PRIVACY POLICY

Crossworld Marine Services, Inc.

1. Introduction

This policy contains Crossworld Marine Services, Inc.’s (Crossworld or the Company) commitment regarding the collection, use, protection, and disclosure of Personal Information during the use of its Electronic Application (App). Crossworld is a company registered in the Republic of the Philippines, engaged in the business of recruitment, selection and placement of human resources for sea based employment. The Company and its related entities are collective known as the “Crossworld Group.”

Crossworld is committed to protecting your data privacy. We will not use or share your information or data with anyone except as described in this Privacy Policy. In processing personal information or data, we seek to adhere to the general privacy principles of transparency, legitimate purpose, and proportionality, and such other relevant principles in the collection, processing, and retention of personal data as required by applicable law.

We use your Personal Information or Data for providing and improving access to our App. By using the App, you agree to the collection, use, processing and storage of your personal information or data in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

2. Data Collection, Use, and Retention

1. Upon registration, you will be required to provide your personal information to be used to identify and activate your account. We will not collect any personal data from you, unless:

1. Specifically required for purposes of activating your account, or as may be necessary in completing transactions and process within our App;

2. Those provided by you in order for the Company to perform recruitment, employment, or deployment process; and

3. Those you voluntarily provided during your registration and use of the APP in the knowledge that will be used or shared in accordance with the available functionality of the APP (please refer to Agreement to Terms of Access and Use)

2. Any personal information or data collected through our App or during the employment or recruitment process, or that you provide voluntarily to the Company via the APP, are processed only by authorized Company personnel and agents for the very purpose for which you have provided them, legitimately, and in accordance with law.

The ways we may use information collected under II.1 serve the purposes of use and functionality of the APP and include (but not limited to) the following:

1. To identify you and to provide you access to the APP;

2. To update your personal information and documentation to facilitate your communication with the Company;

3. To provide you links to be able to access third party websites

4. To administer our App including functions related to testing and troubleshooting, statistical and data analysis, and research purposes in order to improve the APP and the offered functionality and overall user experience.

3. We will store and retain personal information or data for such period as may be required by applicable law or as may be needed to enable us to fully and efficiently achieve the purposes for which they were collected.

3. Rights of the Data Subject

Under the Data Privacy Act of 2012, data subjects have the following rights:

1. Right to object

As a data subject, you have the right to indicate your refusal to the collection and processing of your personal data, including processing for direct marketing, automated processing, or profiling. You also have the right to be informed and to withhold your consent to further processing in case there are any changes or amendment to information given to you. Once you have notified us of the withholding of your consent, further processing of your personal data will no longer be allowed, unless:

(i) The processing is required pursuant to a subpoena, lawful order, or as required by law; or

(ii) The collection and processing are undertaken pursuant to any lawful basis or criteria indicated under the Data Privacy Act of 2012.

2. Right to access

Upon your request, you may be given access to your personal information or data that we collect and process. You also have the right to request access to the circumstances relating to the processing and collection of your personal information or data, insofar as allowed by law.

3. Right to rectification

You have the right to dispute any inaccuracy or error in your personal information or data and may request for its rectification. Upon your request, and after correction has been made, we will inform any recipient of your personal information or data of the said inaccuracy and/or correction.

10.4 Right to erasure or blocking

In the absence of any other legal ground or overriding legitimate interest for the lawful processing of your personal information or data, or when there is substantial proof that it is incomplete, outdated, false, or has been unlawfully obtained, you may request us to suspend, withdraw, or order the blocking, removal, or destruction of your personal information or data from our system. We will also notify those who have previously received your processed personal information or data.

4. Right to damages

You have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use, collection, processing or storage of your personal information or data, taking into account any violation of your rights and freedom as a data subject, as provided by the Data Privacy Act of 2012.

5. Right to data portability

In case your personal information or data was processed through electronic means and in a structured and commonly used format, you have the right to obtain a copy of your personal information or data in such electronic or structured format for your further use, subject to the guidelines of the National Privacy Commission with regard to the exercise of such right.

4. Transmissibility of rights of the data subject

Upon the passing of a data subject, or in case of a data subject’s incapacity or incapability to exercise legal rights, the data subject’s lawful heirs and assigns may invoke the data subject’s rights in place of the data subject.

5. Limitation on rights; manner of exercising

The rights mentioned under this item are not applicable if personal data are processed only for scientific and statistical research purposes, and without being used as basis for carrying out any activity or taking any decision regarding you as the data subject. Your rights as a data subject are also subject to other limitations provided by law.

The law requires you to exercise your rights as described in this Policy in a reasonable and non-arbitrary manner, and with regard to rights of other parties.

All requests, demands or notices which you may make under this Policy or applicable law must be made in writing, and will only be considered made and received if sent personally or via electronic mail to the rightful addresses of the personnel concerned.

6. Disclosure of Information

By submitting any information via this App or directly over email, you agree that we have the right to use, process, share and store this information you have provided in order to properly respond and act on the enquiry with:

• Any member of the Company, including international subsidiaries and affiliates;

• Selected authorized third parties including business partners/agencies, suppliers, and sub-contractors; and

• When we are under the duty to disclose as provided by law, or when compelled by legal processes.

7. Policy Revisions

The Company reserves the right to revise this Privacy Policy as may be necessary or as may be required by amendments, updates, or requirements by applicable law. As data subject, you agree to be bound by such changes as soon as informed through the App or such other modalities that the Company may prescribe.

If you have questions with respect to the use, processing and storage of your personal information or data you may contact the Company’s Data Protection Officer at:

legal@crossworldmarine.com