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UPT

General Privacy Notice (Cyprus)

General Privacy Notice (Cyprus)

Introduction

This General Privacy Notice explains what we do with your personal data.

It applies to any data subject 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

UPT United Product Tankers Ltd (UPT)/ UPT United Product Tankers GmbH & Co. KG is the controller for the personal data it processes. You can contact UPT in a number of ways, which are set out below:

UPT United Product Tankers Ltd
Address: Dodekanison 18, 4043, Limassol, Cyprus
Phone: +357 25 346 999
Email: management@uptankers.com

UPT United Product Tankers GmbH & Co. KG
Address: Große Elbstraße 275 22767 Hamburg, Germany
Phone: +49 40 33957-0
Email: management@uptankers.com

Processing Activities

Bank Account Administration

Data Subject

This section applies to the personal data of Employees (Office Staff).

Purpose of Processing

Where you provide us with your personal data, we will process them for bank account administration purposes only.

Categories of personal data

This includes your personal identification details, contact information, and government identifiers only.

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 for the performance of a contract to which the data subject is party.

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 bank account administration, we will not be able to fulfil our contract with you.

Recipients

The only recipients of your personal data will be banks.

International transfers

They are based in the EEA and the United Kingdom. Where they are based in the United Kingdom, 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 1 year following the termination of your employment or 12 years from the collection of your personal data, whichever is earliest.

Communication Management

Data Subject

This section applies to the personal data of Business Partners, Prospective Customers, Customers, Port Agents, Prospective Vendors, and Vendors.

Purpose of Processing

Where you provide us, or where we are provided from our Charterers 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)(b). This allows us to process personal data when it is necessary for the performance of a contract to which the data subject is party, or 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 communication, we will not be able to fulfil our contract with you.

Recipients

The only recipients of your personal data will be Vessels under our management.

International transfers

They are based globally. We rely on GDPR Article 49(1) (c) for cross-border transfers. These transfers are for specific situations where the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the Company as controller and another natural or legal person.

Retention Period

We will store such personal data for a period of 10 years from our last communication with you.

Employee Management

Data Subject

This section applies to the personal data of Employees (Office Staff).

Purpose of Processing

Where you provide us with your personal data, we will process them for employee management purposes only.

Categories of personal data

This includes your personal identification details, contact information, employment information, government identifiers, 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 for the performance of a contract to which the data subject is party.

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 employee management, we will not be able to fulfil our contract with you.

Recipients

There are no recipients of your personal data for these purposes.

Retention Period

We will store certain personal identification details, contact information, and employment information for a period of 1 year from the termination of your employment contract.

We will store certain employment information for a period of 6 years from the termination of your employment contract.

We will store government identifiers for a period of 12 years from the termination of your employment contract.

Employee Recruitment

Data Subject

This section applies to the personal data of Prospective Employees (Office Staff) and Unsuccessful Candidates.

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, 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, we will not be able to fulfil our contract with you.

Recipients

There are no recipients of your personal data for these purposes.

Retention Period

For unsuccessful candidates, we will store such personal data for a period of 1 year after the job application or interview.

For successful candidates, we will store such personal data for a period of 1 year from the termination of employment.

Office Staff Payroll Processing

Data Subject

This section applies to the personal data of Employees (Office Staff).

Purpose of Processing

Where you provide us with your personal data, we will process them for payroll processing and tax reporting purposes only.

Categories of personal data

This includes your personal identification details, contact information, employment information, government identifiers and financial information.

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 for the performance of a contract to which the data subject is party.

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 payroll processing and tax reporting, we will not be able to fulfil our contract with you.

Recipients

The only recipients of your personal data will be our Vendors. They are based in the EEA.

Retention Period

We will store such personal data for a period of 12 years following the termination of employment.

Non-Necessary 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 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.

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 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. 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.

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:

  1. Confirmation that the Company is processing their personal data;
  2. Copy of their personal data;
  3. 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.

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.

Date of last update

13 June 2023