Effective Date: 15 February 2026

1. Identity of the Parties

This Privacy Policy applies to personal data processed in connection with the ShipShoreGroup (“SSG”) platform.

ShipShoreGroup (SSG) is a brand and coordination platform owned and operated by:

Harborlink Digital Marketing Services
A sole proprietorship duly registered with the Department of Trade and Industry (DTI), Philippines
(“SSG” or “Platform Operator”).

Chuusin Ship Management Inc.
A corporation duly organized under Philippine law
(“Contracting Entity”).

SSG operates solely as a coordination and digital facilitation platform.
Chuusin Ship Management Inc. is the sole operating and contracting entity for husbandry, ship management, and related maritime services.

SSG and Chuusin Ship Management Inc. do not jointly determine the purposes and means of processing personal data and therefore act as separate and independent data controllers within their respective roles.

Nothing in this Privacy Policy shall be construed as creating a partnership, joint venture, or agency relationship between SSG and Chuusin Ship Management Inc.

2. Scope of This Privacy Policy

This Policy governs personal data collected:

  1. Through use of the SSG website and directory platform
  2. In connection with maritime husbandry and port coordination services
  3. In connection with digital products and subscription services sold under SSG

3. Data Controller Structure

Depending on the activity, personal data may be processed under different controller roles.

3.1 Platform Use (Browsing, Listings, Inquiries)

Data Controller: SSG (Harborlink)

Includes:

  • Contact forms
  • Vendor listings
  • Directory accounts
  • General inquiries

3.2 Husbandry & Port Service Coordination

Operational documents may include:

  • Crew lists
  • Passport copies
  • Seaman’s books
  • Medical certificates
  • Cargo documentation
  • Vessel compliance documents

Such documentation may contain Sensitive Personal Information as defined under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173).

These documents may initially be submitted through SSG communication channels (including SSG email).

Controller Structure:

  • SSG acts as Data Controller for the collection and secure storage of submitted documentation for coordination and compliance purposes.
  • Chuusin Ship Management Inc. acts as an independent Data Controller for service execution, regulatory compliance, contractual performance, and dealings with port authorities.

Processing of Sensitive Personal Information is based on contractual necessity, compliance with legal obligations, and the establishment, exercise, or defense of legal claims in regulated maritime operations.

Operational services are executed solely by the Contracting Entity.

3.3 Digital Products & Subscriptions

Digital downloads and subscription services sold under SSG are independent commercial offerings.

Data Controller: SSG (Harborlink)
Payment Processor: PayPal

SSG does not store full payment card details. Payment information is processed securely by PayPal in accordance with its own privacy and security policies.

4. Categories of Data Collected

We may collect:

A. Identity Data

Name, company name, position, contact details.

B. Operational Maritime Data

Crew documentation, vessel documentation, port clearance documentation.

C. Financial Data

Transaction confirmation details for digital purchases (processed via PayPal).

D. Technical Data

IP address, browser type, device information, cookies.

5. Legal Basis for Processing

Processing may be based on:

  • Contractual necessity
  • Compliance with legal obligations (including PPA, MARINA, PCG, and other authorities)
  • Legitimate business interests
  • Consent (where applicable)

We collect only data that is necessary for coordination, regulatory compliance, contractual performance, and legitimate business purposes.

Personal data is not sold, rented, or commercially traded.

6. Government & Regulatory Disclosure

Operational documentation may be submitted to:

  • Philippine Ports Authority (PPA)
  • Maritime Industry Authority (MARINA)
  • Philippine Coast Guard (PCG)
  • Other competent authorities

Such disclosure is made strictly in compliance with maritime and port regulations.

Once submitted to authorities, those authorities act as independent data controllers under their respective laws.

7. Data Storage & Cloud Processing

Data collected by SSG is stored using cloud infrastructure provided by Microsoft 365 (SharePoint and OneDrive).

Data may be processed in regional or international data centers subject to Microsoft’s security framework and contractual safeguards.

Appropriate technical and organizational safeguards are implemented to protect data against unauthorized access, alteration, disclosure, or destruction.

8. Data Retention

Operational maritime documentation is retained for up to two (2) years from completion of vessel stay in Philippine ports.

Data may be retained longer if required for:

  • Legal compliance
  • Regulatory requirements
  • Dispute resolution
  • Defense of legal claims

After the applicable retention period, data is securely deleted if no longer necessary.

Platform account data may be retained while accounts remain active.

Financial transaction records are retained in accordance with applicable tax and accounting regulations.

9. Data Security Measures

We implement:

  • Access controls restricted to authorized SSG personnel
  • Encrypted cloud storage
  • Password-protected systems
  • Role-based access limitation
  • Regular review of access rights

Administrative access is limited to designated SSG personnel.

10. Data Breach Response

In the event of a data breach affecting personal data under our control, SSG will:

  • Conduct prompt internal investigation
  • Take appropriate containment and remediation measures
  • Notify affected individuals and relevant authorities where required under applicable laws

11. International Data Transfers

Because cloud service providers may operate internationally, personal data may be processed outside the Philippines.

Such transfers are conducted under appropriate safeguards, including contractual protections imposed on service providers, consistent with applicable data protection laws.

12. Your Rights

Depending on applicable law, individuals may have the right to:

  • Access their personal data
  • Request correction of inaccurate data
  • Request deletion where legally permissible
  • Restrict or object to processing
  • Withdraw consent (where processing is based on consent)

Requests may be directed to:
smd@shipshoregroup.com

13. Compliance with Applicable Laws

This Privacy Policy is intended to comply with:

  • The Philippine Data Privacy Act of 2012 (Republic Act No. 10173)
  • Applicable international data protection regulations, where relevant

14. Governing Law

This Privacy Policy shall be governed by the laws of the Republic of the Philippines and applicable international regulations where relevant.