PURPOSE OF THIS NOTICE
This Privacy Notice aims to inform you about how Crew Life at Sea manages your personal data in terms of
collection, use, storage according to the new General Data Protection Regulation (GDPR), (EU) 2016/679.
2. INFORMATION WE COLLECT AND PROCESS
We ask for, collect, and process the personal information specified below (where applicable). This information is
necessary for evaluating employment applications, for the adequate performance of the Company’s operations
and of the contract between you and our Company to safeguard the Company’s legitimate interests and to allow
us to comply with our legal obligations. Crew Life at Sea makes every effort to ensure that the information stored
and the process is accurate and up to date.
Name / Surname
Date and place of Birth
Mobile and Home mobile numbers
Diplomas / Training Certificates
Medical History / Medical
Certificates / Sick Leaves
Copy of identification/ Passport (& passport
Bank Account details
Social Insurance Number
Next of Kin information
Personnel / Employee / Crew Records
Complaint and Investigation Records
Personnel / Employee / Crew Appraisal
3. HOW WE USE INFORMATION WE COLLECT AND PROCESS
The information is stored in the Company’s internal server in each employee’s secure and separate folder. All
Crew Life at Sea’s systems are running on a cloud-based system online in the United States. These servers are
supported by BambooHR and no information is kept in hard copy format unless required by law, international
conventions, or contractual obligations. Only authorized personnel have access to this information. It is stored in
order to enable the Company to carry out its contractual obligations with the employee, its legal obligations with
local and foreign governmental Authorities and applicable International Conventions, to safeguard the Company’s
legitimate interests, resolve any disputes and claims and for the execution of the Company’s operations. We will
store your information for as long as necessary for the performance of the contract between you and our Company.
It may be necessary to retain personal information after the conclusion of the contract in the extent that is
necessary to comply with our legal obligations. The Company will retain all necessary information for the maximum
time as allowed by applicable law in effect from time. The Company will disclose the above information to local
and foreign governmental Authorities and/or Agents and/or otherwise where required or permitted to do so by
Law, Collective Agreements, International Conventions, Contract or otherwise and only in the extent required or
permitted to do so according to the terms of employment. We may share your information in the extent required
or permitted to do so with personnel, agents, advisers, lawyers, banks, clients, auditors, service providers,
overseas offices, affiliates, partners and any other third person or entity in connection with our operation or services
who are also obligated to comply with European data protection standards and to provide appropriate
safeguards in relation to your personal information.
Crew Life at Sea will disclose the above information if requested to do so by courts, law enforcement, governmental
authorities or authorized third parties.
4. CHILDREN’S DATA
The Company recognizes the importance of protecting children's privacy. We may collect and process personal
data in relation to children provided that we have first obtained their parents’ or legal guardian’s consent or unless
otherwise permitted under law. For the purposes of this privacy statement, “children” are individuals who are under
the age of sixteen (16).
5. LEGAL BASIS FOR COLLECTION AND PROCESS OF INFORMATION
The Company is committed to protecting your privacy and handling your data in an open and transparent manner
and as such we process your personal data in accordance with the GDPR and the local data protection law for
one or more of the following reasons which provide legal basis:
5.1. For the performance of an employment contract
The processing of personal data is necessary to comply with contractual obligations with regards to the
5.2. For compliance with a legal obligation
The processing of personal data is necessary to comply with legal requirements.
5.3. For the purposes of safeguarding legitimate interests
The processing of personal data is necessary for the legitimate interests pursued by the Company or by a third
party. A legitimate interest is when we have a business or commercial reason to use your information. Examples
of such processing activities include Claims, Court Proceedings, Arbitration and any other legal proceedings we
may have the right to establish, exercise or defend.
Provision of specific consent for the processing of special categories of personal data other than for the reasons set
out hereinabove. For example, consent will be obtained for medical and criminal records.You have the right to
revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will
not be affected
6. HOW DO WE SAFEGUARD THE INFORMATION WE COLLECT AND PROCESS THROUGH
The following processes have been put in place to protect your data from unwanted third parties:
Application design. We've designed the system from the ground up with security in mind. By applying best
practices in web application security, we prevent critical vulnerabilities.
SSL. We encrypt all customer information in transit to a minimum standard of TLS 1.2.
Strong encryption. Especially sensitive information (social security numbers, driver license numbers, etc.)
is encrypted in our database using the Advanced Encryption Standard (AES).
Firewall. Our application, including our customers' data, sits behind a firewall.
Vulnerability scanning. Our servers are scanned regularly for vulnerabilities by a reputable third party. In
addition, our internal security team performs bi-weekly vulnerability assessments against the application.
Intrusion detection. Our servers and all traffic are monitored by an intrusion detection system (IDS).
Data Backup. All of your data is backed up nightly in at least two distinct availability zones. Backups are
encrypted and transferred over TLS to protect the data in transit and at rest. The purpose of backing data
up in this manner is to guard against unforeseen hardware issues (i.e. challenges with a particular server
machine, or an unexpected data center outage) and is therefore designed to be used specifically in restoring
a full account with all data due to an issue similar to those mentioned above.
Crew Life at Sea in conjunction with BambooHR software is certified under the Privacy Shield Framework. You
can view BambooHR's certification under the Framework by going to https://www.privacyshield.gov, selecting
"Privacy Shield List" and searching for Bamboo HR LLC. For any additional questions or concerns please contact
7. DISCLOSURE OF INFORMATION TO THIRD COUNTRIES
Your personal data may be disclosed to other countries,, in such cases, processors in third countries are also
obligated to comply with the European data protection standards and to provide appropriate safeguards in relation
to your personal information.
8. YOUR RIGHTS
Please, keep us informed if your personal data changes at any time. It is important that the personal data we hold
about you is accurate and up to date. You have the following rights in terms of the personal data we hold about
you, subject to jurisdictions and applicable law.
8.1. Receive access to your personal data
This enables you to receive a copy of the personal data we hold about you.
8.2. Request correction [rectification] of the personal data we hold about you
This enables you to have any incomplete or inaccurate data we hold about you corrected.
8.3. Request the erasure of your personal information
This enables you to ask us to erase your personal data [known as the ‘right to be forgotten] where information is
held with no valid legal basis.
8.4. Object to processing of your personal data
This enables you to object if you provide a reasonable basis and specific reasons for the objection. You have the
absolute right to object if the processing of your personal data involves direct marketing and a non-absolute right
if the data is processed for legitimate purposes. We will address your objection duly and according to the GDPR
regulation and relevant applicable law.
8.5. Request the restriction of processing of your personal data
You have the right to submit a request to restrict the processing and only keep the information stored until the
basis of your request is resolved. Notification of incorrect information held will automatically restrict the processing
of your personal data until such information is corrected. You have the right to explicitly and in writing ask the
company to hold on your behalf your personal information, which we no longer process.
8.6. Request to receive a copy of the personal data concerning you in a format that is structured
and commonly used and transmit such data to other organizations
You also have the right to have your personal data transmitted directly by us to other organizations you will name
[known as the right to data portability].
8.7. Withdraw the consent that you gave us about the processing of your personal data at any
time (where applicable)
Consent given for the processing of medical and criminal records is bound by our legal obligation to conform to
relevant laws, regulations, and international conventions, which makes it obligatory for the company to hold and
process such information. (International Maritime Organization (IMO), International Labor Organization (ILO),
Maritime Labor Convention (MLC), The International Convention on Standards of Training, Certification, and Watch
keeping for Seafarers (STCW). This obligation is based on the obligatory medical examinations for the issuance of
the Fit-for-Duty Certificates and the provision of adequate onboard/ashore medical care and treatments.
changes and will amend the revision date at the bottom of this page. We do, however, encourage you to review this
Policy periodically so as to always be informed about how we are processing and protecting your personal
10. QUERIES OR COMPLAINTS
If you have any questions, suggestions, or complaints regarding the issue of data protection, please get in touch with us:
Raymond Crystal Founder – CEO Operations
Roxanne Crystal - VP Operations
11. PERSONAL DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including
for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. We will keep your
personal data for as long as we have a business relationship with you. Once our business relationship with you
has ended, we shall keep your data for the maximum time as allowed by applicable law in effect from time to time.
I acknowledge that I have received, read, and understood this Privacy Notice, the scope and its purpose