provided. This makes these cookies essential. |
| Functional Cookies | These cookies allow our website to remember information about you such as your preferred language and configuration and provide enhanced, more personal features and content. |
| Limited performance Cookies | These cookies gather data to help us understand how you use Services, and how often, so we can improve them to deliver a better experience for our Users and carry out research and statistical analysis to help improve our content, products and services. For example, these cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Services. |
Who has access to your Personal Data?
We handle your Personal Data discreetly. Access is strictly limited to Seareviews, our third-party service providers, and other necessary recipients, on a need to know basis.
Our third party service providers concern:
- vendors that help us to manage and maintain the Seareviews IT infrastructure (such as our cloud storage provider, and third party deployment platform);
- a professional emailing provider that deploys our email service;
- where relevant, our professional advisors, such as legal and financial intermediaries, including but not limited to legal and consulting professionals, financial institutions and other professionals.
Further, we may disclose Personal Data if we believe in good faith that the disclosure is necessary in order to:
- comply with relevant laws or to respond to subpoenas, warrants, or legal processes served on us (though we reserve the right at our sole discretion to take action on behalf of our Users and their possible right to anonymity when we believe there is a legitimate basis to do so);
- enforce our Terms of use , this Notice, and any other agreements we may have;
- prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity;
- act in a manner we otherwise deem necessary and is permitted by applicable laws to protect and defend the rights or property of us, the Users of our Services, or any third parties; or
- act as permitted under applicable laws to meet national security and similar requirements.
We may also disclose Personal Data in a reorganization, merger or sale of our company or assets, subject to the acquirer and its affiliates (as applicable) accepting the commitments made in this Notice and compliance with applicable law.
Children’s Privacy
The Seareviews Services are not intended for individuals under the age of 18. No one under the age of 18 is authorized to provide any Personal Data to Seareviews. We do not knowingly collect Personal Data from members in this age group. If we learn that we have collected or received Personal Data from a child under the age of 18, we will take reasonable steps to delete that Personal Data. If you believe we might have any Personal Data from or about a person under 18, please contact us at privacy@seareviews.com.
Your rights
You have multiple rights, and we want to ensure they are respected. If you wish to exercise any of the rights listed below, please send your request to privacy@seareviews.com. Please state clearly in the subject heading the type of your request, including a detailed explanation of your request. This enables us to respond to your request as quickly as possible. Please confirm as a minimum: The email address your account is associated with.
Your data subject requests will only be exercised after we have validated your identity. This can be achieved by sending the request from the same email address that was used when you created an account on our Services. If your identity is not clear, we are entitled to ask you to provide proof of your identity before we handle your request.
We will respond to your request within one month, but have the right to extend this period by two months. If we extend the response period, we will let you know within one month from the receipt of your request.
- Access: You may ask us if we are processing your Personal Data and, if we do, you can request Seareviews to provide a copy of the Personal Data we hold about you. If your request is clearly unfounded or excessive, we reserve the right to charge a reasonable fee or refuse to comply in such circumstances.
- Rectification: If you believe that the Personal Data that we process is incorrect, inaccurate or incomplete, you may ask us to correct the Personal Data.
- Erasure (‘Right to be forgotten’): If you want us to remove your Personal Data, you can request us to erase your Personal Data. There are certain exceptions where we may refuse a request for erasure, for example, for exercising the right of freedom of expression and information, where the personal data is required for performance of the contract, compliance with law or in connection with legal claims, and for reasons of public interest in the area of public health.
- Restriction: You may request us to suspend the processing of certain types of your Personal Data, for example if you want to establish its accuracy or the reason for processing it.
- Portability: If you want to transfer your Personal Data to you or to another party, you may request us to do so in a structured, commonly used, and machine-readable format (if technically feasible).
- Object: If we are processing your Personal Data based on our legitimate interest, you may object to our processing on this ground. However, in those cases we may be entitled to continue processing your Personal Data based on our compelling legitimate interests.
- Right to withdraw your consent at any time: Where you may have provided your consent to the processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Please note that the withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.
- The right to not be subject to solely automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. Seareviews has not implemented solely automated decision-making, and therefore, this right is not enforceable.
- Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with a supervisory authority in the country of your residence where you work or where an alleged infringement of the applicable data protection law took place. A list of EU data protection authorities is available here.
International Data Transfers
We use technology service providers and cloud-based services located outside the European Union (“EU”) for our business purposes. Therefore, it may be necessary to transfer your Personal Data to servers located in countries outside the EU.
In case of transfers of Personal Data to countries outside the EU that are not recognized by the European Commission as providing an adequate level of data protection (Adequacy Decision), we ensure appropriate safeguards are in place to guarantee the continued protection of your Personal Data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR), as well as conducting the required assessments. For more information on these Standard Contractual Clauses, please see here.
How long do we keep your Personal Data
We do not process your Personal Data any longer than necessary for the purposes outlined in this Notice. If Personal Data is subject to a statutory retention period, we will retain your Personal Data for the period specified by the law.
To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the purposes for which we process your Personal Data, applicable legal requirements or operational retention needs, and whether we can achieve those purposes through other means.
Upon expiry of the applicable retention period, we will securely destroy your Personal Data in accordance with applicable laws and regulations. In some circumstances, instead of destroying your Personal Data, we may anonymize your Personal Data, which means that it can no longer be associated with you.
Updates to this Notice
This Notice may be amended from time to time. Therefore, you are encouraged to review it regularly. Check the date included at the top of this Notice to see whether this Notice has been updated, as your continued use of Seareviews Services following the posting of changes to the Notice signifies your continuing awareness of this Notice.