Job Applicants Privacy Notice
This Privacy Notice (hereinafter “the Privacy Notice”) is addressed to you, as a job applicant (hereinafter “You” or “the Job Applicant”) to “Empire Bulkers Ltd.” (hereinafter “the Company” or “We”), with offices at 88 Vouliagmenis Ave, 16777, Elliniko, Greece, in compliance with the provisions of Regulation 2016/679 of European Parliament and Council of the European Union (also known as the General Data Protection Regulation or GDPR, hereinafter “GDPR”).
All references to “employment” and/or “job” shall apply equally to internships (as may be applicable).
When applying for a job at our Company, the Company collects, keeps and processes information about you that constitute Personal Data (as defined in the GDPR) of yours. This Notice is to inform you on such processing according to the respective legislation in force.
[For more information on our data protection policies and procedures and for exercising your lawful rights as data subjects, you can refer to our Data Protection Policy online ( https://www.empirebulkers.com/company-policies/data-protection-policy ) and you can always directly contact dpo@ empirebulkers.com ]
1. How we collect your personal data
The Company collects your information:
(i) directly from you, when you send your CV to the Company; or
(ii) indirectly, whenever you apply through a third-party platform / HR agency etc.
2. What kind of data we process
The Company may process, as the case may be, your personal Data and information referring to your job application, including, without limitation, your: (a) name, gender, identity card number or passport number, tax and social security number, date of birth, nationality, country and city of birth, bank details; (b) residence or mailing address, telephone numbers, email address, IP address, social media posts and other contact details; (c) Resume, educational qualifications, diplomas, degrees, professional qualifications and certifications and employment references; (d) employment and training history; and (f) pictures/photographs, if any, included in your application or other special categories of Personal Data as defined in the GDPR .
3. Why we process your data
Your Personal Data will be processed by the Company in order to assess and evaluate your suitability for employment in any current or prospective position within our Company, as well as to verify your identity and the accuracy of your personal and professional details and other information provided by you. Your Personal Data may also be processed in compliance with the Company’s legal obligations or for other legitimate reasons or for reasons of public interest or for protecting your vital interests.
We will not retain your resume and supporting documents, if any, in order to inform you of possible job openings appropriate for your qualifications, unless you give us your explicit consent to that end . In such case, your consent will remain valid until such time it is being withdrawn by you in writing to the dpo@ empirebulkers.com.
4. Use of and access to your Personal Data
Your Personal Data will be used for the purposes mentioned in para 3 above and for our management and administrative use only.
Your information will be disclosed only to appropriate Company’s personnel, including representatives of the HR Department or other competent personnel (executive managers involved in the recruitment process).
It may also be disclosed to third parties if we are legally obliged to do so, including to our service providers which may process data on our behalf. Due to our global activities and the nature of our business as a Shipmanagement company, your information may be transferred outside of the E.E.A., in compliance with our legal or contractual requirements or obligations. We will do so only where an adequate level of protection is ensured or where we have in place safeguards including the use of standard contractual terms, to ensure the security of your data in case of these transfers.
We might also transfer information about you to companies affiliated with the Company, for purposes connected with utilizing your job application or the management of the Company’s business.
In all such cases, we shall do so where appropriate and only in accordance with local laws and requirements, always making sure that such third parties have adopted appropriate and necessary data processing procedures to ensure the security and confidentiality of your Personal Data.
5. Duration of retaining
We may retain your Personal Data for as long as it is necessary to fulfil the legitimate purposes mentioned in para 3above or as required or permitted by applicable laws.
If you consent to our informing you of job openings, we will retain the data after the assessment thereof has been concluded for the period that you have provided your consent and in any case for no more than it is necessary for this purpose.
Throughout the period that your data is retained by the Company, we will implement and at all times have in force appropriate technical and organizational procedures, in order to safeguard your rights as data subject. We will also ensure security and confidentiality of your data, by adopting all necessary procedures, including measures and procedures for the restriction of unlawful or unauthorized access to your data and for the limitation of accidental loss, destruction or damage.
6. Your rights
As a Job Applicant, you may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to our authorized Officer at the contact details provided herein. Subsequently, you will have at any time access to the data, right to rectification or erasure (“right to be forgotten”), restriction of the processing, objection to the processing, objection to automated decision making and right to the data portability. You will also have the right to request and have erased and/or destroyed from the Company us without undue delay (see also paragraph 7) any Personal Data of yours by following the above-mentioned procedure.
Upon receipt of your written request to the Company withdraw your consent and/or erase and/or destroy your Personal Data, the Company we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for processing your request to and for us to notify you of the consequences of our acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
In general, we shall seek to process and effect your request within thirty (30) days from the date of due receipt thereof.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may in such case not be in a position to process your job application (as the case may be).
Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws or under another legal basis for processing.
Unless subject to an exemption, you also have the right to request from us access to and rectification or erasure and/or destruction of your Personal Data; to restrict processing, object to processing, as well as in certain cases the right to data portability; and the right to lodge a complaint with the competent Data Protection Authority.
7. What happens if you submit your Resume
By sending your Resume and any supporting documents to the Company:
(a) you acknowledge that you have read, understood and agreed to the present Notice, and consent to the collection, processing use and/or disclosure of your Personal Data by the Company for the purposes set out hereinabove; and
(b) in the event that the Company has received your job application or Personal Data from any third party in accordance to the purposes set out in this Notice, you hereby warrant that such third party has been duly authorized by you as per the GDPR to disclose your Personal Data to us for the purposes set out in this Notice.
8. Before signing this Notice the Job Applicant has been provided the opportunity to review and seek advice on the terms and conditions hereof.
9. The Job Applicant has reviewed carefully the above which is all made absolutely clear and specific to him/her and hereby gives expressly and fully his/her consent for the processing as specified above.
Contact details of the Company’s authorized person