Privacy Statement


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FAIRWAY SHIPPING AGENCIES WEBSITE PRIVACY POLICY


1. INTRODUCTION
Welcome to the Fairway Shipping Agencies Website Privacy Policy. Fairway Shipping Agencies respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

2. PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how Fairway Shipping Agencies collects and processes your personal data through your use of this website, including any personal data you may provide through this website. It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing 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 Policy supplements the other notices and is not intended to override them.

3. WHO IS FAIRWAY SHIPPING AGENCIES
Fairway Shipping Agencies (“Company”) is made up of different legal entities across the globe. For more information about Fairway Shipping Agencies please go to www.ganscargo.com. So when we mention “FAIRWAY SHIPPING AGENCIES”, “Company”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Fairway Shipping Agencies Group responsible for processing your personal data.

4. WHAT PERSONAL DATA DO 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). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
  • Identity Data can include first name, maiden name, last name, username or similar identifier, marital status, title, home address, postal code, date of birth and gender.
  • Contact Data includes email address and telephone numbers.
  • Financial Data includes bank account and payment details
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

5. HOW DOES FAIRWAY SHIPPING AGENCIES USE YOUR PERSONAL DATA?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than if we explicitly ask you for consent for a specific purpose.

6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us on the detail set out in Section 13 below if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client and/or possible candidate. To process your application for vacancies or the traineeship programme. To respond to an approach made by you using the Fairway Shipping Agencies general enquiry or contact forms. (a) Identity
(b) Contact
(c) Usage
(d) Profile
(a) Performance of our services to you
(b) Necessary to comply with a legal obligation
Manage our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, security and fraud prevention, legal compliance and business continuity. (a) Identity
(b) Technical
(c) Financial
(d) Profile
(e) Marketing and Communications
(a) Performance of our service to you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (a) Identity
(b) Contact
(c) Profile
(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation
To use data analytics to test and improve our website, and website users experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
  

Cookies Our cookies used will be session cookies only (temporary cookies that identify and track users on our website which are deleted when your browser is closed or leave your session in the application service). A third party vendor used by Fairway Shipping Agencies is Google Analytics. For more information on how Google Analytics uses data please visit “How Google uses data when you use our partners sites or apps”, located at www.google.com/policies/privacy/partners You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

7. WHO DOES FAIRWAY SHIPPING AGENCIES SHARE MY PERSONAL DATA WITH?
We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 6 above.
  • Group companies, third party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our website);
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
  • Competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation; (ii) to exercise, establish or defend our legal rights; or (iii) to protect your vital interests or those of any other person;
  • To any other person with your consent to the disclosure.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. INTERNATIONAL TRANSFERS
We share your personal data within the Company Group. This may involve transferring, storing and processing your data outside the European Economic Area (EEA). Whenever we transfer, store and process your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring the correct safeguards are implemented by using specific contracts and clauses approved by the European Commission which give personal data the same protection it has within the EEA. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. Please contact us using the details set out in Section 13 below if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

9. HOW DOES FAIRWAY SHIPPING AGENCIES KEEP MY PERSONAL DATA SECURE?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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. When we notify you we will provide you with the relevant details of the personal data breach.

10. HOW LONG WILL FAIRWAY SHIPPING AGENCIES USE MY PERSONAL DATA FOR?
We retain personal data we collect from you where we have an ongoing legitimate business, legal or contractual need to do so (for example, to provide you with a service you have requested or to comply with applicable tax, legal or accounting requirements). Where we have no ongoing legitimate business, legal or contractual need to process your personal data, we will either delete or anonymise it, or, if this is not possible (e.g. if your personal information has been stored in backup archives), then we will secure your personal information and isolate it from any further processing until deletion is possible.

11. YOUR DATA PROTECTION RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are:
  1. 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.
  2. 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.
  3. 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.
  4. 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 particular 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.
  5. 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. 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.
  7. 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 products or 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 using the details set out in Section 13 below. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. We will take appropriate measures to inform you, consistent with the significance of the changes we make. 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.

13. CONTACT DETAILS 
If you have any queries in relation to this Policy please contact:
Email address:
Postal address: Ravelstraat 5
3161 WE Rhoon
The Netherlands
You have the right to make a complaint at any time to your local data protection supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns in the first instance so please feel free to contact us direct.