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PRIVACY STATEMENT

IntroductionWelcome to the SMT Shipping Group's (SMT) privacy statement. SMT respects your privacy and is committed to protecting your personal data. This policy applies to our customers, suppliers, vendors, website visitors, those who visit one of our offices or vessels and those who apply to work with us (whether as an employee, worker or contractor).

 

This privacy statement is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. COOKIES
6. DISCLOSURES OF YOUR PERSONAL DATA
7. INTERNATIONAL TRANSFERS
8. DATA SECURITY
9. DATA RETENTION
10. YOUR LEGAL RIGHTS

 

 1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy statement

This privacy statement aims to give you information on how SMT collects and processes your personal data. It is important that you read this privacy statement together with any other privacy statement or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy statement supplements other notices and privacy policies and is not intended to override them.

 

Controller

This privacy statement is issued on behalf of all companies which receive personal data in the SMT Shipping Group, however SMT Shipping (Cyprus) Ltd is the controller and responsible for this website and for all personal data received by the SMT Shipping Group. Other SMT Shipping Group entities may also be controllers of your personal data when a group company:

    • provides goods or services to you (or someone you represent);
    • discuss a commercial relationship with you (or someone you represent); or
    • provides marketing to you.

 

Contact details

If you have any questions about this privacy statement or our privacy practices, please contact us in the following ways:

Email address: gdpr@smtshipping.com

Postal address: 33, Michalis Zavos street

Agios Athanasios

4107

Limassol

P O Box 57114

3312

Limassol

 

You have the right to make a complaint at any time to the applicable data protection regulator. The UK data regulator is the Information Commissioner's Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach any data regulator, so please contact us in the first instance.

 

Changes to the privacy statement and your duty to inform us of changes

We keep our privacy statement under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

This privacy statement was last updated on 8 April 2024.

 

 

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.

 

 

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

        • Identity Dataincludes first name, last name, details of who you act for (e.g. your employer), your role and information necessary to confirm your identity.
        • Contact Dataincludes billing address, delivery address, email address, telephone numbers, username for telecommunications products, and business contact information (including company name, email address and phone number).
        • Financial Dataincludes bank account, payment details and details for tax compliance.
        • Transaction Dataincludes details related to the services you have purchased or wish to purchase from us. This could include:
          • Information to complete any necessary documentation such as customs documents and any bill of lading.
          • Details of shipments including container numbers and contents of any container.
          • Identity Data and Contact Data of any third party who we are asked to send shipments or information to.
        • Technical Dataincludes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
        • Usage Dataincludes information about how you use our website, products and services.
        • Marketing Dataincludes your preferences for receiving marketing from us and details related to when we send marketing to you.
        • Communications Data includes communications between us, which may relate to our relationship, services we provide, enquires and complaints.
        • Candidate Dataincludes the personal information we collect about you when you apply to work with us which may include:
          • The information you have provided to us in your CV and covering letter;
          • The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.
          • Any information you provide to us during an interview.
          • Copies of photographic ID and proof of address / nationality documents.
          • We may also collect, store and use the following types of more sensitive personal information:
            • Information about your nationality, race or ethnicity, religious beliefs, sexual orientation and political opinions.
            • Information about your health, including any medical condition, health and sickness records.
            • Information about criminal convictions and offences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy statement.

 

We also operate CCTV aboard our vessels, and these would capture images and recordings on or nearby these vessels. We may also operate CCTV at our offices which may capture video recordings of you if you are inside or outside of the office. We have explained below how we use the CCTV data that we collect.

 

Except where you apply to work with us or we capture your image with CCTV, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We do not knowingly collect data relating to children.

 

 

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

        • Direct interactions.You may give us your Identity, Contact, Financial, Transaction, Communication, Marketing, Usage and Candidate Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
        • Automated technologies or interactions.As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We also use CCTV aboard our vessels or at some of our premises which could capture images of you.
        • Third parties or publicly available sources.We will receive personal data about you from various third parties and public sources as set out below:
          • When you apply to work with us, we may collect personal data from recruitment agencies, public databases, your referees, background check providers and credit reference agencies.

 

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

        • Where we need to perform the contract we are about to enter into or have entered into with you.
        • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
        • Where we need to comply with a legal obligation.

 

Generally, we do not rely on consent as a legal basis for processing your personal data although we may get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

 

Providing services to our customers

If you are a customer or potential customer we may process your personal data to:

        • Provide you with an estimate or quote for our services.
        • Process and deliver our services, including booking transport and tracking delivery.
        • Complete necessary paperwork related to our services, including customs documents.
        • Manage payments, fees and charges and to enable us to collect payment.
        • Manage our relationship with you, which may include dealing with any enquiries or complaints.
        • Collect feedback about our services.

 

For our customers and potential customers we may process the following types of personal data:

        • Identity Data.
        • Contact Data.
        • Financial Data.
        • Transaction Data.
        • Usage Data.
        • Communication Data.

 

Our lawful basis for processing the personal data of customers and potential customers is:

        • Performance of a contract with you.
        • Necessary for our legitimate interests, which may include:
          • Maintaining and building our business relationship with you. This may also include communicating with individuals about our services who are not a party to the agreement with our customer (e.g. employees of our customer).
          • Dealing with any enquiry or complaint.
          • Studying how customers use our services, to develop them and grow our business.
          • Keeping our records updated and to study how customers use our services.
          • To enforce legal claims including recovering debts due to us.
          • To perform customs declarations.
        • To comply with a legal obligation.

 

When you visit our website

When you visit our website, we may process your personal data to:

        • Administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
        • Use data analytics to improve our website, services, marketing, customer relationships and experiences.

 

For our website visitors we may process the following types of personal data:

        • Identity Data.
        • Contact Data.
        • Technical Data.
        • Usage Data.

 

Our lawful basis for processing the personal data of website visitors is:

        • Necessary to comply with a legal obligation.
        • Necessary for our legitimate interests, including:
          • 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.
          • To define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.

 

When we work with you as a supplier, vendor or otherwise

If you act as a supplier, vendor or otherwise work with us (but not as a customer or as a member of our staff), we may process your personal data to:

        • Receive services, goods and to work with you.
        • Manage our relationship with you, including and legal claim.
        • To pay for the services and goods that we purchase

 

We may process the following types of personal data:

        • Identity Data.
        • Contact Data.
        • Financial Data.
        • Personal data related to the services or goods that you may provide to us.
        • Communication Data.

 

Our lawful basis for processing the personal data of suppliers, vendors or others that we work with is:

        • Performance of a contract with you.
        • Necessary for our legitimate interests, which may include:
          • Maintaining and building our business relationship with you.
          • Dealing with any enquiry or complaint.
          • To enforce legal claims.
        • To comply with a legal obligation.

 

When you apply to work for us

If you are applying to work with us, we will use the personal information we collect about you to:

            • Assess your skills, qualifications, and suitability for the role.
            • Carry out background and reference checks, where applicable.
            • Communicate with you about the recruitment process.
            • Keep records related to our hiring processes.
            • Comply with legal or regulatory requirements.

 

It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role. We also need to process your personal information to decide whether to enter into a contract with you.

 

When you apply to work with us, we may also process the following Special Categories of Personal Data in the following ways:

            • We may use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
            • We may use information about your race or national or ethnic origin, religious, political or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

 

We envisage that we may process information about criminal convictions dependent on the role you apply for. We may collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We may be required to carry out criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular if:

            • We are legally required to carry out criminal record checks.
            • The role requires a high degree of trust and integrity, for example if it involves dealing with high value client money, and so we would like to ask you to seek a basic disclosure of your criminal records history.
            • Required for the purposes of arranging foreign or work visas.

 

When we market to you

We may wish to market our services to you (or the entity you represent). We process your personal data for marketing to:

            • Make suggestions and recommendations to you about services that may be of interest to you.
            • Update you about our business.

 

To market to you, we may process:

            • Identity Data.
            • Contact Data.
            • Transaction Data.
            • Usage Data.
            • Communication Data.
            • Marketing Data.

 

Where we can, we rely on legitimate interests to send marketing to you. Our legitimate interests include:

            • To develop and promote our services and grow our business.
            • To study how customers use our services, to develop them, to grow our business and to inform our marketing strategy.

If we cannot rely on legitimate interests, we will obtain your consent to send marketing to you.

 

You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase or other transactions with SMT.

 

 

 

When you visit our offices or vessels

We process your Identity Data and Contact Data when you visit our offices or vessels to confirm your identity and to keep our offices and vessels secure. We may also process Communication Data, Usage Data and Transaction Data to facilitate any meeting we have with you at our offices.

 

Our lawful basis for this processing is to comply with a legal obligation or for our legitimate interest which may be:

            • To confirm your identity.
            • To discuss our relationship with you and to promote our business.
            • For security purposes, to protect you and us.
            • To exercise our legal rights.

 

We may operate CCTV on our vessels which may capture video recordings of you if you board or are nearby a vessel. We may also operate CCTV at our offices which may capture video recordings of you if you are inside or outside of the office. Our lawful basis for using CCTV is our legitimate interests of maintaining safety, security, the prevention of crime and in regard to vessels to assist in manoeuvring the vessel.

 

If we process Special Categories of Personal Data (as defined above) that have been captured by CCTV images, our lawful basis is:

            • Substantial public interest, which may include preventing and detecting unlawful acts.
            • Necessary for the establishment, exercise or defence of legal claims.

 

We will only process data related to criminal convictions or offences that have been captured by CCTV images when we are authorised to do so under law.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5. COOKIES

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. We use the following cookies:

            • Necessary cookies. These are cookies that are required for the operation of our website.
            • Analytics cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

 

Cookie Name Purpose Duration
iside_cookies This cookie is necessary. It allows the cookie banner to function. 1 Month
iside_accept_cookies This cookie is necessary. It stores the cookie banner preference and uses the consent for other purposes (if applicable). 1 month
_ga This analytics cookie is provided by Google and enables us to distinguish users. To store, count and track pageviews. 2 years
_ga_PSVR9XWWQQ This analytics cookie is provided by Google and enables us to persist session state and to store, count and track pageviews. 2 years

 

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.

 

 

6. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in this privacy statement.

            • Other companies in the SMT Shipping Group who may be based in Cyprus, Poland, the Netherlands, the United Kingdom, the United States, Norway, Guinea and Ghana.
            • To our agents, contractors and external service providers, which may include IT providers, travel agents, repair companies, banking and payroll providers, ship chandlers and classification societies.
            • Professional advisers including lawyers, bankers, auditors, insurers and P&I clubs.
            • Law enforcement agencies, governmental agencies, courts, regulators and other authorities.
            • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy statement.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

7. INTERNATIONAL TRANSFERS

We share your personal data within the SMT Shipping Group. This may involve transferring your data outside the UK and EEA.

 

Some of our external service providers are based outside the UK and EEA so their processing of your personal data will involve a transfer of data outside the UK and EEA. Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

            • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
            • Where we use certain service providers, we may use specific contracts approved for use which give personal data the same protection it has in the UK and EEA.

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

 

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.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

9. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, investigation or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

 

Details of retention periods for different aspects of your personal data are available in our Data Retention Policy which you can request from us by contacting us.

 

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

            • Request access to your personal data(commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
            • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
            • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
            • Object to processing of your personaldata where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
            • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
              • If you want us to establish the data's accuracy.
              • Where our use of the data is unlawful but you do not want us to erase it.
              • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
              • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
            • Request the transfer of your personal datato you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
            • Withdraw consentat any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

 

If you wish to exercise any of the rights set out above, please contact us using the details set out above.

 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.