Privacy Notice

This online privacy notice statement describes how Sea Talent Crewing Ltd process personal data.

In this Privacy Notice Online Statement policy, your data is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data or any such action as “processing” such personal data.  Personal data shall mean any information relating to you which identifies or may identify you and which includes, for example, your name, address, identification number.

The Company is committed to safeguarding your privacy and handling your personal data in a lawful, fair and transparent manner which respects the privacy of any user that accesses our site(s). Our Privacy Notice Online Statement policy is intended to explain how we protect the privacy of your personal information.

This document will help you understand the following:

  • what personal data we collect and process about you as a Client and as a user of our website;
  • why we collect and process your data;
  • how the Company collects and processes your personal data;
  • where we obtain the data from;
  • your rights under the local data protection law and the EU General Data Protection Regulation (GDPR);
  • how and when we share your personal data with other third parties (for example, our service providers or suppliers).

This Privacy Notice is separate and in addition to client confidentiality obligations that we may have. This online privacy notice statement aims to give you information on how we collect and process your personal data through the use of this website, including any data you may provide us through when you sign up to our newsletter, purchasing a product or service or providing us your details in our contact form.

Phone: +357 25 846 298

1. THE LEGAL BASIS FOR OUR PROCESSING OF YOUR PERSONAL DATA

Sea Talent Crewing Services collects and processes your data prior entering into a contract with you. Specifically, having received your application for employment we will process the data to the extent it is necessary for:

  • taking steps at your request prior to entering into contracts, to which you will be party,
  • the compliance with the legal obligations, to which we and our Clients are subject in relation to your employment,
  • the legitimate interests pursued by us or by our clients.
  • You have specifically consented to your personal data being used by us for a specific purpose.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw your consent at any time by emailing us or submitting a privacy request.

2. HOW IS YOUR PERSONAL DATA COLLECTED?

Sea Talent Crewing may collect personal data from the following sources:

  1. You, the candidate. Data that might be contained in application forms, curriculum vitae’s (CVs), covering letter, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
  2. We may also collect personal data about you from third parties, such as references supplied by former employers. We might seek information from third parties only once a job offer to you has been made and will inform you that we are doing so.
  3. From publicly available sources.
3. THE CATEGORIES OF YOUR PERSONAL DATA

In the course of the recruitment procedure, we will collect and further process the following categories of your personal data, either submitted by you personally (the information entered directly in the online application form as well as separate CV, cover letter, motivation letter or other documents additionally uploaded by you), recorded during personal interviews or collected from external sources (e.g. from your former employers):

  1. Identification information (e.g., full name, date of birth, gender, citizenship, details of an identity document, etc.)
  2. Contact details (e.g., home/correspondence address, mobile or home telephone number, e-mail address)
  3. Education and training history
  4. Proof of your professional qualifications / certification records
  5. Your work history and references from your previous employers
  6. Your expectations with respect to the conditions of employment
  7. Health certificates
  8. Your images are captured by the security CCTV systems installed in our premises

Please note our processing of the information listed above is necessary for the legitimate, effective and reliable performance of the recruitment process. Failure to provide the necessary data or provide incomplete or incorrect/false information is likely to prevent the successful conclusion of your application. Any such incomplete or false statements discovered after entering into a formal contract of employment may lead to the termination of employment and/or other legal consequences.

4. DATA FROM OTHER SOURCES

In addition to the data provided by you personally, we may collect personal information about you from previous employers or other background check providers.

5. SPECIAL CATEGORIES OF YOUR PERSONAL DATA

Please note that to process your application for employment we might be required, following local laws, regulations, and requirements, to ask you for “special categories” of personal data. Such data shall be your latest health certificates and nationality. Special categories of personal data: any information revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, any genetic data, biometric data that may be used for the purpose of uniquely identifying you, data concerning your health, sex life or sexual orientation as well as any details of your criminal convictions or offences.

6. THE PURPOSES FOR WHICH YOUR DATA WILL BE PROCESSED:

We will process your personal data for the following specific purposes (related to the specified legal bases):

  1. Personal identification
  2. Evidencing your work qualifications
  3. Verification of your entitlement to legitimate employment
  4. Evidencing your work experience and performance
  5. Assess your salary and other benefits expectations prior to your employment
  6. Evidencing your training qualifications and development
  7. Administration of information security through management of access rights and monitoring usage of IT infrastructure
  8. Monitoring the security of the office premises
  9. If requested by you, send you automatic alerts about new vacancies that might be of interest to you
  10. Communicating with you
7. RECIPIENTS OF YOUR PERSONAL DATA

Your personal data will be processed by our IT, and shared with the other members of our company, our clients, manning agents and/or third-party service providers as and to the extent necessary in the context of assessing the possibilities of your employment.

8. TRANSFER TO THIRD PARTIES

The Company may transmit your data to third party entities such as outsourced service providers, clients, and manning agents that  have contractual relationships with the Company and are contractually bound to observe the same confidentiality and data protection rules that the Company has to follow.

Your personal data may be, for example, transmitted to the following entities:

  1. Supervisory, regulatory and public authorities, including courts of justice, law enforcement authorities and other governmental bodies.
  2. Legal counsel and consultants
  3. Auditors and accounting consultants
  4. Administrative service providers
  5. Marketing and customer support service providers
  6. Clients (e.g., ship owners, ship managers, manning agents)

We do not share, sell or transfer any personal information to a third party without your permission or unless required to do so under rules and regulations, and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served.

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to:

  • comply with any applicable law, regulation, legal process or governmental request.
  • (enforce our policies (including our Agreements), including investigations of potential violations thereof;
  • investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing.
  • to establish or exercise our rights to defend against legal claims;
  • prevent harm to the rights, property or safety of us, our users, yourself or any third party;
  • or for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights or the prosecution of criminal offenses.

As regards all our third-party service providers, they are required to take appropriate security measures to protect your personal data. We only permit them to process your personal data for specified purposes and in accordance with our instructions and they are subject to a duty of confidentiality.

9. TRANSFER TO THIRD COUNTRIES

Except for the communication of a limited scope of your personal data to the members of our company established outside the EEA and possible occasional necessity of transferring your data to non-European service providers, clients, and/or manning agents.

In doing that we rely on Article 45 that this allows us to transfer personal data to such recipients based on the EU Commission’s adequacy decision or on Article 46(2)© of GDPR for the cross-border transfers based on Standard Contractual Clauses adopted by the EU Commission.

10. RETENTION

Personal data is processed for as long as necessary to provide our services, fulfil our contractual obligations, and comply with applicable laws, regulations, and professional obligations to which we are subject.

Once the retention period has elapsed, personal data shall be securely erased or anonymized, unless further processing is required for compliance with legal obligations and requirements to which we are subject.

11. MEANS OF COLLECTION OF DATA

The majority of the data shall be acquired directly from you, either via the forms available on our website or via email or via other means of communication you chose to use, and we choose to accept.

However, we may also collect and process personal data which we lawfully obtain from other entities such as information aggregation agencies, public authorities, entities that introduce you to us, companies that process your card payments, your Bank(s) and intermediary/correspondent institutions.

12. DATA SECURITY

We are taking all necessary organizational and technical measures to protect your personal data against unauthorized (whether accidental or intentional) access, alteration, disclosure, transfer or destruction. The access to your data kept on paper as well as digital format is restricted to authorized personnel only, who are all bound by the obligation to compliance with the company’s privacy policies and procedures, including the obligation to confidentiality.

All application data processed in digital form are stored on servers within European Economic Area.

Transmission of data both between our offices and to and from our external processors (e.g. providers of cloud storage/computing) is carried out through secure SSL VPN connections. Procedures, controls and systems are in place to ensure our security policies are enforced. Access to personal data is governed by controls based on defined roles – either related to employee job description or third-party service agreements. All vendors, partners and service providers are under legal or contractual obligations to provide the personal data with the level of protection required by the European Data Protection Laws.

13. YOUR RIGHTS
  1. Right to information – You may request to know whether we hold any of your personal data, and, if so, information what type of data we process and why/how we are processing it. Right of access – You have the right to receive a copy of your personal data.  
  2. Right to rectification – You have the right to request the rectification of incorrect or incomplete data.
  3. Right to erase (right to be forgotten’) – You may request that your personal data is deleted, provided that you meet the legal criteria for this request.
  4. Right to object. Object to processing your personal information – If we are processing your data based on our (or a third party’s) legitimate interest and you are in a particular situation which gives you reason to object to the processing, you may submit this request. You may also object if we are processing your data for direct marketing purposes. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.
  5. Object to automated decision-making including profiling – You may object to any automated decisions or profiling taken and performed by us based on your personal data.
  6. Right to restriction – You may request the restriction of the processing of your data under some circumstances.
  7. Right to data portability – This right only applies to the information that you have given to us. You have the right to ask that we transfer the information you gave us from one organization to another or give it to you.

Where you have consented to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once your consent is withdrawn, the processing of your data will be halted, unless said processing is found on another legitimate basis, for example due to a legal obligation to keep your data.

Please contact the Company’s Data Protection Officer at [email protected]   if you wish to exercise your rights. We may apply identification verification measures to you in order to ensure that no personal data is disclosed to unauthorized persons.

Your enquiries will be addressed as soon as possible, within the 30-day period prescribed by the Data Protection Law.

If you have received a response to your complaint by the Company which you deem to be unsatisfactory, you may also complaint to the Office of the Commissioner for Personal Data Protection in Cyprus, (http://www.dataprotection.gov.cy).

14. LINKS TO OTHER WEBSITES

We will not be liable for misuse or loss of personal information resulting from cookies on the site(s) that we do not have access to or control over. Where we provide links to websites of other organizations, this privacy notice online statement policy does not cover how that organization processes personal information. We encourage you to read the privacy notices on the other websites you visit. We are not liable for unlawful or unauthorized use of your personal information due to the negligent or malicious misuse or misplacement of your passwords.

15. AUTOMATED DECISION-MAKING AND PROFILING

In general, your data is not processed automatically, and no decision is taken based on automated processes.

16. COOKIES

A cookie is a small text file stored on your computer for record-keeping purposes. The Company uses cookies on its site(s). We do not link the information stored in cookies to any personal identifiable information you may submit. We use both session ID and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your internet browser’s “Help” file. We may set a persistent cookie for statistical purposes. Persistent cookies also enable us to track and target the location and the interests of users that access our site(s) and to enhance the experience of services offered to you. You may reject our cookies, which could result in a lower quality user experience. Some of our business partners use cookies on their site(s). We have no access or control over these cookies.

For additional information, please refer to our cookie policy.

17. YOUR FEEDBACK

If you find anything unclear or inadequately explained in this notice, please feel free to contact us for clarification at any time. Any opinions or suggestions with respect to the form and content of the notice will also be of great value to us.

18. CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, especially when any significant changes will be expected in the processing of your personal data or the ways you may exercise your rights.

This privacy statement was last updated on 07 February 2025.