1 Introduction
This Policy applies to the following company: Seaborne Shipbrokers SA (hereinafter called “Seaborne”). Seaborne is committed to protecting the personal information collected when you use our website and other services. This Website Privacy Policy pertains to Seaborne website and sets out Seaborne’s commitment in protecting Personal Data and how that commitment is implemented regarding the collection, use, transfer and retention of Personal Data.
2 Personal Data Collection
Seaborne has designed a standard website contact form (Fill the Form – Drop us a line) to initiate communication with any interested individual. This form is used for any inquiries or requests and it directs them to the appropriate department or staff member. In certain circumstances, our website may be used by job applicants, in which case interested parties will be informed on our General Privacy Policy. Additionally, we provide Seaborne phone numbers for a more direct contact if required.
In order to handle and respond to your inquiries and requests we might collect and store your full name, email, phone and any other information you might provide to us. This information is strictly used to adequately respond to your inquiries or requests and will not be disclosed to any third parties others than those mentioned in this policy or where disclosure is required or permitted by law.
For further processing to be lawful under the General Data Protection Regulation (GDPR) and other applicable laws on data protection, we identify a lawful basis before we can process your personal data. In this case, the legal basis for the data processing effected by us is the granting of your explicit consent to the processing, by submitting the consent form only in case you agree with further processing of your Personal Data.
3 Transfer of Personal Data
Seaborne may disclose Persona Data collected to our suppliers or subcontractors insofar as reasonably necessary for dealing with your inquiries or requests. Such transfers will be protected by appropriate safeguards (e.g. appropriate contractual clauses, data processing contracts, intra-group disclosures of personal data, etc.). In addition, we may disclose Personal Data where such disclosure is necessary for compliance with a legal obligation which we are subject to.
4 Personal Data Retention and Deletion
Seaborne is committed not to retain personal data for a longer period than it is necessary with relation to the reasons for which the personal data was obtained and we will make sure that we will delete it securely. For additional information on retention and deletion periods, please refer to the contact person mentioned at the end of the present Policy.
5 Rights of Data Subjects
In this section Seaborne addresses the rights deriving from Regulation (EU) 2016/679 and other applicable laws and how these rights can be accessed from the Data Subjects. For any further clarifications please refer to the contact person mentioned at the end of the present Policy.
5.1 Individual’s Right of Access or Rectification
Seaborne assumes that Personal Data collected directly from the individual will be accurate and complete. Individuals can access and update their own Personal Data using the Personal Data Access Request Form which they can obtain by contacting the contact person mentioned at the end of the present Policy.
5.2 Individual’s Right to Erasure
The data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies. The Right to Erasure can be requested using the Personal Data Erasure Form which may be obtained by contacting the contact person mentioned at the end of the present Policy.
Seaborne is obligated to erase personal data where one of the following applies:
- personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent and no other legal basis for processing exists;
- the data subject objects to the processing carried out on the grounds of the Data Controller’s legitimate interests and there are no other overriding legitimate grounds for the processing.
If the request to erase Personal Data has been received, identity has been confirmed, the request meets one of the above requirements and there is no legal contrary reason for processing, Seaborne shall delete the relevant data in its entirety.
If Seaborne cannot actually delete personal data for any reason, Seaborne ensures that:
- it is not able, or will not attempt, to use the personal data in respect of any individual or in a manner that affects the individual in any way;
- does not give any other organization access to the personal data;
- protects the personal data with appropriate technical and organizational security; and commits to permanent deletion of the information if, or when, this becomes possible.
5.3 Individual’s Right to Restrict Processing
The data subject has the right to obtain from the controller restriction of processing using the Personal Data Consent Withdrawal Form which may be obtained by contacting the contact person mentioned at the end of the present Policy.
5.4 Individual’s Right to Object
Individuals have the right to object at any time to processing of their personal data using the Personal Data Consent Withdrawal Form which may be obtained by contacting the contact person mentioned at the end of the present Policy.
5.5 Individual’s Right to Data Portability
Upon request and provided that the relevant requirements stipulated in Article 20 of GDPR are met, a data subject should have the right to receive a copy of their Personal Data in a structured format using the Personal Data Portability Form which may be obtained by contacting the contact person mentioned at the end of the present Policy.
These requests will be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This will be done for free, if possible.
If Seaborne cannot respond fully to the request within 30 days, we will nevertheless provide the following information to the Data Subject, or their authorized legal representative within the specified time:
- An acknowledgement of receipt of the request
- Any information located to date.
- Details of any requested information or modifications which may not be provided to the Data Subject, the reason(s) for the refusal, and any procedures available for appealing the decision.
- An estimated date by which any remaining responses will be provided.
- An estimate of any costs to be paid by the Data Subject (e.g. where the request is excessive in nature).
- The name and contact information of the contact person.
6 Amendments
Should Seaborne elect to change this Privacy Policy we will post the changes here. Where the changes are significant, we may also choose to email concerned users with the new details.
7 Our Details
If you have any concerns or complaints about this policy, then please contact us at:
4 Andrea Papandreou Str., 166 75
Glyfada Greece
+30 210 89 81888
info@seaborne.com