Privacy Notice
General Privacy Notice
Contents
The Data Protection Officer (DPO). 4
E-Shop Customer Registration. 5
E-Shop Marketing Management. 7
E-Shop Customer Returns Management. 9
E-Shop Customer Complaints Management. 11
E-Shop Necessary Cookie Management. 13
E-Shop Non-Necessary Cookie Management. 14
How do I change my cookie settings?. 17
Right to withdraw consent if processing is based on consent. 19
Right to lodge a complaint with a supervisory authority. 19
How do I exercise my rights?. 20
Changes to the General Privacy Notice. 20
Introduction
This General Privacy Notice explains what we do with your personal data.
It applies to any CSM E-Shop Visitor, and any CSM E-Shop Customer of whom we process personal data.
It describes how we collect, handle, and process your personal data.
This notice is layered. So, if you wish, you can easily select any processing activity to see what to expect us to do with your personal data.
The Data Controller
Columbia Shipmanagement Limited (CSM) is the controller for the personal data it processes. You can contact CSM in a number of ways, which are set out below:
Columbia Shipmanagement Limited
Address: Columbia House, 21 Spyrou Kyprianou Avenue, 4042 Limassol, Cyprus
Phone: +357 25843100
Email: marketing@csmcy.com
The Data Protection Officer (DPO)
If you wish to contact our Data Protection Officer in relation to the processing of your personal data by CSM, you can do so in a number of ways, which are set out below:
Mr Andreas Andreou
Address: Columbia House, 21 Spyrou Kyprianou Avenue, 4042 Limassol, Cyprus
Phone: +357 25843100
Email: csmdpo@csmcy.com
Processing Activities
E-Shop Customer Registration
Data Subject
This section applies to the personal data of CSM E-Shop Visitors.
Purpose of Processing
Where you provide us with your personal data, we will process them for direct marketing purposes only.
Categories of personal data
This includes your personal identification details and contact information.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(f). This allows us to process personal data when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
If legitimate interest, it must be identified
The legitimate interest pursued by us is the direct marketing of our goods.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct direct marketing, we will not be able to communicate special offers and other marketing material to you.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
We will store such personal data from the moment an account is registered until the account is deleted. Inactive accounts shall be deleted 16 months after the last account activity.
E-Shop Customer Management
Data Subject
This section applies to the personal data of CSM E-Shop Customers.
Purpose of Processing
Where you provide us with your personal data, we will process them for customer relationship management purposes only.
Categories of personal data
This includes your personal identification details, contact information and user account information.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(f). This allows us to process personal data when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
If legitimate interest, it must be identified
The legitimate interest pursued by us is keeping a record of our CSM E-Shop Customers for internal administration purposes.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required customer relationship management purposes, we will not be able to fulfil our internal administrative purposes.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
We will store such personal data for a period of 2 years from the date of collection of your personal data.
E-Shop Marketing Management
Data Subject
This section applies to the personal data of CSM E-Shop Customers.
Purpose of Processing
Where you provide us with your personal data, we will process them for direct marketing purposes only.
Categories of personal data
This includes your personal identification details, and contact information.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(f). This allows us to process personal data when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
If legitimate interest, it must be identified
The legitimate interest pursued by us is direct marketing our goods to existing customers to increase sales.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct direct marketing, we will not be able to communicate marketing material to you.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
We will store such personal data for a period of 2 years from the date of communicating the marketing material to you.
E-Shop Payments Management
Data Subject
This section applies to the personal data of CSM E-Shop Customers.
Purpose of Processing
Where you provide us with your personal data, we will process them for payment processing purposes only.
Categories of personal data
This includes your personal identification details, contact information, and user account information.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(b). This allows us to process personal data when it is necessary for the performance of a contract to which the data subject is party.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required payment processing, we will not be able to fulfil our contract with you.
Recipients
The only recipients will be our third party service providers. They will be assisting with the necessary formalities for this matter. They are located in the EEA.
Retention Period
We will store such personal data for a period of 6 months from the date of termination of our contractual relationship.
E-Shop Customer Returns Management
Data Subject
This section applies to the personal data of CSM E-Shop Customers.
Purpose of Processing
Where you provide us with your personal data, we will process them for customer service purposes only.
Categories of personal data
This includes your personal identification details, contact information, user account information, and financial information.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(b). This allows us to process personal data when it is necessary for the performance of a contract to which the data subject is party.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required customer service, we will not be able to contract with you.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
We will store such personal data for a period of 6 months from the date of the creation of our contractual relationship.
E-Shop Customer Complaints Management
Data Subject
This section applies to the personal data of CSM E-Shop Customers.
Purpose of Processing
Where you provide us with your personal data, we will process them for customer service purposes only.
Categories of personal data
This includes your personal identification details, contact information, and user account information.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(b). This allows us to process personal data when it is necessary for the performance of a contract to which the data subject is party.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required customer service, we will not be able to fulfil our contract with you.
Recipients
The only recipients will be our Manning Agents.
Where they are based outside the EEA, these include:
- United Kingdom;
- Philippines;
- Singapore;
- Japan;
- Ukraine;
- Georgia;
- Saudi Arabia; and
- Russia
We rely on GDPR Article 46(2)(c) for cross-border transfers. This allows us to transfer personal data to such recipients based on the Standard Contractual Clauses adopted by the EU Commission.
Where they are based in the United Kingdom or Japan, we rely on GDPR Article 45 for cross-border transfers. This allows us to transfer personal data to such recipients based on the EU Commission’s adequacy decision.
Retention Period
We will store such personal data for a period of 6 months from the date of termination of our contractual relationship.
E-Shop Necessary Cookie Management
Data Subject
This section applies to the personal data of CSM E-Shop Visitors and CSM E-Shop Customers.
Purpose of Processing
Where you provide us with your personal data, we will process them for customer experience purposes only.
Categories of personal data
This includes your browsing information.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(f). This allows us to process personal data when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
If legitimate interest, it must be identified
The legitimate interest pursued by us is maintaining the integrity of our IT systems and the continuity of our business.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required cookie management, we will not be able to improve the customer experience, as it may affect how the website functions.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
We will store such personal data for a period of one month from the date of Cookies’ activation.
E-Shop Non-Necessary Cookie Management
Data Subject
This section applies to the personal data of CSM E-Shop Visitors and CSM E-Shop Customers.
Purpose of Processing
Where you provide us with your personal data, we will process them for market research purposes only.
Categories of personal data
This includes your browsing information.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(a). This allows us to process personal data when the data subject has given consent, subject to the applicable conditions, to the processing of his or her personal data for the specified purposes.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required cookie management, we will not be able to have accurate statistics for CSM E-Shop Visitors and CSM E-Shop Customers.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
We will store such personal data for a period 1 year from the date of Cookies’ activation.
Cookies
Our use of cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We use necessary cookies to make our website work. We would also like to set analytics cookies that help us make improvements by measuring how you use the website.
Necessary cookies
Necessary cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts, and payment processing. Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions.
We use necessary cookies to enable certain functions on our website.
Performance cookies
Performance cookies track how you use a website during your visit. Typically, this information is anonymous and aggregated, with information tracked across all website users. They help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. We would like to set Google Analytics cookies to help us improve our website by collecting and reporting information on how you use it. The cookies collect information in a way that does not directly identify anyone. These will be off by default and set only if you accept.
We use performance cookies on our website.
Targeting cookies
Targeting cookies help determine what promotional content is most relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These will be off by default and set only if you accept. Targeting cookies set by third-parties may be used to track you on other websites that use the same third-party service.
We use Targeting cookies on our website.
How do I change my cookie settings?
You can change your cookie preferences relating to our website at any time by clicking on the ‘C’ icon. You can then adjust the available sliders to ‘On’ or ‘Off’, then clicking ‘Save and close’. You may need to refresh your page for your settings to take effect.
Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, we recommend to visit www.aboutcookies.org or www.allaboutcookies.org.
To find information relating to your specific browser, please visit your browser’s website.
To opt out of being tracked by Google Analytics across all websites, you can visit http://tools.google.com/dlpage/gaoptout .
Data Subject Rights
We shall respond without undue delay to requests made by Data Subjects to exercise their rights in relation to the personal data we process.
Under certain circumstances, data subjects have certain rights, including:
Access
Data subjects have the right to obtain the following from the Company:
- Confirmation that the Company is processing their personal data;
- Copy of their personal data;
- Other supplementary information which is already included in the Company’s General Privacy Notice
Rectification
Where personal data is inaccurate, data subjects have the right to request that it be corrected and incomplete personal data be completed based on information they may provide.
Erasure
The right to erasure is also known as “the right to be forgotten.” It applies only in certain circumstances.
Restriction on Processing
Data subjects may request from the Company the restriction of processing of their personal data.
Object to Processing
Data subjects have the right to object to the processing of their personal data in some circumstances. However, data subjects have the absolute right to object to the processing of their personal data for direct marketing purposes.
Portability
Under certain circumstances, data subjects have the right to receive personal data in a structured, commonly used and machine-readable format. This allows data subjects to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.
Right to withdraw consent if processing is based on consent
Where the legal basis for processing is the consent of data subjects, the GDPR entitles data subjects to the right to withdraw their consent at any time.
Right to lodge a complaint with a supervisory authority
Data subjects have the right to complain if they have concerns about the way the Company is handling their personal data.
Automated decision making
Data subjects have the right not to be subject to a decision which is based on automated decision making or profiling, without the involvement of human intervention.
We do not use automated decision making.
How do I exercise my rights?
If you wish to contact our Data Protection Officer, you can do so in the ways set out in the relevant section at the beginning of this notice.
Alternatively you can use the following link to submit a request via our dedicated portal:
https://columbia-eshop.com/contactus