Introduction and background

Borealis Maritime Limited takes your privacy very seriously and recognises the importance of protecting the privacy and the rights of individuals in relation to their personal information. The purpose of this policy is to outline how Borealis Maritime Limited has established measures to protect your privacy and information rights.

Information Borealis Maritime Limited collect

Borealis Maritime Limited collect and process personal data about you when you interact with us and when you purchase or supply services from us. The personal data Borealis Maritime Limited process includes:

• Name;
• Email addresses;
• Profession, Occupation and Job title;
• Any additional information relating to you that you provide to us directly through our website; and
• Information you provide to us through any telephone enquiries made from time to time.

How do Borealis Maritime Limited collect personal information?

Borealis Maritime Limited collect personal information in the following ways, including:

• Directly from you, such as when you provide information by phone or in documents such as our contact form on our website; and
• From our own records of how you use Borealis Maritime Limited services.

How do Borealis Maritime Limited use this information and what is the legal basis for this use?

Borealis Maritime Limited process the personal data identified in the ‘Information Borealis Maritime Limited collect’ section of this policy for the following purposes:

As required to establish and fulfil a contract with you, for example, if you enter into an agreement with us receive or supply services. This may include communicating with you, providing customer services, billing, and arranging the delivery or other provision of services. Borealis Maritime Limited require this information in order to enter into a contract with you and are unable to do so without it.
To comply with applicable laws and regulations;
In accordance with our legitimate interests in protecting Borealis Maritime Limited legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);Borealis Maritime Limited may use information you provide to personalise our communications to you, our website; and services for you, in accordance with our legitimate interests.

Securing your information

Borealis Maritime Limited are committed to protecting the security of your personal information. Borealis Maritime Limited takes all reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. The ways Borealis Maritime Limited do this include:

• Having in place technical and organisational measures designed to ensure the ongoing integrity, availability and resilience of processing systems and services;
• Limiting physical access to our premises;
• Limiting access to the information Borealis Maritime Limited collect about you;
• Ensuring that Borealis Maritime Limited have appropriate security safeguards to keep personal information secure; and
• Where required by law, destroying or de-identifying personal information.

Sharing your information

For the purposes set out above under ‘How do Borealis Maritime Limited use this information’ we may disclose your personal information to organisations or persons outside of Borealis Maritime Limited.

Where appropriate, these disclosures are subject to privacy and confidentiality protections and other requirements under relevant data protection regulation. The organisations and persons we usually disclose information include:

• Information technology providers i.e. cloud service providers;
• Your representatives (if necessary);
• Borealis Maritime Limited professional advisors, including our accountants, auditors and lawyers;
• Government and regulatory authorities and other organisations, as required or authorised by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws; and
• Our related companies.

Some of these organisations or persons may be located in other countries. The countries in which these organisations or persons are located will vary, but, in the course of our ordinary operations, we generally disclose personal information to organisations, or persons located inside the European Economic Area (EEA) or to other worldwide jurisdictions where our day to day operations permit. When we share your personal data in this way we will do this in accordance with applicable data protection laws and will take appropriate steps to ensure the third parties undertake to ensure the appropriate safeguards are in place to protect the personal data.

Links to other websites

This website contains links to other websites not operated by Borealis Maritime Limited. Borealis Maritime Limited is not responsible for the privacy practices or the content of any non-Borealis Maritime Limited websites to which we link from this site. We are not responsible for the protection and privacy of any information you provide whilst visiting other websites and sites not governed by our privacy policy. We cannot control the content or security of such websites. We cannot be held responsible for any loss or damage incurred by a user as a result of visiting such websites. No links are intended to be, nor should be construed as, an endorsement of any kind by us of that other website.

As Borealis Maritime Limited is not legally responsible for the content and the data protection compliance of such third party operated websites, we kindly ask you to closely pay attention to the respective privacy terms of these third party operated websites.

Retention of information

We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

Where you are a business contact or supplier, we will keep your information for the length of any contractual relationship you have with us and after that for a period of 6 years, excepting information that we are required to retain as above.

Where you are an individual that has provided us with information through our website contact form, we will only retain your data until you unsubscribe from our communications; or, if you have not unsubscribed; while you interact with us and our content or for 6 years from when you last interacted with us or our content.

Your rights

Under current data protection regulation, you are entitled to:

• Right to access – You have the right to access your personal data and supplementary information;
• Right to rectification – If the information we hold on you is inaccurate or incomplete, you can request we correct this;
• Right to erasure – You can request we delete or remove personal data where there is no compelling reason us to continue processing;
• Right to restrict processing – You have the right to request we cease processing your data, if:
  • You consider it inaccurate or incomplete;
  • Where you object to processing and we are considering whether we still have a legitimate interest to process it; and
  • Where we don’t need the data for the original reason, we collected it but may need it to support a legal claim.
• Right to data portability – Where you have consented to our processing your data, or where the processing is necessary for us to deliver a contract, you can request a copy of that data be provided to a third party in a structured, machine readable and electronic form; and
• Right to objection – You have the right to object to our processing under certain circumstances. For example, you can object to:
  • direct marketing; and
  • processing for purposes of scientific/historical research and statistics.

Contact us

We recognise that you may have questions on how we process and/or store your personal information or may want to change either the information we hold on you or how we communicate with you in the future. If you have any questions in respect of this policy, or would like to exercise your rights as a data subject please contact our privacy officer at:

Email: dataprotection@borealismaritime.com

If you do make a complaint or allege a breach and we fail to respond to your complaint or you are dissatisfied with the response that you receive from us, you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.

Changes to our privacy policy

Over time, aspects of our business or technology may change as we respond to changing market and technological conditions. This may require our policies to be reviewed and revised. We reserve the right to change this privacy policy at any time and to notify you by posting an updated version of the policy on our website. If at any point we decide to use personal information in a manner materially different from that stated at the time it was collected, we will notify users by email or via a prominent notice on our website and, where necessary, we will seek the prior consent of our users.