Legal

Privacy Policy

Last updated: 01 June 2026

1. Introduction

This Privacy Policy explains how Merlino ("Merlino", "we", "us", or "our"), based in Malé, Republic of Maldives, collects, uses, shares, and protects information when you use the Merlino mobile application, Merlino Operator Dashboard, and related services (collectively, the "Platform").

Merlino is a booking marketplace that connects passengers with independent ferry operators, activity providers, and transport charter operators across the Maldives. By creating an account or using the Platform, you agree to the collection and use of information as described in this policy.

This policy applies to passengers, ferry and activity operators, and operator staff who use the Platform.

2. Information We Collect

2.1 Account Information

• Full name
• Email address
• Password (stored as a secure hash, never in plain text)
• Nationality
• Phone number, for passengers who select Maldives as their nationality — stored encrypted

2.2 Identity Verification Information

To book ferry transport, you are required to provide a national identity card number (for Maldivian nationals) or passport number (for foreign nationals).

• These identity numbers are encrypted (AES-256-GCM) before being stored
• Only the last 3 digits are visible to operators on boarding manifests (for example, "···234")
• Full identity numbers are used solely for generating official passenger manifests required for maritime safety and regulatory purposes, and are accessible only through controlled administrative processes

2.3 Booking and Travel Information

• Routes searched, booked, and travelled
• Booking history, including dates, times, vessels, and fares
• Saved or favourite routes, operators, and listings
• Watchlist entries for fully booked departures
• Reviews and ratings you submit

2.4 Payment Information

Payments are processed through Bank of Maldives (BML). Merlino does not store your full card or bank account details. Payment processing is subject to BML's own privacy and security practices.

We retain records of transaction amounts, service charges, and booking references for accounting, dispute resolution, and regulatory purposes.

2.5 Location Information

Merlino may access your device's location:

• To show nearby ports, routes, and operators
• During an active booked trip, if you activate the in-app emergency (SOS) feature, your location may be shared with the relevant operator and/or local authorities to assist in an emergency response

Location access outside of these purposes is not collected.

2.6 Device and Technical Information

• A push notification token (Firebase Cloud Messaging) used to deliver booking updates, reminders, and alerts
• Device verification data used to confirm that requests to our servers come from a genuine copy of the app, to protect against fraud and abuse
• App version, device type, and operating system, for diagnostics and troubleshooting

2.7 Communications

Messages exchanged between passengers and operators through the in-app messaging feature are stored so that both parties can refer back to booking-related conversations, and so our support team can assist with disputes.

Merlino requires all booking-related communication to take place through the in-app messaging feature. We do not facilitate or encourage sharing of personal contact details between passengers and operators.

3. How We Use Your Information

We use the information described above to:

• Create and manage your account
• Process bookings, payments, refunds, and cancellations
• Generate boarding manifests and tickets (QR codes)
• Send booking confirmations, departure reminders, trip status updates, and other service notifications
• Notify you when a seat becomes available on a fully booked departure you are watching
• Calculate and display applicable service charges
• Process operator payouts
• Respond to support requests and resolve disputes
• Detect and prevent fraud, abuse, and unauthorised access
• Comply with maritime safety and other legal requirements
• Improve the Platform's features and reliability

4. How We Share Your Information

4.1 Ferry and Activity Operators

When you make a booking, the relevant operator receives the information necessary to provide the service, including:

• Your name
• Masked identity number (last 3 digits only)
• Travel details — route, date, time, seat, luggage
• Masked phone number (last 3 digits only), where provided

Operators do not receive your email address, password, full identity number, or full phone number.

4.2 Payment Processor

Payment details are shared directly with Bank of Maldives to process transactions. Merlino does not have access to your full card details.

4.3 Infrastructure and Service Providers

Merlino is built on Google Firebase and Google Cloud Platform infrastructure, hosted in the asia-south1 region (Mumbai, India). These providers process data on our behalf under their own data processing agreements and security certifications. This means certain data may be stored or processed outside the Maldives.

4.4 Legal Requirements

We may disclose information where required by law, regulation, legal process, or governmental request, including to maritime authorities, immigration authorities, or law enforcement.

4.5 Business Transfers

If Merlino is involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction, subject to the protections described in this policy.

We do not sell your personal information to third parties.

5. Data Storage and International Transfers

Your information is stored on Google Cloud infrastructure in the asia-south1 (Mumbai, India) region. By using the Platform, you acknowledge that your information may be processed and stored outside of the Maldives, in jurisdictions that may have different data protection standards from the Maldives.

6. Data Security

We apply the following measures to protect your information:

• Sensitive identity information, such as National ID and passport numbers, and phone numbers are encrypted using industry-standard encryption before being stored
• Encrypted connections (HTTPS/TLS) for all data in transit
• Device verification measures to help ensure that requests to our servers come from a genuine copy of the app, to protect against fraud and abuse
• Role-based access controls restricting which staff and systems can access personal data
• Integrity checks on boarding tickets to help prevent forged or tampered passes

No system can be guaranteed completely secure. If you believe your account has been compromised, contact us immediately using the details in Section 12.

7. Data Retention

• Booking records are retained permanently as financial and regulatory records, even after account deletion (with personal details anonymised — see Section 8.3)
• In-app notifications are retained for 30 days
• Luggage tag history, where applicable, is retained for 90 days
• Account information is retained until you delete your account

8. Your Rights

8.1 Access and Correction

You can view and update most of your account information directly within the app, under Profile.

8.2 Notification Preferences

You can control which types of push notifications you receive in Profile → Notification Settings.

8.3 Account Deletion

You may delete your account at any time from Profile → Delete Account. When you do:

• Any upcoming confirmed bookings are cancelled and refunded based on our Refund Policy
• Pending activity requests are cancelled
• Active watchlist entries are removed
• Your personal profile data is deleted
• Historical booking records are retained but anonymised — your name and identity details are replaced with "Deleted User" and removed from the record

This action is permanent and cannot be undone.

8.4 Other Requests

For any other requests relating to your personal information, contact us using the details in Section 12.

9. Children's Privacy

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect information from children. If you believe a child has provided us with personal information, please contact us so we can remove it.

10. Cookies and Similar Technologies

The operator dashboard (web application) uses essential cookies and similar technologies required for login sessions and security, including reCAPTCHA for fraud prevention. We do not use third-party advertising cookies or tracking pixels.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified through the app. The "Last updated" date at the top of this policy reflects the most recent revision.

12. Contact Us

If you have questions about this Privacy Policy or how your information is handled, contact us at: