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DATA PRIVACY POLICY

SMT Shipping is committed to the protection of all personal information we control and process as part of our daily operations. Our offices and representative agencies around the world fully comply with the General Data Protection Regulation (GDPR). This Privacy Policy fully describes SMT Shipping’s approach to your personal data and how your data privacy rights are protected under GDPR.

 

SMT has also appointed a Data Protection Officer who assures the company’s compliance with the GDPR and addresses any questions or concerns regarding the company’s data privacy policies.

To contact our DPO, Vanessa Voorham, please email her directly at v.voorham@smtshipping.com or at the general privacy email box at privacy@smtshipping.com

Who is responsible for your data?

Our Privacy Policy applies to the personal data that SMT Shipping and all its subsidiaries collect and hold on your personal data.

 

References in the Privacy Policy to “SMT Shipping”, “SMT”, “we”, “us” or “our” mean SMT Shipping wholly owned subsidiaries, representative offices, agents, and affiliates.

 

SMT controls how your personal data is collected and the purposes for which we use your personal data. SMT Shipping is the “data controller” for the purposes of the Regulation (EU) 2016/679 of 27 April 2016 (the GDPR).

Personal data we collect about you

When using the term “personal data” in our Privacy Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your personal data includes, for example, your contact details or information on how you use our website, or data from when you interact with us.
We collect some personal data from you, for example, when you use our website, use our services or simply contact us. We may also receive your personal data from our suppliers who provide services to you on our behalf (such as insurance claims processors, cargo inspectors, stevedores, etc.).

Categories of data we collect

You have a right to know how we use your data

You have a right under the GDPR to understand not only the specific personal data we gather, hold, and use (actions collectively referred to by the GDPR legislation as “processing data”). SMT may collect and process the following categories of information about you.

Sensitive personal data

It is important to note that in the course of providing services to you, we do not collect sensitive data, such as dietary restrictions, religious preferences, sexual orientation, etc. We will only collect and hold medical information that you consent to provide us and that has a meaningful impact on your safety and other working in our offices and on our vessels.

How and why we use your personal data

We use your personal data for the following purposes:

    • To provide professional services to you
      When you ask for information about the services we provide, help us purchase your goods or services,   or work with us to have us provide you with service, we use your information to assure that those tasks are accomplished efficiently, professionally, and completely. For example, we would use your information to answer an enquiry, to issue an invoice, to pay an invoice, to negotiate a contract, to pay compensation, etc.
    • To communicate with you and manage our relationship with you
      Occasionally we may need to contact you by email or phone for administrative or operational reasons, for example in order to send you information related to your work with us and to follow up on ongoing work. Occasionally, we may need to send you documents or goods to your home address if you determine that this is the best delivery location, in which case we will use that information as well.Please be aware that these communications are not made for marketing purposes and will not be shared with third parties until we receive oral or written confirmation from you that we are free to do so. Your opinion is very important to us, so we may send you an email to seek your feedback.
      We will use your communications with us and the feedback you may provide in order to manage our relationship with you.
    • To personalize and improve your customer experience
      We may use your personal data in order to tailor our services to your needs and preferences to provide you with a personalized experience. For example, if you inform us about your role in shipping and have consented to receive further communications from us, we will be able to send you correspondence relevant to your business and job function.
    • To inform you about our company news
      If you have given us your consent to receive communications like our newsletter or other marketing materials, we will send that information to you. Please note that we do not share your contact details or other personal data with other companies for marketing or any other purpose, unless we have first obtained your oral or written consent to do so.If you do receive our company newsletter or marketing materials and would prefer to be removed from our distribution list, kindly email your removal request to v.voorham@smtshipping.com or use our general privacy email box at privacy@smtshipping.com.
    • To improve our services, fulfil our administrative purposes and protect our business interests The business purposes for which we will use your information include, but are not limited to, accounting, billing and audit, fraud screening, safety, security and legal purposes, statistical and marketing analysis, systems testing, maintenance and development of our services.
    • To facilitate and improve the ways in which we interact with our current and perspective contractors and employees.
      In order to fulfil our obligations and responsibilities as employers, we may use your information for such tasks as, but not limited to, payroll, accounting, insurance claims, next of kin notification, security and legal matters, distribution of marketing, recruitment, and promotional materials, and any task pertaining to the creation, fulfilment, adjustment, renewal, or lawful termination of an employment contract.

Cookies

SMT Shipping uses information that we gather from our own cookies, tracking pixels and other tracking technology integrated into the Services. This processing applies to all groups of end users of the relevant Services.

 

When you access and start using the SMT website or its digital newsletter the Nautical News, you are consenting to SMT Shipping’s processing data about you, as described in this privacy policy.

 

If your browser allows information files, so-called cookies, this is considered as your having given us consent to using cookies as stated in this privacy policy. Please also see our Cookie Policy . However, we wish to inform you that certain parts of the Services’ functionality depend on such consent and that your access to and experience as a user of the Services could therefore be affected.
When you access and start using the SMT website or its digital newsletter the Nautical News, you are consenting to SMT Shipping’s processing data about you, as described in this privacy policy.

 

If your browser allows information files, so-called cookies, this is considered as your having given us consent to using cookies as stated in this privacy policy. Please also see our Cookie Policy. However, we wish to inform you that certain parts of the Services’ functionality depend on such consent and that your access to and experience as a user of the Services could therefore be affected.

Recruitment Privacy Notice

If you contact SMT Shipping regarding a job vacancy, you will be asked to submit the limited personal data which is necessary for us to communicate with you and process your job application. We take your personal data seriously and will process your personal information strictly according to our Recruitment Privacy Policy.

 

Categories of Personal Data Examples of Personal Data in this Category When do we process this type of personal data? Which legal basis do we rely on for processing your personal data?
Name, Surname, and Contact details
  • Email address
  • Job title
  • Telephone numbers
  • Postal address
  • Skype name
  • When you interact with one of our staff
  • When you use our services of our staff
  • When you contact us via our website
  • When you enter into a contract with us
  • We base the processing on our legitimate interest in running our daily business and being able to provide you with our services or in the performance of a contract. Insofar as we receive any sensitive information from you,

e.g. information on your health or religion, our processing will be based on consent, which we will ask you to provide upon receiving the information.
Personal Health Information
  • Results of a seaman’s medical exam and health checks
  • Medical information pertaining to an insurance claim
  • Dietary restrictions
  • When you consent to the seafarer’s medical exam and health checks
  • When you provide us with information pertaining to an insurance claim
  • When you provide us with your dietary restrictions
Corporate and Personal Financial Information
  • Banking details for payments to your company
  • Banking details for payments to you as an employee, seaman, contractor, or investor
  • Banking details for third party designees
  • When you provide your company’s banking details to us
  • When you provide your personal banking details to us
  • When you provide us with the banking details for third party designees that you identify
  • We process your company’s banking details to assure that we pay you in full and in a timely manner for the goods and services you have provided to us.
  • We process your personal banking details to assure that we compensate you in full and on time.
  • When asked by our employees and contractors, we will with permission from both you and your designated beneficiary, send direct payments to your chosen third party beneficiary. We process that beneficiary’s personal financial information to facilitate those payments.
  • In certain circumstances we may provide your banking details to insurers to ensure that the proceeds of any insurance claim is paid directly to you.
Information about your use of our contracts and related transactions
  • Your signed copies of agreements and contracts
  • When you sign a contract, MOA, or any other agreement with us
  • We process this information to enable us to perform the contract.
Records about your role as a personal assistant for colleagues
  • Email address
  • Job title
  • Telephone numbers
  • Postal address
  • Skype name
  • Email and postal correspondence with us
  • When you conduct business on behalf of others
  • We base the processing on our legitimate interest in running our daily business in the most efficient way.
Your communications with us
  • Emails
  • Letters
  • Telephone calls
  • SMS
  • Skype and Whatsapp
  • When you contact SMT or you are contacted by SMT
  • We base the processing on our legitimate interest in running our daily business and being able to provide you with our services or have you provide us with your services.

Your rights regarding your personal data

Your rights

You have certain legal rights under EU data protection legislation, which you can enforce against SMT Shipping. Set forth below is a summary of these rights. For complete information regarding your rights, please see the General Data Protection Regulation (Regulation (EU) 2016/679), sections 3–5.

  • Right of access. You are entitled to be informed as to whether SMT is processing personal data about you. If we are, you are entitled to information regarding, among other things, which personal data we are processing, the purposes of the processing, which external recipients have access to your personal data, and how long we save your personal data.
  • Right to data portability. You have a right to receive a copy of the personal data which you have provided to SMT, in a structured, commonly used, and machine-readable format. You also have the right to require that SMT transfers this personal data to another controller of personal data. The right to data portability applies to personal data which is processed in an automated manner and which is based on your consent or on an agreement to which you are a party.
  • Correction of erroneous data. You have a right to require that SMT corrects erroneous or incomplete information about you.
  • Deletion of certain data. You have a right to require SMT to delete your personal data under certain circumstances, for example where the personal data is no longer necessary for the purpose for which we collected it.
  • Right to object to SMT’s processing of personal data. You have the right, under certain circumstances, to object to BIMCO’s processing of your personal data.
  • Right to object to direct marketing. You have the right at any time to object to SMT processing your personal data for direct marketing purposes. If you object to such processing, SMT must discontinue all direct marketing to you without undue delay.
  • Right to restrict the processing of your personal data. You have the right to require SMT to restrict its processing of your personal data in certain circumstances. For example, if you have denied that your personal data is correct, you can request a restriction on the processing during a period of time which allows SMT to verify whether the personal data is correct.
  • Right to withdraw consent. If our processing is based on your consent, you have the right to withdraw your consent to our processing of your personal data at any time. Such withdrawal does not affect the lawfulness of our processing based on your consent before its withdrawal.
  • Complaints. If you have any complaints regarding the SMT’s processing of your personal data, you are entitled to file such complaints with the Data Protection Authorities.

If you have questions, contact our Data Security Officer

If you have questions in relation to your personal data or would like to submit a request for an extract from the register, data portability, correction, deletion, objection, restriction or withdrawal of consent, please contact our Data Privacy Officer, Vanessa Voorham, at v.voorham@smtshipping.com or our general privacy email box at privacy@smtshipping.org.

Security of your personal data

We are committed to the security of your data

We are committed to taking appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data that we process about you. When you provide your personal data through our website or online services, this information is transmitted across the Internet securely using high-grade encryption.

 

As described in this Privacy Policy, we may in some instances disclose your personal data to third parties. If SMT discloses your personal data to a third party, we require that third party to have appropriate technical and organizational measures in place to protect your personal data.

The information that you provide to us will be held on hosted systems not owned by us, which are located in premises of an appointed third party within the EU. We may also allow access to your information by our subcontractors who act as data processors on our behalf for the purposes described in this Privacy Policy or for other purposes approved by you.

We will monitor how long we hold and process your data

We will retain your personal data for as long as we need it in order to fulfil our purposes set out in this Privacy Policy.

 

We may also save your personal data for a longer period of time where necessary in order to fulfil a legal obligation which requires processing by law or in order for us to be able to establish, enforce, or defend against legal claims.

 

Sharing your personal data

We will share data only when necessary and only when your data can be secured

 

If applicable, we share the minimum personal data required with the companies mentioned below who assist us running the services that we provide to you. These recipients are only entitled to process your personal data on behalf of SMT while performing a service for SMT.

 

SMT takes all reasonable legal, technical and organizational measures in order to ensure that your data is handled securely and with an adequate level of protection when transferring to, or sharing with, such selected third parties. The third parties assisting us fall into the following categories:

  • Agents
  • Insurance Providers and P&I Clubs
  • Webmasters and Domain Hosts
  • Legal and accounting services professionals
  • Relevant Governmental Agencies and Inspectors
  • Classification Societies
  • Repair Companies
  • Ship Chandlers
  • Banking/Payroll Companies
  • Travel Agents

 

The personal data that we transfer to the above vendors and professional services providers varies depending on the nature of the service we are providing you. In most instances the above mentioned suppliers will have their own set of Terms of Use detailing the types of personal data stored by the supplier in the respective system. Those suppliers who do not have their own Terms of Use will be limited to processing the following types of information:

  • Your name and contact details
  • Course or event bookings
  • Need for special assistance
  • Dietary requirements

 

SMT Shipping has entered into written service agreements with all of the above mentioned suppliers, in order to protect your personal data.

Transfers of personal data outside of the EU/EEA

We will protect your data even when we have to share it with those outside the EU jurisdiction

Your personal data will be processed primarily within the EU/EEA, but also processed by staff and contracted employees affiliated with our agent representatives around the world, including in nations such as, but not limited to, Ghana, Guinea, Mexico and the United States. To the extent your data is transferred to a country outside the EU/EEA, such transfers will be based on the Commissions Standard Contractual Clauses, 2010/87/EU. Categories of affiliates who fall under this category include, but are not limited to:

  • Agents who help us run our business. SMT Shipping shares some of your personal data with service providers worldwide who help our business to function efficiently. All of these service providers have been vetted to assure that they will uphold the requirements of the GDPR.
  • Authorities. We may disclose your personal data when this is required by the law of any jurisdiction to which we may be subject unless this is expressly prohibited by EU Member State law or the law of an EU country to which SMT Shipping is subject.

Updating our Policy and Contact Details

We will continually update this data privacy policy

We may make changes to this Privacy Policy from time to time to comply with any changes to legislation or so that we may reflect good business practice guidelines. We will publish any new edition on our website.