The Baltic Exchange Ltd.
European Economic Area.
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
|Personal Information Protection Law (“PIPL”) of the People’s Republic of China
The GDPR applies to ‘personal data’ meaning any information relating to an identified or identifiable person who can be directly or indirectly identified in particular by reference to an identifier
Baltic, a limited company registered in England, Number 64795, is a membership organisation at the heart of the global maritime marketplace.
In connection with operating the organisation and making available its services and data, Baltic collects and handles certain Personal Data.
(1) How we collect Personal Data and what Personal Data we hold
(2) Purpose for which we hold and process your Personal Data
(3) Transfer of Personal Data
(4) Retention Period
(5) Data Subject Rights
(6) Contacting Baltic
(7) Links to External Website
Visitors to publically available pages of our website
If you are merely visiting the public area of balticexchange.com, we do not collect any personal information about you.
1. How we collect Personal Data and what data Personal Data hold
Baltic collects Personal Data supplied by its members and subscribers (“Users”) and other individuals with interests in the maritime industry who contact us or otherwise interact with us (“you”, “your”). We may also collect Personal Data from you when you interact with us or our website or communicate with us, including in relation to membership.
1.1 Data we collect if you are a member or subscriber
The data that you have provided to Baltic (for example via our online or paper membership or subscription forms), including:
- Full name
- Current name
- Previous name if applicable
- Date of birth
- Name of the company you work for; including
- Business address
- Your position/status in the company
- Your department within the organisation
- Business telephone number
- Mobile telephone number
- Email Address
- Your online username granting you access to balticexchange.com
- Your home address and telephone number, if you have provided it to us
- Any additional information necessary to provide you with the Services you request, for example, other information about yourself, your preferences or your experiences that you voluntarily share with us
If you are an applicant for membership and you do not wish your contact details to be included on our membership database and directory, we will be unable to process your membership application.
1.2 Additional data we collect if you are a member
As you continue as a member of the Baltic we will build a history of your employment within Baltic member companies this includes
- Date you were first elected
- Date you started with the Baltic member company
- Date you ceased employment with the Baltic member company
- If you have been awarded 50 year membership status
- Date you became a retired member, if this is the case.
1.3 Data we may collect if you are not a member or a subscriber
If you attend one of our marketing events and/or register an interest in receiving more information about the shipping market and shipping companies, we may collect the following data:
• Contact name
• Name of the company you work for
• Business address
• Your position in the company
• Your department within the organisation
• Business telephone number
• Mobile telephone number
• Email Address
We may also hold the following additional information that you provide to us
• Areas of specific maritime interest
• Photography of event attendees is normal practice and these may later be published.
• Details relevant to your attendance at an event, e.g. dietary requirement
2. Purpose for which we hold and process your Personal Data
Baltic holds and processes your Personal Data for the purposes set out below. Generally, we do so on the basis that it is necessary for performance of our contract with individual Users, and/or because it is necessary for our legitimate interest (namely to operate the platform and make membership and data available to our Users and to send marketing to the employees and representatives of our members) and/or because it is necessary to meet a legal obligation that we are subject to.
Use of Personal Data
We use your Personal Data:
• in connection with the provision of User’s services (“Services”), including assessment of any application made by you;
• to communicate with you;
• to maintain an on-line directory of our members, which contains only our members’ name and contact details and this is made available
to all members on balticexchange.com (note that all the other Personal Data you provide as part of the application and membership
process is only used internally by our membership teams and marketing teams).
• from time to time, to let you know about other Services and products we provide, special offers and to provide news about our
business and to inform you about information that is relevant to the maritime market. If at any time you wish to be removed from
the database please email [email protected] so we can action your request. If you opt out, you acknowledge that we
will still need to contact you about matters relating directly to the Services for which you have subscribed.
No Personal Data is used for automated decision or automated profiling purposes.
3. Transfer of Personal Data
As part of the normal operation of the Services and for the purposes set out in the above, we disclose information about you to the following parties which may include your Personal Data.
• Other Baltic members, who will be able to see your contact information in the on-line directory of members; and
• Business partners and third party service providers, who may assist us in operating our website, partner with us in organising events and undertaking other activities on our behalf.
In addition, in response to a statutory request, it may become necessary to share your Personal Data with law enforcement authorities and/or government institutions.
During the course of our interactions with you, we may transfer Personal Data, for the purposes described above, to countries outside the EEA
which may not provide legal protection of Personal Data equivalent to the level of protection within the United Kingdom.
We will transfer your Personal Data subject to European Commission approved contractual terms that impose different data protection obligations directly on the recipient, or as otherwise permitted under the GDPR. Please contact us as set out in paragraph 6 below, if you would like to see a copy of the specific safeguards we apply to export of your Personal Data.
Cross-Border Data Transfer under the Personal Information Protection Law (“PIPL”) of the People’s Republic of China.
4. Retention Period
- Members and subscribers
Personal Data is retained for a period of 10 years after cessation of your membership or business relationship as a subscriber with the Baltic.
- If you are not a member or a subscriber
Personal Data is retained for a period of 1 year if you were exploring becoming a potential member; otherwise it is not held after the end of the customer relationship.
- If you have unsubscribed
If you have elected to unsubscribe from receiving marketing communications from us, we will continue to hold your email address to stop further communication with you for such period as we reasonably require such data for such purposes.
5. Data subject rights
Under the GDPR, individuals have the right to:
- access their personal data;
- the rectification of their personal data;
- erasure of their personal data;
- request the restriction of processing Personal Data concerning the individual;
- object to the processing of their Personal Data (including the right to object to marketing)
- have their Personal Data transmitted to a third party;
- not be subject to certain automated decision making; and
- lodge a complaint with a supervisory authority
To the extent that Baltic’s processing of your personal data is subject to the PIPL, you may have the following rights:
- request erasure (or deletion) of personal data that is no longer necessary to fulfil the purposes for which it was collected, or does not need to be retained by Baltic for other legitimate purposes;
- request the restriction of processing and for us to pass this on to other recipients of your personal data; and
- obtain from us confirmation as to whether or not your personal data is being processed and where that is the case, access your personal data and information regarding the processing of that data.
These rights may be subject to certain conditions and your exercise of these rights is subject to certain exemptions to safeguard the public interests (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If youexercise any of these rights we will check your entitlement and respond in most cases within a month.
If you wish to contact us to exercise the above rights, or have any question about the above or the information we hold about you please contact us at the details set out in Section 6 Contacting the Baltic.
You also have the right to make a complaint to the Information Commissioners Office
6. Contacting the Baltic
If you have any queries or comments regarding the data we hold about you or if you wish to correct or update this, please either email us at [email protected].
7. Links to External Sites