Privacy Notice

Wallem Agency China - Privacy Notice for Service Users, Customers, Partners and Suppliers

1.INTRODUCTION

Wallem Group ("Wallem"), including its associated body corporates, respect your concerns about privacy. This Privacy Notice describes how we use your personal information and the types of personal information (i.e. personal data) we collect about our service users, customers, partner and suppliers. The notice also describes the measures we take to safeguard the personal information. In addition, we tell you how you can:

  • access or change the personal information we maintain about you.
  • withdraw consent you previously provided to us.
  • opt out from receiving marketing communication.
  • obtain information from us about our privacy practices.

This Privacy Notice applies to all kinds of personal information collection and processing activities undertaken or authorised by Wallem (except for issues relating to employee's personal information for which please refer to CP-Group-013) including collection through our various platforms or other means connected to these platforms (such as email, websites, social media and IT platforms).

We reserve the right to update this Privacy Notice so to ensure our compliance with the applicable data protection and privacy laws. Please review this Privacy Notice from time to time for any amendments.

2.WHO WE ARE AND WHAT WE DO

Wallem operates globally and having offices and/or associated body corporates in different countries within and outside the European Union. On the date of this Privacy Notice, our corporate headquarters is based in Hong Kong.

We offer services to support the complete lifecycle of a vessel from newbuilding supervision to end-of-life recycling guidance. Our extensive portfolio includes technical management, crewing, training, ship agency, commercial services, procurement and lifeboat safety solutions. We leverage our in-house expertise and therefore may transfer the personal information we collect to our other offices and/or associated companies in different countries so to enhance the efficiency of our operations. We may also use third parties in the course of our provision of services to our customers and data users and in the course of our managing the internal affairs of Wallem, our offices and associated body corporates.

3.HOW AND WHAT INFORMATION WE OBTAIN

Apart from our websites ("Websites"), we also have accounts in different social medias such as LinkedIn, Twitter, Instagram and Facebook. We may obtain personal information directly from you, indirectly from our customers or business partner(s), indirectly via public channel(s) and indirectly via our Websites. Obtaining personal information directly means, whatever channel it may be, situations where we request you directly to provide us your personal information. In most of the time, we only obtain personal information directly from you or indirectly from our customers or business partner(s) except for our using of "cookies" as further explained in Section 14 of this Privacy Notice.

We may obtain personal information about various activities such as:

  • use of the Wallem’s Websites and applications.
  • shipping activities, including delivery and pick-up of shipments and arrangement of supports for the cruise passengers and seafarers of our customers.
  • requests to track shipments or answer questions.
  • events in which we participate.
  • marketing, promotions and other offers.

Where we collect personal information directly from you, we will explain to you how that personal information is to be used.

The types of personal information we may obtain include:

  • Individual and business contact information including job applicants (such as name, company name, physical address, email address and telephone or fax number).
  • Shipping information – such as:
    • shipping-related contact details like the shipper’s, and consignee’s name, physical address, email address and telephone number.
    • signature for proof of delivery.
    • information given to us that helps us access locations to which we provide services and information provided to us regarding the content of certain shipments, but only to the extent an identifiable person can be linked to such content.
  • Information that enables us to verify an individual’s identity.
  • Information provided in response to surveys.
  • Username, password and other credentials used to access Wallem’s services.
  • Social media handles, content and other data posted on our official social media pages or elsewhere on the internet (such as other public locations), and information (such as email address and other information you allow to be shared) we obtain through Wallem related social media.
  • Other personal information that may be provided to us to obtain a Wallem service.
  • Cruise passengers’ and seafarers’ information such as their passports, identification documents and health and other medical records.

Observed data about your online usage

When visiting the Websites, observed data about your online usage would be collected. The data is collected using cookies and other similar technologies. Such data may include:

  • Webpages visited by the user
  • Other websites the user accessed via our Website(s)
  • The device model
  • The channel through which the service is accessed (web browser, mobile browser, application, etc.)
  • Browser version
  • Operating System
  • IP address
  • Session identifier
  • Session time and duration
  • Geographical location data
  • Date and time
  • Screen resolution
  • Clicks, scrolling, etc.
4.HOW WE USE THE PERSONAL INFORMATION WE OBTAIN

The personal information we obtain will be used only for the purposes specified in this Privacy Notice provided there is a legal basis under the General Data Protection Regulation (“GDPR”) or otherwise notified to you.

We may use the personal information we obtain where:

  • you use Wallem’s Websites and other social media accounts, for examples, enabling you to post on our blogs and interact with Wallem through social media.
  • you subscribe our service(s), publication(s) and/or update(s).
  • instruction is received from you (whether directly or through our business partner) to deal with shipping activities, such as delivery, tracking and picking-up of shipment.
  • you request us to process and collect payment(s).
  • we answer your enquiry or respond any message left by you.
  • marketing, promotions and other offers are opted by you.
  • you request us to establish and manage your Wallem account(s) in our system(s).
  • we communicate about, and administer your participation in, special events, programmes, surveys, contests, and other offers or promotions.
  • we process claims received from you about our services.
  • there is a need to protect against, identify and prevent fraud and other criminal activity, claims and other liabilities.
  • we are pursuing any legitimate interest(s).
  • we comply with applicable legal requirements and our policies.
  • we process your application for a job in Wallem when you apply it through our job vacancies page or other recruitment agent (including to conduct background checks and employer references).
  • It is necessary for protecting the vital interests of you or another natural person.

In addition, we use personal information collected online through cookies, web beacons and other automated means for purposes such as:

  • customising our users’ visits to our Websites.
  • improve our Websites and website user experience, i.e.
  • delivering content (including advertising) tailored to our users’ interests and the way our users browse our Websites.
  • managing our business.
5.LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
  • Fulfilling contractual relations between you and Wallem.
  • Legitimate interest of Wallem (observing your website usage in order to ensure an efficient and secure use of our Websites, to develop our services, to provide customised content to make our services more relevant to you, to comply with any court order or to prevent fraud or other crime, to correspond with you for any enquiry or message you have left on or via our Website(s) and to collect statistics).
  • Your consent - your consent will be asked in relation to using website cookies, processing your personal data other than for the purpose originally collected and contacting you in relation to subscriptions and registrations or providing you commercial or marketing information. You will find additional information on how cookies are used in this Privacy Notice.
6.INFORMATION SHARE

At Wallem we handle your personal data only according to the defined purposes of processing or otherwise notified to you. We do not sell or otherwise share personal information about you, except there is a legal basis so to do under both GDPR and the local legislation.

Personal data can be disclosed to the following third parties:

  • Internal third parties – associated body corporates in the Wallem Group.
  • External third parties:
    • To perform our pick-up and delivery services, we share shipping information with third parties such as freight forwarder, shippers, consignees and third party payers.
    • We also share personal information with third parties (e.g. service providers) as data processors. These third parties are not authorised by us to use or disclose the personal information except for performing services on our behalf and in accordance with our documented instructions. For examples, web analytics services, providers of marketing automation services, providers of outsourced IT and document storage providers; consultants and other service providers to enable the performance of services for us.

In some cases, the recipients of personal data may be located outside of EU/EEA, in which case we will ensure that the measures as set out in Section 9 of this Privacy Notice shall apply.

We also may disclose personal information about you:

  • if we are required to do so by law, regulation or legal process (such as a court order).
  • in response to requests by government agencies, such as law enforcement authorities.
  • when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or about an investigation of suspected or actual illegal activity. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation).
7.MARKETING AND OPTING OUT

You will receive marketing communications from us if you have requested us so to do. You can ask us to stop sending you marketing messages at any time over the phone or via email by saying 'I do not wish to receive further marketing calls from your company'.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a solution or service purchased, and will not affect continuous business relations, etc.

8.ACCESS AND CORRECTION

Subject to applicable law:

  • you may obtain a copy of certain personal information we maintain about you or update or correct inaccuracies in that information through contacting our data protection team (see Section 16 of this Privacy Notice).
  • you may have the right to obtain access to personal information we maintain about you by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us.
9.DATA TRANSFER

We may transfer the personal information we collect about you to countries other than the country in which the personal information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.

Before transferring your personal information to other countries, we will ensure that the same level of protection as required under GDPR shall be in place until your personal information is either returned to us or securely deleted. We will also use contractual protections for the transfer of personal information among various jurisdictions (including, for example, the European Commission's standard contractual clauses).

10.DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally or unlawfully erased, altered, disclosed, used or accessed. In addition, we authorize access to your personal data only to those employees, agents and contractors and other third parties who have a business need to know (for example, Marketing department will utilize your data to send out marketing materials you opted in to receive). They will only process your personal data on our instructions, and they are subject to duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11.STORING PERSONAL DATA

We handle your personal data that you have provided to us separately from observed data about online service use (for example, details you provided to us when subscribing to the online Wallem magazine) and derived data, in separate databases. Observed or derived data about service usage is always stored in a way that users cannot be personally identified from the identifiers as the identifiers are generated randomly.

Your personal data is stored as long as necessary in relation to the purposes for which the personal data was collected, unless there is a legal obligation to retain the personal data longer (e.g. in case of an ongoing legal proceeding).

If you object to further contact from us, we will keep some basic information about you in order to avoid sending you unwanted communications in the future.

12.ANALYTICS SERVICES

Wallem uses the services of Google Analytics, a web analytics service provided by Google Inc. Data collected by cookies about your use of our Websites, solutions and services, including your IP address, will be transmitted to and stored by Google on behalf of Wallem. We use such analytics services for the purpose of evaluating website performance, usage, and providing other services relating to website activities and internet usage.

According to Google, they will in no event connect your IP address with other of Google's data.

To prevent your data from being used by Google Analytics, you can opt out by following the instructions provided here https://tools.google.com/dlpage/gaoptout

13.THIRD PARTY SERVICES

We use third-party services to display online advertisements on behalf of Wallem across the internet. These service providers may use cookies to collect information about your visits to our Websites in order to display ads while you are visiting other Websites. This information cannot be used to identify you individually, the information is anonymous, however your IP address may be collected.

Our Websites may contain links to other websites and 'share' and/or 'like' buttons, such as Twitter, Facebook, and other social media platforms, that are not operating on Wallem's behalf. Such websites, service or application providers may place their own third-party cookies on users' computers and other devices, collect data, or solicit personal information.

Issuers of such third-party cookies have their own privacy policies. You should refer to any privacy policies from such websites, service or application providers to better understand how your information may be collected and used.

14.COOKIES

A "cookie" is a text file that websites send to a visitor's computer or other internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser.

When you visit our Websites, cookies that contain information used to track your usage of our Websites are stored on your device, provided that you have accepted the use of cookies in your browser. This enables our systems to recognise your browser and tell us how, when and which pages in our Websites are visited and by how many people, and also enables us to recognise a return visitor as a unique user. Cookies placed by the Websites cannot access, read or modify any other data on your device.

We use the following cookies on our Websites:

System cookies

The content managements system (CMS) used to maintain our Websites is called WordPress. WordPress uses cookies necessary for the operation of our Websites. For a full list, please see https://wordpress.org/about/privacy/cookies/

Analytical cookies

We use website analytics for the purpose of evaluating usage, count the number of visitors and see how visitors navigate on our Websites when using them. More information about how Google Analytics use cookies can be found at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Targeting cookies

These cookies record your visit to our Websites, the pages you have visited and the links you have followed. We will use this information to make our Websites and the content displayed on it more relevant to your interests.

Electronic marketing

If you have a professional relationship with us or have given your consent to receive marketing messages from Wallem, we may use your e-mail address to send you electronic marketing information.

How do you disable cookies?

You can control the use of cookies when you visit our Websites. You can block the use of cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Websites, or fully access the services or their features. Read more about disabling cookies in your browser.

Please note that if you have consented to the usage of cookies, you can withdraw your consent at any time by clearing your browser's data.Read more about clearing your browser's data here.

15.YOUR RIGHTS

Under certain circumstances, you have the following rights:

  • the right to check what kind of personal data has been collected about you and how we use your personal information;
  • the right to have your personal information rectified or erased;
  • the right to restrict the processing of your personal data or when the processing is based on our legitimate interests, to object the processing on grounds relating to your particular situation;
  • the right to request your personal data to be provided in a structured, commonly used and machine-readable format and your personal data to be transferred to another data controller, when technically feasible;
  • the right to withdraw your consent given to us for the processing of your personal data at any time;
  • the right to object to the processing of your personal data at any time;
  • the right to prevent your personal information from being used for direct marketing purposes. You can opt out from receiving marketing materials from us at any time;
  • the right to lodge a complaint with a competent supervisory authority, if you consider that the processing of your personal data infringes any applicable data protection and privacy law.
  • Wallem has nominated Die Hamburgische Datenschutzbeauftrage as our lead supervisory authority.
       Ludwig-Erhard-Str 22, 7. OG
       20459 Hamburg, Germany
       Phone.: 0049 40 / 428 54 – 4040
       Fax: 0049 40 / 428 54 – 4000
       E-Mail: mailbox@datenschutz.hamburg.de
       https://datenschutz-hamburg.de

We would however appreciate the chance to deal with your concern before you approach them, so please contact us in the first instance.

16.CONTACTING WALLEM

We have appointed a data protection team which is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions regarding this Privacy Notice or the use of your personal data, please contact the data protection team using the details set out below:

       Full legal entity name: Wallem Group Limited
       Postal address: 9/F Dorset House, Taikoo Place, 979 King's Road, Quarry Bay Hong Kong
       Data Protection Team email: wallemdpt@wallem.com
       Data Protection Representative:
       Alfred Siu
       Phone: + 852 2876 8042
       E-mail: ALFR@wallem.com