SeaFort Maritime Limited Privacy Policy (April 2020)
This Privacy Policy sets forth how SeaFort Maritime Limited (“SeaFort” or “we”) collects and processes personal data about you. We are providing this Privacy Policy to you to satisfy disclosure requirements required under data protection and privacy regulations adopted by regulatory authorities in the jurisdictions in which we conduct business. These regulations require that SeaFort (as a data controller) ensure that you understand how we collect, use, process and share your personal data. If you provide personal data to us about any person other than yourself, you must ensure they understand how their data will be used.
Please direct any questions regarding SeaFort’s Privacy Policy to: info@seafortmar.com
What are your rights?
You may ask us for a copy of your personal data, to correct it, to erase it or to transfer it to other organisations. You may also have rights to object to some processing and, where we have asked for your consent to process your personal data, to withdraw this consent. In particular, you have rights to object to direct marketing at any time. To make a request in relation to your personal data, please contact info@seafortmar.com. We will attempt to deal with all requests at the earliest opportunity.
In addition, if you have unresolved concerns about our data handling practices, you may contact the UK Information Commissioner's Office at https://ico.org.uk/concerns/handling/.
What personal data do we collect?
We collect personal data in different ways (directly and/or indirectly) from the following categories of individuals:
Website Visitors
If you wish to subscribe to certain communications from us, we will need you to provide your email address. Please note, if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via directions in the particular communication.
For more information on technology and cookies used on this website, please see our Technology and Cookies Policy
Business Contacts and Prospective Clients.
We may collect personal data about individuals or representatives of organisations with whom SeaFort has a business relationship (or with whom we are seeking to establish a business relationship), as well as prospective clients.
Such information may include the following in relation to you, your individual representatives, underlying investors and/or beneficial owners and control persons (where applicable):
name, address, telephone number, email address and other contact details;
employment information such as organisation name and address, job title;
AML/KYC or similar information such as place of birth, nationality, details from passports or other government issued documents, social security number or other tax or national identification numbers;
Financial information such as account number, financial institution, wire transfer details or other financial status (such as source of wealth); and
product and communication preferences (if you choose to receive marketing communications, you will have the option to opt out of receiving such communications at any time by contacting us or unsubscribing via directions in the particular communication).
Third-Party Service Providers and Suppliers
SeaFort may collect certain personal data about third-party service providers and suppliers and/or about their individual representatives and associates in the course of engaging or interacting with them, including:
name, job title, telephone number, email address and other contact details;
the name of the third-party service provider, vendor or supplier with whom you are associated and its address; and
information required to process payments, such as a tax ID number and wire instruction details.
Please note, we typically do not collect sensitive or special category personal data about individuals. When we do need to process sensitive personal data, it is with the consent of the individual unless it is obtained indirectly for legitimate purposes.
The website is not intended for or targeted towards, and we do not knowingly collect personal data via the website from, children under 13 years of age. If we learn we have collected or received personal data via the website about a child under 13, we will delete that information.
How do we collect personal data?
We obtain personal data both directly and indirectly from individuals in a variety of ways. We might obtain personal data directly from you including when you:
provide us with a business card;
subscribe to our newsletters/reports or request marketing to be sent to you;
purchase or subscribe to a product or service;
attend events we host; and/or
contact us.
We might obtain personal data indirectly from you including from:
third parties such as consultants, brokers or other service providers;
public sources, such as public registers (such as Companies House), news articles, sanctions lists, business intelligence services and internet searches; and/or
through technology or cookies - for more information on technology and cookies used on this website, please see our Technology and Cookies Policy.
How do we use personal data?
We only use your personal data where we have a lawful basis for doing so, for example (i) in order to comply with our legal and regulatory obligations; (ii) because we need the information for reasons of substantial public interests; (iii) in order to comply with our obligations under contract; and/or (iv) because we have a legitimate business interest in processing it, including for the following purposes:
Managing our broking relationship with you and the provision of other services to you;
For marketing, including sending marketing communications, newsletters or reports;
Exchanging mail correspondence or documentation; and/or
Complying with applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of the jurisdictions in which SeaFort conducts business.
Where SeaFort is relying on its legitimate interests as the ground for processing your personal data, we must carry out an assessment to ensure our interests do not override any rights you may have.
Who do we share personal data with and where do we transfer it?
We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. For example, we may share personal data with third parties including, but not limited to:
third parties acting on your behalf such as agents, consultants, brokers or other service providers;
third party service providers (such as providers of telecommunications systems, archiving services, courier services or other package delivery services, payment service providers or marketing service providers);
our, or our clients’, professional advisers including lawyers, auditors, accountants and insurers;
our consultants; and
law enforcement or other governmental bodies, public registers and regulatory or tax authorities in various jurisdictions to comply with reporting and notification requirements or as required by, and in accordance with, applicable law or regulation.
We store personal data on servers located in the UK . We may transfer personal data to reputable third party organisations situated inside or outside the EEA or the UK when we have a business reason to engage these organisations. When transferring personal data from outside the EEA or the UK, we seek to comply with European Union and UK law by ensuring adequate safeguards are applied in accordance with our contractual obligations and applicable data protection legislation.
How do we protect your personal data?
We endeavour to limit access to personal data about you to those employees, agents and other authorised parties who need to know the information to enable us to provide products or services to you, as well as to satisfy regulatory and/or legal obligations. Please note that such safeguards, however, do not guarantee that personal data transmitted via the internet or stored in our systems or is otherwise under our care will be absolutely safe from unauthorised use or intrusion from third parties due to the inherent nature of the internet.
Retention of Personal Data
We will retain personal data only for so long as is necessary for the purpose for which we use it (unless applicable law or regulations require or permit a longer retention period). In addition, we may retain your personal data for the duration of any period necessary to establish, exercise or defend legal rights. As a general rule, we retain personal data for seven years. We will dispose of personal data in a secure manner when we no longer need it.
Updates to this Privacy Policy
SeaFort reserves the right, in its sole discretion, to modify or amend this Privacy Policy in any way at any time. Any changes are effective upon posting and we will indicate in the Privacy Policy when it was most recently updated. You should review this Privacy Policy periodically for changes applicable to you. Additionally, note that by accessing this website subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended.
Links to Third Party Websites
The website may contain links to third party websites which, in some cases, may be integrated into, and appear to be part of, this website. SeaFort encourages you to read the privacy policies of other websites you link to from this website and disclaims any responsibility for the privacy policies and procedures of any third party websites that you reach via a hyperlink contained on this website. Such hyperlinks are provided for your convenience only, and you access them at your own risk.