Bernhard Schulte Shipmanagement (“BSM”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice applies to information obtained through this website and how we use it.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy 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 other notices and privacy policies and is not intended to override them. Other specific policies are applied by BSM where your relationship with BSM is that of a representative of a client, a prospective client or other third party professional contact, and that of an employee, contractor or job applicant.
BSM consists of different legal entities, details of which can be found in http://www.bs-shipmanagement.com/en/contact. This privacy notice is issued on behalf of BSM so when we mention” Bernhard Schulte Shipmanagement”, “BSM”, “BSM Group?” “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the BSM Group responsible for processing your data.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our internal GDPR team at [email protected]
You have the right to make a complaint at any time to the concerned supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy notice under regular review. This version was last updated on 22.06.2018. We will inform you when we update our policy with a link to view historical versions.
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 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 notice of every website you visit.
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:
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 does 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 notice.
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.
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 (for example to provide you our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
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:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will 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.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We 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. The legal grounds for processing your data are:
We maintain a separate privacy notice about our marketing activities which you can view here
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or registered to receive our newsletter “BSM Highlights” and to receive information about events and industry news and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at [email protected] 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 product/service purchase, product/service experience or other transactions.
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.
We share your personal data with the parties set out below for the purposes set out in the table above.
We share your personal data within the BSM Group. This will involve transferring your data outside the European Economic Area (EEA). Not all countries provide the same level of protection in relation to personal information as within the EEA. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information. This will include having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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
HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?
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 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 Retention Policy which you can request from us by contacting us.
In some circumstances, you can ask us to delete your data: see “Your Legal Rights” below for further information.
In some circumstances, we will anonymise 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read below to find out more about these rights:
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 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.
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:
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.
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 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 at [email protected]
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.
The Schulte Group and its affiliates have an internal recruiting team to fill open roles that are posted to the general public. In certain cases, the Schulte Group may wish to add to its internal team’s capabilities by engaging with external recruiting vendors and employment agencies (“Recruiting Vendors”). Recruiting Vendors are not authorized to send resumes or candidate data or otherwise directly or indirectly contact the Schulte Group employees for the purposes of presenting candidates for employment.
The only exception to this directive is for Recruiting Vendors who fulfil the below requirements:
(1) have an active and Valid Agreement (as defined below) on file with the Schulte Group which has been authorized by the Schulte Group’s recruiting team (“Authorized Recruiting Vendors”); and
(2) must be specifically invited by the Schulte Group’s recruiting team to assist with searching for and submitting candidates for a specific position.
In compliance with this Directive, and to ensure only Authorized Recruiting Vendors can share resumes and/or candidate personal information, the Schulte Group will not accept unsolicited resumes from any other source whatsoever. Any unsolicited resumes or other candidate data submitted to the Schulte Group regardless of the means of transmission (email, fax, etc.) shall be considered Schulte Group’s property. The Schulte Group will not pay any placement or other fees of any kind for any unsolicited resumes or candidate data that is submitted in violation of this Notice. Any unsolicited resumes or other data submitted to the Schulte Group in violation of this Notice may be used by the Schulte Group without obligation to pay any fees of any kind to Recruitment Vendors. The Schulte Group may consider any candidate from whom a Recruitment Vendor has submitted an unsolicited resume to have been referred by the Recruitment Vendor free of any charges or fees. In case a Valid Agreement is not in place, the Schulte Group is under no obligation to provide any evidence of the source of any unsolicited resume received.
Valid Agreements are defined as being in writing and signed by an authorized designated signatory of the Schulte Group’s Recruiting team. No other Schulte Group employee or officer is authorized to sign an agreement with a Recruiting Vendor. If a Recruiting Vendor does not have a Valid Agreement, the Schulte Group or any affiliate companies do not accept liability under any legal doctrine such as course of conduct, oral agreements, implied contracts, or otherwise based on negotiations with a candidate identified from an unsolicited resume or data in violation of this Notice.