Last modified: 14.03.2025

We value your right to privacy and data protection. We want you to know for which purposes and how we collect and use your personal data (also known as personal information) and which rights you have. You will find important information about the processing of your personal data in this privacy notice (hereinafter: Privacy Notice). This Privacy Notice describes the Personal Data Processing done by SEG, which takes place only within the framework of the management, use and provision of this Website. This Website contains links that might direct you to webpages administered by SEG and/or Third Parties. This Privacy Notice does not describe the Personal Data Processing which occurs from the moment you are directed to a dedicated Ephemeris Suite application webpage or a Third Party webpage, for which dedicated Privacy Notices are applicable.

This Privacy Notice applies to the processing of personal data by SEG EU OÜ (a limited liability company incorporated in the Republic of Estonia with the registration number 16255825 and registered address at Narva mnt 5, 10117 Tallinn, Estonia; hereinafter SEG, we or us). This Privacy Notice is supplemented by the Website’s Cookie Notice available on Cookie Policy.

1. Definitions

The following terminology is used in this Privacy Notice in the following meaning:

• Data Subject is a natural person who has visited the Website and on who SEG has data or information that can be used to identify the natural person;
• Personal Data is any information relating to an identified or identifiable Data Subject, particularly information that SEG has gathered as a result of the Data Subject visiting the Website;
• GDPR is the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons about the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC;
• Third Party is a natural or legal person, public authority, agency or body, and any person other than the Data Subject, SEG, an authorized employee of SEG, or a person who may process the Personal Data of the Data Subject under the authority of SEG or Processor of SEG;
• Website is a webpage administered by SEG under the URL https://ephemeris.app, which is a webpage dedicated to showcase the different products in the Ephemeris Suite lineup;
• Processing means any operation or set of operations, which is performed on Personal Data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction, regardless of the method of operation or the used means;
• Processor means a natural or legal person, public authority, agency, or other body which Processes Personal Data on behalf of SEG, the controller.

2. What Security Measures Does SEG Implement?

SEG takes the security of all data in its possession very seriously. SEG ensures the confidentiality of Personal Data under applicable law and implements appropriate technical and organisational measures to protect Personal Data from unauthorized access, unlawful Processing or disclosure, accidental loss, alteration, or destruction.

SEG may use Processors for Processing of Personal Data. In such cases, SEG will ensure that the Processing of Personal Data is carried out in accordance with SEG's instructions and in accordance with the applicable law and this Privacy Notice. We apply contractual and appropriate security measures to protect your Personal Data and maintain confidentiality.

As soon as we receive your data, we implement reasonable security measures and procedures to avoid unauthorised access from any Third Party. However, transmission of such data over the Internet using personal computers or mobile devices is not completely safe and, therefore, we cannot guarantee absolute security of all information submitted to our Website and/or to us. Any transmission of such information and documents is at your own risk.

3. How Do We Collect Your Personal Data?

SEG collects Personal Data primarily in the following ways:

• Personal Data disclosed by the Data Subject as a result of the intended use of the Website and any subsequent processing, e.g. data disclosed during e-mail correspondence, emerged as a result of normal communication between the Data subject and SEG, data disclosed by the Data Subject when expressing his/her interest in receiving additional information about different Ephemeris Suite applications (e.g. newsletter) and data disclosed during the registration of the user account and data disclosed as a result of the Data Subject expressing interest in applying to the vacant positions advertised on the Website;
• by automatic means when using our Website and/or services (e.g., tracking the Data Subject use of our Website and services; see also our Cookie Notice how and which cookies and similar technologies are used, which includes any information on Personal Data received from Third Parties).

4. Which Personal Data Do We Process?

The categories of Personal Data that SEG mainly, but not exclusively, collects and processes are the following:

• Data entered into the contact form of the Website (e.g., name, phone number, e-mail address and any data disclosed in the content of the message);
• Data entered into the job application form of the Website (e.g, name, phone number, e-mail address, the position you are applying for, your CV and any Personal Data disclosed in the CV, and any data disclosed in the content of the message);
• Data disclosed by the Data Subject during e-mail correspondence (e.g. the e-mail address and associated communications data transmitted from the e-mail address);
• Data disclosed by the Data Subject in one of the placeholder subpages of the Website dedicated to the different Ephemeris Suite applications (e.g. e-mail address);
• Data disclosed by the Data Subject during the registration of the user account and the subsequent use of the account (e.g. name, e-mail address, password);
• Data provided by you and gathered by SEG for the processing of your job application, including personal identification data (details of the identification document), medical information and any other Personal Data that is necessary for the assessment of the candidate for the position that the candidate is applying for;
• Data automatically gathered from the use of the Website (e.g., the Internet Protocol (IP) address and other identification data necessary for the functioning of the Website).

In addition to the categories of Personal Data explicitly stated in this Privacy Notice, SEG may collect additional and other Personal Data in accordance with the law, if needed.

5. For Which Purposes And On Which Legal Basis Do We Process Your Personal Data?

SEG processes your Personal Data primarily:

• to administrate and to ensure the functioning of the Website, based on: SEG’s legitimate interests to prevent, limit and investigate any misuse or unlawful use or disturbance of the Website and/or services;
• to analyse the usage of the Website and to make improvements to the Website, based on: consent of the Data Subject or the legitimate interest of SEG to improve the usage and content of the Website;
• to answer to your requests, e.g. to identify the person who made the request and to ask for any additional information necessary to answer your question, based on: the performance of a contract (including any pre contractual processing necessary for entering into a contract) or the legitimate interest of SEG;
• to create and provide access to your user account, based on: the performance of a contract (including any pre contractual processing necessary for entering into a contract);
• to establish, exercise, and defend legal claims, such as keeping records of communication you have had with SEG, based on: SEG’s legitimate interests to exercise and defend against legal claims;
• to provide you with the newsletter service, based on SEG’s legitimate interests;
• to comply with the legal obligations that SEG may be subject to, based on: SEG being subject to a legal obligation.

In the case that we are going to use your personal data for other purposes as provided above, we will communicate it to you in a timely manner.

6. SEG EU OU Contracted Consultants & Subcontractors

If we engage external professionals to assist in operational support, they are granted access only on a need-to-know basis and must sign NDAs before handling any personal data.

7. Where Your Personal Data Is Being Processed?

Generally, Processing of Personal Data takes place within the European Union / European Economic Area (EU/EEA). If there is a need to Process Personal Data outside EU/EEA (e.g. for utilizing subcontractors), the transfer will only take place if the appropriate legal basis stated in chapter 5 of the GDPR applies. Examples of appropriate legal bases include:

• an adequate level of data protection is in place in the country outside of the EU/EEA in accordance with the decision of the European Commission;
• existence of a valid agreement containing standard contract clauses developed by the EU or approved codes of conduct or certifications or other similar things that comply with the GDPR.

8. How Long Do We Store Your Personal Data?

SEG does not Process Personal Data for longer than it is necessary for the purposes related with such data and/or to comply with the statutory data storing obligations. The retention period may also be based on SEG's legitimate interest or applicable law (e.g., legislation about accounting or limitation period). The retention period for cookies is noted in the Cookie Policy of the Website.

Data, including Personal Data, are generally processed for the duration of the service provided, until consent is withdrawn or until the Data Subject has raised an objection to the processing of Personal Data in the event that the Processing of Personal Data is based on the legitimate interest of SEG.

The processing of personal data may be extended in cases where the Processing is necessary for the preparation, presentation or defence of possible claims, and after this period only within the time prescribed by law. After the end of the processing period, the data is deleted or anonymized.

9. Which Rights Do You Have?

The Data Subject has the following rights in connection with the Processing of his/her Personal Data:

• to obtain information about the Processing of their Personal Data and the right to request a copy of the Personal Data being Processed;
• to request the rectification of their Personal Data if it has changed or is otherwise inaccurate;
• to object to the Processing of their Personal Data if the Processing of Personal Data is based on a legitimate interest;
• to request restriction of the Processing of their Personal Data, for example at a time when SEG assesses whether the Data Subject is entitled to delete its Personal Data;
• to withdraw their consent for Processing of Personal Data. Upon withdrawal of the consent, SEG will no longer Process the Personal Data of the Data Subject for the purpose of the respective consent. The consent is valid until it is withdrawn;
• to receive the personal data concerning him or her, which he or she has provided to SEG, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from SEG to which the personal data have been provided (data portability right);
• to request deletion of their Personal Data, for example, if SEG has no right to Process such data or if the Processing of Personal Data is based on a consent and the consent has been withdrawn. Such right does not apply (or to such an extent) if Processing of Personal Data that is requested to be deleted has also been Processed for other legal bases or for the performance of legal obligations;
• to contact us at any time regarding the use of their Personal Data. To do so, please send us an e-mail. You also have the right to lodge a complaint to the Estonian Data Protection Inspectorate (website: https://www.aki.ee) or to a competent court.

The Data Subject can exercise its rights by contacting us at support@ephemeris.app. We will respond to the request without delay, but not later than within one month from receiving the request. To protect the integrity and security of the Personal Data SEG holds, we may ask that the Data Subject follows a defined access procedure, which may include steps to verify Data Subject´s identity.

Please note that the Data Subject´s rights are not absolute and are subject to such considerations as allowed under the applicable law.

10. Validity And Changes to Privacy Notice

SEG has the right to unilaterally amend the Privacy Notice at any time in accordance with the applicable law.

SEG will notify the Data Subject of any changes to the Privacy Notice via the Website and by the e-mail at least one month before the changes take effect, except if the Privacy Notice is amended because of changes in legislation.

This cookie notice contains the conditions of and information on how the cookie notice on SEG’s website is applied, and which cookies are used. You would not be generally identifiable with the cookies, however, if you are logged in to your account, SEG can connect you with a specific cookie. You can read how SEG processes personal data in the SEG’s Privacy Policy.

We would like to point out that this cookie notice applies regardless of the type of device used, i.e. it does not matter whether you visit our website on a tablet, laptop, smartphone or other smart devices.

What are cookies and how do they benefit you?

A cookie is a small text file (under 1kB) saved on your device’s (e.g. a laptop, smartphone, tablet) web browser (e.g. Internet Explorer, Google Chrome, Firefox, Safari or Opera) when you visit websites. They are widely used to ensure a better and more efficient performance of websites and to support the personalization of your browsing experience by displaying content that is most likely interesting and relevant to you. The use of cookies is standard procedure for most websites nowadays. By disabling cookies some functions of the website may be impaired.

Cookies are usually held in temporary (TEMP) files, which are either deleted after the browsing session or saved onto the device’s hard drive, depending on the expiry date of the cookie. More information on cookies can be found on the following address: https://www.allaboutcookies.org

Cookies help us to:

• make the website work according to your expectations;
• remember your devices and settings during and in between visits;
• if necessary, remember your settings and choices during and between visits (e.g. in the shopping cart);
• fix the speed/security of the website;
• constantly improve our website for you;
• make marketing more efficient and personal.

What kind of cookies do we use?

We use two types of cookies, known as session cookies and persistent cookies. These are the cookies used by us and/or third parties.

The type of cookies we use:

• Session cookies are used every time you visit our website. We use these cookies to link your activities on our website, and each session cookie lasts only for the duration of the visit, after which it will expire. Each session begins when you open your web browser and ends when you close it. After visiting the website all session cookies are deleted.
• Persistent cookies allow us to remember your preferences or activities on the website (or between the webpages). They have a longer lifespan than session cookies and they last for the duration of time specified in the cookie, which can vary. These cookies are not deleted by closing the browser and they will be saved on your device. They will be activated every time you visit the website that created the specific persistent cookie.

How do we categorise cookies?

To better understand cookies, we have categorised each cookie as follows:

• Strictly necessary cookies and functionality cookies: These cookies are indispensable for the website, allowing the visitor to move around and use various functions, such as language settings, when the visitor moves between different pages during the browser session. Without indispensable cookies, certain services of the website may not be possible and the website may not perform as smoothly. Functionality cookies also allow the website to remember your choices and to offer you improved and personalised functions. These cookies do not collect any sort of information for marketing purposes nor in order to remember where you have been on the internet.
• Analytical or performance cookies: Performance cookies collect information about visiting the website and help us improve the way the website works. For example, performance cookies can show which pages are most frequently visited, save whatever difficulties may have occurred during the visit and show whether the advertising on the website has been effective or not. Performance cookies do not collect information which would identify the person of the visitor and all information gathered by them is assembled and anonymous.
• Targeting or marketing cookies: Targeting or marketing cookies are used to forward you the advertising most fitting with your interests or in order to limit the number of times you see the same advertising on the website. These cookies are also used to help measure the effectiveness of advertising campaigns and to remember what you have looked at on the website.

What cookies do we use on our website?

How to manage cookies?

If you have not set up your browser in a way that it refuses all or certain types of cookies, then cookies will be assigned at the moment you visit the website. When visiting our website for the first time, a notification regarding the use of cookies will be displayed (cookie notification). To accept the use of all cookies click on the “Accept all cookies” button. You have the possibility to choose which categories of cookies you would like to accept, after choosing acceptable cookies click on the “Accept cookies” button. If you do not click on the “Accept all cookies”, or “Accept cookies” button, or click on the “Only necessary cookies” button, you have not given your consent to the use of cookies. In that case, no cookies will be installed, with the exception of those necessary for the functioning of our website – the strictly necessary cookies (functionality cookies).

Strictly necessary and functionality cookies go along with using our website. When refusing these cookies, we cannot predict how well the website will function. You can control the use of analytic cookies, targeting cookies or marketing cookies by adjusting your browser settings or choosing acceptable cookies when visiting our website for the first time.

You can opt-out of being tracked by Google Analytical across all websites on this browser here.

Most browsers allow you to control cookies through the user preferences of your settings. If you prefer to not accept cookies you can set your browser in a way that it refuses all cookies or sends out a warning when receiving a cookie. We cannot delete the cookies that are already placed on your web browser. In case you would like to remove cookies from your device, different web browsers have help pages with information on how to remove cookies. When using several browsers do not forget to remove cookies from all of them. Additional information on how to adjust settings regarding cookie preferences on the most common web browsers can be found here:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Safari
• iOS

We would like to draw your attention to the fact that by deleting or refusing cookies you may lose access to certain areas or functions on our website. Adjusting cookie settings also affects other websites you visit.

If you would like more information about the cookies used on our website, please get in touch via the following e-mail address: support@ephemeris.app.

The applicability and changes to the cookie notice

We have the right to unilaterally change our cookie notice at any time in accordance with the applicable law.

This cookie notice has been approved and published March 7. 2024.

Last modified: 28.12.2023

These and Conditions are stipulated by SEG EU OÜ, a limited liability company incorporated in the Republic of Estonia with the registration number 16255825 and registered address at Narva mnt 5, 10117 Tallinn, Estonia.

Please read carefully these Terms and Conditions and all material and information incorporated here as reference, as these set out your and our legal rights and obligations in relation to using the Application. You will be asked to agree to these Terms and Conditions before creating the Account and/or using the Services. It is not possible to register the Account and/or use any Service without agreeing with these Terms and Conditions.

These General Terms are available in the English language only. You should print a copy of these Terms and Conditions for future reference as any specific version of these Terms and Conditions may not be accessible on the Application in the future. You can always see the currently valid version of these Terms and Conditions on the Application or contact us to receive a copy of these Terms and Conditions via email.

These General Terms may change. In such case, we will give you a 30-day notice, at the end of which period you will be deemed to have accepted the new General Terms by continuing to use the Services. For more information on the Company, you can refer to the “Contact Us” section of the Website.

1. Subject matter

The Ephemeris Suite comprises of products that have been designed to support various sectors of the superyacht industry, from ISM compliance to administration, finance, technical management, human resources and training.

2. Definitions

• 2.1. Account - a personal user account on the Application where the User can use the Services, and which includes the User’s personal data.
• 2.2. Application – SEG management and solution software which is accessible through the android application or the Website.
• 2.3. Company or us – SEG EU OÜ, a limited liability company incorporated in the Republic of Estonia with the registration number 16255825 and registered address at Narva mnt 5, 10117 Tallinn, Estonia.
• 2.4. Party or Parties – under these Terms and Conditions, separately the User or the Company or jointly the User and the Company.
• 2.5. Service – vessel management and other solution services that are accessible through the Application.
• 2.6. User Content – content shared by the User on the Application, including, but not limited to, feedback ideas, modifications, suggestions and improvements, shared by the User on the Application.
• 2.7. User or you – a natural person with active legal capacity who is at least 18 years old or a legal entity and who has agreed to these Terms and Conditions.
• 2.8. Website – a web-based online environment available https://ephemeris.app through which the Application is accessible, and which is operated by the Company.
• 2.9. Force Majeure Event – an event, or a series of related events, that is outside the reasonable control of the Party affected (including but not limited to failures of or problems with the Internet or a part of the Internet, hacker attacks, virus or other malicious software attacks, power failures, telecommunication failures, disputes affecting any third party, changes to the law, disasters, explosions, fires, floods, riots, strikes, terrorist attacks, wars, government restrictions, embargoes, earthquakes).

3. General Provisions

• 3.1. By using the Company’s Services, you confirm that you have read these Terms and Conditions, agree to these Terms and Conditions and undertake to comply with these Terms and Conditions. If you do not agree to these Terms and Conditions, you must refrain from using the Services and/or registering the Account.
• 3.2. These Terms and Conditions set out the rights and obligations of the User for using the Service, including, but not limited to, terms for using the Application, the liability of the Parties.
• 3.3. The Services are designed to give you access to vessel management and other solution software through the Application.
• 3.4. To use the Services, the User must register the Account. To register the Account, the User will be required to provide an e-mail address and choose a safe password.
• 3.5. The User can only access the Account and use the Services on their own behalf and in their own name. Account access and use of the Services on behalf of third parties is forbidden.
• 3.6. The User can use the Application under these Terms and Conditions for a fee agreed upon by the Parties via the Website. The User is responsible for all additional costs and expenses associated with the use of the Application and the performance of the Application.

4. Term and Account Termination or Suspension

• 4.1. Either party may terminate these Terms and Conditions at any time for any reason by deleting the Account or providing the other party a written notice 30 days in advance.
• 4.2. The Company has the right to cancel, suspend or restrict access to its Application or Services, and to take any other action it deems appropriate if the User does not meet the requirements referred to in these Terms and Conditions or stops fulfilling them. Under no circumstances will the Company be responsible for costs, losses or damages of any kind that the User or any third party may suffer as the result of such cancellation, suspension or restriction of access to the Application or the Services.
• 4.3. The rights and obligations of the Parties set forth in Section 7 (Intellectual Property) shall survive termination of these Terms and Conditions for any reason.

5. User’s Obligations

• 5.1. When using the Services, you will not:
  • 5.1.1. provide false, inaccurate, or misleading information;
  • 5.1.2. breach or attempt to breach the security of the Application, including but not limited to modifying or attempting to modify any information, unauthorised data access or deletion, interfering with the Services, system, host or network, spamming, hacking, falsifying data, introducing viruses, Trojan horses, worms or other destructive or damaging programs or engines in any way; or
  • 5.1.3. use the Application and Services in any way unlawfully or fraudulently.
• 5.2. The User is solely responsible for the safekeeping of their Account information. The User is responsible for all activities under their log-in e-mail and Account. The User agrees to notify the Company immediately if they are aware of any unauthorised use of their Account and will strictly observe the security, authentication, and any other mechanism or procedures established on the Application or requested by the Company.

6. Exclusion of Liability

• 6.1. Provision of the Application under these Terms and Conditions shall not create any obligation for the Company to continue to develop, productize, support, repair, offer for sale or in any other way continue to develop the Application to the User or any other party. The Company is under no obligation to provide technical support under these Terms and Conditions.
• 6.2. The Company shall not be liable to the User for:
  • 6.2.1. any failure to fulfil your instructions as a result of circumstances which could reasonably be considered to be outside our control;
  • 6.2.2. malfunctions in communications facilities which cannot reasonably be considered to be under our control;
  • 6.2.3. any losses or delays in the performance of the Services arising out of the use of any internet services provider, or caused by any browser or other software which is not under our control;
  • 6.2.4. errors on the Application or with the Services caused by incomplete or incorrect information provided to us by you or a third party; or
  • 6.2.5. any content, damages, losses, or practises of any third-party website or services that the website links to.
• 6.3. Subject to these Terms and Conditions, the Company agrees to provide the Services to you using reasonable care. The Services and Content are provided on the principle “as is” and “as available” and with all faults and defects without warranty of any kind. The Company does not guarantee that the Application, Services, or any content on it, will always be available or be uninterrupted or be error free. The Company will not be liable to you if for any reason the Application or the Services are unavailable at any time due to a Force Majeure Event.
• 6.4. If the Application contains links to a third-party website, the Company does not guarantee that the information displayed on these websites is correct, complete, or accurate. The Company is not obligated and will not control the information of these websites. The owners of these third-party websites will be liable for the content of these websites.

7. Intellectual Property

• 7.1. The Application and Services and all intellectual property relating to and contained in them (including but not limited to, copyright, patents, database rights and trademarks) are owned by or licensed to the Company. All right, title and interest in and to the Application and the Services shall remain the property of the Company.
• 7.2. The Application and Services may be used, accessed, downloaded or installed, and operated only for the purposes permitted by these Terms and Conditions. The company grants the User a personal, non-exclusive, non-transferable, revocable license to use the Application. The User may not duplicate, publish, modify, create derivative works from, participate in the transfer or sale of, post on the internet, or in any way distribute or exploit the Application or Services without the Company’s express written permission.
• 7.3. The User retains all intellectual property rights in, and is responsible for, the User Content created and shared. To the extent that User provides User Content, User grants immediately and fully automatically the Company a transferable, royalty-free, perpetual, worldwide, and sub-licensable license to copy, distribute, modify, create derivative works based on, publicly perform, publicly display, and otherwise use the User Content for any purposes associated with the provision of the Services or the Application in the maximum amount their licensing is possible under the applicable law.
• 7.4. The Company reserves the right to remove or modify User Content for any reason, including, but not limited to, User Content that violates these Terms and Conditions.

8. Processing of Personal Data

• 8.1. The User’s personal data related to and under these Terms and Conditions will be processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation) and the Company’s Privacy Notice. Detailed information regarding the processing of personal data by the Company and information about data subjects’ rights and implementation of them can be obtained from Privacy Notice available on the Website here .

9. Applicable Law and Jurisdiction

• 9.1. The law of the Republic of Estonia shall apply to these Terms and Conditions.
• 9.2. All disputes arising from these Terms and Conditions shall be settled by negotiations between the parties. If the dispute is not settled by negotiations within a reasonable timeframe, it is to be referred to the Harju Country Court, Tallinn, Estonia.

10. Miscellaneous

• 10.1. If the Terms and Conditions conflict with the information provided on the Application or any other document, the Terms and Conditions will prevail.
• 10.2. Materials and other content published on the Application or elsewhere are not binding and do not unless explicitly referred to herein, form part of these Terms and Conditions, and are of descriptive nature only.
• 10.3. These Terms and Conditions and the rights and obligations arising from it cannot be assigned nor transferred to any third party by the User without a prior written agreement of the Parties.
• 10.4. If any provision of these Terms and Conditions is or becomes illegal or unenforceable under a relevant jurisdiction, in whole or in part, such a provision will be deemed ineffective from these Terms and Conditions without affecting the remaining provisions, which will continue in full force and effect.