PRIVACY NOTICE
This Privacy Notice (“Notice”) outlines how Seaborn (“Seaborn”, “we”, and “us”) collects, utilizes, shares, transfers, stores, retains, or otherwise processes personal information in compliance with applicable data protection laws and regulations. This applies when you visit our websites or engage with our services. Within this Notice, you will find specific examples of how and why we handle your personal information.
We are company number 14726003 registered in the United Kingdom. Our registered office is located at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF United Kingdom.
OUR DEDICATION TO PRIVACY
Seaborn is committed to upholding your privacy and maintaining the confidentiality of your data. Our approach goes beyond legal requirements; it reflects our respect for you and your personal information. We strive to earn your trust by ensuring the secure handling of all information you provide.
COMPLIANCE WITH DATA PROTECTION LAWS
This policy adheres to the Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR). We are committed to safeguarding your rights and ensuring that your personal information is handled responsibly in accordance with applicable data protection laws. Given our global client base, we also recognize the necessity to comply with other relevant laws that may apply to the personal data we process, ensuring comprehensive protection for all our clients, regardless of their location.
SEABORN AS A DATA CONTROLLER
A Data Controller is an individual or organization that decides to collect or process personal data, establishes the purpose of that processing, and determines what data to collect and from whom.
Seaborn acts as the “Data Controller” for your personal information as outlined in this Privacy Notice. We support ship suppliers in their operations through our Supplier Assistant Software, which digitalizes various paper-based processes to enhance efficiency in the maritime industry. Additionally, Seaborn offers an Enterprise Resource Planning (ERP) system and cloud-based services tailored for ship suppliers. Unless specified otherwise, Seaborn serves as the data controller of your personal data under applicable data protection laws.
HOW WE COLLECT PERSONAL DATA
Seaborn collects Personal Data through various means, including contact via our official website, post, telephone, email, and other channels. We also collect data when engaging with clients through electronic means.
We collect information when you:
- Visit our websites
- Contact us through our phone, email, or social media
- Become our customer
WHAT TYPES OF INFORMATION WE COLLECT
- Information Collected on Our Website:
We request your name, company name, and email address. Additionally, users can send us emails through the “Contact Us” section.
- Information Collected via Supplier Assistant Software (SAS):
We store only your name and email address.
- Information Collected in the CRM Module of our Software:
Our CRM module retains company information, as well as contact person details (name, phone, email), and meeting notes.
- Information Collected in the Human Resources (HR) Module of our Software:
The HR module stores the following data:
- Name, Surname, Gender
- Bank Information
- Identification Number
- Date and Place of Birth
- Educational Background
- Assignment Details
- Contact Information:
- Phone Number
- Address
CONSEQUENCES OF NOT PROVIDING PERSONAL INFORMATION
If you do not provide the personal information we require, particularly when mandated by law or necessary for fulfilling a contract with you, we may be unable to perform that contract. In such cases, we may have to discontinue the relevant service. If this occurs, we will inform you at the time of the request.
DATA PROTECTION PRINCIPLES
We are committed to upholding the data protection principles outlined in the Data Protection Act 2018, GDPR, or applicable data protection laws. We adhere to the following principles:
- Lawful, Fair, and Transparent: Personal data must be processed legally, fairly, and transparently.
- Purpose Limitation: Data should only be collected for specific, lawful purposes.
- Data Minimization: Information must be adequate, relevant, and limited to what is necessary.
- Accuracy: Personal data should be accurate and kept up to date when necessary.
- Storage Limitation: Data should not be held longer than required.
- Integrity, Confidentiality, and Security: Personal data must be protected appropriately.
LAWFUL BASES FOR PROCESSING PERSONAL DATA
When you purchase a service from us or agree to our terms and conditions, a contract is established between you and us. To fulfill our obligations under this contract, we must process the information you provide, which may include personal information.
We will process your personal data only when permitted by law, typically in the following circumstances:
- To perform a contract with you.
- When necessary for our legitimate interests, ensuring these do not override your rights.
- To comply with legal or regulatory obligations.
- For direct marketing communications, based on your consent, which you can withdraw at any time.
- To enhance our website and services through data analytics.
- To provide tailored suggestions and recommendations.
- To manage our relationship with you, including soliciting reviews and conducting surveys.
We process this information based on the existence of a contract or upon your request prior to entering into a legal agreement. Processing will continue until the contract ends or is terminated by either party according to its terms.
MARKETING
We aim to provide you with choices regarding the use of your personal data, particularly concerning marketing and advertising. We may analyse your personal data to understand what you might want or need, helping us determine which services and offers may be relevant to you. We will send you marketing communications only if you have given us your consent. If you wish to stop receiving marketing messages, you can contact us anytime at [email protected].
HOW WE USE YOUR PERSONAL DATA
Seaborn may utilize your personal data to build and manage relationships with potential and existing clients, suppliers, and partners. This involves fulfilling contractual obligations and delivering services you request. We also share information about Seaborn’s products and services that may be of interest to you.
Effective communication is essential, and we engage with our clients and partners in several ways, including:
- Informing you about relevant Seaborn services.
- Sharing important details such as pricing, invoices, and updates on shipping or production.
- Responding to any inquiries you may have.
In addition to these primary uses, we may process your personal data for other purposes that align with the context in which the information was collected or based on your consent. We also reserve the right to anonymize or aggregate the information for research and product development, ensuring that such data does not identify any individual.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal information for the purposes outlined in this Notice with the following parties:
- Crime Prevention Authorities: Authorized entities that request information for crime prevention and detection.
- Legal Advisors: Professionals involved in any legal disputes who require access to your personal data.
- Financial Institutions: Banks and payment processors, such as Visa and Mastercard, for payment processing.
- Professional Advisors: Accountants, consultants, and auditors who need access to personal data for legitimate business needs.
- Regulatory Bodies: Authorities that necessitate reporting of processing activities under certain circumstances.
- Contractual Third Parties: Parties involved in facilitating our contract with you.
- Business Transactions: Third parties related to any sale, transfer, or merger of our business or assets. If such changes occur, the new owners may use your personal data as described in this Notice.
We require all third parties to respect the security of your personal data and comply with applicable laws. Our third-party service providers are prohibited from using your personal data for their own purposes and may only process it in accordance with our instructions. Additionally, we may disclose your information to protect our rights, enforce terms and conditions, or ensure the safety of our customers and others, including sharing with government authorities and law enforcement as necessary to comply with legal obligations.
INTERNATIONAL TRANSFERS
You acknowledge that personal data from you and your users may be processed by our service providers located outside the UK or EEA. These countries may not have data protection laws that are equivalent to those in the UK or EEA. However, when we transfer personal data outside these regions, we implement adequate safeguards to protect that data. This includes entering into appropriate contractual agreements, such as Standard Contractual Clauses approved by the EU Commission or the UK Information Commissioner’s Office, as well as utilizing any other approved mechanisms that may arise in the future. We are committed to ensuring that your and your users’ personal data is protected to the same standard as it is within the UK or EEA.
DATA SECURITY
At Seaborn, data security is a top priority. We have implemented measures to protect your personal data from accidental loss, unauthorized access, alteration, or disclosure. Access is restricted to employees, agents, and third parties with a legitimate business need.
We maintain strict confidentiality obligations for all personnel who handle personal data and have established procedures to address any suspected data breaches, notifying you and relevant regulators as required by law.
We employ appropriate technical and organizational measures in line with the Data Protection Act 2018, GDPR, or applicable laws. While we strive to safeguard your data, we cannot be held responsible for the security of personal data transmitted over the internet, which you do at your own risk.
If you have any questions or concerns about our data security practices, please reach out to us.
HOW LONG WE RETAIN YOUR INFORMATION
We retain your personal data only as long as necessary to fulfil the purposes for which it was collected, including any legal, accounting, or reporting obligations. When determining the appropriate retention period, we consider relevant laws, the nature and sensitivity of the data, potential risks from unauthorized access, and whether the purposes can be achieved by other means.
In some cases, we may anonymize your personal data for research or statistical purposes.
Generally, we keep your personal information for the following reasons:
- To provide the services you requested.
- To comply with legal requirements, including those mandated by tax authorities.
- To support any claims or defences in court.
If you have any questions about our data retention practices, please feel free to contact us.
YOUR LEGAL RIGHTS
Under data protection laws, you have several important rights concerning your personal data:
- Right of Access: You can request a copy of the personal data we hold about you, allowing you to verify that it is being processed lawfully.
- Right to Rectification: If your personal data is inaccurate or incomplete, you have the right to request corrections to ensure its accuracy.
- Right to Erasure: You can ask us to delete your personal data when it is no longer necessary for the purposes for which it was collected or if you withdraw your consent.
- Right to Restrict Processing: You have the right to request a temporary or permanent halt to the processing of your data under certain circumstances.
- Right to Object: You may object to our processing of your data based on legitimate interests or for direct marketing purposes, enabling you to control how your data is used.
- Right to Data Portability: You can request your personal data in a structured, commonly used, and machine-readable format, allowing you to transfer it to another service if you choose.
- Right to Withdraw Consent: If we process your data based on your consent, you can withdraw that consent at any time, without affecting the legality of prior processing.
- Rights in Automated Decision-Making: You have the right not to be subject to decisions made solely by automated processes, including profiling, which significantly affects you.
To exercise these rights, please reach out to us at [email protected].Typically, there is no fee for accessing your data, although we may charge for excessive or repetitive requests. We aim to respond to legitimate requests within one month, but more complex inquiries may require additional time, and we will keep you updated throughout the process. If you believe your rights are not being upheld, you can lodge a complaint with the relevant data protection authority. Your rights are designed to ensure transparency and give you control over your personal information.
CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
Seaborn may modify this Notice at any time without reducing your privacy protections. Significant changes will be highlighted, and for certain services, we may notify you via email. As we continually enhance our services, updates to this Privacy Policy may occur, so please check the “LAST UPDATED” date at the top of the page for the latest revision.
It is crucial that the personal data we hold about you remains accurate, so please inform us of any changes.
THIRD-PARTY LINKS
Our website may contain links to third-party websites, plug-ins, and applications. By clicking these links or enabling connections, you may allow third parties to collect or share your data. We do not control these external sites and are not responsible for their privacy practices. We encourage you to review the privacy notices of any website you visit after leaving our site.
CONTACT
For questions regarding our use of your personal data, concerns about its usage, or to exercise your rights, please reach out to us at [email protected] or write to us at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF United Kingdom.
COMPLAINTS
If you have concerns about how we handle your personal information, you can file a complaint by contacting us at [email protected].