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Your privacy is important to
The Trust Company of the Marshall Islands, Inc.
if you have any questions.
This policy may be amended at any time by posting a revised version at www.register-iri.com.
The revised version will be effective as of the time it is posted.
COLLECTION AND USE OF PERSONAL INFORMATION
Personal information is data that can be used to identify or contact a single person.
In addition, you have rights regarding the information you provide to the Companies. These include the right to:
access any information you have provided to the Companies;
correct any information you have provided to the Companies;
delete any information you have provided to the Companies;
object to the use of information you have provided to the Companies; and
have information you have provided to the Companies transferred to another company
Please note that if your information is required for the Companies to provide a service and you wish to restrict or delete that data, it may impact the ability of the Companies to provide such service(s). You will be advised of this outcome in the event that it arises.
Personal Information the Companies Collect
When you apply for any service, the Companies may collect a variety of information including, but not limited to: name, mailing address, phone number, email address, contact preferences, or other banking information.
Sometimes, in order to process your request, the Companies may have to collect a government-issued identification ("ID"), photo, or other form of documentation to prove your identity and/or residence (which may include an ID, number, or other similar unique identifier). The Companies may also have to collect certain information pertaining to your age or date of birth, marital status, ethnic origin, education, health, or disciplinary history.
Some examples of the services the Companies provide where the collection of personal information occurs includes processing or the assistance in processing of:
authorization of filing agents or qualified intermediaries;
formation, documentation, or other corporate services for an RMI non-resident
a billing account or address of record;
registration, documentation, and other services related to RMI registered vessels,
including investigations and inspections;
other activities in furtherance of or related to the above.
If you use the website at
(the "Payment Website"), then the following also applies:
TCMI may collect the Internet Protocol (IP) address and domain names of all visitors to the Payment Website in order to measure the Payment Website's effectiveness and to determine ongoing improvements. TCMI may also collect the email addresses from email messages received. No IP addresses, domain names, or email addresses will be shared with or sold to any other company or individual.
If the Payment Website services are used, the following types of information may also be collected by the Companies or a contracted third party:
contact information - user name, address, phone, email, Skype ID, and/or other similar information; and/or
financial information - credit card numbers that the user has provided through the Payment Website.
How the Companies Use Your Personal Information
The Companies may use your personal information, including date of birth, to assist with identification and to comply with local and international laws, trade regulations, and other similar obligations.
The Companies may also use personal information to help create, develop, operate, deliver, and improve services and advertising, and for loss prevention and anti-fraud purposes.
The Companies may also use personal information for internal and administrative purposes such as auditing, data analysis, and research to improve the Companies' services and customer communications.
From time-to-time, the Companies may use your personal information to send important notices, such as communications about current services and changes to our terms, conditions, and policies.
How Personal Information May Be Used If You Use the Payment Website
The primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience.
Personal information may be used to:
provide the requested TCMI services and customer support;
process transactions and send notices about user transactions;
resolve disputes, collect fees, and troubleshoot problems;
prevent prohibited or illegal activities;
customize, measure, and improve TCMI services and the content and layout of the
Payment Website and applications; and/or
compare information for accuracy and verify it with third parties when necessary.
Collection and Use of Non-Personal Information
The Companies also collect data in a form that does not, on its own, permit direct association with any specific individual. The Companies may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that the Companies collect and how the Companies may use it:
The Companies may collect information such as occupation, language, zip code, and area code so that the Companies can better understand customer behavior and improve their products, services, and advertising.
The Companies may collect and store details of how you use their services, including search queries. This information may be used to improve the relevancy of results provided by their services. Except in limited instances to ensure quality of the Companies' services over the Internet, such information will not be associated with your IP address.
If the Companies do combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.
COOKIES AND OTHER TECHNOLOGIES
Cookies may be encountered from third parties via links made available on the Payment Website which cannot be controlled by TCMI (for example, if a user views a website created by a third party or uses an application developed by a third party, there may be a cookie placed by that webpage or application).
he Companies treat information collected by cookies and other technologies as non-personal information. However, to the extent that IP addresses or similar identifiers are considered personal information by local law, the Companies also treat these identifiers as personal information.
As is true of most Internet services, the Companies gather some information automatically and store it in log files. This information includes IP addresses, browser type and language, Internet service provider ("ISP"), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. The Companies may use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve their products and services, and to gather demographic information about their user base as a whole.
In some email messages, the Companies may use a click-through uniform resource locators ("URL") linked to content on the Companies' websites. When you click one of these URLs, they pass through a separate web server before arriving at the destination page on the website. The Companies may track this click-through data to help determine interest in particular topics and measure the effectiveness of customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable the Companies to send email messages in a format users can read, and they tell whether mail has been opened. The Companies may use this information to reduce or eliminate messages sent to users.
DISCLOSURE TO THIRD PARTIES
At times the Companies may make certain personal information available to strategic partners or concerned parties that work with the Companies to provide products and services, or that help the Companies market to customers.
For example, if you serve on board an RMI flagged vessel, you authorize the Companies to share your information with other concerned parties, which may include other flag States or governments.
Personal information will only be shared by the Companies to provide or improve products, services, and/or advertising; it will not be shared with third parties for their marketing purposes.
Disclosure to Service Providers
The Companies may share personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products, managing and enhancing customer data, providing customer service, assessing interest in products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever the companies operate.
Disclosure to Others
It may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence for the Companies to disclose your personal information. The Companies may also disclose information about you if the Companies determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
The Companies may also disclose information about you if the Companies determine that disclosure is reasonably necessary to enforce their terms and conditions or protect operations or users. Additionally, in the event of a reorganization, merger, or sale, the Companies may transfer any and all personal information the Companies collect to the relevant third party.
Disclosure to Third Parties if You Use the Payment Website
Personal information may be shared with:
Service providers who support TCMI services such as fraud prevention, bill collection, marketing, and technology services, among others. These service providers may only use user information in connection with TCMI services they perform and not for their own benefit;
Credit bureaus to report account information, as permitted by law;
Banking partners as required by credit card association rules; and/or
Law enforcement, government officials, or other third parties when:
TCMI is compelled to do so by a subpoena, court order or similar legal
it is necessary to comply with the law or credit card rules;
disclosure is necessary to prevent physical harm or financial loss or to report
illegal activity; and/or
the user consents or directs TCMI to do so.
TCMI will not sell or rent any personal information to third parties for their marketing purposes and only shares personal information with third parties as described in this policy.
PROTECTION OF PERSONAL INFORMATION
When users visit the Payment Website or send an email to the Companies, technology is used to prevent unauthorized third parties from viewing and downloading user information. The Companies processes personal information on servers in the United States and Canada and protects it by maintaining physical, electronic, and procedural safeguards such as: firewalls, secure sockets layer ("SSL") encryption, URL data encryption, file access privileges, physical server access controls, and authorizing access to personal information only for employees who require it to fulfill their job responsibilities. When your personal data is stored by the Companies, the Companies use computer systems with limited access housed in facilities using physical security measures.
No data transmission over the Internet can be guaranteed to be 100% secure. As a result, the Companies cannot ensure or warrant the security of any information transmitted over the Internet. The Companies make every attempt to ensure the security of all information collected.
INTEGRITY AND RETENTION OF PERSONAL INFORMATION
ACCESS TO PERSONAL INFORMATION
You can help ensure that your contact information and preferences are accurate, complete, and up-to-date by sending an email to
. For other personal information the Companies hold, the Companies will provide you with a copy for any purpose including to request that the Companies correct the data if it is inaccurate or delete the data if the Companies are not required to retain it by law or for legitimate business purposes. The Companies may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Request for information, correction, or deletion can be made by emailing
CHILDREN AND EDUCATION
The Companies understand the importance of taking extra precautions to protect the privacy and safety of children using the Companies' services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to use the Companies' services, unless their parent provided verifiable consent.
If the Companies learn that they have collected the personal information of a child under 13, or equivalent minimum age depending on the jurisdiction, without verifiable parental consent, the Companies will take steps to delete the information as soon as possible.
If at any time a parent needs to access, correct, or delete data associated with their child's information, they may email
THIRD PARTY SITES AND SERVICES
The Companies' websites, products, applications, and services may contain links to third party websites, products, and services. The Companies products and services may also use or offer products or services from third parties. The inclusion of any link does not imply the Companies' endorsement of any other company, its products, services, or privacy practices. Furthermore, the Companies are not responsible for personal information voluntarily disclosed by users to third parties that are contacted through links on any website.
Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. The Companies encourage you to learn about the privacy practices of those third parties.
The Companies, as global companies, have a number of affiliated legal entities in different jurisdictions which are responsible for the personal information which they collect and which is processed on their behalf. The Companies employ appropriate technological and physical safeguards to keep information secure. However, please be aware that these safeguards may not meet the same standards as is required by the country in which you reside.
COMMITMENT TO YOUR PRIVACY
To make sure your personal information is secure, the Companies communicate their privacy and security guidelines to their employees and strictly enforce privacy safeguards.
When a privacy question or access/deletion request is received, the Companies have a dedicated team which seeks to address the specific concern or query which you are seeking to raise. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. Upon request, the Companies will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
Attn: Data Privacy Officer
11495 Commerce Park Drive, Reston, Virginia 20191 United States
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