Privacy Policy - Siem Global Logistics

Welcome to the Siem Global Logistics privacy policy. Siem Global Logistics respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy policy This privacy policy aims to give you information on how Siem Global Logistics collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, apply for a job, or request a rate for a service. This website is intended for a business audience and provides general information on our fleet, agents and the services we provide. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. Controller Siem Global Logistics is made up of different legal entities. This privacy policy is issued on behalf of the Siem Global Logistics Group so when we mention "SCC", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Siem Global Logistics Group responsible for processing your data. SGL Administration Services LLC is the controller and is responsible for this website. Contact details If you have any questions about this privacy policy or our privacy practices, please contact us at compliance@siemcarcarriers.com. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the privacy policy and your duty to inform us of changes We keep our privacy policy under regular review. This version was last updated on 17 June 2021. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Third-party links 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 policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
Technical Data may include (but may not be limited to) internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes purchases or orders made by you, your interests, preferences and feedback.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

request a rate and/or apply for our services;
subscribe to our service or publications;
request marketing to be sent to you; or
give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:

analytics providers such as Google based outside the UK;
search information providers such as Google, Yahoo, Bing based inside and/or outside the UK.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity, Financial and Contact Data from credit agencies, such as Dun & Bradstreet, Inc. based outside of the UK.
Identity and Contact Data from publicly available sources such as Companies House in the UK and similar sources in other jurisdictions.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To respond to your request for a rate and/or process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To enable you to subscribe to updates, complete a survey or to give feedback	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.

Cookies

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 cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

Within the Siem Global Logistics Group

As stated above, SCC Administration Services LLC carries out the data processing function on behalf of Siem Global Logistics. Accordingly, your personal information will be processed by that company.

Each of the companies in the Siem Global Logistics group have their own specific remit. If necessary, we will pass your personal information to the relevant subsidiary so that it can be actioned appropriately.

Our Business Partners

Your information may be accessible by our electronic communications providers and our search engine providers.

The following are used by us:

Bison Grid (web hosting services); and
Microsoft (Cloud Services); and
Google Analytics.
Google Cloud Services
Digital Ocean (UK data centers and virtual web servers)
Sendgrid (Data transmission services)
Pulsant (Data back up services)

Legal Requirements and Law Enforcement

We may also disclose your personal information to third parties in the following circumstances:

If we sell our business, in which case the personal information that we hold will be part of the transferred assets.
If we are required to by law, or in order to enforce the Website terms of use. This includes exchanging information with other organisations for the purposes of fraud protection and credit risk reduction and also law enforcement agencies.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We may share your personal data within the group of companies of which Siem Global Logistics is a part when processing or dealing with your requests or when providing our services to you. This will involve transferring your data outside the EEA and/or UK. In addition, many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the EEA and/or UK.

Whenever we transfer your personal data out of the EEA and/or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the EEA and/or UK which give personal data the same protection it has in the EEA and/or UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

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 in respect to our relationship with you.

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 unauthorised 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.

Where by law we are required to keep basic information about our contractual customers (including Contact, Identity, Financial and Transaction Data), this will be held for seven years after they cease being customers for compliance purposes. Data submitted through our website which does not result in a contractual relationship with us, will be stored for a period of 30 days only.

In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Your Rights

Access to information

You have the right to access information that we hold about you. If you wish to receive a copy of the information that we hold, please contact us at compliance@siemcarcarriers.com. or write to us at the address above.

Changing or deleting your information

You can ask us at any time to change, amend or delete the information that we hold about you or ask us not to contact you with any further marketing information. You can also ask us to restrict the information that we process about you.

You can request that we change, amend, delete your information or restrict our processing by emailing us at compliance@siemcarcarriers.com or writing to us at the address above.

Right to prevent Automated decision making

You have a right to ask us to stop any automated decision making. We do not intentionally carry out such activities, but if you do have any questions or concerns, we would be happy to discuss them with you and you can contact us at compliance@siemcarcarriers.com.

Transferring Personal Information

You have the right to request that your personal information is transferred by us to another organisation (this is called “data portability”). Please contact us at compliance@siemcarcarriers.com with the details of what you would like us to do, and we will try our best to comply with your request. If may not be technically feasible, but we will work with you to try and find a solution.

Third-party links

The Website may contain links to websites owned by other organisations. If you follow a link to another website, these websites will have their own privacy policies. We suggest that you check the policies of any other websites before giving them your personal information as we cannot accept responsibility for any other website.

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 aim to deal with all legitimate requests within a reasonable time frame and in accordance with any requirement set out in law or regulation. Occasionally if your request is particularly complex or you have made a number of requests it could take us longer to deal with the request. In this case, we will notify you and keep you updated.