This Privacy Policy explains how Sabiedrība ar ierobežotu atbildību “Duna Marine Shipmanagement”, registration No.40103591924 (“Duna Marine”, “we”, “us” or “our”) processes personal data in connection with our website, recruitment, crewing, crew management and related maritime personnel services.

This Privacy Policy applies to website visitors, seafarers, cadets, applicants, candidates, crew members, former crew members, emergency contacts, representatives of shipowners, ship managers, clients, suppliers, service providers and other persons whose personal data we process in the course of our activities.

Data controller

Sabiedrība ar ierobežotu atbildību “Duna Marine Shipmanagement”

Registration No.: 40103591924

Registered address: Duntes iela 17A, Rīga, LV-1005, Latvia

E-mail: info@dunamarine.com

For privacy-related requests, please contact us by e-mail and use the subject line “Data Protection Request”.

Personal data we process

Depending on your relationship with us and the services involved, we may process the following personal data:

• identification and contact data, such as name, surname, date of birth, nationality, address, e-mail address, telephone number, photograph, passport details, seafarer’s book details and other identity documents;
• recruitment and professional data, such as CV, application form, rank, availability, employment history, sea service records, references, interview notes, appraisals, experience, skills and suitability for maritime positions;
• qualification and training data, such as certificates of competency, STCW certificates, flag state endorsements, training records, diplomas, licences, expiry dates and verification records;
• medical, fitness and safety-related data, such as medical fitness certificates, vaccination or health-related information where required for a particular assignment, emergency information, accident or incident records and other data necessary for occupational health, safety or maritime compliance;
• travel and immigration data, such as visa information, travel itineraries, tickets, port and joining arrangements, accommodation details and information required by immigration, border, port or flag state authorities;
• financial, payroll, tax and insurance data, where relevant to payments, expenses, payroll, accounting, insurance or related administration;
• compliance and risk-management data required for legal, regulatory, maritime labour, sanctions, anti-fraud, audit, safety, security or dispute-resolution purposes;
• correspondence and business contact data, including e-mails, messages, call notes, meeting notes and contact history;
• technical website data, such as IP address, browser information, device information, access time, visited pages, error logs and security logs, where such data is processed by website infrastructure or security systems.

Sources of personal data

We may collect personal data directly from you or from other lawful sources, including shipowners, ship managers, vessel operators, masters, previous employers, referees, crewing agencies, training providers, medical clinics, travel agents, visa service providers, maritime authorities, flag state authorities, port agents, public registers, professional databases and other parties involved in recruitment, verification, documentation, deployment or crew management.

If you provide personal data about another person, such as an emergency contact or referee, you must ensure that you are authorised to do so and that the person has been appropriately informed.

Purposes of processing

We process personal data for the following purposes:

• to communicate with you and respond to enquiries;
• to receive, review and manage applications, CVs and candidate profiles;
• to assess suitability, qualifications, experience, availability and eligibility for maritime positions;
• to verify identity, certificates, sea service, references and other relevant information;
• to present suitable candidates to shipowners, ship managers, vessel operators and other manning principals;
• to arrange recruitment, employment or engagement processes, crew changes, travel, visas, port formalities, flag state documents, training, medical fitness checks, insurance and other operational requirements;
• to manage crew planning, rotations, records, communications, appraisals and operational support;
• to administer payments, payroll, expenses, accounting, tax, insurance and invoicing where applicable;
• to comply with maritime labour, crewing, recruitment, employment, immigration, tax, accounting, safety, security, audit and other legal or regulatory obligations;
• to protect health, safety and vital interests in emergencies;
• to prevent, detect and investigate fraud, document irregularities, security incidents, unlawful activity or breaches of applicable requirements;
• to establish, exercise or defend legal claims and protect our rights, business and reputation;
• to manage business relationships, service quality, internal records, audits, reporting and administration; and
• to maintain the functionality, security and integrity of our website, IT systems and records.

Legal bases for processing

We process personal data only where a lawful basis applies. Depending on the circumstances, we may rely on:

• performance of a contract or pre-contractual steps, for example when assessing your application, arranging a position, preparing documentation or managing deployment;
• compliance with legal obligations, including obligations under Latvian law, European Union law, maritime labour requirements, employment, immigration, tax, accounting, safety, security, court or authority requirements;
• legitimate interests, including operating a crewing and maritime recruitment business, maintaining candidate and crew records, matching candidates with vacancies, verifying professional information, ensuring service quality, protecting IT systems, preventing fraud and defending legal claims;
• consent, where required for specific processing activities, including certain uses of special category data or where we ask for consent for a particular purpose;
• vital interests, for example in medical emergencies, accidents, urgent repatriation or emergency contact situations.

Where we process health data or other special categories of personal data, we do so only where permitted by law, including where explicit consent has been given, where processing is necessary for employment, occupational health or assessment of working capacity, where vital interests must be protected, where legal claims are involved, or where another lawful basis applies.

Where criminal offence-related data or similar sensitive compliance information is processed, this is done only where permitted or required by applicable law and subject to appropriate safeguards.

When personal data is required

Certain personal data is necessary for us to assess applications, verify eligibility, comply with maritime and legal requirements, arrange crew deployment, prepare documents, organise travel, make payments or perform contractual and operational obligations.

If required information is not provided, we may be unable to consider your application, submit your profile, arrange deployment, complete documentation, provide services or comply with applicable requirements.

Disclosure of personal data

Where relevant and lawful, we may disclose personal data to:

• shipowners, ship managers, vessel operators, manning principals, masters, superintendents and authorised client representatives;
• maritime administrations, flag state administrations, port authorities, immigration and border authorities, consulates, tax authorities, social insurance authorities, courts, law enforcement bodies, regulators and other competent authorities;
• training centres, certificate verification bodies, educational institutions and professional organisations;
• medical clinics, doctors, occupational health providers, laboratories and insurance providers;
• travel agents, airlines, transport providers, hotels, visa service providers, port agents and logistics providers;
• banks, payroll providers, accounting service providers, auditors, insurers and financial service providers;
• IT, hosting, communication, document management, recruitment, crew management and cybersecurity service providers;
• professional advisers, including lawyers, accountants, auditors and consultants;
• affiliated companies, authorised agents, representatives and cooperation partners involved in recruitment, crew management, documentation, deployment or related support;
• other persons or organisations where disclosure is required or permitted by law, necessary to protect our rights, safety or legitimate interests, necessary for legal claims, or necessary for the provision of our services in a particular case.

International transfers

Crewing and maritime recruitment are international by nature. Personal data may be transferred outside Latvia and outside the European Economic Area to shipowners, ship managers, vessel operators, agents, authorities, travel providers, port agents and other recipients involved in international crew deployment.

Where required by law, we use appropriate safeguards for such transfers, such as European Commission standard contractual clauses, contractual confidentiality and security obligations or other recognised transfer mechanisms. In specific cases, transfers may also be necessary for contract performance, pre-contractual steps, legal claims, important public interest reasons, protection of vital interests or based on your explicit consent.

Retention of personal data

We retain personal data only for as long as necessary for the purposes for which it was collected or otherwise lawfully processed. The applicable retention period depends on the type of data, the nature of our relationship with you, maritime and regulatory requirements, contractual obligations, accounting and tax requirements, safety considerations, limitation periods and the need to establish, exercise or defend legal claims.

Candidate and crew records may be retained where necessary for recruitment, future maritime opportunities, crew management, verification of sea service, compliance with maritime requirements, audit, safety, insurance, accounting, dispute-resolution or legal purposes. When personal data is no longer required, we delete it, anonymise it or securely restrict access to it, unless continued retention is required or permitted by law.

Security and confidentiality

We apply appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access and other unlawful processing.

Although we take reasonable steps to protect personal data, no internet, e-mail or electronic storage system can be guaranteed to be completely secure. You should take appropriate care when sending sensitive documents electronically.

Your rights

Subject to applicable legal conditions and limitations, you may have the right to:

• access your personal data;
• request correction of inaccurate or incomplete data;
• request deletion of data in certain circumstances;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive certain data in a portable format where applicable;
• withdraw consent where processing is based on consent;
• lodge a complaint with a supervisory authority.

To exercise your rights, please contact us using the details mentioned above. We may ask for information necessary to verify your identity and locate the relevant data.

Your rights are not absolute. We may refuse or limit a request where permitted by law, including where processing or retention is necessary for legal obligations, maritime records, safety, contractual obligations, legal claims or the rights of others.

Supervisory authority

You have the right to lodge a complaint with the Latvian supervisory authority:

Data State Inspectorate of Latvia / Datu valsts inspekcija

Address: Elijas iela 17, Rīga, LV-1050, Latvia

E-mail: pasts@dvi.gov.lv

We encourage you to contact us first so that we can try to resolve your concern directly.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our activities, website, technology, legal requirements or internal procedures. The updated version will be published on our website and will apply from the date of publication unless stated otherwise.