SeaARCTOS Management LLC Web Site

Privacy Policy and Cookie Use

1. Acceptance of the Privacy Policy

The privacy and security of your personal information is of utmost importance to SeaARCTOS Management LLC (“SeaARCTOS”, “we” and/or “us”).  The Services that we provide you are subject to the following Privacy Policy (the “Privacy Policy”).  This Privacy Policy applies to all SeaARCTOS sites within the “” domain name.  The most current version of the Privacy Policy can be reviewed by clicking on the “Latest Privacy Policy” hypertext link located at the end of this web page.  We have developed this Privacy Policy to explain SeaARCTOS’s policies with respect to the use, storage and disclosure of personally identifiable information (“Personal Data”) and other data collected through the web site.  By using this web site and accepting our Privacy Policy by checking “Accept” in the cookie pop-up window related to the “” domain name, you consent to the terms of this Privacy Policy.

2. Description of Services

Through our network of web properties, SeaARCTOS provides you with access to a variety of resources, including our public website, extranet, web services, download areas, communication forums and product information (including, but not limited to, any updates, enhancements, new features, and/or the addition of any new web site related features to the “” domain name) (our “Services”).

3. Personal and Non-Commercial Use Limitation

Unless otherwise specified and authorized by SeaARCTOS, the Services we provide you are for your personal and non-commercial use.  You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any information, software, products or other services obtained from our Services.  Specifically, this includes a prohibition on the unauthorized use of automated software to retrieve, display, copy, store or otherwise use data obtained from our Services.

4. Unlawful or Prohibited Use

As a condition of your use of our Services, you will not use our Services for any purpose that is unlawful or prohibited by these terms, conditions, and notices.  You may not use our Services in any manner that could damage, disable, overburden, or impair any SeaARCTOS server, or the network(s) connected to any SeaARCTOS server, or interfere with any other party’s use and enjoyment of any of our Services.  You may not attempt to gain unauthorized access to any Services, other accounts, computer systems or networks connected to any SeaARCTOS server or to any of our Services, through hacking, password mining or any other means.  You may not obtain or attempt to obtain any materials or information through any means not intentionally made available through our Services.

5. Member Account, Password, and Security 

You may use our public website without providing any Personal Data to us.  The information gathered during general browsing of the “” domain is used to analyse trends and usage of SeaARCTOS sites and to improve the usefulness of the sites.

If any of our Services requires you to open an account, you must complete the registration process by providing us with current, complete and accurate information as prompted by the applicable registration form.  You also will choose a password and a username.  You are entirely responsible for maintaining the confidentiality of your password and account.  Furthermore, you are entirely responsible for any and all activities that occur under your account.  You agree to notify SeaARCTOS immediately of any unauthorized use of your account or any other breach of security.  SeaARCTOS will not be liable for any loss that you may incur as a result of someone else using your password or account, either with or without your knowledge.  However, you could be held liable for losses incurred by SeaARCTOS or another party due to someone else using your account or password.  You may not use anyone else’s account at any time, without the permission of the account holder.

6. Collection of Personal Data

When you use our Services, our systems automatically keep a log of your IP (Internet Protocol) address, domain name, browser type, operating system, and information such as the web site that referred you to us, the files you download, the pages you visit, and the dates/times of those visits.

If you register to use our Services, subscribe to a mailing list, provide feedback on our Services, we keep the Personal Data you provide to us securely in our database.  Our registration form requires users to provide certain Personal Data.  For example, users are asked to identify themselves, to provide contact information and their company or personal billing information.  Vessel operators provide certain Personal Data, such as vessel operation details.  We use this information to operate our web site (including by customizing certain features for more personalized use), to bill for Services provided, and to contact you as necessary.  We also post a list of current users on our web site and will use your Personal Data to obtain details for this list.

SeaARCTOS sites with specific requirements to collect Personal Data may publish a separate privacy policy specific for that site.  In these cases, the site-specific privacy policies will be complementary to this Privacy Policy, but will also give additional details for that particular site’s policies.

“Sensitive Personal Data” is a subset of Personal Data and is generally defined as any 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 geo-location information, financial and bank account numbers, or unique identifiers such as government-issued social security numbers, driver’s license, and passport numbers.  We do not collect “Sensitive Personal Data”.

Providing Personal Data on SeaARCTOS site is optional.  If you choose not to provide Personal Data, you can still browse and use SeaARCTOS site, but you will not be able to carry out certain actions.

Joining electronic discussion groups via the domain may mean that other participants of the discussion group (including non-SeaARCTOS employees) will see Personal Data that you have volunteered and for any open discussion groups, this information will be public.

7. How we use Personal Data

The Personal Data that we collect is used to:

  1. provide you information that you have requested or which may be relevant to a subject in which you have demonstrated an interest;
  2. fulfill an obligation or agreement that SeaARCTOS have entered into with you or with the entity that you represent;
  3. ensure the security and safe operation of our websites and underlying infrastructure, and/or
  4. manage any communication between you and us.

8. Our Disclosure of Your Personal Data.  

SeaARCTOS considers your Personal Data to be a vital part of our relationship with you.  We do not use Personal Data for profiling or automated decision making.  We will not share, sell or rent any Personal Data to third parties for marketing purposes without your consent.  There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

  1. Business Transfers.  As we develop our business, we might sell or buy businesses or assets.  In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
  2. Agents, Consultants and Related Third Parties.  SeaARCTOS, like many businesses, sometimes hires other companies to perform certain business-related functions.  Examples of such functions 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.
  3. External Links.  This web site may contain links to other web sites operated by third parties.  Before it engages with third parties, SeaARCTOS requires that the third parties maintain security measures that comply with applicable privacy and data protection laws.
  4. Legal Requirements.  SeaARCTOS may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of SeaARCTOS, (iii) act in urgent circumstances to protect the personal safety of users of the web site or other third parties, or (iv) protect against legal liability.

We share Personal Data with others only as described in this Privacy Policy, or when we believe that the law permits or requires it.

SeaARCTOS 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.

9. Managing your Personal Data

You may access a copy of the Personal Data we hold about you.  In order to process your request, please email  We will ask you to provide proof of identification for verification purposes.  Once we have verified your identity, we will provide access to the Personal Data we hold about you.

If at any point you believe the information we process on you is incorrect, you may request to see this information and have it corrected, completed or deleted.  If you wish to raise a complaint on how we have handled your Personal Data, you can email who will investigate the matter. 

If you are not satisfied with our response or believe we are processing your Personal Data not in accordance with the law, you can complain to the relevant supervisory authorities.  You may always request that we delete your Personal Data, including any Personal Data that you may have provided to us, and we will take all reasonable steps to ensure erasure.

Some of our Services that are made available through the web site allow users to store certain Personal Data on the web site.  We will not access, monitor or use the contents of any user’s Personal Data stored on our servers, except in the following circumstances: (i) the Personal Data is related to user identification and access authorization; (ii) the Personal Data is to be used to assist you, provided that you have consented to such use; (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 and conditions of our Services or applicable law, or that a user is engaging in actions which threatens the network, servers or client data, or otherwise threaten users’ property rights, the web site, SeaARCTOS and/or any third parties.

10. Security measures

We have what we believe are appropriate security controls in place to protect Personal Data, and we take appropriate steps to ensure that Personal Data is processed, secured, and transferred according to applicable law.  We do not share your information outside SeaARCTOS and will not use your information in ways other than those set forth in this Privacy Policy.  Risk assessment, including assessing risks to the Personal Data, is at the heart of our security controls.  However, we do not have any control over what happens between your device and the boundary of our information infrastructure.  You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information.

SeaARCTOS has a data protection regime in place to oversee the affective and secure processing of Personal Data.  SeaARCTOS takes reasonable steps to protect the Personal Data provided via the web site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  However, no Internet or e-mail transmission is ever fully secure or error free.  Therefore, you should take special care in deciding what information you send to us via e-mail.  With respect to your payment information, when applicable, please note that SeaARCTOS will work to protect the security of all your Personal Data during transmission over the Internet by using encryption methods for your credit card number and Personal Data.  SeaARCTOS 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.

All our employees who have access to, and are associated with the processing of your Personal Data, are obliged to respect the confidentiality of official business matters, including your Personal Data security.

The SeaARCTOS web site contains links to sites external and/or unrelated to the domain.  SeaARCTOS is not responsible for the privacy practices or the content of such sites.


11. Non-Identifiable Personal Data and Cookies

When you interact with SeaARCTOS through our web site, we receive and store certain non-identifiable information.  Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you.  SeaARCTOS may use such information and pool it with other information to track, including, but not limited to, the total number of visitors to our web site, the number of visitors to each page of our web site, and the domain names of our visitors’ Internet service providers.  It is important to note that no Personal Data is available or used in this process.  In operating our web site, we may use a technology called “cookies.”  A cookie is a piece of information that the computer that hosts our web site gives to your browser when you access the web site.  For certain SeaARCTOS sites, registering or supplying Personal Data sets a cookie.  By setting these cookies, we will remember your details the next time you visit, so you don’t have to re-enter the information.  This helps us remember your preferences, and generally improve the user experience.  Our cookies help provide additional functionality to the web site and help us analyze web site usage more accurately.  On most web browsers, you will find a “help” section on the toolbar.  Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off.  We recommend that you leave cookies turned on because they allow you to take advantage of some of our web site’s features.

12. Liability Disclaimer

Any usage of any SeaARCTOS websites as well as any related web services on the “” domain implies acknowledgement and acceptance of the terms and conditions set out in this Privacy Policy (the most current version of which can be accessed by clicking on the “Latest Privacy Policy” hypertext link located at the end of this web page).

13. Changes to this Privacy Policy

This web site and our business may change from time to time.  As a result, it may be necessary for SeaARCTOS to make changes to its Privacy Policy.  SeaARCTOS reserves the right to update or modify our Privacy Policy at any time and from time to time without prior notice.  Please review the Privacy Policy periodically, and especially before you provide any Personal Data.  The most updated version of the Privacy Policy will be available by clicking on the “Latest Privacy Policy” hypertext link located at the end of this web page.”  The current Privacy Policy was last updated on the date set forth in Paragraph 15 below.  Your continued use of our web site after any changes or revisions to the Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

14. Contacting Us

If you have any questions about anything in this Privacy Policy, or about the collection of Personal Data through our web site, please contact our privacy coordinator at:

Last Updated: July 1, 2021