External Privacy Notice

Last Updated: 05/08/2024

1. Who we are and what we do

Who we are

AW Ship Management (“AW Ship Management”, “us”, “we”, “our”) is a limited company registered in England and Wales under registration number 09223499, our registered office is at Osborne House, 12 Devonshire Square, London EC2M 4TE. We are registered with the UK supervisory authority, the Information Commissioner’s Office (“ICO”) in relation to our processing of Personal Data under registration number ZA278700.l only request and process information from a “Data Subject” for the purposes that we have outlined and that have been agreed between the “Data Subject” and AWSML.

What we do

AW Ship Management Ltd provides a complete ship management service from new build, valuation, repair and maintenance to crewing, purchasing and accountancy. We and our affiliates, subsidiaries and related entities are committed to protecting the privacy and security of the Personal Data we process about you.
Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.

2. Purpose of this privacy notice

The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.

3. Who this privacy notice applies to

This privacy notice applies to you if:

1. You visit our website
2. You use our services
3. You enquire about our products and/or services
4. You sign up to receive newsletters and/or other promotional communications from us

4. What Personal Data is

‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.

‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation.

5. Personal Data we collect

The types of Personal Data we collect about you will depend on our relationship with you. Below is an example of the different categories of personal data we may collect and process about you, please note this list is not exhaustive.

• Full Name
• Job Title
• Company Name
• Phone Number
• Email Address

6. How we collect your Personal Data

We collect most of the Personal Data directly from you in person, by telephone, text or email and/or via our website. Common forms include:

• When you navigate through our website
• When you contact us via post, email or phone
• When you engage with us on social media

7. How we use your personal data

We will only use your Personal Data when the law allows. Most commonly, this will be in the following circumstances.

• To engage with you when you express an interest in our services
• To tell you about our services and any offers we might have
• To provide our services
• To provide updates about the service you are receiving

8. Lawful basis for processing

Applicable Data Protection legislation requires us to identify appropriate lawful bases to process personal data. The lawful basis we rely on as a data controller are detailed below with brief examples for when they may apply:

9. Sharing your Personal Data

We may share your Personal Data with our carefully selected third parties, including but not limited to:

• Other organisations we engage to help provide our services
• Government/law enforcement for the purposes of preventing and detecting crime, if we are required to do so by law.

10. International Transfers

Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK.

We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in the UK. We do this by ensuring that:

• Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation), or
• We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary.

11. Your rights and how to complain

You have certain rights in relation to the processing of your Personal Data, including to:

• Right to be informed
  You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.
• Right of access (commonly known as a “Subject Access Request”)
  You have the right to receive a copy of the Personal Data we hold about you.
• Right to rectification
  You have the right to have any incomplete or inaccurate information we hold about you corrected.
• Right to erasure (commonly known as the right to be forgotten)
  You have the right to ask us to delete your Personal Data.
• Right to object to processing
  You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.
• Right to restrict processing
  You have the right to restrict our use of your Personal Data.
• Right to portability
  You have the right to ask us to transfer your Personal Data to another party.
• Automated decision-making
  You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.
• Right to withdraw consent
  If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.
• Right to lodge a complaint
  You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at:
  Contact us | ICO
  Or by telephone on 0303 123 1113

  For supervisory authorities in other countries within the EU see the link below:
  https://edpb.europa.eu/about-edpb/about-edpb/members_en

How to exercise your rights

You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.

12. Children’s Privacy

We do not offer our products and services to children, and we do not knowingly collect Personal Data of children without parental consent, unless permitted by law. If you are a child, you must have your parent’s permission to use our services. If you learn that a child has provided us with their Personal Data without parental consent, you may contact us, as described below, and if appropriate, we will securely and permanently delete it, in accordance with applicable law.

13. Automated Decision-Making and Profiling

We do not use Automated decision making or profiling as part of our services.

14. Use of Cookies and Similar Technologies

Our website, survey service and app utilise cookies and similar technologies. You can find out more by viewing our Cookies Notice available [here].

15. Security and storage of information

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

If we become aware of any loss, misuse, alteration of personal data we will work closely with our IT team, DPO and other parties as necessary to investigate the incident at hand. We have put into place the relevant procedure and policies in place to investigate, mitigate and report (when needed to relevant parties) such instances.

16. Data Retention

We will not keep Personal Data longer than is necessary, for the purpose or purposes for which they were collected. AW Ship Management will take all reasonable steps to destroy, or erase from its systems, all Personal Data which is no longer required. This does not apply to anonymised data.

17. How to contact us and our Data Protection Officer

If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:

AW Ship Management Ltd.
Osborne House
12 Devonshire Square
London
EC2M 4TE

T: +44 207 575 6000
F: +44 207 575 6200
E: shipman@awsml.co.uk

We have also appointed a Data protection Officer (“DPO”). Our DPO is Evalian Ltd can be contacted as follows:

Evalian Limited
West Lodge
Leylands Business Park
Colden Common
Hampshire
SO21 1TH
United Kingdom

Phone: +44 (0)333 050 0111
Website: www.evalian.co.uk

18. Changes to this privacy notice

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.

Last modified 05/08/2024

You can contact us for previous versions of this Privacy Notice.