GENERAL PRIVACY NOTICE

1. When you visit the osmthome.com website

When you visit the osmthome.com website, we collect data through cookies as described in our Website Cookie Notice and in the nominated section below. The information we collect through cookies consists of data relating to your device, IP address, and your use of the website. We use the data collected through cookies for the purposes of offering you the best user experience and for improving the website content by tracking usage patterns and recording preferences. You can accept and reject cookies by heading to the settings section in your browser.

2. When you contact us

When you contact us, for example for customer offers, or for website feedback, we can collect personal data about you, such as your name, e-mail address, and other information you wish to provide us with to respond to your comment or enquiry. If you register for one of our events, we can collect information about your name, contact information, and, if applicable, dietary preferences or similar information.

The legal basis for this processing is that the processing is necessary for fulfilling a contract with you or for taking steps prior to entering into a contract, or that it is in our legitimate interest to meet your request and to improve our business and services and these interests are not overridden by your rights to data protection.

3. Recruitment

When you apply for a job through the website, we use a job application portal operated by an external service provider on our behalf, for processing and handling your job application. When you apply for a job, we collect your name, contact information, CV, education level, competencies and skills, career, and work experiences. If relevant, you may also provide us with your social security number, job certificates, references, and other relevant background information.

We use this information in order to determine your eligibility for the job that you apply for by assessing whether you are the right candidate for the position in question.

With your consent, we may also retain your data for the purposes of identifying you as a potential candidate for future suitable vacancies and/or to inform you of future suitable vacancies.

The legal basis for processing and storing your job application, CV, and related information is your consent, and that the processing is necessary in order to take steps at your request prior to entering into a contract. You can withdraw your consent or update your information at any time through the job application portal or by contacting us at dataprotection@osmthome.com 

For certain positions, for very limited positions, it may be necessary to process your criminal records in order to ensure that you are permitted to undertake the role in question. Such information will only be processed in accordance with GDPR Article 10 and applicable local legislation.

4. Management and support

OSM Thome processes business-related data on customers, suppliers, and partners, and their employees, to support and manage customer, supplier, or partner relationships (internal/external), to provide products and services to third parties as well as for business operation and protection of business interests and security.

The legal basis for this processing is our legitimate business interests in ensuring good management of and support for customers, suppliers, partners, and third parties and to comply with legal obligations. On some occasions, the legal basis may also be consent.

5. Compliance with legal obligations and information relating to legal proceedings

OSM Thome may process personal data necessary to comply with legal obligations, for example, tax and accounting information and information relating to legal proceedings. The purpose and legal basis for this processing are our legal obligations and legitimate interests in the establishment, exercise, or defense of legal claims.

6. If you fail to provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

In the course of your ordinary dealings with us, we may collect personal information directly from you when you:

– Submit your employment application, curriculum vitae, personal data sheet, and similar applications.
– Fill out forms, contracts, and agreements necessary for the processing of your employment applications.
– Submit your personal information when you register with “E-Crew”, our online applicant and crew management system.
– Submit your personal information when registering with our “Applicant Kiosk” in the Philippines.
– Other communications with us (such as when you contact us for inquiries regarding job availability or the status of your application). We may also collect information indirectly from third parties (such as head hunters, background check providers, and recruitment agencies) to which you have given consent for the disclosure of such information relating to you and where otherwise permitted by law.

As you interact with our website, we will automatically collect technical data about your equipment, browsing actions, and patterns. This we collect using cookies, add-ins, or other similar technologies. Please use our Website Cookie Notice page for more information.

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookies are text files containing small amounts of information that are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie.

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Website Cookie Notice.

We share your personal data with the parties set out below for the purposes set out above.

– Internal Third Parties are other companies in the OSM Thome that are based in the EU as well as in Non-EU countries. For the full list of entities that form part of the OSM Thome, with their geographical location, please visit appendix 1 of this notice.
– We do not share the information we collect about you from the website with any 3rd parties. However, we may share this information with law enforcement agencies, Government, and regulatory bodies to meet legal and regulatory obligations.

We share your personal data within OSM Thome. This will involve transferring your data outside the European Economic Area (EEA). Not all countries provide the same level of protection in relation to personal information as within the EEA.

Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to personal information.
This will include having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for personal information. Examples of such safeguards are Binding Corporate Rules, the EU`s modernised Standard Contractual Clauses or if the receiving party is certified under the EU-US Privacy Shield.

In order to protect your personal information against misuse, alteration, loss, or destruction and against accidental or unauthorized access or disclosure, we strictly enforce this Notice within the Company and have implemented appropriate physical, organizational, and technical security measures and procedures.

These measures/procedures are regularly reviewed and updated in order to maintain the accuracy and integrity of the information. We will implement the necessary changes to ensure the continuous security of your personal information.

In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a clear and strictly necessary business need to know.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you. However, under no circumstances are personal data to be kept longer than the law provides.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, you can ask us to delete your data: see “Your Legal Rights” below for further information.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

– Request access to your personal data
– Request correction of your personal data
– Request the erasure of your personal data
– Object to processing of your personal data
– Request restriction of processing your personal data
– Request transfer of your personal data
– Right to withdraw consent

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

-If you want us to establish the data’s accuracy
-Where our use of the data is unlawful but you do not want us to erase it
-Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims
-You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to information we process by automated means, where the processing is on the basis of your consent or for us to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

You could exercise any of the rights set out above by contacting us at dataprotection@osmthome.com

NO FEE IS USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our internal GDPR team by e-mail at dataprotection@osmthome.com or by post and send it to:

OSM Thome Headquarters Norway
Group Data Privacy Officer: Dag Henning Stavelin
P.O. Box 1684, NO-4857
Arendal, Norway
Contact No.: +47 41 49 20 00

OSM Thome Brazil
Data Privacy Officers: Vanuza Sampaio, Vivian da Silva Braga
OSM Brasil Gerenciamento de Operações Marítimas Ltda.
Rua da Assembléia, 10 sala 2213 – Rio de Janeiro – Brasil
No de Contato: +5521 99218 0810
Email: dataprivacyofficerbrazil@osmthome.com

OSM Thome Nigeria
Data Privacy Officer: Emmanuel Ononogbu
TOG Shipping & Offshore Management Nigeria Ltd
Empire Building – Plot 1683, Sanusi Fafunwa Street, Victoria Island, Lagos State, Nigeria

OSM Thome Philippines A’
Data Privacy Officers: Richard Macarubbo, Morena Jara, Angela Chow
OSM Maritime Services Inc and OSM Ship Management Pte. Ltd.
OSM Building, 479 Pedro Gil Street Ermita, Manila 1000 Philippines
Contact No.: +6325238871
Fax No.: +6323021132
Email: dataprivacyofficermanila@osmthome.com

OSM Thome Philippines B’
Data Privacy Officer: Jun Amomonpon 
Aegir, Thome Maritime Academy (TMA), and Thome Services Inc (TSI)
1753 Dian St., Palanan, Makati City, Philippines, 1235

OSM Thome Philippines C’
Data Privacy Officers: Capt. Alfredo Agustin and Capt. Jones Tulod
TSM Dry Shipping (Phils.) Inc, and TSM Shipping (Phils.) Inc
3rd Floor, TSM, House, 1753 Dian St., Palanan, Makati, 1235 Metro Manila

OSM Thome Philippines D’
Data Privacy Officer: Artemio Serafico
TSM Maritime Services (Phils.) Inc.
5th Floor 1751 Bldg. Dian St. Brgy. Palanan, Makati City

OSM Thome Singapore
Data Privacy Officers: Ng Wei Kuan, Alex Choo, Jamie Morgan Ramsamy
1 Marina Boulevard, #17-01 One Marina Boulevard, Singapore 018989
Contact No.: +65 6220 7291

You have the right to make a complaint at any time to the concerned supervisory authority for data protection issues.

We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

Please note that OSM Thome reserves the right to amend this Privacy Notice at any time without prior notice, in order to fulfil our legitimate business purposes or to comply with government and regulatory requirements. We will notify you of any such updates and amendments via our official website or by email.