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 mobile
application (regardless of where you visit it from) and tell you about your privacy
rights and how the law protects you.
This privacy notice is provided in a layered format so you can
click through to the specific areas set out below. [Alternatively, you can
download a pdf version of the notice here:
1. IMPORTANT
INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW WE USE YOUR PERSONAL DATA
4. DISCLOSURES
OF YOUR PERSONAL DATA
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice applies to information obtained using
application and how we use it.
This application 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 that of a
representative of a client is, a prospective client or other third-party
professional contact, and that of an employee, contractor or job applicant.
CONTROLLER
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.
The owner of this application is Mariapps Marine Solutions Ltd and
is the data processor of the information.
CONTACT DETAILS
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 30-07-2019. 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.
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).
Data we collect through the application is as follows:
1)
Device information: On installation of application, permission to access
to your calendar, contacts, storage and access to your internet data and
network connection is sought.
2)
Registration information: When you sign up the application, we require
your email address and password.
3)
Any other information which is directly uploaded by the user of the
application to process any expense claim, travel booking etc.
4)
Technical information, including cookies, is collected when you use our
application (Cookie policy link).
5)
Device details like name of the device, version of Operating system is
collected when you raise a support ticket with us.
Please note that we display many other personal information of the user
which we have received from the user not collected directly through this
application. You must refer the relevant privacy notices to know more about the
usage of such information obtained.
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.
3. HOW WE USE YOUR
PERSONAL DATA
Personal information collected through the application will be
used to
a) Technical information, including usage of cookies
(please click here to learn more on
cookies) collected during your use of the application is used to analyze
usage of the application and improve our service.
b) Email address and password collected is to verify the authenticity
of the user.
c) All other information uploaded by the user (like travel expense
claim) would be used for the benefit of the data subject and for the
performance of the contract with the data subject.
d) If you use our chat services for communication, it will be used to
resolve your queries or complaints and to further enhance our service level or
to contact you for providing relevant information.
RESTRICTING ACCESS
You can restrict the access to the application to your calendar,
contacts, media, telephone etc. through the settings in your mobile phone.
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.
4. DISCLOSURES OF YOUR PERSONAL DATA
We share your personal data with the parties set out below for the
purposes set out in the table above.
5. INTERNATIONAL TRANSFERS
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.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an unauthorized
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.
7. DATA RETENTION
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 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,
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.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection
laws in relation to your personal data. Please click on the links below to find
out more about these rights:
•
Request
access to your personal data.
•
Request
correction of your personal data.
•
Request
erasure of your personal data.
•
Object
to processing of your personal data.
•
Request
restriction of processing your personal data.
•
Request
transfer of your personal data.
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 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:
•
If you want us to
establish the data’s accuracy.
•
Where our use of the
data is unlawful but you do not want us to erase it.
•
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.
•
You have objected to
our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
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 several requests. In this case, we will
notify you and keep you updated.