Introduction
This General Privacy Notice explains what we do with your personal data in relation to this website only. Each entity included on this website has its own website and Privacy Notice. Columbia Holdings Ltd (Columbia) does not exercise control over the content of these websites.
It applies to any Prospective Customers, Customers, Business Partners, Prospective Vendors, Vendors, Prospective Employees (Office Staff), Unsuccessful Candidates (Office Staff), Prospective Seafarers and any Company Website Visitors of whom we process personal data.
It describes how we collect, handle, and process your personal data.
This notice is layered. So, if you wish, you can easily select any processing activity to see what to expect us to do with your personal data.
The Data Controller
Columbia Shipmanagement Limited (CSM Ltd) is the controller for the personal data that is processed through this website. You can contact CSM Ltd in a number of ways, which are set out below:
Columbia Shipmanagement Limited
Address: Columbia House, 21 Spyrou Kyprianou Avenue, 4042 Limassol, Cyprus
Phone: +357 25843100
Email: [email protected]
The Data Protection Officer (DPO)
If you wish to contact the Data Protection Officer of CSM Ltd in relation to the processing of your personal data by CSM Ltd, you can do so in a number of ways, which are set out below:
Mr Andreas Andreou
Address: Columbia House, 21 Spyrou Kyprianou Avenue, 4042 Limassol, Cyprus
Phone: +357 25843100
Email: [email protected]
Processing Activities
Communication
Data Subject
This section applies to the personal data of Prospective Customers, Customer, Prospective Vendors, Vendors and Business Partners.
Purpose of Processing
Where you provide us with your personal data, we will process them for communication purposes only.
Categories of personal data
This includes your personal identification details and contact information.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(f). This allows us to process personal data when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
If legitimate interest, it must be identified
The legitimate interest pursued by us is the direct marketing of our services.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct direct marketing, we will not be able to approach new business opportunities.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
We will store such personal data for 10 years from our last communication.
Recruitment of Seafarers
Data Subject
This section applies to the personal data of Prospective Seafarers.
Purpose of Processing
Where you provide us with your personal data, we will process them for recruitment purposes only.
Categories of personal data
This includes your personal identification details, contact information, education and skills.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(b). This allows us to process personal data when it is necessary in order to take steps at the request of the data subject prior to entering into a contract.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required recruitment purposes, we will not be able to enter into a contract.
Recipients
The only recipients will be:
- our third party service providers;
- our Customers (Shipowners);
- our Manning Agents.
They will be assisting with the necessary formalities for this matter. They are located globally.
Where they are based outside the EEA, these include, but are not limited to,:
- United States of America;
- Philippines;
- Singapore;
- Japan;
- Ukraine;
- Georgia;
- Saudi Arabia; and
- Russia.
We rely on GDPR Article 46(2)(c) for cross-border transfers. This allows us to transfer personal data to such recipients based on the Standard Contractual Clauses adopted by the EU Commission.
Where they are based in Japan, we rely on GDPR Article 45 for cross-border transfers. This allows us to transfer personal data to such recipients based on the EU Commission’s adequacy decision.
Retention Period
We will store such personal data for a period of 10 years from the date of collection of your personal data.
Employee Recruitment
Data Subject
This section applies to the personal data of Prospective Employees (Office Staff), Unsuccessful Candidates (Office Staff).
Purpose of Processing
Where you provide us with your personal data, we will process them for recruitment purposes only.
Categories of personal data
This includes your personal identification details, contact information, employment information, professional experience and affiliations, education and skills.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(b). This allows us to process personal data when it is necessary in order to take steps at the request of the data subject prior to entering into a contract.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required recruitment purposes, we will not be able to enter into a contract.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
For unsuccessful candidates (office staff), we will store such personal data for a period of 1 year after the date of the job application or interview.
For successful candidates, or prospective employees (office staff), we will store such personal data for a period of 10 years from the termination of employment.
Cookie Management
Data Subject
This section applies to the personal data of company website visitors.
Purpose of Processing
Where you provide us with your personal data, we will process them for cookie management purposes only.
Categories of personal data
This includes your browsing information.
Legal Basis
The legal basis we rely on to process your personal data for necessary cookies is GDPR Article 6(1)(f). This allows us to process personal data when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
The legal basis we rely on to process your personal data for non-necessary cookies is GDPR Article 6(1)(a). This allows us to process personal data when the data subject has given consent, subject to the applicable conditions, to the processing of his or her personal data for the specified purposes.
If legitimate interest, it must be identified
The legitimate interest pursued by us is maintaining the integrity of our IT systems and the continuity of our business.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required cookie management, we will not be able to track visitor behaviour, maintain the integrity of our IT systems, maintain the continuity of our business and measure site performance.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
We will store such personal data for the periods below depending on the type of cookie as from the Cookies’ activation:
- Necessary cookies shall be stored for a few seconds;
- Performance cookies shall be stored for:
- __utmc for the session;
- __utmb for 30 minutes;
- __utma for 2 years;
- __utmt for a few seconds and expires after 10 minutes;
- __utmz for 6 months.
Cookies
Our use of cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We use necessary cookies to make our website work. We would also like to set analytics cookies that help us make improvements by measuring how you use the website.
Necessary cookies
Necessary cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts, and payment processing. Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions.
We use necessary cookies to enable certain functions on our website.
Performance cookies
Performance cookies track how you use a website during your visit. Typically, this information is anonymous and aggregated, with information tracked across all website users. They help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. We would like to set Google Analytics cookies to help us improve our website by collecting and reporting information on how you use it. The cookies collect information in a way that does not directly identify anyone. These will be off by default and set only if you accept.
We use performance cookies on our website.
Targeting cookies
Targeting cookies help determine what promotional content is most relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These will be off by default and set only if you accept. Targeting cookies set by third-parties may be used to track you on other websites that use the same third-party service.
We use Targeting cookies on our website.
How do I change my cookie settings?
You can change your cookie preferences relating to our website at any time by clicking on the ‘Cookie Settings’ link. You can then adjust the available sliders to ‘On’ or ‘Off’, then clicking ‘Save and close’. You may need to refresh your page for your settings to take effect.
Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, we recommend to visit www.aboutcookies.org or www.allaboutcookies.org.
To find information relating to your specific browser, please visit your browser’s website.
To opt out of being tracked by Google Analytics across all websites, you can visit http://tools.google.com/dlpage/gaoptout .
Data Subject Rights
We shall respond without undue delay to requests made by Data Subjects to exercise their rights in relation to the personal data we process.
Under certain circumstances, data subjects have certain rights, including:
Access
Data subjects have the right to obtain the following from the Company:
- Confirmation that the Company is processing their personal data;
- Copy of their personal data;
- Other supplementary information which is already included in the Company’s General Privacy Notice
Rectification
Where personal data is inaccurate, data subjects have the right to request that it be corrected and incomplete personal data be completed based on information they may provide.
Erasure
The right to erasure is also known as “the right to be forgotten.” It applies only in certain circumstances.
Restriction on Processing
Data subjects may request from the Company the restriction of processing of their personal data.
Object to Processing
Data subjects have the right to object to the processing of their personal data in some circumstances. However, data subjects have the absolute right to object to the processing of their personal data for direct marketing purposes.
Portability
Under certain circumstances, data subjects have the right to receive personal data in a structured, commonly used and machine-readable format. This allows data subjects to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.
Right to withdraw consent if processing is based on consent
Where the legal basis for processing is the consent of data subjects, the GDPR entitles data subjects to the right to withdraw their consent at any time.
Right to lodge a complaint with a supervisory authority
Data subjects have the right to complain if they have concerns about the way the Company is handling their personal data.
Automated decision making
Data subjects have the right not to be subject to a decision which is based on automated decision making or profiling, without the involvement of human intervention.
We do not use automated decision making.
How do I exercise my rights?
You can contact us in the ways set out in the relevant section at the beginning of this notice.
Alternatively you can use the following link to submit a request via our dedicated portal:
https://columbiagroup.org/contact/
Changes to the General Privacy Notice
If any changes are made to the General Privacy Notice, these will be posted on this page. Please check back frequently to stay informed of any updates or changes. Where we intend to further process your personal data for a purpose other than that for which the personal data were collected, we shall provide you, prior to that further processing, with information on that other purpose and with any relevant further information.
