Privacy Policy

PRIVACY NOTICE

In Centrofin Management Inc (hereinafter referred to as the “Company” or “we”), we are committed to respect your privacy and comply with applicable laws on data protection. We are sharing with you this Privacy Notice to inform you on the processing of your data in relation to the following purposes:

(a)        Processing of data of the visitors of the website www.centrofin.gr (“Website”). You may find relevant information under section “Website Privacy Notice”;

(b)       Processing of data of individuals that apply for a job position published by the Company or send voluntarily their Curriculum Vitae (CV) to the Company. You may find relevant information under section “CVs Privacy Statement”;

(c)        Processing of data of our Business Partners. You may find relevant information under section “Privacy Notice for Business Partners”.
We confirm that any data processed by the Company are:
Processed lawfully, fairly and in a transparent manner in relation to individuals;

Processed in accordance with the applicable laws, regulations and guidelines and the provisions of our contractual relationship;
Used only for legitimate purposes and to the extent that this is necessary to fulfill our obligations as per our agreement and/or the law;
Processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by using appropriate technical or organizational measures;

Processing of your personal data is governed by these terms, by the relevant provisions of Greek and EU legal framework on data protection, including the General Data Protection Regulation (2016/679) and the relevant decisions, guidelines and regulations.
Website Privacy Notice

The Website Privacy Notice forms an integral part and is incorporated into the Terms of Use of the Website and may be subject to modifications. We advise you to regularly check this Privacy Notice in order to remain informed and updated on any amendments.

By visiting and navigating through the Website you agree to this Privacy Notice as in force at the time. When substantial amendments are made we will ensure that a relevant notice is posted for visitors of our Website.
This Privacy Notice explains how we collect, process and/or use information that we receive via our website and the emails we send (collectively, the “Website”) that link to this Privacy Notice, as amended from time to time. This Privacy Notice also describes how we collect, process, use and share the personal information you provide us with. It also describes your choices regarding use, access, transfer, correction and deletion of your personal information.

1.1  Information we collect

We collect information about you to provide the services you request. In this context, it is essential that we are able to collect and use the information as described in this Privacy Notice.

1.2  Information You Give Us

i. Communication
When you submit your data in our contact form, we collect and retain your data exclusively to communicate with you and fulfil your request. In this context, we collect you name, surname, email, telephone number and company you are working for, as well as any data you may choose to include in your message.

ii. Submission of CVs
When you submit your CV through the Website, we collect and retain identification data, such as name and surname. We also collect and retain personal data included in your CV. By submitting your CV to the Company you agree and accept our CVs Privacy Statement.

1.3  Information We Collect Automatically
When you use the Website, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect may also include usage information and statistics about your interaction with the Website. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the platform.
This information is collected by using Cookies & other similar Tracking Technologies. We strongly advise you to review our Cookies Policy in order to learn more about Cookies, how we use them and how you can control the use of Cookies.

1.4  Why we collect your information
We process your data exclusively for the below purposes:
Communication
When you submit your data in our contact form, we will use them to communicate with you and provide the information and/or services required. Processing of your data is necessary to perform the requested service.
Submission of CV
When you submit your CV through the Website, we will collect and process your data to assess your professional skills and competencies and to examine possibilities of cooperation. Processing of data is based on consent. You may revoke your consent at any time. In that case we will not be able to examine possibilities of cooperation. Please check our CVs Privacy Statement [link] for more information.
Improvement of services
We maintain your data and the history of usage of our services in order to produce statistics that allow us to better assess the visits and navigation of users through our website in order to improve its content and structure. The processing of data is based on the legitimate interest of the company in monitoring visitors’ response to its services and improving its services.
Legal Obligations & Claims
When a legal obligation is in place, we will provide your data to the competent authorities. We will maintain and process your data to the extent necessary to establish, exercise or support legal claims
With respect to the use of Data collected through Cookies, please see our Cookies Policy.

1.5. Recipients of your data
Access to your data may only be provided to our duly authorised employees or business partners who act on our behalf for the above purposes of processing, by offering us IT services for the registration and storage of your data and/or for the operation of our website. Data collected are kept in digital format and with safety at Company’s premises.

1.5  Duration of processing
Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When you submit your data in our contact form, we will retain your data for the period required to respond to your request. After this period, we will archive and retain your request and your contact details for one (1) year. At the expiry of the retention period we will delete your data.

CVs Privacy Statement

By submitting your CV to the Company, we are given the opportunity to review your information and, if we feel that it meets the formal requirements for a position that the company wishes to cover, we may contact you to provide any other required information or to arrange an interview. By sending your CV to us you accept the following terms:

2.1 Personal Data that we collect
We collect the following categories of data:
–           Identification data (name, surname)
–           Contact information (residence address, telephone number, email)
–           Information related to your educational attainment
–           Information related to your professional experience
–           The position you are interested in
–           Any other information included in your CV

2.2. Why do we process your data
When you submit your CV to the Company, we collect and process your data to assess your professional skills and competencies and to examine possibilities of cooperation. Processing of data is based on consent. You may revoke your consent at any time. In that case we will not be able to examine possibilities of cooperation.

2.3 Recipients of your data
Access to your data may only be provided to our duly authorised employees. We may transfer your data to other companies or persons related to the Company when this is necessary for the purposes of this processing. In these cases, these parties either act as controllers, determining the means and the purposes of the processing, or act as processors on behalf of Centrofin. In both cases, this privacy statement applies. If you submit your CV for a position ashore, we will not transfer your data to countries outside the European Economic Area (EEA). If you are interested in working onboard, we will transfer or disclose your data to third parties, who act as manning agents on behalf of the owners and are established outside the European Economic Area (EEA). The purpose of the transfer of data is the assessment of your working capacity as per local laws and regulations. In this case, Centrofin ensures that the transfer is made on the basis of appropriate safeguards and in accordance with applicable data protection laws, in order to maintain the required level of protection of the relevant data

2.4 Data Retention
We will retain your CV for six (6) months after completion of the hiring process, when you submit your CV in response to a job announcement published by the Company. We will retain your CV for two (2) years, when you submit your CV to the Company voluntarily. Data collected are kept in hard copies and/or in digital format and with safety at Company’s premises.

2.5 Representations
If you choose to submit your CV through the Website, you agree and accept Website Privacy Notice.
By submitting your CV, you declare that:
You provide accurate and true information.
You do not provide information on criminal convictions and offenses or specific categories of personal data (such as information on political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, etc.)
You do not provide information related to a third party, unless explicitly authorized by the third party.

Privacy Notice for Business Partners

3.1 Personal Data that we collect
We collect and process indicatively the following personal data of our Business Partners:
Identification data (name, surname, signature, if applicable);
Contact information (address, telephone number, email);
Data necessary to perform payments (including but not limited to tax registration number, bank account number, beneficiary);
In the case of legal entities, information related to their legal representatives (name, surname, signature);
Any other information that you disclose to the Company and is necessary for the performance of our contractual relationship.

3.2 Why do we process your data
We will process your data for the following purposes:
For the execution of our contractual relationship;
To comply our statutory obligations, including safety requirements and internal due diligence policies;
To organize and execute our business operations, such as to perform payments, communicate and manage our relationship with you;
For purposes of auditing Company’s procedures by competent authorities, regulatory bodies or organizations and third parties having a legitimate interest and / or obtain certifications.
To reply to official requests from the authorities.
To establish, exercise and defend legal claims and investigate incidents and legal liabilities in general.

3.3 Recipients of your data
For the above purposes, your data will be processed by Company’s authorized employees.
We may transfer your data to other companies or persons related to the Company, when this is necessary for the purposes of this processing. In these cases, these parties either act as controllers, determining the means and the purposes of the processing, or act as processors on behalf of the Company and/or the Principal. In both cases, this privacy statement applies.
Data which are necessary for the purposes of each processing are transferred to the following categories of recipients:

–           to third parties providing services to the Company, such as IT companies, telecommunication companies, credit institutions, tax and legal advisers, insurance companies, travel agencies and other service providers.
–           to third parties in the context of vessel management services provided by the Company, including but not limited to ship owners, directors, shareholders, related companies or persons, insurers, port agents, manning agents, shipyards, suppliers, charterers, brokers, port authorities and other local authorities.
–           to national or international regulatory, tax or other authorities or public bodies or courts or other legal authorities, where required by law or regulation or upon an official order
–           to other business partners when required to execute requested transactions
–           to third parties who carry out inspections and audits on the Company and/or the vessels managed by the Company in the framework of relevant regulatory obligations, customer relationship or obligations under applicable law.

As part of its activities, the Company will have to transfer or disclose certain data, such as your name, surname and contact details to third parties, local authorities and agents established outside the European Economic Area (EEA). In these cases, the Company ensures that the transfer is made on the basis of appropriate safeguards and in accordance with applicable data protection laws, in order to maintain the required level of protection of the respective data.

3.4 Data Retention
Data retention period may vary according to the category of data. Your personal data will be retained for a maximum period of 10 years after termination of our contractual relationship. Your data are stored with safety in digital form and/or in hard copy and at Company’s premises.

4. Your rights

You have the following rights regarding your personal data:
Right to be informed
You have the right to be informed about the collection and use of your personal data.

Right of Access
You have the right to obtain from the Company confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, access to the Personal Data in a concise, intelligible, transparent, and easily accessible form.

Right to Rectification
You have the right to obtain from the Company without undue delay the rectification of inaccurate or the completion of incomplete personal data concerning you, including by means of providing a supplementary statement.

Right to Erasure
You have the right to obtain from the Company the erasure of personal data concerning you without undue delay and the Company shall have the obligation to erase personal data without undue delay under the conditions laid down by law.

Right to Restriction
You have the right to obtain from the Company restriction of processing only to specific purposes, under the conditions laid down by law.

Right to Object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you. The Company shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Right to Portability
You have the right to receive the personal data concerning you, which you have provided to the Company, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from the Company under the conditions laid down by law.

Right to Obtain Human Intervention
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
The Company will satisfy your request under the conditions set forth by law. The possibility of exercising a right conferred by the law does not always mean that it can be fully satisfied, especially when other legal provisions restrict it. In case we are unable to meet your request, we will inform you about the reasons.

If you have any request or question regarding this privacy statement, you may email us or send us a written request, using our contact details set out below.

10, Diadochou Pavlou str.
166 75 Glyfada – Greece
T +30 210 8926000
F +30 210 8983231
dataprotection@centrofin.gr

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the Hellenic Data Protection Authority.

LAST UPDATED: 10 May 2019