We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the EU General Data Protection Regulation (EU GDPR) and the local applicable legislation.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | IYC |
| Our data protection officer | Iacovos Kouppas |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation Criminal Records |
| Data subject | The individual who the personal data relates to |
Personal data we collect about you
The personal data we collect about you depends on the particular services we provide to you. We will collect and use the following personal data about you:
- your name, address and contact information, including email address and telephone number
- information to check and verify your identity, such as passport details, national ID, resident card etc.
- distinguishing marks, colour of hair, colour of eyes and height
- your gender
- marital status and number of dependent children
- next of kin information and contact details
- your banking information,
- your personal or professional interests
- information from accounts you link to us,
- information to enable us to undertake criminal or other background checks on you
- CoC licenses and Seafarer certificates
- medical certificates and medical information
- employment information
and any other personal information that might be necessary for the required services we provide to you or the vessel you are joining We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from onboarding you.
How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:
- from publicly accessible sources,
- directly from a third party, eg:
- sanctions screening providers;
- credit reference agencies;
- background check agencies,
- from cookies on our website—for more information on our use of cookies, please see our cookie policy here
- via our IT systems, eg:
- through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
- through MyIYC.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract and setting up your IYC crew profile; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests[, to balance our interests against your own].
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Onboarding you as a crew member on a vessel | To create your Crew Profile in our data base as well as take other necesarry steps and actions (as applicable) such as: employmnet and payroll arrangements; insurance, legal and professional arrangements etc. |
| Preventing and detecting fraud against you or us | For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us |
Conducting checks to identify crew members and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules | Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect our business, interests and rights |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests, ie to make sure we are following our own internal procedures |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances: —for our legitimate interests, ie to protect trade secrets and other commercially valuable information; —to comply with our legal and regulatory obligations |
| Preventing unauthorised access and modifications to systems | Depending on the circumstances: —for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us; —to comply with our legal and regulatory obligations |
| Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Updating and enhancing records | Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract; —to comply with legal and regulatory obligations; —for our legitimate interests, eg making sure that we can keep in touch |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | Depending on the circumstances: —to comply with our legal and regulatory obligations; —for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. | For our legitimate interests, ie to promote our business to existing and former customers |
| External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above | Depending on the circumstances: —for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards; —to comply with our legal and regulatory obligations |
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out in the table below.
| Purpose | Processing operation | Lawful basis relied on under and EU GDPR | Relevant categories of personal data |
|---|---|---|---|
| Communications with you not related to marketing, including changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Addressing and sending communications to you as required by data protection laws, ie: the EU GDPR | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | —your name, address and contact information, including email address and telephone number; —your account details (username) |
| Addressing and sending communications to you as required by the applicable legislation | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | —your name, address and contact information, including email address and telephone number; —your account details (username) | |
| Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | —your name, address and contact information, including email address and telephone number [and company details] —your account details (username) |
How and why we use your personal data—Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
- personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership;
- genetic data;
- biometric data (when used to uniquely identify an individual);
- data concerning health, sex life or sexual orientation.
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post).
Who we share your personal data with
We routinely share personal data with:
- companies within the IYC group
- third parties we use to help deliver services to you, eg payroll companies, travel agencies, background check agencies, insurers, brokers etc.;
- other third parties we use to help us run our business, eg marketing agencies or website hosts;
- our bank[s];
- Maritime schools/authotiries/course centres
- Flag authorities
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
- our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the and EEA’.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data. Further details on this are available upon request to [email protected]
If you no longer have an account with us or we are no longer providing services to you, we will usually delete or anonymise your account data after seven years from the termination of our relationship.
Following the end of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the EEA
It is sometimes necessary for us to transfer your personal data to countries outside the EEA. In those cases we will comply with applicable and EEA laws designed to ensure the privacy of your personal data.
We will transfer your personal data to:
- our service providers located outside the EEA; and
Under data protection laws, we can only transfer your personal data to a country outside the EEA where:
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the EEA, we do so on the basis of an adequacy regulation. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by the loacl data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object | The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
| The right to withdraw consent | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consent by [insert details as relevant depending on consents] Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below).
If you would like to exercise any of those rights, please:
- email [email protected], call or write to us—see below: ‘How to contact us’; and
- provide enough information to identify yourself (eg your full name, address and customer or matter reference number)] and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the Hellenic Data Protection Authority (www.dpa.gr) and/or the relevant supervisory authority in your jurisdiction. For more information, please contact us if you would like further information.
Changes to this privacy policy
This privacy notice was published on December 2024 and last updated on December 2024.
We may change this privacy notice from time to time—when we do we will include a summary of changes. Please check this page regularly for any changes
e, eg our website or other means of contact such as email].Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address—You can update your personal data by contacting IYC Crew Manager in change of the vessel you are joining/you are employed on.
How to contact us
You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
| Our Data Protection Officer's contact details |
|---|
Iacovos Kouppas |
Do you need extra help?
[If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).]