1. GENERAL INFORMATION

JSC “sofia shipping” is a company registered in the Republic of Lithuania, a member of the European Union (EU), which shall maintain legal jurisdiction. The Company and its international subsidiaries, hereafter referred collectively as “Sofia shipping”, provides international crew and ship management services, including but not limited to: crew management, full technical ship management, new ship building supervision, crew training and safety.

Sofia shipping is committed to protecting your privacy. The official group website, This email address is being protected from spambots. You need JavaScript enabled to view it., is presented as is seen by the user, and makes no express or implied representations or warranties regarding its professional business services in crew and ship management.

Please read the following Privacy Policy carefully, as it explains what data may be collected via this website www.askoldas.info, or that you provide voluntarily to the company, and how it may be used/processed, respecting the privacy of all website visitors and any personal data. By submitting any personal data via this website, you agree to its possible use, processing and storing, as explained hereafter in this Privacy Policy. The Sofia shipping website may include, however, links to other third party and external websites which are not covered by this privacy statement.

For more information regarding any legalities, unlawful copyright and misuse of information on the Sofia shipping website.If anything is unclear or for further information regarding this Privacy Policy, please contact the Sofia shipping Data Protection Officer directly:

JSC “Sofia shipping”

Malunininkustreet 3, 3^rd floor.

Klaipeda

Lithuania

LT92264

1. INFORMATION WE COLLECT & PRIVACY OF DATAGENERALLY ON THIS WEBSITE & DURING THE RECRUITMENT / EMPLOYMENT PROCESS

JSC “Sofia shipping”("We") appreciate your interest and visit to our website and would like to explain what data we collect, how and why, and to emphasise the importance we place on your privacy so you may feel comfortable in using this website and when submitting an application for employment. For the purposes of the General Data Protection Regulation (GDPR), we are the data controller.

Company-wide, we are committed to protecting and respecting your privacy in the processing of your personal data. We pay special consideration to this matter, both with regards to processing data collected or provided via this website, or that you provide voluntarily to the company, as well as generally in the context of business processes as per our Corporate Data Protection and Maritime industry-specific policies. Any and all specific personal data collected via this website, or that you provide voluntarily to the company, is done so as seen and voluntarily by you as the user, for instance in the context of a job application or general business enquiry. The type of data collected may then be held by us on paper and electronically.

1. GENERALLY ON THIS WEBSITE

This website collects only basic data for a few specific purposes, including:

• Processing unsolicited job applications for careers at sea
• Subscribing (opt-in) to the newsletter database, done so only with an email address
• General enquiries with regards to our crew and ship management services
• General enquiries from suppliers, partners, sponsorships, media and other interests, and
• Standard statistical information on user website activity for analytical purposes to help enhance content and the overall user experience on this website.

Other than for subscription to the official “Sofia shipping” Newsletter, which in itself only requires an email address, and the basic data initially collected during the “Jobs at Sea” application process, all other enquiries that are submitted via the website’s forms are not actually stored on the website or its servers as such, but rather sent securely by email over Simple Mail Transfer Protocol (SMTP) to the relevant recipient.

                DURING THE RECRUITMENT / EMPLOYMENT PROCESS

More specifically to the recruitment process, the “Sofia shipping” Careers “Jobs at Sea” section requires you to initially provide essential personal data in order to submit an unsolicited job application, including your name, email, rank/job position, preferred recruitment centre/location, and a survey on how you heard about our Company. This data is necessary in order to allow us to process the enquiry for its intended use, i.e. jobs at sea, whilst meeting our legal obligations as a maritime employer to identify, qualify and administer the recruitment process. Subsequently, some of this data, basically rank, recruitment location and the survey on how you heard about our Company is also used for internal analytical purposes to help improve our services as a seafarer recruitment company and manning agency, and more generally as a crew and ship manager, as well as to enhance the overall user experience on this website.

To complete an application of interest for a job at sea, you must also upload your CV/Resume. However, the website DOES NOT actually log or store the CV or any information within, but rather sends it securely, together with all other necessary details, by email over Simple Mail Transfer Protocol (SMTP) to the relevant recruitment team to be actioned accordingly.

In turn, or even at the same time, we also specifically request that you complete the “Data Processing Consent Form” providing explicit consent for the Company to collect, hold, process, store, transfer, and use personal information, including any special category of personal information as relevant, required and appropriate for employment requests and that you have read and agreed to these terms before any further processing of your application can take place. After which, your application may proceed through the recruitment process and in turn be recorded in the Company's database system. It is important to note that WE WILL NOT HOLD, PROCESS, STORE or TRANSFER any of your personal data until we receive your written consent via this form. This applies to all applications of employment received regardless of the source.

                USES OF PERSONAL INFORMATION

Any personal data collected via this website, or that you provide voluntarily to the company, are processed only by authorized Company personnel and agents for the very purpose for which you have provided them, legitimately, and according to the legal provisions valid for the jurisdiction in which the website is maintained and/or the nature of the enquiry.

The ways we may use information collected from this website include:

• Processing an unsolicited request for a job application at sea
• Sending out an email to notify the release of our official Company newsletter
• Providing more information about our Company and its services in crew and ship management, or as per the specific enquiry
• Providing access to the company’s online portals, such as the Crew Portal and Client Access areas, and
• Administering our website and its recruitment process for internal operations, such as testing and troubleshooting, statistical and data analysis, and research purposes in order to improve our website with regards to content, processes and overall user experience.

                TRANSFERRING PERSONAL DATA TO A COUNTRY OUTSIDE THE EU

As an international crew and ship management company, we may transfer certain personal data that we collect via this website, or that you provide voluntarily to the company, on European Union (“EU”) and non-EU data subjects to a country outside the EU, as needed for the specific enquiry and standard business operations, as well as for adhering to local legal requirements. For example, if a user is seeking employment and is based in the Ukraine then our office in the Ukraine should handle this enquiry. As such, personal data that we collect via this website and hold might also be processed by our employees operating outside the EU, who work for us or for one of our suppliers. These members of staff may be engaged in, for instance, the recruitment process, fulfillment of contracts and administration purposes with you the data subject, provision of support services, training, and procurement, among other.

                SECURITY AND SAFETY OF DATA AND ITS STORAGE

Despite only collecting and storing minimal and basic personal data on this website (as explained above), we make every effort to put in place suitable precautions to safeguard its security and privacy, and to prevent it from being altered, corrupted, destroyed or accessed by unauthorized parties. The same tight controls and best practices are true for any data processed beyond this website and on our Company’s internal networks.

Please be aware that this website may include links to other external websites or other Internet sources, including social media platforms and third party websites. Since we cannot control these websites and external sources, the Company cannot be held responsible for the provision or display of these websites and external sources, and may not be held liable for the content, advertising, products, services, or any other material available on or from these websites or external sources, nor their collection and processing of any personal data. However, every effort has been made to vet these external websites and sources at the time of providing any outgoing link from our own website.

With regards to the security and safety of data and its storage, “Sofia shipping” assures:

• To take appropriate security measures against unlawful or unauthorized processing of personal data, and against the accidental loss of, or damage to, personal data.
• It will be processed lawfully with your consent for the specific purpose it is required and will not be kept for longer than is legally necessary. We will only process any special category of personal information relating to you for legal, personnel, administrative and management purposes and to enable us to meet our legal obligations as a maritime employer and crew and ship manager.
• It will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction or erasure. Personal data will only be transferred to a data processor if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves.
• It will maintain data security by protecting the confidentiality, integrity and availability of the personal data.

                LIMITATION ON STORAGE

We will not keep personal data active longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable actions to destroy, or erase all data from our website and other systems which is no longer required.

With regards to data that is processed beyond this website, we will retain our Employees records for a period of 7 years. And where information on applications from prospective employees are concerned, we will retain these for a period of 12 months. After this time, the information will be encrypted and archived securely.

                DISCLOSURE OF INFORMATION

You are always voluntarily providing specific personal detail via this website or indeed to our Company directly over email. In order to fulfill our obligations to respond and action to such enquiries, information must be passed on to the relevant Company department/personnel or authorized agency.

As such, by submitting any information via this website or directly over email, you agree that we have the right to share this information you have provided in order to properly respond and action the enquiry with:

• Any member of “Sofia shipping”, including international subsidiaries, and
• Selected authorized third parties including business partners/agencies, suppliers and sub-contractors

                COMPULSORY DISCLOSURE OF INFORMATION

We will only disclose any information if we are under a duty to disclose or share in order to comply with any legal obligation and other agreements; or to protect the rights, property, or safety of “Sofia shipping”, our customers, or others. This might include exchanging information with other companies and organizations for the purposes of criminal investigation, fraud protection and credit risk reduction.

“Sofia shipping” may be compelled to disclose a certain amount of information in relation to you under local governing law, or court orders or on receipt of legal notices to produce documents/information.

                FREEDOM OF INFORMATION / YOUR RIGHTS UNDER THE GDPR

Under the EU’s GDPR, you have the right to access information/data held about you, and the right to correct, amend, delete, and object to further processing.

Your right of access can be exercised in accordance with the GDPR. Any access request will be free of charge, although multiple copies will be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you. We will endeavour to provide you with the personal data in the same machine-readable format and will make it capable of porting to a third party data controller, only if it is technically feasible to do so.

You should also notify us if any of your personal details change or if you are aware of any inaccuracies so that this can be corrected.

Once you’re written consent has been obtained (as described in point 2.2) your personal data is stored electronically in our database. You can access the personal data we have on file and submit requests to rectify and delete data. Such requests should be made in writing to the Company’s Data Protection Officer:

JSC “Sofia shipping”

Malunininkustreet 3, 3^rd floor.

Klaipeda

Lithuania

LT92264

                PERSONAL DATA – FAMILY MEMBERS / MINORS

In order to meet our statutory obligations as employers the personal data of family members may be required. For example, in order to execute the payment of allotments and insurance benefits to individuals nominated by the employee (seafarer). We will not process, store, transfer, transmit and use any personal data until we have received written consent from the nominated individual.

Persons under the age of 14 are considered to be minors. In such cases the appointed legal guardian / parent should provide consent on their behalf.

If you believe that we may have collected personal information from someone under the applicable age without the proper consent, please inform us at This email address is being protected from spambots. You need JavaScript enabled to view it. and we shall take appropriate measures to investigate and address the issue promptly.

The individual’s rights as described in point 9 are applicable to all family members whose data we have on file.

                AUTOMATIC COLLECTION OF NON-PERSONAL DATA – WEBSITE TRAFFIC TRENDS

In order to better understand user behavior and in turn enhance the user experience on our website, the “Sofia shipping” web server automatically (i.e. not by registration) collects and records basic statistical information on website activity, such as number of users who visit the website, date, time and length of visits, which pages are viewed, general location of the user, the link of the website in which the user visited from, type of Internet browser being used, type of device being used to access the website, among other general web browsing statistical information. However, such statistics are not always collected accurately, as many Internet technologies can now be used or set to prevent or manipulate information being shared.

Collection of such information on website traffic trends is standard and commonly practiced on websites throughout the Internet. This information does not identify individuals as such, but rather provides device and IP related statistics. This information is then used solely by authorized“Sofia shipping”personnel and/or the official “Sofia shipping”Web Master to observer and analyze such website traffic trends.

Various data that may be observed through the website traffic analytics includes:

• Standard machine identity details (used to access the website), as is normal and necessary when a user interacts with a website and its server; and
• Data on the nature of a user's visit to the site, including server address, user's upper domain category and thereby origin, date and time of the visit, path taken to the “Sofia shipping” website (i.e. through a search engine, social media channel, hyperlink from at another third party website), the various pages accessed on the website, exit pages and exit links, publications downloaded, as well as sometimes searched words or terminology performed to find the website through a search engine (generally these now tend to be encrypted/incognito by search engines).

                PRIVACY POLICY REVISION

“Sofia shipping” reserves the right to modify, alter, or update this website’s Privacy Policy at any time. As the user, you agree to be bound by such changes, and to its current relevancy, as presented on this website at any given time.

If you have any questions regarding the processing of your personal data or more generally about this Privacy Policy, please contact the “Sofia shipping” Data Protection Officer

‘You have a right to complain to the Lithuanian Supervisory Authority if you believe that there is a problem with the way we are handling your data.’

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