DATA PROTECTION POLICY

NIOVIS SHIPPING Co S.A (the “Company”) respects your privacy and strives to handle all personal data responsibly.

This Policy has been developed to clearly describe what types of information we gather, how this information is used, with whom it is shared and why, and to ensure that the Company complies fully with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (the “General Data Protection Regulation” or “GDPR”).

PRIVACY PROTECTION CONTENTS

1. IMPORTANT INFORMATION

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. DATA SECURITY

7. DATA RETENTION

8. YOUR LEGAL RIGHTS

9. GENERAL STAFF GUIDELINES

10. GLOSSARY

11. AFTERWORD

1. IMPORTANT INFORMATION

1.1 Purpose of this Privacy Notice

This privacy notice aims to give you information on how NIOVIS SHIPPING Co S.A collects and processes your personal data.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

1.2 Controller

NIOVIS SHIPPING Co S.A is a data controller and responsible for your personal data (referred to as the Company, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below:

Any requests or objections should be made in writing.

Our full details are:

Full name of legal entity:  NIOVIS SHIPPING Co S.A 

Email address:

Postal address: Akti Themistokleous & Ygeias 1-3 TK 18536 Piraeus – Greece

Person in Charge: Capt. Christos Gianneios / Crew Department

1.3 Changes to the Privacy Notice and Your Duty to Inform us of Changes

This version came into effect in May 2018. 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.

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 follows:

1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, ID, Passport, Social Security Number, family status, contact and emergency contact details etc.
2. Contact Data includes email address and telephone numbers.
3. CV’s details such as application forms and references, education, working experience, correspondence with or about you.
4. Bank Accounts/customer account information number for safe transfer of money orders and cash advances, in connection with credit requests, Social Security Number or other national/tax identification number
5. Crew’s and office personnel Degrees, diplomas and service on board records.
6. Technical Data includes internet protocol (IP) address, browser type and version, email addresses, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology that interacts during communication through emails via computers.
7. We may also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data for statistical authorities (ELSTAT: Hellenic Statistical Authority). 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 notice.
8. We may also collect Special Categories of Personal Data about you. This includes information about your health such as vessel’s personnel medical cards and reports, required by authorities for all crew on board.

We do not knowingly collect personal data about any person under the age of 18.
We will not collect any information about criminal convictions and offences, unless we have obtained your express consent.

We ask that you not send us, and you not disclose, any sensitive personal data (for example, information related to racial or ethnic origin, political opinions, religion or other beliefs trade union membership etc.).

2.1 If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product, service or contract you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

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

1. Direct interactions. You may give us your Identity, Contact and financial data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
2. apply for a position in our Company or crew;
3. offer your or your company’s business services to the Company;
4. where you work for one of the Company’s clients, business partners, consultants, advisors or other third parties the Company interacts with in a business context;
5. otherwise interact with us for your and our business purposes, including marketing to us (whether by email or in person) or meeting us or any of our representatives in business context.

We collect personal data and keep them in electronic or hardcopy records and we use a combination of working practices and technology to ensure that your information is kept confidential and secure.

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:

1. Where we need to perform the contract we are about to enter into or have entered into with you or your employer.
2. 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.
3. Where we need to comply with a legal or regulatory obligation.

NIOVIS SHIPPING Co S.A may maintain personal data for:

• suppliers
• service providers
• business partners
• consultants and professional advisors
• enquirers, complainants
• employees
• claimants

Generally, we do not rely on consent as a legal basis for processing your personal data.

4.1 Purposes For Which We Will Use Your Personal Data

We may use and process the data you submit to accommodate your requests and inquiries and comply with applicable laws and legislation.

Your personal data is required for communication purposes with a view of potentially setting up a collaboration with you.

Your data may also be used and processed in considering an application for a vacancy within our Company and her managing vessels. Without these data NIOVIS SHIPPING Co S.A will not be able to communicate with you or enter into a contractual agreement with you. This includes both business and employment contracts.

4.2 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. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

1. Internal Third Parties as set out in the [Glossary].
2. External Third Parties as set out in the [Glossary].
3. Specific third parties such as 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 notice.
4. Port agents and competent authorities

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.

6. DATA SECURITY

NIOVIS SHIPPING Co S.A is committed to protecting the security of personal data. While no security measure can guarantee against compromise, we use a variety of security technologies and procedures to help protect data from unauthorized access, use, altered, disclosed or being accidentally lost.

In addition, in case of a need only, we limit access to your personal data to those agents, contractors and other third parties who have a business need to know and for that extend that required. They will only process your personal data on our instruction, and they are subject to the duty of confidentiality.

Should NIOVIS SHIPPING Co S.A need to transfer your personal data, will take all necessary and appropriate measures to ensure that the transfer of your personal data is conducted securely and in compliance with the requirements of the GDPR.

6.1 International transfers of personal data:

To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information. For example, where required to send crew details to port agent in that countries we use email disclosures – confidentiality notice.

If we notice any suspected personal data breach, will notify subject person(s) and any applicable regulator of a breach where we are legally required to do so.

7. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements unless a longer retention period is required or permitted by law.

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 unauthorized 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 requirements.

We will also retain and use your information for as long as necessary to resolve disputes and/or enforce our rights and agreements. We retain accounts information for as long as our employer’s account is active.

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. YOUR LEGAL RIGHTS

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

1. 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.
2. 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.
3. 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.
4. Object to processing of your personal data 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.
5. 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

1. Request the transfer of your personal data to 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.
2. Withdraw consent at 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 products or 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.

8.1 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.

8.2 Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

9. GENERAL STAFF GUIDELINES

The only people able to access data covered by this policy should those who need it for their work.

Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.

NIOVIS SHIPPING Co S.A will provide training to all employees to help them understand their responsibilities when handling data.

Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

In particular, strong passwords must be used and they should never be shared.

Personal data should not be disclosed to unauthorized people, either within the company or externally.

Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

Employees should request help from the Company’s person in Charge for data if they are unsure about any aspect of data protection.

9.1 Data Storage

These rules describe how and where data should safely stored. Questions about storing data safely can be directed to our outsourced IT personnel or Company’s person in charge for data.

When data is stored on paper, it should be kept in a secure place where unauthorized people cannot access it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

1. • When not required, the paper or files should be kept locked drawer or filing cabinet.
   • Employees should make sure paper and printouts are not left where unauthorized people could see them, like on a printer.
   • Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorized access, accidental deletion and malicious hacking attempts:

1. • Data should be protected by strong passwords that are changed regularly and never shared between employees.
   • If data is stored on removable media (like a CD or DVD). These should be kept locked away securely when not being used.
   • Data should only be stored on designated drives and servers in company’s premises.
   • Servers containing personal data should be sited in a secure location away from general office space.
   • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
   • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
   • All servers and computers containing data should be protected by approved security software and a firewall. 

9.2 Data Use

It is when personal data is accessed and used that it is at the greatest risk of loss, corruption or theft:

1. • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
   • Personal data should not be shared informally and without a reason.
   • Employees should not save copies of personal data to their own computers.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

1. • Data will be held in a few places, as necessary. Staff should not create any unnecessary additional data sets.
   • Staff should take every opportunity to ensure data is updated.
   • Data should be updated as inaccuracies are discovered.

10. GLOSSARY

1. Personal information refers to any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information or when put together with other information would directly and certainly identify an individual.
2. Legitimate Interest means the interest of our business in conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
3. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or your employer is a party and processing your personal data is necessary for such performance (e.g., where your email identifies you in person or where we are given access to your mobile or home telephone numbers) or to take steps at your request before entering into a contract with you.
4. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
5. Third Parties means Internal Third Parties and External Third Parties.
6. Internal Third Parties Other companies in our Group acting as processors and who are based in the United Kingdom and provide insurance, chartering and commercial services to us.
7. External Third Parties:
   1. Service providers acting as processors who provide IT and system administration services.
   2. Professional advisers including lawyers, bankers, auditors and insurers based in and/or out EEA who provide consultancy, banking, legal, insurance and accounting services.
   3. Ergani/other public bodies

11. AFTERWORDS

NIOVIS SHIPPING Co S.A recognizes the importance reviewing the present policy on a regular basis (typically on an annual basis) unless a critical occurrence has taken place.

This Policy will state the date it was last reviewed and also the date on which any revisions were made.

Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified.