1 Introduction
This Privacy Policy applies to the following company: Seaborne Shipbrokers SA and its affiliates and/or subsidiary companies, (hereinafter called “Seaborne”). Seaborne is committed to protecting the personal information (Personal Data) collected when you use our website and other services and to give you certain rights and remedies in respect of that information collected. The data protection laws governing the processing of the personal information means all applicable data protection and privacy legislation in force from time to time in the Hellenic Republic, including, without limitation, the General Data Protection Regulation ((EU) 2016/679); Law 4624/2019, implementing Directive 2016/679/EC and Law 3471/2006 implementing Directive 2002/58/EC (GDPR). This 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. Seaborne is the controller and responsible party for this website in relation to your Personal Data.
Please read this Privacy Policy carefully. Your agreement to use your Personal Data is provided by visiting our website and using our services. In case you have any further questions, please refer to the contact person mentioned at the end of the present Privacy Policy.
2 PERSONAL DATA COLLECTION
In order to handle and respond to your inquiries and requests we might collect and store different kinds of Personal Data as follows (the below list is non exhaustive):
- your full first name, last name, previous names, username, marital status, title, date of birth and gender;
- residential address, billing address, email address and phone number;
- transactional data in relation to services you have purchased from us;
- financial information and data;
- profile data (if applicable);
- technical data, including but not limited to IP addresses, browser type and version and login data; and
- usage, marketing and communications data.
This information is strictly used to adequately respond to your inquiries or requests and will not be disclosed to any third parties’ other than those mentioned in this policy or where disclosure is required or permitted by law.
We might use a number of methods for collecting your Personal Data, for example when you:
- apply for our products and services;
- perform a contract with Seaborne;
- apply for a job with us;
- request marketing material to be sent to you;
- participate on a tender or competition;
- perform a survey; and
- give us feedback and/or contact/correspond with us via post, e-mail, phone or otherwise.
For further processing to be lawful under GDPR and other applicable laws on data protection, we need to identify a lawful basis before we can obtain and process your Personal Data. The legal basis for the data processing effected by us is the granting of your explicit consent to the processing or other lawful base, as follows:
- submission of clear consent by email only in case you agree with further processing of your Personal Data;
- submission of the standard website contact form to initiate communication with any interested individual. This form is used for any inquiries or requests, and it directs clients to the appropriate department or staff member;
- when performing a contract with you or when we are about to enter into a contract with you;
- for the purpose of fulfilling legitimate/public interests, for example to prevent fraud and offer you with the most secured customer experience; and
- where such disclosure is necessary for compliance with a legal obligation which we are subject to.
3 PURPOSES FOR WHICH WE WILL USE PERSONAL DATA
We set out below a summary of all the ways we plan to use the various categories of your Personal Data:
| Purpose/Use | Type of data | Legal basis |
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your profile data | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR having obtained your prior consent to receiving direct marketing communications |
| To carry out market research through your voluntary participation in surveys | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services) |
4 TRANSFER OF PERSONAL DATA
Seaborne may disclose Personal Data collected to our suppliers or subcontractors insofar as reasonably necessary for dealing with your inquiries or requests or to third party service providers that carry out certain functions on our behalf. Seaborne is made up of different legal entities and affiliate offices in this regard, we may also disclose your Personal Data with Seaborne members, affiliates or other subsidiary companies, which could include transferring data to other countries and Seaborne’s overseas offices. Such transfers will be protected by appropriate safeguards (e.g. appropriate contractual clauses, data processing contracts, intra-group disclosures of personal data, etc.).
5 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 (including the purposes for satisfying any legal, regulatory, tax, accounting or reporting requirements) and we will make sure that we will delete it securely. We may retain copies of our customer contracts in order to enable us to deal with any issues in addition to the information provided to us for identification verification checks, financial crime and anti-money laundering checks for 5 years after termination or expiry of our contract with you. We may also retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. For additional information on retention and deletion periods, please refer to the contact person mentioned at the end of the present Policy.
6 RIGHTS OF DATA SUBJECTS
In this section Seaborne addresses the rights deriving from GDPR 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.
6.1 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, receive a copy 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.
6.2 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.
6.3 Individual’s Right to Withdrawal
The data subject has the right to withdraw its previous consent for the processing of its personal data by contacting the contact person mentioned at the end of the present Privacy Policy.
6.4 Individual’s Right to Object
Individuals have the right to object at any time to processing of their personal data using the Personal Data Objection Form which may be obtained by contacting the contact person mentioned at the end of the present Privacy Policy.
6.5 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 Privacy 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.
6.6. Individual’s right to Complaint
In Greece, the authority responsible for handling complaints about GDPR breaches is the Hellenic Data Protection Authority (HDPA) (Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα). You can submit a complaint directly to the HDPA if you believe your Personal Data rights under the GDPR have been violated.
7 THIRD PARTY LINKS
This website may include links to third-party websites, plug-ins and other applications. By clicking on those links, you might allow third parties to collect or share data about you. We are not responsible for third parties’ privacy notices and their procedures are out of our control.
8 DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.
9 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.
10 OUR DETAILS
If you have any concerns or complaints about this Privacy Policy, then please contact us at:
4 Andrea Papandreou Str.
16675 Glyfada Greece
+30 210 8981888
info@seaborne.com