Marine-CRM Data Act Switching and International Access Information

Version: 1.2
Last updated: 25 August 2026

1. Purpose

This page provides the online information required for switching from the Marine-CRM data processing service and describes the jurisdiction of the intended production ICT infrastructure and safeguards concerning conflicting third-country governmental access to non-personal data held in the European Union.

Contractual switching rights are set out in the EU Data Act Switching Schedule incorporated into the applicable Customer Agreement. This page is an information and format register; it does not replace the signed contract. Before signature, a current version of this register must be supplied with the execution pack, verified against the implemented export, and identified in the Order Form.

2. What a customer may switch or retrieve

Subject to actual use, available schema, and any non-excludable mandatory right, the following list is the exhaustive contractual description of the customer's exportable tenant data and customer-specific outputs directly or indirectly generated or co-generated through use of the CRM:

• customer company/account details and customer-created workspace settings;
• user identities, roles and permissions, excluding credentials and authentication secrets;
• organisations, contacts and relationship records entered from the customer's own lawful sources;
• deals, pipeline stages, activities and customer-created history;
• projects, tasks, deadlines and assignments;
• notes and internal organisational comments;
• customer-created quotations and invoices and ordinary related metadata;
• uploaded files and documents; and
• identifiers, relationships, assignment, creation/modification timestamps and other metadata reasonably necessary to interpret the customer's CRM workflow.

The standard structured formats are CSV and/or JSON. Uploaded files are supplied in their original format where available. Generated quotations and invoices are supplied in their original or a commonly readable format. The export manifest identifies included data categories, files, format/version and delivery date.

3. What is not customer export data

The export does not include Marine-CRM Platform Data or Shared Dataset records merely viewed or made available in the Service; source/provider datasets; source and provenance records; global suppression data; another customer's data; CIRCLESEA security or technical logs; credentials, password hashes, MFA material or secrets; source code, algorithms, models, internal analytics, database structure, matching/enrichment methods; vulnerability information; or CIRCLESEA/third-party intellectual property and trade secrets that are not exportable customer input/output data under mandatory law.

A private tenant record entered by the customer from its own lawful source is treated as Customer Data. A source-licensed Marine-CRM record does not become exportable merely because it was displayed or referenced.

4. Switching process

A customer may request switching to another provider, transfer to its own on-premises environment, retrieval without a destination provider, or an erase-only exit. A verified request is sent to legal@marine-crm.com with a copy to support@marine-crm.com. It must state the selected outcome, whether the affected Service contract should end, the destination or retrieval route, and any requested later initiation date.

The contract provides:

• no advance-notice requirement and an administrative initiation maximum of ten Business Days after the necessary verification information is received;
• a standard maximum transition period of 30 calendar days;
• one customer-requested extension;
• a protected retrieval period of at least 30 calendar days after transition;
• no switching charge for mandatory switching actions; and
• erasure following the retrieval period or earlier successful-switch confirmation, subject only to mandatory law, legal hold and the controlled disaster-recovery backup tail described in the contract.

Where completion within 30 calendar days is technically unfeasible, CIRCLESEA will provide the contractually required reasoned notice and alternative period. The alternative period will not exceed seven months.

For a switch to another provider or the customer's on-premises infrastructure selected as a contract exit, the affected Service contract terminates automatically when switching is successfully completed. For an erase-only exit, it terminates at the end of the ten-Business-Day initiation-notice period measured from the complete verified request, or on a later date requested by the customer. CIRCLESEA confirms the termination timestamp. No separate early-termination penalty applies. The prepaid Base Subscription Fee attributable on a daily pro-rata basis to the unused period after termination is refunded; elapsed-period fees and properly earned onboarding remain payable. Retrieval alone does not end the contract unless contract exit is expressly selected and the mandatory exit rule applies.

5. Interfaces and interoperability

At launch, the standard switching interface is a verified protected download or encrypted archive produced from the customer's isolated tenant. CSV/JSON structures use stable field labels and identifiers available in the export manifest. Relationships are represented through record identifiers or documented reference fields.

Required interfaces and ordinary switching assistance are provided equally to customers and their verified destination providers without a switching charge. Optional bespoke migration, cleansing, transformation or custom development outside mandatory switching may be separately agreed.

Known continuity risks include destination-schema and mapping differences; inability to port credentials, MFA material, provider software, source/provenance records, Platform Data, Shared Dataset records, or CIRCLESEA security controls; possible loss of Marine-CRM-specific presentation, validation, enrichment, identifiers, workflow logic, or relationships that depend on excluded provider material; and the need for the customer or destination provider to test imports, permissions, calculations, files, and business processes. CIRCLESEA identifies any additional material technical continuity risk known from the verified scope. Destination readiness, mapping, testing, security, and lawful post-delivery use remain the customer's and destination provider's responsibility.

This register will be updated before adding a materially different export format, mandatory standard, open interoperability specification or switching interface. The version used for a completed switch is retained with the switching record.

6. ICT infrastructure jurisdiction

The intended production architecture for customer activation is:

• Germany: Hetzner Online GmbH infrastructure for the application backend, primary production database/storage and protected backups; and
• Estonia: Zone Media OÜ infrastructure for corporate email, operational support communication and relevant domain/DNS services.

The infrastructure is therefore subject principally to European Union law and the applicable laws of Germany and Estonia. The exact production provider list and locations must pass the launch verification gate before customer activation and will be updated here if they change materially.

7. Safeguards concerning conflicting international governmental access

General safeguards for non-personal data held in the European Union include:

• EU-based intended production hosting and routine personnel access limited to Estonia or another EU/EEA location;
• access control, least privilege, authentication, logging and confidentiality restrictions;
• secure transport and protected storage/backup controls subject to launch verification;
• minimisation of data disclosed in response to a binding demand;
• legal review of the authority, scope and legal basis of a governmental request;
• notification to the affected customer where legally permitted;
• referral of the authority to the customer or a reasonable opportunity to seek protective measures where lawful and practicable; and
• use of contractual and technical safeguards before any new non-EEA provider or routine third-country access is enabled.

CIRCLESEA does not voluntarily provide customer data to a third-country authority merely because it requests access. A binding request is assessed under applicable law. CIRCLESEA discloses only what it reasonably determines is legally required and records the decision, subject to lawful confidentiality restrictions.

8. Contact

CIRCLESEA OÜ
Registry code: 17563486
VAT number: EE103012063
Registered address: Võistluse tn 23-44, Kesklinna linnaosa, 10132 Tallinn, Harju maakond, Estonia
Legal: legal@marine-crm.com
Support: support@marine-crm.com
Privacy: privacy@marine-crm.com