+ 30 210 8907800
ancora AT ancora.gr

Seagoing personnel privacy notice

Purpose of this notice

This Privacy Notice aims to inform you about how Ancora Investment Trust Inc. (individually and jointly referred to as “the Company”) manages your personal data in terms of collection, use, storage and any potential further handling according to the General Data Protection Regulation (GDPR), (EU) 2016/679.

Information and Data we Collect

  1. Personal and Family Contact Details,
  2. Financial Documents and Data (i.e. Payroll, IBAN, Bank Account), Tax Information,
  3. Personal Identification and Social Security & Insurance Data,
  4. Performance Evaluation,
  5. Interview Evaluation Data

(all the above herein after the “Personal Data”)

Legal Basis for Processing your Personal Data

The Company is committed to protecting your privacy and handling your data in an open and transparent manner and as such we process your personal data in accordance with the GDPR for the following reasons which provide legal basis:

A. For the performance of a Crew Employment Contract

B. For compliance with a legal obligation of National & International Laws and Regulations (i.e. MLC 2006 & STCW, ISM, Tax Laws, Labour & Social Security Laws etc)

C. For the purposes of safeguarding legitimate interests

The processing of your personal data is necessary for the legitimate interests pursued by the Company. A legitimate interest is when the company has a business or commercial reason to use your information in order to establish, exercise or defend its rights against any Claim, Court Proceeding, Arbitration and any other legal proceeding.

Disclosure of Information to Third Parties

Your Personal Data may be shared to third parties within and outside EU to several Public Authorities and Private Entities. In such cases where your personal data may be disclosed to third countries, i.e. countries outside of the European Union. Processors in third countries are also obligated to comply with the European data protection standards and to provide appropriate safeguards in relation to your personal information.

The Company may disclose information to local and foreign governmental Authorities and/or local port Agents and/or vessel’s Protection & Indemnity or other Insurance Clubs. Otherwise where required or permitted to do so by Law, Collective Agreements, International Conventions, Contract or otherwise and only in the extend required or permitted to do so according to the terms of employment. We may share your information in the extend required or permitted to do so with personnel, agents, advisers, lawyers, banks, clients, auditors, service providers, overseas offices, affiliates, partners and any other third person or entity in connection with our operation or services who are also obligated to comply with the European data protection standards and to provide appropriate safeguards in relation to your personal information.

Confidentiality Warning & Disclaimer

Our Company shall require its directors, officers and employees to keep confidential all the information obtained in connection with your Personal Data except for information that is in the public domain or is lawfully obtained from a 3rd party entitled to disclose such information.

How and why we use Information we collect

All information collected are processed in order to fulfil specific purposes of your employment. Only authorized personnel have access to this information. It is stored in order to enable the Company to carry out its contractual obligations with the Crew Member, its legal obligations with local and foreign governmental Authorities and applicable International Conventions, to safeguard the Company’s legitimate interests, resolve any disputes and claims and for the execution of the Company’s operations.

Security Measures for Protecting your Data

Our Company is committed to protecting your privacy and uses adequate security controls to prevent unauthorized access, use, loss, destruction and damage of the above information. We use firewalls, access controls, standards and other procedures to protect information from unauthorized access.

We have conducted privacy and information security awareness training to emphasize and inform employees of the need to protect and secure personal information.

Personal Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for including the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. Your data will be retained throughout your engagement with the company plus 15 years.

Declaration

Only applications submitted through the official website will be accepted. Applications send to Company’s email addresses will be deleted.

Your Rights

In terms of your Personal Data we keep, subject to jurisdictions and applicable law, you have the following rights:

  • Right to have access to your personal data kept by the Company and to receive copy of them.
  • Right to Request correction [rectification] of the personal data kept by the Company.
  • Right to request erasing of your Personal Data (known as the “right to be forgotten”.
  • Right to object to processing of your Personal Data: Subject toproviding a reasonable basis and specific reasons for the objection, you have the absolute right to object if the processing of your Personal Data involves direct marketing and a non-absolute right if the data is processed for legitimate purposes. We will address your objection duly and according to the GDPR regulation and relevant applicable law.
  • Right to request the restriction of processing of your Personal Data: Processing is restricted only to keeping the information stored until the basis of your request is resolved. Notification of incorrect information held will automatically restrict the processing of your Personal Data until such information is corrected. Furthermore, you have the right to explicitly and in writing ask the company to hold on your behalf your personal information which we no longer process.
  • Right to request and receive a copy of your Personal Data in a format that is structured and commonly used and transmit such data to other organizations (Data Portability).
  • Right to Withdraw your Consent: In case you provide us your consent for specific processing you have the right to withdraw it at any time (where applicable).

Important: Consent given for processing of medical and criminal records is bound by our legal obligation to conform with relevant laws, regulations and international conventions which makes it obligatory for the company to hold and process such information. (International Maritime Organization (IMO), International Labor Organization (ILO), Maritime Labor Convention (MLC), The International Convention on Standards of Training, Certification and Watch keeping for Seafarers (STCW). This obligation is based on the obligatory medical examinations for issuance of the Fit-for-Duty Certificates and for the provision of adequate onboard/ashore medical care and treatments.

Raising Queries or Lodging a Complaint

Should you have any questions, suggestions or complaints regarding the possessing of your personal data, you can contact the Company at:

E-mail: ancora@ancora.gr

Address: Artemisiou 3A & Themidos, Glyfada, Greece

You have also the right to lodge your complaint with the Supervisory Authority for Data Protection by submitting your complaint/ query in their website (http://www.dpa.gr/).