As of: 22 July 2019
We would like to assure you that the collection and processing of your personal data by Clearlake Shipping Pte Ltd. (“we”, “our”, “us”) as per the below will be always in full compliance with the EU General Data Protection Regulations 2016/679 (“GDPR”) and other applicable privacy laws.
You can find more information about our activities by clicking on the page “About”.
For what purpose and on what legal basis do we collect your personal data?
You can visit our website without disclosing your identity. The collection and processing of your personal data takes place for the following purposes, in accordance with Art. 6 GDPR:
What kind of personal data do we collect and why?
Personal data is any information relating to an identified or an identifiable natural person who can be directly or indirectly identified by reference to an identifier.
Personal data includes, for example, information such as your name, location data, online identifier, address, telephone number and organization. Statistical information that cannot be directly or indirectly associated with you – such as measuring traffic on our website – is not considered personal data. In any case, your personal data is collected only to the extent necessary: it will be processed solely for the purposes mentioned above.
In addition, the use of our website may result in indirect personal data processing about you, for example:
Your personal data is obtained via the Contact form or otherwise on our website, emails, phone calls/voicemail; when initial requests or enquiries are made and subsequently processed by our teams. Such contact may be made directly or indirectly.
Our website is not intended for minors and we do not knowingly collect personal information from minors. If persons under the age of 16 transfer personal data to us, it will only be processed if the parent or guardian/legal representative has consented or validated the minor’s consent. For this purpose, the contact details of the legal representative must be communicated to us in accordance with Art. 8 para. 2 GDPR.
We may share the personal data you provide to us within the Gunvor Group, always in accordance with the GDPR and any other applicable privacy laws.
We may perform some of our operations by relying on third-party suppliers. The personal data that you provide may be shared with these suppliers in order to enable them to perform the required tasks. However, these suppliers are required to exclusively use the received information for the respective services on behalf and as instructed by us and they are obliged to comply with the applicable data protection regulations.
Third parties may have access to your personal data without your consent if there is a legal basis for it.
Where a data transfer may be necessary, we will take necessary steps to ensure that your personal data has the level of protection required by the GDPR. We will notify you and seek your consent to processing, in each case if required.
We store your personal data in various locations and with different service providers (i.e. external datacenters).
As a matter of principle, personal data is retained (1) for as long as needed to achieve the purposes as described in this Policy, or (2) if we have another legal basis that requires a longer storage period.
We will delete or anonymise personal data (or equivalent) once they are no longer necessary to achieve the purposes for which they have been collected, subject however (i) to any applicable legal or regulatory requirements to store personal data for a longer period, or (ii) to establish, assert, exercise and/or defend actual or potential legal claims, investigations or similar proceedings, including legal holds.
You have the right, subject to the applicable local data protection legislation, to:
If you object to the processing of your personal data, we will no longer process the personal data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Subject to the limitations set forth herein and/or in applicable local data protection laws, you can exercise the above rights free of charge by contacting us at: firstname.lastname@example.org
We have established the security in accordance with the GDPR principles. The measures taken are technical and organizational measures relating to data security in order to guarantee an adequate level of protection regarding confidentiality, integrity, availability of the data and resilience of the systems.
Technical measures are those that directly involve the IT system. Organizational measures, on the other hand, are related to the system’s environment and processes; and particularly to the people using it. The combination of both types of measures can prevent data from being destroyed or lost by mistakes, fakes and unauthorized access from occurring.
These measures are part of the life cycle of our organisation and are implemented at every level of the system. Furthermore, security is an ongoing process, not a static element. In this perspective, the technical and organizational measures are subject to technical progress and further development as risks and threats do.
We use Google Analytics, a web analytics service made by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are small text files are placed on your computer’s hard drive when visiting our website. Once you agree for the file to be added, the cookie helps analyze web traffic or your visit/use of a particular website (including your IP address) and will be transmitted and stored by Google servers. This web application gather data on your interests and save your personal preferences. By doing so, you do not have to re-enter your preferences each time you visit the website.
Cookies help us to provide you with a better website, by enabling us to monitor which pages of our website that you find useful and which you do not. Cookies do not provides us with access to your computer.
We will not use this information in connection with any personally identifiable information you have provided. Before cookies are placed on your computer or device, you may choose to accept or decline, following an automatic prompt which will appear requesting you to do so.
Most web browsers automatically accept cookies by default, but you can modify your browser setting to decline cookies if you would prefer, however this may prevent you from availing full advantage of our website.
Please keep in mind that in case of complete cookies removal from your browser, you may have to reset this when you visit our website again. Cookies are also browser specific, which means they must be set separately for each browser you use on each device you use.
We reserve the right to review this Policy periodically and where necessary, due to changes in business operations or data protection regulations or applicable employment legislation. Any updated version of this Policy will be uploaded on our website. By doing so, you are consistently aware of what and how data is processed. We recommend that you check our website from time to time to ensure that you remain satisfied with any such changes at time you send us new or additional information. You will find the date of the latest version at the beginning of the present Policy.
Feel free to contact us for more information. In addition to the Contact page on our website, should you have any enquiries, concerns or requests regarding this Policy, how your personal data is processed, please use the contact details below. You can address your questions, comments or request regarding privacy.
Clearlake Shipping Pte Ltd.
2 Marina Boulevard 35-02 Marina Bay Financial Centre Tower 3, Singapore, 018982