PRIVACY POLICY
1. Scope
Our Privacy Policy applies to the personal
data that NIRIIS SHIPPING SA collects and uses.
NIRIIS SHIPPING SA is registered at PANAMA and
has office in GREECE
NIRIIS SHIPPING SA controls how the personal
data is collected and the purposes for which the personal data are used. NIRIIS
SHIPPING SA is the “data controller” for the purposes of the Hellenic Data
Protection Act or the Regulation (EU) 2016/679 of 27 April 2016 (the GDPR).
2. Personal data
collected by NIRIIS SHIPPING SA
When using the term
“personal data” in our Privacy Policy, we mean information that relates to the
applicants for employment or employees of the Company or the crew of the
vessels that Company manages and allows the Company to identify them, either
directly or in combination with other information that we may hold. The Personal
data includes, for example, the name, the contact details, the Passport or the ID.
We collect some
personal data, for example when an employee or a seaman applies in order to be
employed by our Company or in one of our managed vessels. We may also receive
personal data from companies we cooperate with (for example our manning Agent).
For more information on the parties who may
share your personal data with us, please see section 7 below.
Categories of data we
collect
We may collect and process the following
categories of information about you:
|
Categories of
personal data processed |
When do we process
the personal data mentioned? |
Which legal basis do
we rely on for processing your personal data? |
|
Name and surname and
contact details |
In case of
application for employment or employment with our Company or our managed
vessels |
We base the
processing on our legitimate interest in running our daily business and being
able to provide our services. |
|
Identification
Documents |
In case of
application for employment or employment with our Company or our managed
vessels |
We base the
processing on our legitimate interest in running our daily business and being
able to provide our services. |
|
C.V. or application covering the personal and professional part. Information about Employees’
and seamen’ (employed or applicants) previous employments |
When an application
for employment with the Company or any
managed vessel is received |
We base the
processing on our legitimate interest in being able to decide whether a
candidate seaman or employee can cover our needs and the applicants are
competent for the position they apply for and also in being able to decide
whether the applicant has the experience required for the post he applies
for. Our processing will
be based on consent, which we will ask the seaman to provide upon receiving
the information. |
|
Communications with us (for example, emails, letters or
messages) |
When the crew
/applicant contacts NIRIIS SHIPPING SA or is contacted by NIRIIS SHIPPING SA |
We base the
processing on our legitimate interest in running our daily business and being
able to provide you with our services. |
|
Pictures or videos taken at events on board our managed
vessels which may include the seaman or Company’s employee (training drills,
works …). |
When the crew or
Company’s personnel participate in any event on board one of our managed
vessels. |
These pictures or
videos are of a situational character and does not specifically depict the
employees or the seamen. |
|
Employed or
applicants feedback |
When Employees and
seamen reply to our requests for feedback |
We base the
processing on our legitimate interest in running our daily business and being
able to provide our services. |
|
Information that
relates to period of employment |
During Employees’
and seamen’ employment or on the completion of the employment. |
We base the
processing on our legitimate interest in running our daily business and being
able to find out how our employees / seamen perform during their employment
and further to decide whether are re-employable or not. Our processing will
be based on consent, which we will ask the seaman to provide upon employment. |
|
Payment history of Employees’
and seamen’ salaries |
During employment. |
We base the
processing on our legitimate interest in being able to document all payments
as per the agreement between employee / seaman and our Company. This processing
enables us to cover our contractual obligations as well as our legal
obligations against the state authorities. |
Sensitive personal data
In the course of
providing services we do not collect sensitive data, unless any Employee or
seaman (employed or applicants) has provided such information in order to
allow us to decide whether he/she may be employed by our Company or in one of
our managed vessels and such information reveals health information about the
individual. In such case, we will seek specific individual’s consent before we
process any such information and we do not send this information to a third
party, unless we have the data subject’s consent and we have notified the
Personal Data Authority.
3. How and why we use the
personal data
We use the personal data for the following
purposes:
To provide professional services.
When we receive an employment application or someone is employed by our Company
or in one of the managed vessels, we use the personal data to perform our
services in relation to the employee. The personal information we collect and
process in this regard is required in order to:
- Find out that the applicant meets the requirements for
the job he applies for.
- Be able to proceed with a contract of employment
- In case of contract, be able to meet the requirements
of the interaction with the involved authorities and / or
- Meet the requirements of the pertinent laws, rules and
regulations related to the job
- To issue travelling tickets, visas and response to Port
Authorities requirements during vessel’s visits in various ports
To communicate with the applicant or the employee and manage our
relationship.
Occasionally we may
need to contact the applicant or the employee by email or phone for
administrative or operational reasons, for example in order to inform the
applicant about the upcoming employment, the flight details, etc. or to notify the
applicant of delayed changes of the travelling details.
We will also use the personal data if we contact the applicant after receipt of
any request for information.
To inform candidate seamen or employees about employment opportunities.
We do not share contact details or other personal data with other companies,
unless we have first obtained individual’s written consent to do so.
To improve our services, fulfil our administrative purposes and
protect our business interests.
The business purposes for which we will use the personal data include, but are
not limited to, accounting, billing and audit, credit or other payment verification,
fraud screening, safety, security and legal purposes, statistical analysis.
4. Your rights
The EU Data Protection
legislation provides for certain legal rights for each data subject, which you
can address to NIRIIS SHIPPING SA. 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 or contact us
at niriis@niriisshipping.gr
Right of access. You are entitled to be informed as to whether
NIRIIS SHIPPING SA is processing personal data about you. If we are, you are
entitled to receive 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 NIRIIS SHIPPING SA, in a structured,
commonly used, and machine-readable format. You also have the right to require
that NIRIIS SHIPPING SA 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 the right to require that NIRIIS
SHIPPING SA corrects erroneous or incomplete information about you.
Deletion of certain data. You have a right to require NIRIIS SHIPPING
SA 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 NIRIIS SHIPPING SA’s processing
of personal data. You have the right,
under certain circumstances, to object to NIRIIS SHIPPING SA’s processing of your
personal data.
Right to restrict the processing of your
personal data. You have the right
to require NIRIIS SHIPPING SA 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 NIRIIS SHIPPING SA 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.
The withdrawal of your consent may result in termination of your
employment in circumstances where the non-processing of your data will not
allow us meeting the requirements imposed by involved authorities or pertinent
laws, rules and regulations. In such a
case you will be informed about the consequences of your withdrawal of your
consent. In case that you finally withdraw your consent, this shall be
considered as an important reason for contract termination, and you will be
responsible for any resulting consequences, as per your contract of employment.
Complaints. If you have any complaints regarding the NIRIIS SHIPPING SA’s processing
of your personal data, you are entitled to file such complaints with the Data
Protection Authorities.
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 us at: niriis@niriisshipping.gr.
5. Security of the
personal data
NIRIIS SHIPPING SA takes reasonable security measures to protect
your Personal Information against loss and misuse, as well as unauthorized
access, disclosure, destruction or alteration of the information that is under
our control.
We strictly limit worker (i.e., employees or contractors) access
to Personal Information by giving our workers only the necessary access to
carry out their job responsibilities. NIRIIS SHIPPING SA periodically audits
for compliance and updates its security measures in an effort to provide
appropriate security for all information held.
All necessary technical and organizational measures are taken to
ensure your personal data is protected against unauthorized use.
The information that is provided to us will be
held on in-house or hosted systems owned or not owned by us. We may also allow
access to the 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 the individual.
6. For how long we
process your personal data
We will retain 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 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.
Data of past employees are kept by NIRIIS for
as long as the fiscal, social security and employment legislation requires.
7. Sharing the
personal data
Personal data may be shared within NIRIIS
SHIPPING SA and the entities NIRIIS SHIPPING cooperates with, in the frame of
our professional relationship.
We may also share some of your personal data
with, or obtain your personal data from, the following categories of third
parties:
Suppliers providing services to us in order to help us run our
business. 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 NIRIIS SHIPPING SA while
performing a service for NIRIIS SHIPPING SA
NIRIIS SHIPPING SA takes all reasonable 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 with providing the above list of NIRIIS SHIPPING SA services
are:
·
Manning Agent
·
Port Agents in ports
visited or to be visited by the vessel you are employed in.
·
State, Flag
Administration and Port Authorities
·
Classification
Societies
·
Charterers and Brokers
·
Companies rendering
services to the vessel, on permanent or occasional basis.
·
Travel Agents
·
Airport Authorities.
·
Insurance companies.
·
Custom Offices.
The personal data that we transfer to the
above suppliers varies depending on the kind of service we receive. Above
mentioned suppliers may or may not 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 instructed to limit
their processing to the absolutely necessary data and only in the scope of
services provided.
NIRIIS SHIPPING SA shall state the scope of use of the provided
personal data in the correspondence with these third parties.
Bank Account. NIRIIS
SHIPPING SA shares some of your personal data, which includes information required
for your payment to the service provider used for processing your payments.
Authorities.
We may disclose your personal data to state authorities 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 NIRIIS SHIPPING SA is subject.
8. Updates to our
Privacy Policy
We may make changes to this Privacy Policy
from time to time, including as part of the new European data protection
legislation which will start to apply on 25 May 2018 (the “General Data
Protection Regulation”) - we will update this Privacy Policy and publish any
new edition. Our current policy is published at www.niriisshipping.gr
9. Contact information
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to niriis@niriisshipping.gr.