Hubel Marine B.V. processes personal data of our (prospective) clients from various sources, either provided by you as data subject, at our request or at your own initiative, obtained in the execution of our services, provided by third parties, or obtained through public sources (such as the trade registry). Hubel Marine respects your privacy and finds it important to protect your personal data.
This policy describes, among others, what information we process and for what purpose.
This policy is issued to comply with EU regulations on General Protection of Data Regulation (“GDPR”) in force since 25 May 2018
I Categories of Data and Purpose/Objectives of processing
At Hubel Marine we process the following 3 categories of personal data:
Basic personal data, such as name and title; Contact details such as e-mail address, postal address, phone number; Data from devices our website is visited with (such as IP-address); data about the visit to our website.
We process this data, as well as all other personal data provided by you or obtained by us for purposes of performing our services, collect payment on our invoices, to abide by any statutory obligation, for commercial and marketing objectives, as well as to engage in and maintain a relationship with you and to improve our services.
Personal data provided in support of vessel registration documents or incorporation documents. Hubel Marine B.V. provides, among others, vessel registration services which requires, dependent on the registration flag state, submission of for example, copies of identification documents and evidence of residential address. Hubel Marine B.V. will not request more personal data than required to provide the agreed services, including the legalization of documents. The information is limited to what is required to perform the service requested
Personal data required for submitting a request for the issuance of Seafarer endorsement(s) by a flag state. This information can concern: Passport copies, Passport Photograph, medical health certificates, evidence of sea services and copies of job specific training.
The information requested by Hubel Marine shall be limited to the requirements of International conventions such as STCW and national requirement of the flag state. The information is only used with the objective of the issuance of Seafarer Endorsements.
The personal data mentioned above in categories B and C is required for the performance of the registration and endorsement services provided by Hubel Marine.
The personal data mentioned above in categories A, B and C are exclusively processed based on the following grounds within the meaning of Clause 6 GDPR:
- Performance of an agreement;
- To comply with statutory legal obligations;
- Our legitimate interests;
- Your consent.
II Sharing of Data
Hubel Marine B.V. may, when required, share your personal data with third parties if such is required for the performance of the service and for the above mentioned purposes. For example:
- Kitts & Nevis Ship registry www.stkittsnevisregistry.net (located within the EU)
- Third party suppliers for the processing of your personal data (such as IT suppliers, accountant).
- Law firms in various EU countries providing ship registration services for the ship registries of these nations
The nature of the agreed services provided by Hubel Marine require Hubel Marine to share and transfer Personal data with third parties outside of the EU/EEA. These parties are either foreign governmental bodies or commercial organizations such as law firm/trust companies that uphold strict privacy policies which are comparable to EU requirements. These third parties can be:
- Belize ship registry immarbe.com
- Panama ship registry amp.gob.pa and segumar.com
- Liberia ship registry liscr.com
- as well as third party commercial organizations such as law firms.
The European Commission has not issued adequacy decisions for the states in which the above mentioned organizations are established. Hubel Marine shall therefore refrain from transferring any personal data to third parties outside of the EU/EEA, unless it is strictly required in order for Hubel Marine to be able to provide the agreed services, or unless Hubel Marine has your (the data subject’s) explicit consent.
In the event a third party as mentioned above qualifies as a data controller under the GDPR and as such provides services for the (further) processing of your personal data, that third party is responsible for compliance with GDPR.
Hubel Marine has data processor agreements in place with third party processors for the event that these are processing any of your personal data.
III Retention of Data
We do not process more data than is necessary for the objectives specified above, neither do we keep your personal data longer than necessary for the specified objectives, and/or based on legal obligations.
Hubel Marine B.V. protects your personal data and has implemented the appropriate technical and organizational measures to ensure an appropriate level of security, taking into account the state of the art.
V Your Privacy Rights
You are entitled to the following rights without payment:
- the right of access to your personal data and the processing thereof;
- Rectification of your personal data if and when these are incorrect or incomplete, or erasure or deletion of your personal date from Hubel Marine files and databases; If your request for rectification or erasure concerns personal data in category B or C stored in flag state databases we will forward the request for removal. The actual removal is subject to retention requirements under international conventions and national law;
- the right to object against the processing or to request a restriction of processing and the right to refuse to provide personal data or withdraw the right of use of your personal data. Please note that the exercise of these rights may cause Hubel Marine b.v. to be unable to provide/complete the requested service;
- the right to data portability;
- Request Hubel Marine B.V. to share the information with another entity;
- the right to lodge complaints with Hubel Marine B.V. or national or international institutions for the protection of privacy;
Please note that there may be circumstances in which Hubel Marine may (wholly or partially) refuse a request to exercise the abovementioned rights. For example if granting such request compromises any legal retention time or if granting a request compromises a third party’s personal data protection rights.
You can exercise these rights by contacting Hubel Marine B.V. using the contact information provided below
VI Social Media and external links
Our website includes links to external websites or social media such as LinkedIn, Facebook, Twitter, Instagram, YouTube and Skype. These external links and social media services are not supervised by Hubel Marine and Hubel Marine is not responsible for the processing of your personal data through and by such third parties. The use of such websites and social media is therefore at your own risk. We recommend that you read the privacy policies of these websites and social media carefully so that you are aware of what may happen to your data.
VII Contact information
Hubel Marine B.V.
Karel Doormanweg 5
3115 JD, Schiedam
T +31 10 4587338