April 2021

1. Who is responsible for your data

Our Privacy Policy applies to the personal data that companies of the Jumbo-SAL-Alliance collect and use.

References in this Privacy Policy to “Jumbo-SAL-Alliance”, “we”, “us” or “our” mean the Jumbo-SAL-Alliance or companies pertaining to same, all for the purposes of this Privacy Policy being represented by Jumbo SAL Alliance GmbH & Co. KG, Hermann-Hollerith-Str. 10, D-28355 Bremen, Germany (“Jumbo-SAL-Alliance”). Jumbo-SAL-Alliance is responsible for acquiring, processing and utilising your personal data in accordance with the German Federal Data Protection Act and is the data controller in accordance with applicable law, including the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).


2. Personal data we collect about you

When using the term “personal data” in our Privacy Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your personal data includes, for example, your name, your contact details including email and/or postal address, your medical records, your bank details, your date of birth, your professional qualifications or information on how you use our website, or data from when you interact with us. We collect some personal data from you, for example when you apply for a job with us or work for any of the alliance companies, come on board any of the ships we manage or operate, enter our offices, use our website, use our services or simply contact us. We may also receive your personal data from our suppliers who provide services to you on our behalf.

Categories of data we collect

We may collect and process the following categories of information about you: 

Categories of personal data processed When in general do we process the personal data mentioned? Which legal basis do we rely on for processing your personal data?
Your name and surname and your contact details
(email address, job title, telephone number and/or postal address)
When you interact with one of our staff We base the processing on our legitimate interest in running our daily business and being able to provide you with our services.
Your C.V. and other data on professional qualifications as well as pre-employment medical information for seafarers only When you apply for a job or employment with us We base the processing first on the necessity to evaluate it prior to any employment with us and then to duly perform any such employment/crew/service contract with you and to run our daily business.
Contact details, bank details, contact details of your next of kin, medical records to the extent necessary When you work with or for us We base the processing on our legitimate interest in running our daily business and to duly perform any employment/crew/service contract with you.
Your communications with us (for example, your emails, letters, telephone calls, or your messages on our online chat service) When you contact us or you are contacted by us We base the processing on our legitimate interest in running our daily business.
Pictures or videos taken at our events which may include you. When you participate in our events, seminar, receptions, come on board any of our ships or visit our offices We will base the processing on consent, which we will ask you to provide if relevant. In certain circumstances, we may however base the processing on our legitimate interest, if the pictures or videos are of a situational character and do not specifically depict you.
Your posts and messages on social media directed to us When you interact with us on social media We base the processing on our legitimate interest in running our daily business. We ask that you do not disclose sensitive information such as health information in messages on our social media platforms. If you do so anyhow, we reserve the right to delete such information from our platform.
Information about how you use our websites, from where you access it and what system you use when accessing it When you navigate to and on our websites We process this information based on your consent, which you provide when entering our websites.
Historic data, including relevant personal data For as long as we are obliged by law to retain same We base the processing on our legitimate interest in running our daily business.

Sensitive personal data

In the course of interacting with you we usually do not collect sensitive data. However, in cases of you falling ill or suffering injury in a work context we base the processing on our legitimate interest in running our business and assisting you as necessary under the given circumstances. 

3. Data we collect in business relationships

If you represent an organization that we have a business relationship with, we will process your personal data for this relationship. The legal basis is a balance of interest in that your personal data is being processed for the purpose of communicating with you as a representative of our business partner which overrides your potential interest in protecting your personal privacy. 

4. How and why we use your personal data

We use your personal data for the following purposes:

To communicate with you and manage our relationship with you
Occasionally we may need to contact you by email or phone for administrative or operational reasons. We will also use your personal data if we contact you after you have sent us a request, filled in a web-form through our website or contacted us on social media.

To run our daily business
This is primarily to manage and operate ships and related means of transport and infrastructure, to store, handle or transport cargoes, goods, or people. In the course of doing so we will process your relevant personal data, including passports or copies thereof or other documents, share same with agencies, embassies, consulates, port authorities or other official bodies or public entities, or private companies by the latter for carrying out specific tasks and services, as well as with insurance brokers and insurers as and when the need to do so arises, e.g. in cases of illness or injury.

Please note that we do not share your contact details or other personal data with other companies for marketing purposes, unless we have first obtained your written consent to do so.

5. Your rights

You have certain legal rights under EU data protection legislation, which you can enforce against us.

You have the right to receive information about what personal data we store about you and how that personal data is used and processed. In the event your personal data is inaccurate or wrong you have the right to request that we correct or remove the personal data and that we provide you with a copy of the personal data concerning you. If your request is unfounded or excessive we have the right to refuse to act on your request, or to charge you a reasonable fee which covers the administrative costs of the action requested by you.  

If you have any complaints regarding our processing of your personal data, you are entitled to file such complaints with the Data Protection Authorities.

For complete information regarding your rights, please see the General Data Protection Regulation (Regulation (EU) 2016/679), sections 3–5 as well as the German Federal Data Protection Act and relevant rules and regulations. 

6. Security of your personal data

We are committed to taking appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data that we process about you.

As described in this Privacy Policy, we may in some instances disclose your personal data to third parties. If we disclose your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data.

The information that you provide to us will be held on hosted systems not owned by us, which are mostly located in premises of an appointed third party within the EU. We may also allow access to your 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 you. 

7. For how long do we process your personal data

We will retain your 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 your 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. 

8. Cookies or other tracking technologies

In order to improve our services and to provide you with more relevant content and to analyse how visitors use our website, we may use available technologies and tools such as cookies, Google Ads, Google Maps and the like. A cookie is a small text file, which is stored on your computer in order to recognize your computer at recurring visits. A cookie cannot retrieve information from your computer and cannot carry any virus or other damaging files.

Insofar as the tracking technologies that we use collect personal data such as your IP-address, we rely on our legitimate interest as the legal basis for such processing. The legitimate interests we pursue in this regard is to help us understand how users of our website navigate on our site in order to develop the design and layout and enhance the user experience for visitors of the website.

You can at any time remove the cookie created via our websites. To remove, follow your browser’s guide to disable or delete cookies. 

9. Sharing your personal data

Your personal data may be shared within the Jumbo-SAL-Alliance. 

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 personal data with external suppliers who assist us in running our business or in fulfilling our contractual requirements or rendering our services.

Our suppliers are requested to take all reasonable legal, technical and organizational 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 personal data that we transfer to the above suppliers varies depending on the kind of product or service we deliver to you. In most instances the above mentioned suppliers will have their own set of Terms of Use detailing the types of personal data stored by the supplier in the respective system.

Authorities. We may disclose your personal data when this is required by the law of any jurisdiction to which we may be subject unless this is expressly prohibited by German law.   

10. Transfers of personal data outside of the EU/EEA

Your personal data will be processed primarily within the EU/EEA, but also processed by staff of our subsidiaries worldwide.

11. Updates to our Privacy Policy

We may change or update this Privacy Policy from time to time and will then publish any new edition on our websites. 

12. Contact information

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to the company DPO (Data Protection Officer) at privacy@hp-shipping.de.