GENERAL PRIVACY POLICY

1. Data Processing and Data Processing Purposes

1.1 The Company SIRIOS SHIPMANAGEMENT CORP. (hereinafter: «the Company») processes, in the context of your cooperation with the Company and your communication with it, personal data collected by you and/or third parties (such as your employer), in accordance with Regulation (ΕU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter: «GDPR») and Greek legislation. More specifically, the Company processes personal, passport/ID and communication information, banking, social security and tax data, information about your education and previous and current employment, photo, information about your cooperation with the Company and about your presence in a vessel managed by the Company, travel information, your communications with the Company and any other personal data that may be necessary to achieve the below purposes of personal data processing.

1.2 The Company processes your personal data during your or your employer’s cooperation with it, if such exists, while such processing may extend after the completion of such cooperation or despite the absence of such cooperation, if this is required in order for the Company to comply with its legal obligations towards the authorities and/or third parties, due to applicable provisions on the obligatory data retention periods or in order for the Company to support its claims or rights.

1.3 The Company processes your data in order to comply with its legal and contractual obligations, to receive services, to assess its counterparties and to conduct business communications.

 

2. Transfer of personal data to third parties

2.1 Your data may be made accessible to the Company’s personnel, as well as to third parties, such as the competent authorities, local agents, travel agents, airlines and other agents employed by the Company, technical contractors, investigators and other legal entities employed by the Company, accountants, auditors, lawyers and legal counsels, the P&I Club employed by the Company, as well as the latter’s correspondents, IT companies providing technical or cloud services or i-storage platforms, banks and the companies owning the vessels managed by the Company.

2.2 The Company may also transfer some or all your data for the above purposes to persons located in third countries, non-members of the European Economic Area (EEA). In case where such countries have not been granted with an adequacy decision by the European Commission, any transfer shall take place under the appropriate safeguards in accordance with the GDPR, such as Standard Contractual Clauses approved by the Commission or by the competent national authority, or appropriate contractual clauses between the Company and the recipient of such data.

 

3. Your rights

In accordance with and pursuant to the relevant requirements of the GDPR, you have the right to: (a) request access to your data and to information relating to the processing thereof by the Company, (b) request corrections and/or the completion of your data, (c) request the Company to delete your data, (d) request the restriction of the scope of processing, the way that the Company is processing your data, as well as the purposes for which the Company is processing them, (e) receive the personal data you provide to the Company and to transmit them and/or request the Company to transmit them to another data controller, (f) object to the processing of your personal data, (g) file a complaint before the Hellenic Data Protection Authority, and (h) so far as the processing relies upon your consent, to withdraw such consent at any time. To exercise your rights, please contact the Company as illustrated below at 5.

 

4. Legal basis for the processing of personal data

The Company processes your personal data because the processing is necessary, in order for the Company to:
(a) comply with its legal obligations,
(b) fulfill its obligations and/ or satisfy its rights deriving from an agreement between you and the Company,
(c) satisfy its legitimate interests, such as to ensure the security of its premises or of the vessels it manages, to fulfil its legal/contractual obligations, to assess its counterparties, to establish, exercise or defend legal claims and to conduct business communications, and/or
(d) to process your personal data on the basis of your consent.
The above processing is required by law or due to a contract executed between you and the Company. Therefore, if you do not provide us with your data, your cooperation with the Company may not be possible.

 

5. Communication

You may communicate with the Company as follows:
SIRIOS SHIPMANAGEMENT CORP.

Communication
For any information in relation to the present information, please contact us at sirios@sirios.co or at tel.: +30 22210 66 300