PRIVACY NOTICE UNDER GDPR
The
privacy and security of your personal data is very important
to us. Whether you are our employee, our client or our business
partner or a third party, we want to ensure that the information
that you have provided to us is being properly managed and protected.
We have prepared this Privacy Notice to explain more about the
way that we collect and process your data.
Who
we are
This Privacy
Statement is issued by Weberseas (Hellas) S.A. (referred to
as “Weberseas” or “we” or “us”
in this Privacy Statement), who is the Data Controller and is
committed to protect your rights in line with the General Data
Protection Regulation (GDPR).
Information
we collect and how we use and share it
We collect
and use personal data, that is kept in secure electronic and/or
hardcopy records. We apply adequate technologies and working
practices to ensure that your information is safe and secure.
We generally collect your information directly from you either
with your consent or in the course of interacting with you for
the performance of a contract or as required by law. In some
cases, we may obtain your data from public records or business
catalogues that should have collected your personal data with
your consent or initiative. Records which we hold about you
include among others the following information:
Employees
• Details about you
such as name/surname, date of birth, address, telephone number,
email address, ID or
Passport, Social Security Number, bank account number etc.
• CV’s
details such as education, working experience, references.
• Degrees, diplomas
• Medical certificates and health questionnaires
• Beneficiaries (name & relation to employee)
Suppliers
• Details
about you such as name/surname, address, telephone number, email
address, VAT number, bank account number etc.
Business
partners and clients
• Details about you such
as name/surname, address, telephone number, email address, VAT
number, bank account number etc.
The
legal basis for processing your data: Why do we collect this
information?
We are committed
to collecting and using your information in accordance with
GDPR and other applicable data protection laws. We will only
collect, use and share your information where we are satisfied
that we have an appropriate legal basis to do this. This may
be because:
• You have
provided your consent to us using the personal information
• Our use of your information is necessary to perform
our contract with you, for example, executing and honouring
the employment contract with you, if you are an employee, or
providing our brokering services if you are a business partner
or client.
• Our use of your information is necessary to meet responsibilities
we have to our regulators, tax officials, social security officials,
law enforcement or otherwise meet our legal responsibilities.
• Our use of your information is necessary for the protection
of your vital interests or the vital interests of a third person.
• Our use of your information is in our legitimate interest
as a commercial organisation, for example to operate and improve
our services provided to you and to keep you informed about
our services and about trends in the business. In any case,
we will look after your information at all times in a way that
is proportionate and respects your privacy rights and you have
a right to object to processing, as this is explained below
under your rights section.
Our use of your personal data is usually related to the following
purposes, per category of personal subjects:
Employees
• managing
employees’ records
• maintaining our own accounts and records
• providing employee support services
• safeguarding and promoting the welfare of employees
• ensuring employees’ safety and security
Suppliers
• executing
the contracts with our suppliers
• contacting our suppliers in connection with after-sales
services
• maintaining our tax records
• being prepared for possible court disputes
Business
partners and clients
• executing
the contracts with our clients
• sending our clients and business partners new business
offers
• informing our clients and business partners about possible
new trends and business
• maintaining our tax records
• being prepared for possible court disputes
If
you would like to find out more about the legal basis for which
we process your personal information, please contact our offices
(details found in the How to contact us section). If you have
provided your consent to our processing of your information
you may withdraw your consent at any time by contacting our
offices (details found in the How to contact us section).
Data
transfer: Who might we share your information with?
As
our business is part of the global shipping industry and our
services are intermediary services between ship owners located
around the globe, it may be necessary to transfer, in restricted
cases, some information about you to a country outside of Greece
or Europe. The information that you provide us during the course
of a transaction or through the provision of any other services
may be transferred to any of our business partners or prospective
business partners or clients for the purpose of carrying out
or facilitating such services, under the below terms:
Your personal
data will be treated as strictly confidential, and will be shared
only with the following parties. We will only share your data
with third parties with your consent or as required or permitted
by applicable law.
We may share your
information with:
• our service providers and agents (including their sub-contractors)
or third parties which process information on our behalf
• partners, including system implementers, independent
software vendors and developers
• any third party in order to meet our legal and regulatory
obligations, including statutory or regulatory reporting or
the detection or prevention of unlawful acts;
• professional advisors and auditors for the purpose of
seeking professional advice or to meet our audit responsibilities;
• Banks, tax authorities, Social Security funds
• Government departments where reporting is mandatory
under applicable law.
Where
we transfer information which originates in the European Union
to a country outside the EU, we will take steps to make sure
that such transfer is carefully managed to protect your privacy
rights. In particular:
•
where we transfer your data to other companies or third parties
providing us with a service, we will obtain contractual commitments
and assurances from them to protect your information,
• we will only transfer personal information to countries
which are recognised as providing an adequate level of legal
protection or where we can be satisfied that alternative arrangements
are in place to protect your privacy rights, and
• any requests for information that we receive from enforcement
or regulators will be carefully validated before personal information
is disclosed.
How long will your
information be held?
We keep your
personal data for as long as it is reasonable required for the
reasons explained in this Privacy Notice. We keep transactional
records (which may include your information) for longer periods
if necessary to meet legal, regulatory, tax or accounting needs.
We will also retain information if we reasonably believe that
there might be a prospect of a litigation.
In any case, we maintain a data retention policy which we apply
to the records that we hold.
Using
our website and data protection: How is the use of our website
related to data protection?
We and our
third-party providers do not use cookies on our website to collect
any information about you and other Internet users.
How
we secure your information:
We are committed
to protecting your information and ensure security of the information
that you provide to us. In order to achieve this, we apply technical,
physical and organisational security measures to protect your
data against any unauthorised access, disclosure, damage or
loss of your information. Although there is no possibility for
any company to guarantee that the collection, transmission and
storage of information is completely secure, we take all steps
to ensure that appropriate security safeguards are in place
to protect your information. In addition, we have adopted adequate
policies for the application of security measures and the protection
of your data. Our systems are monitored for enabling the intervention
in case of security violations or accidents and our protection
systems are tested and updated regularly.
What are your rights?
You have legal
rights under EU data protection laws in relation to your personal
information. To exercise any of your rights, please contact
us by emailing [abuse[at]weberseas.com].
In particular,
unless subject to an exemption under applicable data protection
laws, you have the following rights with respect to your personal
data:
• The right
to request a copy of your personal data;
• The right to request that we correct any personal data
if it is found to be inaccurate or out of date;
• The right to request that your personal data is erased
where it is no longer necessary for us to retain such data;
Please note, though, that we may not always be able to comply
with your request, for example where we need to keep using your
information to comply with our legal obligations or where we
need to use your information to establish, exercise or defend
legal claims.
• The right to withdraw your consent to the processing
at any time;
• The right to request that we provide you with your personal
data and where possible, to transmit that data directly to another
data controller, if you request us to do so;
• The right, where there is a dispute in relation to the
accuracy or processing of your personal data, to request a restriction
to be placed on further processing. Please note, though, that
we may continue to use your information following your request
to restrict it, where we need to use it to establish, exercise
or defend legal claims, or if we need to use it to protect the
rights or another individual or company;
• The right to object to the processing of personal data,
where applicable. Please note, though, that we may continue
to use your information if we have compelling legitimate interests
to use the information;
• The right to lodge a complaint.
We may ask
you for proof of identity when making a request to exercise
any of these rights. We do this to make sure that we only disclose
information where we know we are dealing with the right individual.
We will not
ask for a fee, unless we think that your request is unfounded,
repetitive, excessive or abusive. Where a fee is necessary we
will inform you before proceeding with your request.
We aim to respond
to all valid requests within one month. It may however take
us longer than one month, if the request is particularly complicated
or you have made several requests. We will let you know if we
think that a response will take longer than one month. To help
us respond more quickly, we may ask you to provide more details
about what you want to receive or are concerned about.
We may not
always be able to provide you with the information requested,
for example if it would impact the duty of confidentiality we
owe to others, or if we are otherwise legally entitled to deal
with your request in a different way. In any case, we will inform
you accordingly if we are not able to deal with your query or
petition as requested.
How to make a complaint
If you are
unhappy with the way in which your personal data has been processed,
you may in the first instance contact us by using the contact
details below.
[To administration
Department, address, @: abuse[at]weberseas.com]