Effective Date: 6th February, 2024

​

This Privacy Policy (the “Policy”) describes the policies and procedures of Nautical Miles Group, (the “Company”, “we”, “our” or “us”) for the collection, use, storage, transfer, sharing and disclosure of information, through our Website, www.nm-club.com (the “Website”), which includes its applications, widgets or online services owned or controlled by the Company. This Policy applies to all users and visitors of the Website of the Company.

​

Your privacy is extremely crucial to us. By reading this Policy and by your action to create an account and use our services as a legal adult or as the legal guardian or Parent for an account created with us you provide an informed consent to have read, agreed and understood to abide by this Policy.

​

If you are the parent or legal guardian of a child under applicable age based on country regulations, you will find that we have high privacy standards towards children accessing our platforms. We comply with the Children’s Online Privacy Act (the “COPPA”) and partner with parents and legal guardians to ensure your child’s safe use of our services. Under the COPPA Rule we take reasonable steps the security of children's and protect this data from unauthorized access, disclosure, or misuse.

​

Please read through this Privacy Policy carefully in order to understand how the Website collects, stores, uses, discloses, retains, and protects your personal information. If you do not provide the information which the Website requires, we may only be able to provide limited Services (as defined in our Terms of Service) to you.

​

By accessing or using our Services and / or registering an account on our Website, you agree to the handling of your information as described in this Privacy Policy. However, you retain the utmost control over your data. You are hereby informed about your choices regarding the use, access, correction, and deletion (where applicable) of your personal information. Any dispute over the privacy of your information is subject to this Privacy Policy and the applicable Terms of Service, including their mechanisms for resolving disputes and limitations on damages.

​

The Terms of Service are incorporated by reference into this Privacy Policy and, for the sake of brevity, are hereinafter referred to as “Terms of Service”.

​

This Privacy Policy also articulates the rights users have concerning the information collected on our Website. By submitting information through our Website, you affirm that you possess the authority to authorize us to process your data on your or your child's behalf, adhering to this Policy. We urge you to review it thoroughly, especially if you are under applicable age based on country regulations. If you are a child, please ensure that a parent or guardian reads it on your behalf.

​

1. SCOPE OF THIS POLICY

​

1.1   This Privacy Policy applies to users who create an account, subscribe to our services, or submit personal information through our website. Visitors who only browse the website without interacting are not subject to this policy.

​

1.2   Any reference to the term “you” throughout this Policy shall mean and include all the users of this Website.

​

1.3   This Policy applies to your use of this Website and the services being provided by the Website, regardless of how you access or use this Website (including access via desktop, mobile devices and mobile applications)

​

1.4   For the purposes of any account for the users our services are not directed towards children. The parent / guardian, is the primary account holder  and hence, you, the parent / guardian:

​

1.4.1   Are primarily responsible for requesting services and paying any fees or other charges made to the account;

 

1.4.2   Are responsible for deciding whether to share your child’s content with third parties;

​

1.4.3   We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately for deletion

​

2.INFORMATION WE COLLECT

​

At Nautical Miles Club, we believe that you can have great products and great privacy. This means that we strive to collect only the personal data we need. When you register an account with us as a member or partner with us to avail our Services, and during the course of our connection with you, we collect certain the following categories of personal information.

​

Information collected from the users

​

2.1  Account Information: related account details, including email address, devices registered, account status.

​

2.2   Basic Information: Personal data, which you may share with us while registering an account on our Website to avail the benefits of our Services including your first and last name, date of birth, country and city of residence and contact information like your email address, phone number and other contact information.

 

2.3   Corporate Information: include information like ship name/type, rank, and department from active / retired seafarers, ship agent or corporate staff.

 

2.4   Financial Information: Your financial details, such as credit card numbers, preferred payment methods, and transaction specifics, are securely stored exclusively with our trusted third-party payment processing partner. These details are maintained with the highest industry-standard protocols and security measures, ensuring the utmost protection for both your information and our company's integrity.

​

2.5  Device Identification Data: information which may assist us to identify your device, including your IP Address, login information, browser type and version, your operating system, etc.

 

2.6   Fraud Prevention Information that helps us identify and prevent fraud, including a device trust score.

​

Optional information collected from the users/ usage data

​

​2.7   Conversations with us: Content of your emails, chats shared with us by you for any purposes, whenever you may choose to connect with us regarding our services, for dispute resolution purposes, customer care services, inquiries, etc.

​

2.8   Other data which we may collect from you during the course of your engagement with us including:

​

•  Whether you use our mobile application - iOS or Android or web application or both;

​

• Whether you are a member or a partnering business enterprise;

​

• Whether you are eligible for benefits under our C-Dior scheme;

​

• Statistics about whether you open the push notifications sent to you, including that of the events, special offers, rewards and incentives available and likelihood of opening such notifications;

​

•  Usual time at which you use our Website or mobile application and the amount of time spent on our Website or mobile application, etc.

​

• Data which may be legally required to be collected from you for the purposes of your authentication, for obtaining verifiable parental consent, identification or verification.

​

3. MEANS OF COLLECTION OF YOUR DATA

​

Most of your personal or other data collected from you whenever you register a membership account with us, have a partnership with us use our Website.

​

Information collected automatically

​

3.1.1   Data that is collected automatically as soon as you register an account with our Website (for example, your personally identifiable data).

​

3.1.2   Data that is generated as part of one of your transactions or that is linked to your membership account as a result of a transaction in which you are involved, such as transaction amounts, card details, time and location of transactions.

​

3.1.3   Data that is generated through your other actions when you use our Website and which is linked to your account on our Website, e.g. when you surf our Website to look for various shopping outlets in your region, or when you browse products and their details;

​

3.1.4   Data regarding all other interactions with our Website including your location related information (like your IP address and location) and your communications with us.

​

Personal Data we collect in connection with the use of cookies and similar technologies

​

​3.1.5   We use web beacons and similar technologies to collect data in connection with our Services. We collect this data from the devices (including mobile devices) that you use to avail our Services. The data collected includes the following usage and device-related information:

​

• Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our Website and in email content.

​

• Data about your activities and interactions with us including data about the push notifications, when and where they were shown, and whether you took any action, such as clicking on it and opening the app.

​

• Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, individual device token, and cookie-related data (e.g. cookie ID).

​

• The IP address from which your device accesses our Services.

​

3.2.When the information is automatically collected by software

​

We may also employ software technology known as “web beacons” and/or “tracking tags” as part of data collection mentioned under section 3.2 to help keep track of what content on our Website is effective. Web beacons are small graphics with a unique identifier that may be invisible to the user, and which are used to track the online activity of internet users. Web beacons are embedded in the web pages reviewed or email messages received. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, to monitor how users navigate the Website, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.

​

3.3.Cookies

​

3.3.1   Our Website, uses cookies and similar technologies to provide you with a better, faster and safer user experience. Cookies are small text files that are automatically created by your browser and stored on your device when you use the Website.

​

3.3.2   The cookies and similar technologies used in connection with the services which the Website is providing have different functions listed below:

​

• They may be technically necessary for the provision of our services.

​

• They help us optimize our Services technically (e.g. monitoring of error messages and loading times).

​

• They help us improve your user experience (e.g. save font size and form data entered).

​

• They help us in recognizing you whenever you sign-in to your membership account on our Website which would help us personalize your experience with our services.

​

• They allow us to show you more relevant marketing and promotional information.

​

• They help us in understanding and keep track of your preferences.

​

• They also help us in analyzing the performance of our services.

​

3.3.3   You are also free to disable the use of cookies and similar technologies if this is supported by your device. You can manage your cookie settings in your browser or device settings.

​

3.4.Personal Data collected from Other Sources

​

We may also collect information about you from other sources, to the extent permissible by law. In particular, the same includes the following data:

​

• Data from public sources, for example, demographic information;

​

• Data from data providers;

​

• Data from government agencies, to the extent permissible by law in order to verify your identity.

​

4. PURPOSE FOR COLLECTION OF YOUR DATA

​

4.1   We collect your personal data lawfully and in a transparent manner and only when we have a legal basis for doing so. We process your personal data for various legal and permissible purposes. As example:

​

4.1.1 to provide and improve our services,

 

4.1.2 to understand the age of the user, to obtain verifiable parental consent as outlined in clause 1.4, for operating our website and to send personalized marketing notifications to you regarding discounts available to you as a user of the Website.

​

4.1.3 to provide customer service and to detect, prevent, mitigate and investigate fraudulent or illegal activity.

​

4.2   You have the right to change your mind any time (however, this will not affect any processing that has already taken place).

​

4.3.We process your personal data in order to allow you to use our Services as a Member or as a Business Partner.

​

4.3.1   For provision of our Services: We collect your personal data in order to process your registration on our Website as a member to a specific member category, to enable you to use our Services provided via our Website, to respond to your queries and all other ancillary services which we may provide to you from time to time in lieu of your usage of our Website.

​

4.3.2   For displaying your transactions history to you: We collect and retain your data in order to provide you with your transaction related history to enable you to keep a record of it. It shall further enable you to track your membership with us which would therefore enable you to renew the same before expiration.

​

4.3.3   For enhancement of our Services: We process your data, your feedback, the issues encountered while using our Services through our Website or technical glitches encountered by you to continuously upgrade and improve our services.

 

4.3.4   For providing recommendations based on your membership history, including but not limited to recommending the information pertaining to the special events, offers, rewards etc. to you, providing you with notifications about upcoming promotions or deals, providing you with information about change in pricing of membership services provided by the Website, sharing information about new business partners in your region added by us from time to time, etc.

​

4.3.5   Providing general customer support including the solution of problems with your usage of our Website, management of disputes, providing other services within the scope of customer service as well as enforcement of claims, if any. For these purposes, we may contact you via notification in email, telephone, SMS, push notification on your mobile device or by mail. If we contact you by telephone, in order to ensure efficiency, we may use automatically dialed calls with tape announcements or automated text messages in accordance with our Terms of Service, to the extent permitted by applicable law.

​

4.3.6   Processing of general location data (such as IP address or zip or postal code) in order to provide you with specific location-based services and other content that is personalized on the basis of your general location data.

​

4.3.7   Enforcement of our Terms of Service.

​

4.4.We process your personal data in order to comply with legal obligations to which we are subject. This includes the following purposes:

​

4.4.1  To obtain verifiable parental consent from you when your child’s personal information is shared with us.

​

4.4.2   Participation in investigations and proceedings (including judicial proceedings) conducted by public authorities or government agencies, in particular, for the purpose of detecting, investigating and prosecuting illegal acts.

 

4.4.3  Prevention, detection and mitigation of illegal activities (including but not limited to fraud, money laundering or terrorist financing).

​

4.4.4   Complying with information requests from third parties based on any statutory information rights they have against us (e.g. in the event of an intellectual property infringement, product piracy, or other unlawful activity).

​

4.4.5   Ensuring the information security of our Services.

​

4.4.6   Retention and storage of your personal data to comply with specific legal retention requirements.

​

4.5.We process your personal data in order to protect your vital interests or the vital interests of another natural person. This includes the following purposes:

​

Prevention, detection, mitigation and investigation of unlawful activities that may result in impairment of your vital interests or the vital interests of another natural person, unless there is a statutory obligation to this effect.

​

5. DURATION OF RETENTION OF YOUR DATA

​

5.1   Data collected from children below the age specified by country specific regulations shall be deleted as soon as:

​

5.1.1 The purpose for which the data was collected has been met;

​

5.1.2 If the concerned user has decided to delete their account;

​

5.1.3 If the user has unsubscribed from our services;

​

5.1.4 If the parent of such a user has requested for deletion of data of such a user.

​

5.2   Data collected from users above the age of 16 (sixteen) shall be retained indefinitely unless you request that we delete certain information, either in the form in which you have submitted it to us or in the form of backups or copies made for business continuity purposes. If you have provided us with personal data, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you.

​

5.3   Your data shall be safely retained by us after the same has been provided to us. Hence, we shall not delete your personal data even after you have stopped using our Services for the following reasons:

​

5.3.1   Provision of Services: We shall retain your data to effectively provide you with Services through our Website. Further, we shall retain your data for such things as executing the Terms of Service with you, maintaining and improving the performance of our Website, keeping our systems secure, and maintaining appropriate business and financial records.

 

5.3.2   Statutory or contractual or other similar obligations: Corresponding storage obligations may arise, for example, from laws or official orders. It may also be necessary to store personal data with regard to pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.

​

6. DATA SHARING

​

6.1   We may share your data with third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, third party data / cloud storage providers, payment service provider, web-hosting and server providers, our employees, contractors and/or related entities; courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and third parties, including agents or sub-contractors, who assist us in providing information, services or direct marketing to you.

​

6.2   We do not share user information with any third parties for the purposes of direct marketing by them unless consented to by you, and any sharing of information shall only happen with the affiliates, vendors, employees and representatives of the Company.

​

6.3   We may use data processors for providing some elements of services. But we have contracts in place with them. This means that such third parties shall process the data only in accordance with the terms of the contracts and with the objective to provide the requested services. Such third parties shall hold your personal data securely and retain it for the period instructed, in accordance with appropriate data retention policies.

​

6.4   In some circumstances we may be legally obligated to share your personal data such as in the event that the information is sought under a court order or where the Company is cooperating with other American supervisory authorities in handling complaints or investigations. We might also share information with other regulatory bodies or law enforcement agencies in order to further their, or our, objectives. In any scenario, before sharing any personal data of the user we will satisfy ourselves that there is a lawful basis on which to share the information and shall document such decision making and satisfy ourselves on the subject of having a legal basis to share the information.

​

6.5   Your personal data is only shared by us, for the purposes set out in the present Policy. In order to enable a seamless flow of Services, we shall share your personal data with:

​

Your personal data shall be processed in accordance with this Policy and shared with our service providers on a need-to-know basis. Hence, the service providers shall only be made aware about your personal data and information which is extremely necessary for provision of Services. Further, we shall share your banking or credit card details with our payment Service Provider, viz. “Stripe” for the purposes of processing payments seamlessly. We also share your information with third party servers who store your data for safety (i.e. Amazon Web Services or MongoDB Cloud).

​

6.6   Third Party Database Service Provider / Cloud: We share your personal data with our third party database service provider, i.e., Amazon Web Services or others, who shall securely store your personal data. In view thereof, your data shall be shared with Third Party Database Service Provider / Cloud who shall process your data in accordance with this Policy.

​

6.6.1 Third Party Database Service Provide/ Cloud shall share your personal data with their service providers to facilitate seamless protection of your data.

​

6.7     We share your information with our officers and employees for the purpose of processing your personal data on your behalf, and it is ensured that these recipients of such information agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.

​

7. SAFETY AND SECURITY OF YOUR DATA AND STORAGE

​

​7.1     All reasonable and necessary steps to protect your personal data during transmission by using encryption protocols and software, however no security measures can be 100% foolproof.

​

7.2     SSL encryption is used to protect your data against unauthorized access and loss of data.

​

7.3     We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, processing, and disclosure of personal data and only users who have permission by the administrator can access your data at the back-end.

​

7.4     To protect yourself against unauthorized access to your password and to your computers, devices and applications. You must be sure to sign off when finished using a shared computer.

​

7.5     All data is safely and securely stored on a third-party database/ cloud, specifically employed by us for the purpose of secure storage of your personal data.

​

7.6     Our company handles all personal data according to the laws of the EU-Data Protection Regulation (EU-GDPR) and the Federal Data Protection Act (BDSG New)

​

8. YOUR RIGHTS AS A DATA SUBJECT

​

You, as a data subject, have certain rights to the personal data which has been provided by you to us. We have enlisted the same, hereunder:

​

8.1     As a registered member/partner on the Website, you can update your choices of communication that you may receive in the course of your interaction, or you can opt out of receiving any marketing communication, or receiving push notifications, or any other promotional communication.

​

8.2     You can access the information which has been retained by us by visiting the “Profile” section of our Website which would display information supplied by you to us. Information which you shall find in that section would be:

​

• Status of your subscription,

​

• Your personal data, like your name, email, password, and other details

​

• Status of your membership with us;

​

8.2.2  Should you require any further access to the information retained by us, you may contact us at: legal@nm-club.com.

​

8.3     We ensure to keep your data up to date. Further, you can request us to update/correct your information which is in our records. You have the options built-in the app/ website to do it on your own. Alternatively, you may reach out to us at: legal@nm-club.com.

​

8.4     You can exercise your rights as a data subject via our Website per the details contained within the present Policy. You won't be charged for exercising your rights as mentioned above.

​

8.5     You have the right to ask us to rectify information that you find inaccurate, or to complete the information that is otherwise incomplete.

​

8.6     You have the right to ask us to erase any and all personal data that we have collected and are holding in certain circumstances. Please note that we may not be able to honor all requests for deletion of your personal data since certain information may be required to be retained either to meet the requirements of law or for the purpose of audit or for the purpose of maintaining business continuity. In addition, if you have yourself posted information which is publicly available, we may not be able to honor requests for deleting the same.

​

8.7     You have the right to ask us to restrict the processing of your personal data in certain circumstances.

​

8.8     You have the right to ask us to transfer the information that has been shared by you from one organization to another, or ask for it to be given back to you. But such right shall apply only if we are processing the information of the user based on his consent, or we are having a communication with the user for entering into a contract and the processing is automated.

​

8.9     The Company works to high standards when it comes to processing user’s personal data. If you have any queries or concerns, you can address the same vide complaint to the legal@nm-club.com, and we shall duly respond.

​

8.10    The Website may include links to third party Websites, plug-ins, services, and applications. Clicking on such links may allow respective third parties to collect or share data about you. We neither control nor endorse these third party services and we are not responsible for their privacy statements. When you leave our Website or access third party links through the Website, we encourage you to read the privacy policy of such third party Service Providers. Clicking on a Third Party Offer will redirect you to a Third Party website not governed by this Policy. We disclaim any liability for information made available on or through these links. Even though we may earn an affiliate commission on link access or participation, the access to such Third Party websites shall be at your own risk.

​

8.11    If we receive personal data about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such person’s consent to provide the personal data to us.

​

8.12    You may choose to restrict the collection or use of your personal data. If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal data, we will let you know how the restriction affects your use of our Website or products and services.

​

8.13    You may request details of the personal data that we hold about you. You may request a copy of the personal data we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal data we hold about you at any time. You may also request that we transfer this personal data to another third party.

​

8.14     If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

​

8.15    We will comply with laws applicable to us in respect of any data breach.

​

8.16    If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

​

8.17    In case of any data breach, cyber hacking, or otherwise, we shall take reasonable steps and legal actions against such illegal activities and in no circumstances, the user will have any right to claim any damages including but not limited to liquidated or unliquidated.

​

8.18    To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

​

9. CHANGES TO THIS POLICY

​

​9.1     With or without notice we may change this Policy in order to meet with the changing requirements of the business or law, from time-to-time, per our sole discretion. Any material changes or updates made to this Policy will be notified via a notice on our Website or via email to you. If you are a Service Provider, changes to this Website’s Privacy Policy may be notified to you via your dashboard. Further, the Effective date subsequent to changes shall be indicated at the top section of this Policy with the title: “Last Updated On”.

​

10. CONTACT US

​

If you have any queries, complaints, or concerns with regards to content and or breach of these terms, please immediately reach out to,

Designation: Communication Officer

Email address: legal@nm-club.com