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Notice on the Processing of Personal Data (‘Notice’)
Thenamaris* with contact details: +30 210 8909000, e-mail: comms@thenamaris.com (hereinafter referred to as the “Company”), in its capacity as data controller, collects and processes your personal data for recruitment purposes under the terms and conditions set out in this Notice. You should carefully read this Notice before deciding to create your account on this website.
- INTRODUCTION
The Company is committed to protecting privacy by maintaining the integrity and confidentiality of the personal data that applicants submit when seeking a job on board the vessels under its (co)management.
This Notice describes how the Company treats personal data that applicants submit during the recruiting and hiring process for the purposes of screening, deciding whether an applicant will be hired or not and also internal reporting.
Personal data, including identification and contact details, educational and professional background, health data, as well as any other information that you voluntarily submit through this website, is processed in accordance with the General Data Protection Regulation (EU) 2016/679 and the Greek Law 4624/2019. By submitting the application form and your Curriculum Vitae (CV), you declare that you have understood that your personal data will be processed for the sole purpose of the evaluation of your qualifications and skills regarding currently open positions and/or any other future job vacancy on the vessels under the Company’s (co)management and for ensuring that you are fit to work. The Company may also use from time to time the provided data to communicate with you about the progress of your application and/or to send you importance notification in relation to the processing of your personal data.
- ACCESS TO PERSONAL DATA
The Company places appropriate restrictions on access to personal data and implement appropriate measures and controls to store and transfer data securely. The personal data are processed by the Marine Personnel Department and other internal stakeholders. In principle, the Company does not disclose personal data to third party recipients. The Company may make certain personal data available to third parties mainly service providers, always in compliance with the applicable data protection legislation, such as certain manning agencies and/or consultants who may be authorized by the Company to perform a certain task. The Company may also disclose certain personal data if required by law or Court and/or by governmental authorities with jurisdiction over it, or if required for the purposes of law enforcement, national security or other issue of relevant importance. Access to the applicants’ personal data may be also granted to other service providers of the Company, such as IT service providers who are responsible for ensuring the security of the Company’s IT systems and are bound by strict confidentiality obligations.
- LAWFULNESS OF PROCESSING (LEGAL BASES)
The processing of your personal data by the Company is justified on the basis of your job application and it is necessary prior to deciding whether or not an employment contract will be signed with you, as well as on the basis of the Company’s legitimate interest to make informed choices on the selection of the seafarers employed on board the managed vessels. As regards health data and other special categories of personal data (if any), the legal basis of the processing is the assessment of your working capacity as well as the necessity for compliance by the Company with the industry’s requirements imposed by maritime conventions and regulations.
- APPLICATIONS’ PROCEDURE
The Company takes precautions including technical, operational and physical measures to protect your personal data against loss, misuse, unauthorized access or alteration. For transparency and personal data protection reasons, only applications made through this website will be considered. Any other applications received via e-mails sent directly to the corporate mailboxes, or physical paper applications or applications received through any other source and format, will not be processed but will be safely deleted and/or destroyed along with the relevant personal data. In the aforementioned cases, upon receipt of the information, the Company will contact you in order to inform you regarding the specific procedure and urge you to properly submit your application via the recruitment website so as to allow us to keep your personal data and application. Following the communication, all your personal data will be safely deleted and/or destroyed.
- PERSONAL DATA RETENTION PERIOD
Your personal data shall be retained for a period of two (2) years as from the submission of the application, unless you choose in the meantime to renew the retention period, a time during which the Company might consider your application for future vacancies. Longer retention periods are possible only with your consent, which you can freely provide in the retention period form. After completion of the retention period, the personal data will be automatically deleted and/or encrypted, without any prior warning, and the Company and/or any other external partners will no longer have access to them.
You can help ensure that your personal data are accurate, complete and up to date by logging in to your account and proceeding with the necessary amendments.
If, on the other hand, your application is successful and you proceed to hiring, then your personal data will not be deleted but will be processed in accordance with the Company’s Seafarers’ Personal Data Protection Policy (you will receive a relevant copy upon hiring).
The Company may retain data for longer than the above-mentioned period, if the Company is obliged by applicable laws to retain it. Whatsoever, your personal data will not be used for any other purposes by the Company and their processing will fully comply with the applicable legislation.
- TRANSFER OF PERSONAL DATA
The applicants’ personal data are stored in electronic systems and physical files in Greece. In case the Company transfers the applicants’ personal data in countries outside the EU/EEA, including sharing personal data with the Company’s third-party service providers, the Company will ensure that the country in which the personal data are transferred ensures an adequate level of data protection or that there are other appropriate or suitable safeguards in place to protect the applicants’ personal data, including the conclusion of the standard contractual clauses. Currently (on the date of the last update of this Notice found below) the only transfers of applicants’ personal data to countries outside the EU/EEA that take place are the transfers of the personal data of certain applicants to the Company’s manning agents in the Philippines, Ukraine and Ethiopia. It is noted that these transfers are carried out in full compliance with the applicable data protection laws and on the basis of appropriate safeguards (standard contractual clauses).
- YOUR RIGHTS OVER YOUR DATA
Subject to the applicable legislation, you have the right to request access and/or request the correction/update of the submitted data, as appropriate. The personal data may also be updated or supplemented by updating the related fields. Under conditions, you have also the right to erase your personal data, ask for the restriction of the processing as well as receive the data in a structured, commonly used and machine-readable format.
In the event of placing such a request, the Company, before proceeding with the requested action, retains the right to request from you information confirming your identity. Action will be performed as soon as possible and you will be informed accordingly, definitely within one (1) month since your request was communicated to the Company. That period may be extended by two (2) further months where necessary, considering the complexity and number of the requests. The Company shall inform you of any such extension within one (1) month of receipt of the request, together with the reasons for the delay.
You can exercise your data protection rights mentioned above at any time by either deleting or updating your account and all the processed personal data or by sending an e-mail to dataprivacy@thenamaris.com
If you consider that the Company violates the applicable data protection laws when processing your personal data, you have the right to lodge a complaint with the Hellenic Data Protection Authority (DPA).
* Thenamaris (Ships Management) Inc. and/or Thenamaris LNG Inc. and/or Thenamaris ConBulk Inc., each of Liberia and each with an established office in Greece at 16 Athinas Avenue, Vouliagmeni 16671, as the case may be depending on your application(s)