PRIVACY POLICY

We, at Cyprus Shipping Association, (“we” “us” or “our”) value your privacy and wish to ensure that your personal data is handled accordingly and correctly. This privacy policy (“Privacy Policy”) aims to inform you of when we might collect and process your personal data, why we may need to do so, the limitation imposed on such collection and processing, your rights in respect thereof, as well as other information that may be of relevance or assistance to you.

The Privacy Policy may, at our discretion, be updated from time to time. Please ensure that you refer back to this policy regularly to keep yourself up to date with any amendments.

I.          When we collect and process

We collect personal data (a) when persons subscribe to us for marketing and/or newsletter purposes; (b) when persons are employed by us; (c) when persons apply to work for us; (d) of persons whose personal data we obtain from third party sources and/or partners, in relation to our services and/or assistance; (e) when persons visit our website at www.csa-cy.org; (f) of persons whose personal information we may process once they enter our premises located at 172 Franglinou Roosvelt Str. ; (g) when persons contact us through our website and/or by e-mail and/or by phone; (h) persons who work for and/or otherwise represent our members. References in this Privacy Policy to “you”, “your” or “yours” should be construed as references to the foregoing persons.

II.         What we collect and process

Depending on the circumstances, we may collect and process specific personal data for different categories of persons. In particular, without limitation, we may collect and process personal data as follows:

(a)        when persons subscribe to us for marketing and/or newsletter purposes, we may collect and process:

                        (i)         name and surname;

(ii)        contact details, such as phone number, e-mail address, postal address; and/or

(iii)       Internet Protocol (IP) address, the name of your internet service provider (ISP) depending on the configuration of your ISP connection, the date and time of your visit to our website, the length of your session, the pages which you have accessed, the number of times you access our website within any month, the file URL you look at and information relating to it, the operating system which your computer uses.

(b)        when persons are employed by us, we may collect and process:

                        (i)         name and surname;

                        (ii)        contact details, such as phone number, e-mail address, postal address;

                        (iii)       details of your emergency contact(s) and next of kin;

                        (iv)       copy of your passport or identity card;

                        (v)        previous employment history, experience and qualifications;

(vi)       payment related details, including bank account details (IBAN, name of bank, branch number, etc);

(vii)      information relating to previous criminal convictions (if any);

(viii)     health related information (e.g. any health-related problem that you may have or suffer from or any health-related assistance that you may require);

(ix)       social insurance number;

(x)        curriculum vitae, inclusive of information on previous education;

(xi)       tax identification number; and/or

(xii)      any other information that you is relevant to such persons’ employment with us.

(c)        when persons apply to work for us, we may collect and process:

(i)         any and all of the information referred to under the immediately preceding paragraph (b) above; and

(ii)        any further information that may help us in evaluating such persons’ application.

(d)        persons whose personal data we obtain from third party sources and/or partners, in relation to our services and/or assistance, we may collect and process:

(i)         any and all of the information referred to under paragraph (b) above;

(ii)        job title or position;

(iii)       organization or company being represented or being acted on behalf of;

(iv)       VAT identification number; and/or

(v)        any further information that may help us in processing and/or carrying out the relevant request or task.

(e)        when persons visit our website, we may collect and process:

                        (i)         any and all of the information referred to under paragraph (a) above; and

                        (ii)        any other information provided to us.

(f)         when persons enter our premises, we may collect and process:

                        (i)         name and surname;

                        (ii)        reason for visiting;

                        (iii)       date and time of entry; and/or

(iv)       date and time of exit.

(g)        when persons contact us through our website and/or by e-mail and/or by phone, we may collect and process:

                        (i)         any and all of the information referred to under paragraph (a) above; and

                        (ii)        any other information provided to us.

(h)        when persons work for and/or otherwise represent our members, we may collect and process, depending on the circumstances, any and all of the information referred to above.

III.        Why we collect and process

Depending on the circumstances, we will collect and process your personal data for any one or more of the following reasons:

(a) to carry out the request you have submitted with us (whether on your own behalf or on the behalf of the entity you represent), including, without limitation, to include you unto our mailing/newsletter list, process an application for registration and/or register the entity you represent as a member of ours, or for providing any assistance required from us;

(b)        to carry out the contractual obligations we may owe to you (whether in our capacity as your employer or otherwise) and/or the entity you represent (whether such entity is a member of ours or not);

(c)        to evaluate your application for employment and for other employment related purposes;

(d)        to comply with legal obligations or any court order or other process or directions or request of a local authority, including, without limitation, where processing is necessary for the purposes of carrying out our or your obligations and exercising our or your specific rights that relate to social security and social protection law, or to comply with any direction or request of the Cyprus Ports Authority;

(e)        to be able to provide you with access to and browsing of our website, and/or to improve your browsing experience and/or improve the website;

(f)         to ensure the safety and protection of our employees, property and website;

(g)        to enforce any agreements, we may have with you and/or defend our legal rights and interests and/or those of any third party;

(h)        to prevent or investigate fraud or other unlawful activities and/or detect security incidents;

(i)         to be able to assess your request and/or inquiry; 

(j)         to get in touch with you in respect of any permitted purpose;  

(k)        in rare cases, where the processing of personal data may be necessary to protect your life or that of a third person;

(l)         to assess and evaluate the performance of our employees, provide equal opportunities, and award them;

(m)       to maintain our internal records up to date; and/or

(n)        for business and/or internal administration purposes.  

IV.        Legal Basis(-es) for collecting and processing

Depending on the circumstances, we will collect and process your personal data for any one or more of the following legal bases:

(a)        in order to perform our obligations in accordance with any contract that we may have with you (or the entity you work for or represent) or in order to take steps to enter into a contract with you (or the entity you work for or represent);

(b)        that it is in our legitimate interest or in a third party's legitimate interest to process your personal data;

(c)        it is our legal obligation to process your personal information to comply with any legal obligations imposed upon us;

(d)        where we have your consent to do so; and/or

(e)        in reliance on any other applicable legal basis provided under applicable laws and regulations.

V.         Sharing and disclosure 

Unless we obtain your prior consent, we will not share or disclose your personal data to anyone. However, we reserve the right to disclose, communicate and share your personal data in one or more of the following circumstances:

(a)        where the disclosure of your personal data is necessary in order to fulfil the purpose for which you have provided it to us for;

(b)        where the disclosure is necessary in order to comply with applicable laws or if we are compelled to do so by a governmental agency, regulation, a court or other legal process, including, without limitation, disclosure to trade unions or employer associations, the Deputy Ministry of Shipping, the Cyprus Ports Authority and tax authorities. Disclosure of your personal data may also take place in order to prevent or investigate a possible crime, such as fraud or identity theft or to protect our own rights or property, or to resolve any problems or inquiries or property, or to protect the rights, property or safety of others;

(c)        where the disclosure takes place with the service providers, we have engaged to perform services for us or on our behalf, including, without limitation, postal and courier, recruiting, credit card verification, storage fulfilment, disaster recovery and web-hosting service providers. We always request that such service providers protect your privacy in every possible manner and in accordance with applicable laws and regulation, and we prohibit them from using your personal data for their own marketing purposes or otherwise;

(d)        we reserve the right to transfer your personal data in the event of a merger, joint venture, acquisition, change of control, or other business combination. In such case, steps will be taken to ensure that your personal data will continue to be protected by this Privacy Policy;

(e)        when the non-disclosure of data constitutes or poses a serious risk of damage to health or physical integrity or the life of a natural person or may have a serious impact on society as a whole; and/or

(f)         violation of our website terms and conditions of use in case we have an indication or believe that your use of our website has or may potentially violate any law and/or regulation, or our said terms and conditions.

Please note that the above list is non-exhaustive as there might (depending on the circumstances) be other instances and persons to whom we may disclose your personal data to. Any transmission of your personal information, as set out above, shall, at all times, comply with applicable laws and regulations.

Further and without prejudice to the above, we may, in connection with our obligations towards you, appoint sub-contractor data processors. We may appoint external data controllers where necessary to perform our obligations towards you, including auditors, accountants or other third-party service providers. All parties that act as joint data controllers or as our data processors respect and protect the security, integrity and confidentiality of your personal data in accordance with applicable laws and regulations.

VI.      Security of your personal data

We maintain a strict policy with regard to confidentiality and security and want you to know that we have in place appropriate technical and organizational measures against unauthorized and/or unlawful access, use, disclosure, loss, destruction or damage. Through our data storage and management systems and policies, we have put in place suitable digital procedures and security safeguards to achieve the foregoing but also maintain physical and managerial procedures both in respect of data kept in digital as well as physical form. Where personal data is included and/or provided to us in hard paper form, it is securely stored in a designated space within our premises where no unauthorized access is permitted.

We regularly review and update our policies and systems in order to ensure they are kept up to date and effective.

Notwithstanding the above, as you may appreciate, we cannot guarantee that our foregoing measures, systems, policies and safeguards will indeed prevent our computers or systems from being accessed illegally and that the personal data stored or maintained thereon will not be stolen, misused or altered.

We maintain a strict policy with regard to confidentiality and security and we require all our staff, advisors and data processors to do the same.

VII.      Retention period

As a general rule, we will retain and process your personal data for as long it is necessary for the purposes referred to under paragraph III. above, always in accordance with applicable laws and regulations and taking into account limitation periods for taking legal action, good practice and business purposes. Each retention period will depend on the specific category of personal data as follows:

(a)        where we process your personal data following a request you have submitted with us (whether on your own behalf or on the behalf of the entity you represent), your personal data will, subject to any further lawful processing (including, without limitation, requirement to retain personal data for compliance with a legal requirement to which we are subject to and/or where processing is necessary on the basis of our legitimate purposes), be retained for a period of at least 1 calendar year from our last interaction with you or with the entity you represent;

(b)        where we carry out the contractual obligations we may owe to you (whether in our capacity as your employer or otherwise) and/or the entity you represent (whether such entity is a member of ours or not), your personal data will, subject to any further lawful processing (including, without limitation, requirement to retain personal data for compliance with a legal requirement to which we are subject to), be retained for a period of at least 6 calendar years from our last interaction with you or with the entity you represent;

(c)        where we evaluate your application for employment and for other employment related purposes, you personal data will, subject to any further lawful processing (including, without limitation, your consent to us to retain such information, and/or requirement to retain personal information for compliance with a legal requirement to which we are subject to), be securely deleted or destroyed following an unsuccessful application for employment;

(d)        where we provide you access to and browsing of our website, and/or to improve your browsing experience and/or improve the website, or where you contact us through our website and/or by e-mail, your personal data will, subject to any further lawful processing (including, without limitation, requirement to retain personal information for compliance with a legal requirement to which we are subject to and/or where processing is necessary on the basis of our legitimate purposes), be retained for a period of at least 1 calendar week from our last interaction with you or with the entity you represent; and

(e)        in all other instances, your personal data will, subject to any further lawful processing, be retained for a maximum of 1 calendar week from our last interaction with you or with the entity you represent.

VIII.       Your rights    

(a)        Right to Access: you can request details of the personal data we have in our possession and how we process it. In case that we do not hold and/or process any personal data that concerns you, we will inform you accordingly.

(b)        Right to Rectification: you can request and obtain without undue delay the rectification of inaccurate personal data we hold on you. If you are entitled to rectification and if we have shared your personal information with others, we will let them know about the rectification where possible. Upon your request, where possible and lawful to do so, we will also tell you with whom we have shared your personal information so that you can contact them directly.

(c)        Right to Erasure: you can request the erasure of your personal data and we will be obliged to do so without undue delay. Unless such request is contrary to our legal obligations, we will not be required to satisfy your foregoing request.

(d)        Right to Restriction: you can request to restrict the processing of your personal information in certain circumstances, including where there is a contest of the accuracy of your personal information. If you are entitled to restriction and if we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. Upon your request, where it is possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

(e)        Right to Lodge a Complaint: you can lodge a complaint with the Office of the Data Protection Commissioner.

(f)         Right to Portability: you can request your personal information to be provided to you in a structured, commonly used and machine readable format and to transmit, where technically feasible, such information to another controller without hindrance, where (i) processing is based on your consent or on the performance of a contract with you; and (ii) such processing is carried out by automated means.

(g)        Right to Withdraw Consent: If we process your personal data upon your prior consent, you can withdraw such consent at any time.

(h)        Right to Object: if you demonstrate that your fundamental rights and freedoms outweigh our legitimate interests, you can object to any processing of your personal data that is carried out on the basis of our legitimate interests. Once you have objected, we will have the right to prove our legitimate interests to continue processing your personal data.

IX.         Changes to this Privacy Policy

We reserve the right to change, amend, modify this Privacy Policy at any time. Any amendments will apply prospectively to your personal information collected or modified after we have updated our page. We therefore urge you to frequently visit this page in order to stay up to date with how your personal data is processed. Where possible, we will notify you of any significant changes via an e-mail or will otherwise bring such changes to your attention.

X.         Cookies 

To find out more about cookies, which types we use and how to adjust your settings in respect thereof, please click review our cookie policy uploaded on our website at www.csa-cy.org.

XI.        Contact us

Please feel free to contact in the event you have any question with regard to this Privacy Policy or where you would like to exercise any of the rights mentioned under paragraph VIII. as follows:

By post:           172 Franglinou Roosvelt Str. P.O. Box 50529

By e-mail:        info@csa-cy.org

By Tel.:            +357-25827882

By Fax:            +357-25360675

Date: December 2020

COOKIE POLICY

This is the cookie policy of Cyprus Shipping Association’s, (“we” “us” or “our” accordingly) website at https://www.csa-cy.org (“Website”, and collectively the “Cookie Policy”).

This Cookie Policy aims to inform you about cookies, the types we use, why we use them and your rights in respect thereof.

We will inform you of our use of cookies when you first visit the Website and will request you to confirm that you have read, understood and agreed to this Cookie Policy. Thereafter, assuming that you continue to use the Website, such use will be viewed and deemed by us as an indication of your acceptance of the Cookie Policy in accordance with this Cookie Policy.

This Cookie Policy may, at our discretion, be updated from time to time. Please ensure that you refer back to this policy regularly to keep yourself up to date with any amendments.

I.          What are Cookies 

Like many other web sites, the Website makes use of small log files, which are stored on your device in order to improve your browsing experience. In particular, the Website uses cookies to store information about visitors' preferences, to record user-specific information on which pages the Website visitor accesses or visits, and to personalize or customize the Webpage based upon visitors' browser type or other information that the visitor sends via their browser.

These small log files will primarily capture your internet protocol (IP) addresses, browser type, internet service provider (ISP), date/time stamp, referring/exit pages, and possibly the number of clicks you make on the Website.

For more information about cookies and other useful information relating to similar technologies you may visit  https://www.allaboutcookies.org/.

II.         The types of cookies we use

We use the following cookies on the Website:

(a)        Essential

These cookies are necessary to provide you some of the features of the Website’s services, and cannot be switched off in our systems. They are usually only set in response to actions made by you, such as when you login to member’s area or set your privacy preferences. These cookies also enable us to support security features to help us detect malicious activities and violations of our terms and conditions. You can set your browser to block or alert you about these cookies.

(b)        Performance

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of the Website. They help us to know which pages are the most and least popular and see how visitors move around the Website. These cookies may collect your IP address, web browser, time spent on pages, links clicked, and conversion information. We may use this information to understand, improve, and research features and services, including how you access the Website from different applications or devices.

III.        Your rights

You may access the cookies settings by visiting https://www.csa-cy.org, navigate to the bottom of the page and click “Cookie Settings”, and prevent the setting of specific cookies accordingly. You should note though that disabling or disapplying specific cookies may impact and/or affect your browsing experience on the Website and/or otherwise the functionality of the Website.

IV.        Retention period 

Cookies files will remain saved on your device even after you end your session on the Website and exit the same. Cookies will become active again when you next visit the Website, until removed.  The cookies will not collect any information when you are not accessing the Website. The cookies can be deleted by you at any time.

V.         Contact us

Please feel free to contact in the event you have any question with regard to this Cookie Policy or where you would like to exercise any of the rights mentioned under paragraph VIII. as follows:

By post:    172 Franglinou Roosvelt Str. P.O. Box 50529

By e-mail:             info@csa-cy.org

By Tel.:    +357-25827882

By Fax:    +357-25360675

Date:   December 2020