SIMMIT MANPOWER
Human Resources - Manning Services
Personal data operator no. 9980

PRIVACY POLICY

SIMMIT MANPOWER Co. Ltd. (www.simmitmanpower.com) is a recruitment organization which provides work seeking services to its clients and candidates. We must process personal data (including sensitive personal
data) in such way as to provide the services of recruitment, selection and placement of personnel at shore and on board vessels (Seafareres). To perform our duties we are acting as a <personal data operator nr.9980>.
The entities covered by this agreement are:  SIMMIT MANPOWER Co. Ltd, Clients and Candidates..
You may give your personal details to us directly at office by hard copy, by e-mail as a job application, registration form, via our website, or we may collect them from another source. We must have a legal basis for
processing your personal data. For the purposes of providing you with work seeking services and/or information relating to our vacancies we will only use your personal data in accordance with the terms of this statement.

Legal bases for processing your data
Legitimate Interests
We are thinking that we have a legitimate interest in processing your personal data for the purposes of providing work seeking services to both our clients and candidates, helping us to provide you with much specific
service and that it's in everybody’s interest.
Candidates
•   We are thinking that it is reasonable to expect that if you are looking for employment or have posted your CV on a network site, you will agree for us to collect and use your personal data in order to offer/provide you with
more vacancies and employment opportunities. This can include forwarding your details to prospective employers or matching your details against our open vacancies. Our organization and  possibly employers might
want to verify certain aspects such as your references and qualifications. As a recruitment organisation we need to do it in order to avoid any non-conformities.
•  We should comply with various legal, regulatory and tax obligations therefore we may share your data with the appropriate authorities to comply with these obligations.
•  We will need to use your personal data for internal processes such as payroll or employers' invoicing in order to provide services to our customers and to you.    
• We wish to help you finding a job, so that, sending to you the job recommendations and relevant market intelligence will easy the activity. We will process your personal data to send you the appropriate summary.
Clients
To ensure that we can provide you and your organisation with the best possible service we store details of the organisation and its contacts as well as notes of conversations, emails, meetings and previous jobs and  
recruitment activity. We believe that this falls within our legitimate interest in providing recruitment services to you.
Consent:   In certain cases, such as processing sensitive data, we will need to obtain your consent. In these cases:
• You have to give your consent freely
• You have to know what you are consenting to
• You should be able to control your consent
• We will keep a record of your consent
• You have the right to withdraw your consent
Establishing, exercising or defending legal claims
Occasionally we may need to process your data when it is necessary for the establishment, exercising or defending of legal claims or whenever the courts are acting in their judicial capacity.

Collection of personal data
Candidates
During the course of providing you with work seeking services we may collect some or all of the following types of personal data.  The reason we do this is to enable us to provide the best service we can to help you find
your next job. The following list is not exhaustive and is in addition to any data that we are required by law to process:
•  Name   • Contact details  • Sex/gender  • Date of birth  • Education  • Employment history  • Immigration status  • Nationality  • Copy of passport / ID card / other form of identification  • Tax information such as social security
numbers  • Details of criminal convictions where applicable to the role  • Current salary and package  • Any further information that you tell us included in future employment preferences  • IP addresses
•  Dates that you make contact with our organisation
Clients
We will collect data that will help us ensure that the relationship between our organisations runs as smoothly as possible. This will normally be restricted to name, telephone number and email address of individual     
contacts. We may also hold IP addresses if you visit our websites.

How we collect your personal data
Candidates
We collect personal data from you in 3 (three) ways:
1.- Personal data that you give us. We need to know certain information about you in order to provide an work place to you. This will enable us to make better matches and to identify the most appropriate roles for you.  
The ways in which you can provide us with this information includes:
•   Registering on our websites
•   Sending us a copy of your CV electronically or by post
•    Applying for a role via a job board which then redirects you to our website
2.- Personal data that we receive from third parties. We may receive personal data about you from third parties and these can include:
•    Our clients may share information about you
•    Your referees may share information about you
•    We may obtain data about you from websites such as job boards and LinkedIn
•    Through social media channels
3.- Personal data that we receive automatically. We may automatically collect data about you as a result of you visiting our website and clicking of e-mails.
Clients
We collect personal data from you in 3 (three) ways:
1.- Personal data that you give us. To help us provide the best service to you and send you the most appropriate candidates we receive data as follows:
•   You contact us by phone or email
•   We contact you by phone or email, either during the normal course of business or as a result of our business development efforts
2.- Personal data we receive from other sources. We may seek and obtain additional information about you as part of our business development and due diligence processes.
•   From offline and online media
•   Delegate lists from meetings, events and conferences
3.- Personal data that we receive automatically. We may automatically collect data about you as a result of you visiting our website and clicking of emails.

How we use your personal data
Candidates
We use your data for a number of purposes:
1.- Work Seeking Services. We provide work seeking services to candidates. We want to connect you to relevant opportunities as they arise. We may use your data in the following ways if we deem it necessary to do so for  
our legitimate interest. The ways in which we might use and process your data is as follows. Again this list is not exhaustive:
•  Submitting your data to prospective employers to apply for jobs
•  Assessing your data against open vacancies to determine your suitability
•  To provide you with work seeking services
•  Storing your details on our database so that we can contact you in relation to future vacancies
•  To provide you with job alerts and other work seeking related communications
•  To enable us to meet our obligations of any contracts between you and us
•  To enable us to meet our obligations of any contracts between us and third parties with regard to your recruitment
•  Facilitating of payroll and invoicing processes
•  Verifying details that you have provided (e.g. references, qualifications and criminal history)
•  Complying with our legal obligations
2.- Marketing Activities. Where you have previously contacted us (such as registering on our web site, submitting a CV, applying for a job) we may send you details of recruitment related services,similar to the one you
specifically applied for. We may also ask you to participate in salary surveys and job related questionnaires to provide  
us with benchmarking data to better advise in your job search. For other marketing we will need your consent.
If you do not wish to receive any marketing communications from us, you can withdraw your consent by cancelling your subscription at any time.
3  Sensitive Personal Data. We may need to collect sensitive personal data such as medical information and criminal convictions if required for a specific role. We will only do this with your explicit consent. You may
withdraw your consent at any time.
4  To help establish, exercise or defend a legal claim. Occasionally we may need to use your data to establish, exercise or defend a legal claim.
Clients
We use your data for a number of purposes:
1.- Recruitment Services. Our primary function is to provide you recruitment services including presenting you with candidates; providing market intelligence such as salary surveys; and the provision of recruitment process
outsourcing services. To enable us to provide these services we will process your data in the following ways:
•        Storing your data on our database so we can contact you in relation to recruitment activities
•        Recording notes of conversations and meetings
•        For targeted marketing campaigns
•        Customer satisfaction surveys
2.-  Marketing Activities. As a matter of course we shall not seek your consent when sending marketing materials such as our salary surveys to corporate email addresses. If you wish to opt out of receiving marketing  
information you can unsubscribe from receiving them at any time.
3.- To help establish, exercise or defend a legal claim. Occasionally we may need to use your data to establish, exercise or defend a legal claim.

Who we share your personal data with
We share your data with a variety of other parties during the course of conducting our business, in a number of ways, for a number of reasons. They are as follows:
Candidates
•  Our group companies
•  Our clients and other recruitment businesses in the performance of finding suitable employment for you
•  Third party IT companies with whom we are contracted to and have appropriate data processing agreements
•  Third party services providers who perform work on our behalf (e.g. auditors, lawyers, IT providers etc.)
•  Tax and local authorities to enable us to comply with laws and regulations
•  Marketing technology providers
•  Job boards and job aggregators, where it helps us find you work
•  Managed Service Providers where our clients have outsourced their recruitment process
Clients
•  Our group companies
•  Third party IT companies with whom we are contracted to and have appropriate processing agreements
•  Third party services providers who perform work on our behalf (e.g. auditors, lawyers, IT providers etc.)
•  Tax and local authorities to enable us to comply with laws and regulations
•  Marketing technology providers

How we safeguard your personal data
We take all reasonable steps to ensure that your data is safe and protected from misuse, loss or unauthorised access. We ensure this by implementing a range of technical safeguards and operational processes. We
also have processes to deal with any suspected data breach.
If you suspect that your data has been misused, or has been compromised please contact us immediately
persdataprivacy@simmitmanpower.com   

Retention Policy
We will not retain your data longer than we need it. In certain cases we are required to hold your data to comply with tax, legal or regulatory issues, for instance payroll records. Subject to this, we will delete your data if we
haven’t had any relevant contact from you (or for clients, the company you work for or with) for a 3 (three) year period.
If you supply your services via a third party, then the relevant contact shall be with that third party. Where that third party informs us that they no longer have a relationship with you, we will hold your data for a period of 3
(three) years from that point. For the purposes of this policy, relevant contact means:
•   Communicating with us via email, telephone or mail
•   Submitting your CV or applying for a role
•   Registering and logging onto our websites
•   Completing any surveys
•   Clicking through from any of our marketing communications

Your rights
Please be aware that you have the following data protection rights:
•   The right to be informed about the personal data that we process on you;
•   The right of access to the personal data that we process on you;
•   The right to rectification of your personal data;
•   The right to erasure of your personal data in certain circumstances;
•   The right to restrict processing of your personal data;
•   The right to data portability in certain circumstances;
•   The right to object to the processing of your personal data that was based on a public or legitimate interest;
•   The right not to be subjected to automated decision making and profiling;
•   The right to withdraw consent at any time.
Where you have consented to us processing your sensitive personal data you have the right to withdraw that consent at any time by contacting our Data Controller
Mitica Stoica at persdataprivacy@simmitmanpower.com  

Overseas Transfers
We are an international business. We provide work seeking services to candidates and clients around the world, therefore to enable us to give you the best service possible we will sometimes need to transfer and store your
data internationally. This could be:
•  Between our group companies
•  To overseas clients
•  Our clients may transfer your data internally
•  To data storage facilities
•  To our suppliers where appropriate
The company may transfer only the information you provide to us to countries outside the European Economic Area (“EEA”) for the purposes of providing you with work seeking services. We will take steps to ensure
adequate protections are in place to ensure the security of your information. The EEA comprises of the EU member states plus Norway, Iceland and Liechtenstein.

Cookies
Our website stores a number of different cookies on the computer or device that you use to access our website. Cookies are small text files used by browsers to store small bits of information about a device or computer,
such as preferred settings or preferred languages.
Cookies do not take up much space (unless you have thousands of them) and cannot contain viruses or other harmful code.

Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact Data Controller Mitică Stoica at persdataprivacy@simmitmanpower.com  
Our contact details:

By post,  Data Controller, S.C SIMMIT MANPOWER S.R.L., 19 Mercur Street, 900699, Constanta City, Romania
By email: persdataprivacy@simmitmanpower.com  
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Data protection: Rules for the protection of personal data inside and outside the EU.      
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    PROGRAM:                                                                                               ADDRESS:                                                                                   
                
    Monday - Friday: 10:00 - 18:00 (GMT + 2)                                              19 Mercur Street, Constanta city, 900699 ROMANIA                +4 0241 545 606                           +4 0341 176 750

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