Neptunedry

EMPLOYEE/CONTRACTOR DATA PROTECTION NOTICE

This notice (Privacy Notice) applies to personal information relating to your employment or engagement (prospective, current or former) with NEPTUNE DRY MANAGEMENT, a company duly established under the laws of Marshal Islands, having its offices in Moschato, Greece, at 32 Lagkadion Street. It explains what information we collect about you, how we'll use that information, who we'll share it with, the circumstances when we'll share it and what steps we'll take to make sure it stays private and secure.

We, as your employer will act as Data Controller for the purposes of this notice. We'll only collect your information in line with relevant regulations and law. Some information will come from you directly or we will obtain it from public or other sources (e.g former employer).

What information we collect

A. Information you provide to us

- Personal Information e.g name, surname, father's name, gender, date and place of birth, employment history, rank

- Contact details, e.g address, email address, mobile and landline numbers, corporate mobile number

- Information about who to contact in case of an Emergency

- Information regarding your Identity, e.g photo ID, passport number, VISA number (if applicable), National insurance and Tax ID No.

- Information about your Skills and Qualifications e.g Diploma, Seaman's Book, Driving licence

- Information necessary to your payment e.g bank account details

- Health data including medical condition and accidents in the context of employment, e.g health certificate, absence records, health and sickness records.

B. Information we collect and generate about you

- Information about your suitability to work for the Company, e.g work permit when necessary

- Information about the Terms of Employment and your development in the Company e.g contract, benefits and rewards, training attendance records, rank

- Complaints, disciplinary and grievance information

- Information needed for natural access to vessels, buildings, equipment and technical systems, eg. passwords, answers to security questions, photographs, video images (including those captured via CCTV).

- Information regarding behavior at the workplace

- Records of correspondence and other communications between us, including telephone, email, live

chat, instant messages and social media;

- Information that we need to support our regulatory obligations and risk management.

How we will use your information and under which grounds

Lawful basis	Processing activities
Performance of a contract	Recruitment, staff vetting; Αdministering and maintaining personal records; Payroll, pension and retirement savings, insurance schemes; Maintaining medical records, holiday records, sick leave/pay information; Carrying out performance reviews and appraisals, evaluation reports; Disciplinary and grievance matters; Employee training attendance records Providing information to future employers;
Compliance with Legal obligation and public interest	To avert or limit the repercussions of accidents in the context of employment. To avert or limit the repercussions of accidents at sea. To prevent and detect crime or unlawful actions including, e.g. fraud, piracy, terrorism; To comply with our legal obligations towards port authorities, tax authorities, social security funds etc;
Legitimate interests	Business continuity and emergency management purposes; Taking decisions about an employee's fitness for work; Service improvement: we’ll analyse your information to identify possible service improvements. Safety of persons. Security of cargo, equipment, ships and premises. Insurance of risk related to ship management. Data analytics: we’ll analyse your information to identify relevant job opportunities and to better manage our workforce. Protecting our legal rights: we may need to use your information to protect our legal rights, e.g. in the case of defending or the protection of legal rights and interests (e.g. labour law disputes); court action; managing complaints or disputes; in the event of a restructuring of companies or other mergers or acquisition. This may be in connection with action taken against you or other persons.

Who we might share the information with

We may share your information with others where lawful to do so including:

• Competent authorities, such as tax and port authorities;

• Registries of shipping and seamen;

• Other companies of our Group;

• Service providers and agents who work for us or provide services to us;

• Natural persons or legal entities where required in connection with potential or actual corporate restructuring, merger, acquisition or takeover;

• Anyone you give us permission to do so.

• Law enforcement agencies, government, courts, dispute resolution bodies, our regulators, auditors

• Litigation or asserting or defending legal rights and interests;

How long we will keep your data

We keep your information in line with our data retention policy. For example we'll normally keep your core employment data for a minimum period of twenty (20) years unless and we are obliged to retain it for a longer period by law. If we don't need to retain information for this period of time, we may destroy, delete or anonymise it more promptly.

Transfers of data overseas

In necessary circumstances, your information may be transferred outside of the European Union or the European Economic Area, including countries that may don't have the same level of protection for personal information, in order to comply with our legal or contractual requirements. When we do this, we will ensure that it has an appropriate level of protection and that the transfer is lawful. For more information about these third parties use the contact details below.

Safety measures

We use a range of measures to keep your information safe and secure which may include encryption and other forms of security to prevent accidental or illegal destruction, loss, alteration, disclosure or access of the data. We require our employees and any third parties who carry out any work on our behalf to comply with appropriate compliance standards and safety regulations.

Your rights

You have a number of rights in relation to the information that we hold about you. In particular:

1. The right to be informed about the information we process and the right of access this information we hold about you.

2. The right to rectify any information which is inaccurate or incomplete.

3. The right to erasure, in some circumstances. We might continue processing your information if we are required to do so by law, eg to keep record of your social security contributions.

4. The right to restrict and object to certain processing activities, which are explicitly determined by law.

5. The right to data portability, namely to request the portability of your personal data to another employer in a structured, commonly used format (e.g. cd).

6. The right not to be subjected to a decision which is taken exclusively based on automated means.

You can exercise your rights by contacting us using the details set out in the "More details about your information" section below. You also have a right to complain to the Hellenic Data Protection Authority by visiting www.dpa.gr or to the data protection regulator in the country where you live and work.

More details about your information

You are responsible for making sure the information you give us is accurate and up to date, and you must tell us if anything changes as soon as possible. If you'd like further information contact us at: m.stavrou@neptunedry.com