This document is a working draft. It has not been reviewed or approved by legal counsel and is not yet in force. It is published here for internal review only.
Privacy Policy
Last updated: [PENDING CLIENT APPROVAL] · Controller: [LEGAL NAME PENDING]
1. Data Controller
[LEGAL NAME OF IM AGENCY ENTITY — PENDING CONFIRMATION], domiciled at [ADDRESS — PENDING], Costa Rica. Contact: Im-agency@ima.cr
2. Data we collect and why
When you submit a service request through our contact form, we collect the following information:
| Data | Purpose | Legal basis |
|---|---|---|
| Name, company | Identify the requesting party | Contractual pre-steps / legitimate interest |
| Email address | Respond to the request | Contractual pre-steps |
| Phone number (optional; required for PDA) | Operational coordination | Contractual pre-steps |
| Vessel data (IMO, LOA, draft, GT/NT) | Prepare port disbursement account (PDA) | Contractual pre-steps |
| Service type, port, date, message | Route and process the request | Contractual pre-steps / legitimate interest |
3. Recipients
Form submissions are delivered by email to the IM Agency operations inbox. The email delivery service is provided by GoDaddy (Airo platform). No data is transferred to third-party CRM systems, marketing platforms, or data brokers. [PENDING: confirm whether any ticketing or CRM tool receives this data.]
4. Retention
Data submitted through the form is retained in the IM Agency email inbox for as long as operationally necessary. The website itself does not store form data in a database. [PENDING: IM Agency to confirm inbox retention policy and any archiving practices.]
5. Cookies and analytics
This site uses the GoDaddy C2 analytics service (SCC script). The script loads on every visit; data collection is gated by your consent choice in the cookie banner.
- If you click "Accept": click events and page interactions are collected to measure site performance.
- If you click "Decline": no interaction data is collected. Your preference is stored in your browser's localStorage for 365 days.
- The interactive map uses Stadia Maps tiles. Tile requests may transmit your IP address to Stadia Maps servers. [PENDING: confirm Stadia Maps data processing terms.]
You can change your cookie preference at any time by clicking "Manage cookies" in the site footer.
6. Your rights
Under applicable data protection law (Costa Rica Ley 8968 and, where applicable, the GDPR), you have the right to:
- Access the personal data we hold about you
- Rectify inaccurate data
- Request erasure where data is no longer necessary
- Object to processing based on legitimate interest
- Withdraw consent at any time (for consent-based processing)
To exercise your rights, contact us at: Im-agency@ima.cr. [PENDING: IM Agency to confirm DPO or rights-exercise contact and response timeframe.]
7. Changes to this policy
We will update this page when the policy is approved and when processing practices change. The "last updated" date at the top of this page will reflect the most recent revision.