Salén Ship Management AB, a legal entity incorporated in Sweden with company registration number 556783-1689, Östra Hamngatan 52, 411 09 Göteborg (below referred to as “Salén”), processes personal data in accordance with law, including the General Data Protection Regulation.

The type of personal data that Salén processes

Salén will process personal data submitted by you to Salén as well as personal data that Salén will collect from you.

When you contact Salén, by phone, e-mail, letter or the web page contact form, or as a contact person for your organization, Salén will process the personal data you have provided us with. Personal data that you provide us with or we collect about you and process may, for example, consist of first and last name, title or role, address, e-mail address, telephone number, status of your relationship with Salén and a copy of your passport.

Salén may also process personal data regarding your health that you or our partners provide us with, and that we collect about you if you have suffered injury, sickness or other health issues onboard vessels managed by us.

Salén will only process your personal data in accordance with this Integrity Policy and applicable laws and regulations. In order for us to manage the vessels you need to provide us with contact details, as the ones explained above. Apart from that, it is voluntary to provide your personal data.

Personal data included in communication

Salén may receive e-mails containing personal data about third persons and therefore process such personal data. If required, Salén will inform you as a third person of the processing separately.

What are the purposes of the processing and what is the legal basis for the processing?

It is important that you understand the purpose why Salén process your personal data and the legal basis that Salén will be using for processing it.

Contracts between your organization and Salén

For the purpose of being able to fulfill Salén’s commitment to you as a valued customer or supplier when managing the vessels, Salén must process your first and last name, title or role, address, e-mail address, telephone number and status of your relationship with Salén.

The legal basis for Salén’s processing of your personal data is that the processing is necessary for the performance of a contract or to take steps to enter that contract. If you have contact with Salén as a representative for your organization, Salén will process your personal data mentioned above in order to be able to fulfil the company’s commitment to your organization. The legal basis for Salén’s processing of your personal data is that the processing is necessary for the purpose of a legitimate interest which is not overridden by your interests, rights or freedoms. Salén’s interest in processing your personal data for the purpose of communicating with a representative for its business partner overrides your potential interest in protecting your personal privacy.

Health

If you have suffered an injury, sickness or other health issues onboard, we will process personal data including sensitive data that you or our partners provide us with or that we collect about you. We may also share this personal data with our insurers and health care facilities. The legal basis for the processing is consent or protection of your vital interests if you are not physically or legally capable of giving your consent, or a balance of interest. Salén must process your personal data in order to assist you and this interest overrides your potential interest in protecting your personal privacy. The supplementary legal basis for the processing of your sensitive data is that the processing is necessary for the establishment, exercise or defense of legal claims or for medical diagnosis and the provision of health care or treatment.

Security

In order for you to board one of our vessels, we will obtain a copy of your passport from you and submit it to the relevant port authority. The legal basis for Salén’s processing is that it is a legal obligation.

Accounting legislation

Salén will process information about economical transactions between Salén and your organization for accounting purposes. Salén is required by accounting legislation to keep records of certain personal data. In light hereof, Salén will process your first and last name, title or role, address, e-mail address and telephone number. The legal basis for Salén’s processing is that it is a legal obligation.

Even if one legal base is no longer applicable, Salén may continue processing your personal data to the extent required on other legal basis.

For how long will Salén process the personal data?

Salén will store your personal data for as long as needed for the processing related to the purposes and legal grounds described above. Your personal data can be stored in different locations and for different purposes. In light hereof, personal data which has been deleted from a system, because it is no longer needed, may still exist in another system for a different purpose.

Personal data that Salén process in order to fulfill Salén’s obligations to you, or the organization you represent under a contract or due to a balance of interest, will not be stored longer than it is necessary for Salén to fulfill our contract with you or your organization or for the time during which Salén’s interests overrides yours.

Sensitive personal data will be stored during your treatment and as long as it is necessary for establishment, exercise or defense of legal claims or for the medical diagnosis and provision of health care or treatment or to satisfy any legal requirements

Your passport copy will be stored as long as we have a contract with your employer, and in any event no longer than one year after you have last boarded one of our vessels.

Personal data that Salén process for accounting purposes will, according to applicable accounting legislation, be stored for up to seven years.

Processing by third parties and transfer of personal data

In addition to the processing performed by Salén, your personal data may also be processed by others such as partners that Salén works with in order to provide its services, such as vessel charters and suppliers of goods and services, insurers, health care providers, authorities and regulatory bodies.

Your personal data may also be disclosed to actors who process personal data on Salén’s behalf, so-called processors. Salén has contracts in place that ensures that the processors process your personal data in accordance with this Integrity Policy and Saléns instructions.

Salén may disclose your personal data in order to permit a merger, an acquisition or a sale of all or parts of Salén’s assets.

Your personal data will be disclosed to actors both within and outside of the EU and EEA. Should Salén transfer your data outside of the EU or EEA, Salén will see to that contracts are in place to ensure that such third parties process your personal data in accordance with this Integrity Policy and Salén’s instructions.

Your legal rights

You have the right to free of charge, upon written request to the e-mail address listed below, receive information about what personal data Salén stores about you and how that personal data is used and processed.

If your request is unfounded or your request is excessive, e.g. should you frequently and within short intervals ask to receive information about what personal data Salén stores about you or that Salén shall provide a copy of or remove the personal data in question, Salén has the right to refuse to act on your request, or to charge a reasonable fee which covers the administrative costs of the action requested by you.

Your right to correction and erasure

If your personal data are incorrect or incomplete you have the right to request that we correct or complete such personal data.

You have the right to request that we erase your personal data under certain circumstances. Provided that these circumstances apply we will erase your personal data.

Your right to request restriction

You have under certain circumstances the right to request that the processing of your personal data is restricted. If you have this right, your personal data will only be processed with your consent, for legal claims, in order to protect another person’s right or for reasons related to an important public interest. Your personal data will in addition thereto be stored by us.

Your right to dataportability

You have the right to receive personal data about you that you have provided us with in a structured, commonly used and machine readable format, and have the right to transfer these data to another controller when so is technically possible

Your right to complain

You may also contact Salén if you are unhappy with the way Salén is processing your personal data. You have the right to file a complaint with the supervisory authority regarding Salén’s processing of your personal data or handling of any inquires related to it. The Swedish supervisory authority is Datainspektionen/Integritetskyddsmyndigheten (the Swedish Data Protection Authority will change its name during 2018), www.datainspektionen.se, and it is also the lead supervisory authority for cross border processing carried out by Salén. You should therefore as a main rule file a possible complaint with the Swedish authority.

Salén may change this integrity policy. Such changes will enter into force no earlier than 30 days after Salén informed you of the revised integrity policy on the website http://www.salenship.com/, by letter or other notification by email or text message.