ESVAGT A/S, business registration no. 60698813, Dokvej 4, 6700 Esbjerg, Denmark and each of its subsidiaries (collectively referred to as “ESVAGT”) are committed to handling personal data responsibly and in accordance with applicable data protection legislation.
Unless otherwise informed, ESVAGT A/S is the data controller in relation to the processing activities below.
This privacy policy is intended to provide information on ESVAGT’s processing of personal data collected from users of our website, users of our profiles on social media platforms, contact persons at ESVAGT’s customers, suppliers and other business partners, our shareholders as well as data subjects which are part of a whistleblower reporting (i.e. the senders of notifications, the reported persons and other third parties involved).
We encourage you to read this internal privacy policy to learn more about the ways we collect, use, disclose and protect your personal data.
-
If you visit our websites
Collection of personal data
ESVAGT may collect, process and store personal data about you in the following instances:
- When you visit and browse our websites
- When you communicate with ESVAGT
- When you make use of other functions and services offered by ESVAGT
Types of personal data
ESVAGT may collect, process and store the following personal data about you:
- Name, e-mail address, telephone number and similar identification data
- Company name and company address
- Branch/business area
- Content of inquiries
- IP address
- Information about your usage of our websites
Cookies
We use cookies on our websites. Please read more about the use of cookies in our cookie polices, which are available on ESVAGT’s websites.
Purposes of the processing
Your personal data may be processed for the following purposes:
- Promotional marketing in general
- Completion of requests received from you
- General communication
- Providing support
- Product and service development
- Statistics and analysis
Legal basis
ESVAGT will mainly process your personal data based on one or more of the following legal bases:
- Legitimate interests: In most cases, the processing of your personal data will be based on our legitimate interest in, for instance, conducting statistics, analysis, marketing activities (where consent is not required), providing support as well as improving and developing our products and services (Article 6(1)(f) of the GDPR).
- Consent: ESVAGT will only use your personal data in order to send you marketing material via e-mail if you have provided your prior and explicit consent hereto, unless applicable legislation allows us to contact you without such consent (Article 6(1)(a) of the GDPR).
Retention period
Your personal data will be deleted when it is no longer needed for one or more of the purposes mentioned above.
Personal data relating to statistics and analytics is deleted within 1 year.
The personal data may, however, be processed and stored for a longer period of time if anonymized.
-
If you visit our profiles on social media
ESVAGT and the individual social media are joint data controllers in the processing of your personal data. ESVAGT complies with the guidelines of the European supervisory authorities concerning joint controllership and ESVAGT attempts to ensure that you receive information on the processing of your personal information when you visit our sites on the social medias.
This section applies to ESVAGT’s processing of personal data which you leave behind and/or provide when you visit ESVAGT’s sites on social medias such as Facebook (including Instagram) and LinkedIn (the “social medias”). This section is a supplement to the general internal privacy policy issued by the social medias individually. Both Facebook and LinkedIn have published an addendum on the joint controllership which you may go to by clicking here (Facebook or LinkedIn).
Processing of your personal data through social medias
Depending on your conduct on the social media sites, ESVAGT and the social medias may retrieve the following personal data about you:
- Your “likes” or other reactions expressed on the sites
- Comments left by you on the sites
- Your visits to the sites
Purposes of the processing
Your personal data may be processed for the following purposes:
- Development, improvement and protection of our products and services
- Performance of research activities and statistics
The social medias collect statistical data on the visitors’ behavior for their own purposes through cookies and pixels on your device when you visit the sites. Each cookie contains a unique identification code which remains active for a certain period, unless it is deleted prior to expiry of such period.
You can read more about the social medias processing of personal data by visiting their privacy policies (Facebook or LinkedIn) and cookie policies (Facebook or LinkedIn).
Legal basis
ESVAGT will mainly process your personal data based on the following legal basis:
- Legitimate interests: We process your personal data pursuant to our legitimate interest in being able to improve our products and services (Article 6(1)(f) of the GDPR).
Sharing of your personal data
ESVAGT will at no point disclose your personal data collected via social medias to third parties.
The social medias may share your personal data internally among its subsidiaries and externally among its partners using analytical services, advertisers, other individuals, surveying partners and researchers and academics. Such transfers may include transfers to countries outside EU. For more information, please refer to the social medias’ terms and conditions and privacy policies linked to above.
Rights towards the social medias
The social medias general set-up dictate that you must contact the social media in question if you wish to exercise your rights. This is owing to the fact that only the social medias are, in pure functional terms, capable of taking the steps necessary to comply with most of your requests. If, however, you are of the opinion that ESVAGT is capable of complying with your request, please do not hesitate to contact us.
If you are a Facebook user, you may exercise your rights by changing your private settings (link) or configure your preferences (link) in order to have an influence on how your personal data will be collected and processed when you visit and use the Facebook site. If you are a LinkedIn user, click here (link) to change your settings or here (link) to exercise your rights.
-
If you are a contact person at our customers, suppliers or other business partners
This section sets out the policy of ESVAGT’s processing of personal data collected from owners of sole proprietorships or contact persons at ESVAGT’s customers, suppliers and other business partners who collaborate with ESVAGT.
Collection of personal data
ESVAGT may collect, process and store personal data about you in the following instances:
- When your company or the company you are employed with enters into an agreement with ESVAGT, including buys services offered by ESVAGT
- When you have shown an interest in ESVAGT’s products or services, e.g. by providing your business card to ESVAGT
- When you make use of ESVAGT’s website and portals
- When you collaborate and communicate with ESVAGT
- When you visit our physical addresses or our vessels
Types of personal data
ESVAGT may collect, process and store the following personal data:
- Name, e-mail address, telephone number and similar identification data
- Individual data, such as preferred language
- Organizational data, such as company name, company address, job position, business area, primary work location and country
- Contractual data, such as purchase orders, invoices, contracts and other agreements between your company (or your employer) and ESVAGT, that may include e.g. your contact information
- Financial data, such as payment terms, bank account details and credit ratings
- IT-related data, such as logs about your usage of ESVAGT’s website and portals
- Information provided when you visit our physical addresses or vessels, e.g. registration of visitors or recordings from video surveillance, or any information that you are required to provide when entering our vessels according to maritime law or our internal security or safety rules.
Such information may be provided directly by you (primarily via e-mails and other correspondence) or by a third party such as your employer.
Purposes of the processing
Your personal data may be processed for the following purposes:
- Generally, to plan, perform and manage the business relationship, including any contracts
- Administration, such as processing payments (including collection of outstanding invoices), evaluation of credit ratings, performing accounting, auditing, billing activities, arranging shipments and deliveries as well as providing support services
- Ensuring safety and security on our physical addresses or vessels
- Completion of requests received from you
- General, including promotional, communication
- Evaluation and development of our services, including statistics and analytics
- Compliance and regulatory purposes, such as fulfilling our legal and compliance-related obligations to prevent illegal activity
- Dispute handling
- Medical treatment (sea services)
Legal basis
ESVAGT will mainly process your personal data based on the following legal bases:
- Contractual obligation: The processing of your personal data will in some cases be necessary for the performance of a contract (Article 6(1)(b) of the GDPR).
- Legitimate interests: We may process your personal data pursuant to our legitimate interest in, for instance, to manage daily operations according to lawful and fair business practices, including planning, performing and managing the business relationship or our legitimate interest in e.g. fulfilling our contractual rights and obligations with our company, conducting credit ratings, statistics, analysis, marketing activities (where consent is not required), providing support as well as improving and developing our products and services (Article 6(1)(f) of the GDPR).
- Legal claims: The processing may also be necessary to prevent fraud or establish, exercise or defend legal claims (Article 6(1)(f) of the GDPR).
- Legal obligation: The processing of your personal data will in some cases be necessary to comply with legal obligations, such as our obligations to prevent illegal activity or according to maritime law or legal requirements set out by the Danish Maritime Authority etc. (Article 6(1)(c) of the GDPR).
- Consent: In exceptional cases and only when no other legal basis can be applied, ESVAGT may ask separately for your consent to process your personal data (Article 6(1)(a) and 9(2)(a) of the GDPR). ESVAGT will, for instance, only use your personal data in order to send you marketing material via e-mail if you have provided your prior and explicit consent hereto, unless applicable legislation allows us to contact you without such consent.
- Vital interests: If you – due to circumstances beyond our control – need medical attention as part of our services, it may be necessary for us to process and disclose your personal data to help you (Article 6(1)(d) and 9(2)(c) of the GDPR).
Retention period
Your personal data will be deleted when it is no longer needed for one or more of the purposes mentioned above.
However, subject to other requirements under local law, the following retention periods apply:
- Personal data included in accounting records is kept for 5 years from the end of the financial year to which the records relates.
- Personal data collected in connection with business, support or other commercial activities will be stored as long as such data is relevant for the handling and monitoring of the issue in question. The retention period will typically be commensurate with the period laid down in the rules on limitation of legal claims or the duration of our business relationship.
The personal data may, however, be processed and stored for a longer period of time if anonymized or if we are obliged to do so according to law.
-
If you are a shareholder
This section sets out the policy of ESVAGT’s processing of personal data collected about our shareholders.
Collection of personal data
ESVAGT may collect, process and store personal data about you in the following instances:
- When you purchase shares in ESVAGT
- When you communicate with ESVAGT
Types of personal data
ESVAGT may collect, process and store the following personal data:
- Name, e-mail address, telephone number and similar identification data
- Bank account details
- Copy of passport
- National identification number
- Information on equity interest and voting shares
- Call options
- Starting date of ownership
We might be provided with this information directly by you or through your third parties representing you.
Purposes of the processing
Your personal data may be processed for the following purposes:
- Completion of inquiries and requests received from you
- Pay of dividends, or similar payments, to you
- Provision of shareholder communications, such as notices of meetings, etc.
- Provision of copies of our annual reports and accounts
- Maintenance of our share register and keeping this up to date
- General communication
- Statistics and analytics
- Compliance with legal obligations to which we are subject and corporate with regulators
Legal basis
ESVAGT will mainly process your personal data based on the following legal basis:
- Legal obligation: The processing of your personal data is necessary to comply with legal obligations (Article 6(1)(c) of the GDPR).
Retention period
We will keep your personal data for as long as we have a relationship with you. Once our relationship with you has come to an end, we will store your personal data for a period of time that enables us to:
- Maintain business records for analysis and/or audit purposes or risk management purposes
- Comply with our business record retention requirements
- Defend or bring any existing or potential legal claims
-
If you use our whistleblowing system
Serious and sensitive concerns that may have an adverse impact on the operations and performance of ESVAGT or which may have a significant effect on a person’s life or health may be reported via our whistleblower system, whereby ESVAGT will process personal data about data subjects which are part of a whistleblower reporting (i.e. the senders of notifications, the reported persons and other third parties involved).
Collection of personal data
ESVAGT may collect and process personal data when a reporting is made as well as during the investigation of reports.
Types of personal data
If you report a suspected misconduct, such report will remain confidential and, if desired, anonymous. You should in any case provide a contact email address, as the investigating person may need to contact you for further details on the incident to be able to handle the case properly.
We may process the following personal data about the reported person:
- Name, job position, contact information and reported facts, including description of the suspected misconduct
The following personal data may be processed about other third parties mentioned in the report:
- Name, job position, contact information and reported facts
Purposes of the processing
ESVAGT may process personal data for the following purposes:
- Initial reporting and investigation of reports of alleged breaches
- Provide responses to requests made by the whistleblower, the reported person or other third parties involved
Legal basis
ESVAGT will mainly process the personal data based on one or more of the following legal bases:
- Legitimate interest: We may process the personal data pursuant to our legitimate interests in investigating reports (Article 6(1)(f) of the GDPR).
- Legal obligation: Establishment of a whistleblower system is mandatory to ESVAGT as per 17 December 2021 from which date the processing of personal data is necessary to comply with a legal obligation (Article 6(1)(c) of the GDPR).
Retention period
Subject to other requirements under local law, the report and collected information will be deleted:
- Immediately if the report is outside the scope or is manifestly unfounded, or if no internal action is made in relation to the concern.
- Right after the closing of the case by the authorities if a report is filed with the police or other relevant authorities.
- 2 months after the investigation has been completed if no further action is taken.
- If disciplinary sanctions are made towards the reported employee based on the collected information or there are other reasons for it being necessary to continue storing the information, the collected information may be transferred to the employee’s personnel file. In such case the personal data will be deleted no later than 5 years after termination of employment.
-
General information applicable for all individuals covered by this privacy policy
Disclosure to other data controllers and transfer to data processors
To meet the purposes mentioned above we may give third parties, who provide relevant services on basis of a contractual relationship with ESVAGT, access to your personal data, including providers of e.g. IT services, ERP systems, invoicing systems, marketing services, website analytics, IT support, IT service development as well as digital developers, e-mail operators, hosting providers and other suppliers providing systems or services to ESVAGT. Such service suppliers may only process personal data on behalf of ESVAGT and in accordance with our instructions.
Your personal data may be disclosed to accountants. Under certain circumstances it may also be necessary to disclose your personal data to lawyers, courts, public authorities, the police and potential buyers.
In connection with ESVAGT’s development, the company structure may change, e.g. through a full or partial sale of ESVAGT. In case of a partial hand over of assets containing personal data, the legal basis for the related disclosure of personal data is, as a general rule, ESVAGT’s legitimate interest in handing over parts of its assets as well as making commercial changes.
If your personal data is transferred to data processors or data controllers established in countries outside the EU/EEA which do not have an adequate level of protection, such transfers will in general be based on the EU Commission’s Standard Contractual Clauses.
Security
We have implemented numerous security measures to prevent, for example, the loss and misuse of personal data under our control. Accordingly, we use our best endeavours to protect the quality and integrity of your personal data.
Your rights
- You have the right to access the personal data we process about you
- You have a right of objection towards our collection and further processing of your personal data
- You have the right to have your personal data rectified and deleted, with certain national statutory exceptions
- You have the right to request us to restrict the processing of your personal data
- Under certain circumstances you may also request to receive a copy of your personal data as well as the transmission of your personal data which you have provided us with to another data controller (data portability)
- You may at any point withdraw the consents that you have given.
Questions or complaints
If you have any questions in relation to this internal privacy policy or if you wish to make a complaint in connection to our processing of your personal data, please contact us on gdpr@esvagt.com. You can also write to us at the following address:
ESVAGT A/S
Dokvej 4
6700 Esbjerg
Denmark
If your complaint is not resolved by us and you wish to proceed with the case, you can send your compliant to the supervisory authority in your country. A list of European supervisory authorities is available on the EU website.