1. INTRODUCTION
Genco Shipping & Trading Limited (“Genco”) is an international ship owning company. We are committed to being transparent about how we collect and use personal data and to meeting our data protection obligations. Where Genco is the data controller of any personal information provided to us by customers, vendors or suppliers, this statement will explain how we may process and use such information.
2. WHAT PERSONAL DATA WE COLLECT ABOUT YOU
The personal information we collect about our customers, vendors and suppliers is very limited. We collect only information about their employee representatives (work email addresses and telephone numbers).
3. HOW THIS PERSONAL DATA IS COLLECTED
We may collect personal data about you in several separate ways including, but not limited to the following:
- during our contracts with you;
- from business cards; and/or
- through third party agencies, service providers and/or publicly available information.
4. HOW WE USE PERSONAL DATA
We may use your information for:
- performing the contract we are about to enter or have entered with you;
- maintaining and developing our relationship with you;
- facilitating our internal business operations including accounting, billing, collections, and payments;
- fulfilling our legal and regulatory obligations;
- monitoring and analyzing our business;
- sending you marketing bulletins and other promotional materials; and/or
- invitations for corporate hospitality and other events.
This is not intended to be an exhaustive list, and we may use personal data provided to us for related and/or ancillary purposes.
5. SHARING YOUR PERSONAL INFORMATION
We may share your personal data:
- with other Genco affiliated entities on a confidential basis for the performance of our contracts and/or in compliance with our legislative and regulatory requirements;
- for auditing and accounting purposes;
- with regulators, courts and law enforcement agencies as necessary; and
- with third party service providers, and in doing so we will take reasonable steps to provide for the confidentiality, integrity and security of your personal data is maintained when being handled by any such service provider; and
- in other circumstances where we have your express consent to do so.
5.1 Third party personal information shared with us
Where we receive personal data relating to someone else from a third party (“discloser”), the onus is on the discloser to ensure that they have the relevant authority and/or consent to disclose that personal data to us and that the information that they have provided is accurate and up to date. On this basis, we may collect, use and disclose that personal data as described in this Privacy Policy.
Information security
We will take reasonable steps to provide that the information that we hold about you is kept confidential and secure. In addition to personal information being kept electronically, we may also store physical documents on file.
5.2 Transferring data abroad
Your personal information will be shared with our parent entity in the US. To ensure that personal information covered by EU data protection laws is treated in a way consistent with and which respects such laws, we plan to enter into data transfer contracts as appropriate with our affiliates and third party providers containing model contract clauses approved by the European Commission. Similar instruments will be implemented to for other data as required.
Updating your personal data
Should you wish to amend the personal information that we hold for you, please contact chartering@gencoshipping.com or operations@gencoshipping.com We will not be responsible for any losses arising directly or indirectly from any inaccurate and/or incomplete information provided to us by you.
Retention of your personal information
We will retain your personal information only for as long as is reasonably necessary in the circumstances and in compliance with our legislative and regulatory requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
6. YOUR RIGHTS
In accordance with data privacy laws in certain jurisdictions in which we operate, you may have the right to:
- request access to the personal information which we hold about you;
- request correction of personal information;
- request the transfer of your personal information to another party;
- request the restriction of process; and
- request the deletion of your personal information if Genco or its group entities are no longer under a legal obligation to process such data. Genco can also refuse to delete your data if in its view it requires the information for defense of legal claims against it or its group entities.
If you wish to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Genco Shipping & Trading Limited, 299 Park Avenue, 12th Floor, New York, NY 10171, U.S.A. in writing or please contact chartering@gencoshipping.com or operations@gencoshipping.com. Please note that there may be limitations on these rights, depending on the specific circumstances concerning your data and applicable law.
7. STATUS OF THIS PRIVACY POLICY
We review this Privacy Policy regularly and reserve the right to revise it or any part of it from time to time to reflect changes in the law, information security and technology practices or in the way in which we process your personal information.
8. CONTACT INFORMATION
If you have any questions about this Privacy Policy, or want to submit a written complaint to us about how we handle your personal information, please contact us at Genco Shipping & Trading Limited, 299 Park Avenue, New York, NY, 10171, U.S.A. in writing or please contact chartering@gencoshipping.com or operations@gencoshipping.com.
You may also have the right to submit a complaint to the relevant supervisory authority in your jurisdiction depending on your location. In relation to the EU data protection matters, please contact the Danish Data Protection Authority at www.datatilsynet.dk .