Privacy Policy

POLICY STATEMENT

The UK General Data Protection Regulation, as retained by the European Union (Withdrawal) Act 2018, the Data Protection Act 2018 was enacted to introduce the General Data Protection Regulation ((EU) 2016/679)) (“GDPR”) to UK law and repeal and replace the Data Protection Act (DPA) 1998. It sits alongside the UK General Data Protection Regulation, (the retained law version of the GDPR) (the “UK GDPR”) (together “Data Protection Laws”). The Data Protection Laws govern the processing, such as the use or holding, of personal data, which is essentially any information about identifiable living individuals, and gives those individuals certain rights and remedies in respect of that information.

1.    ABOUT THIS NOTICE

This privacy notice (“Notice”) sets out how Braemar Plc and its subsidiaries (“Braemar”) uses and protects your personal data. This Notice sets out the essentials in relation to personal information collected by Braemar and aims to help your confidence regarding the privacy and the security of your personal information. We may collect information from you using this website, including any data you may provide to us when you register with us, apply for a job with us, become our client, or contact us in person, by telephone, by email or by post. We also collect information from you when you provide feedback or complete a contact form on our website.

Please read this Notice carefully. By visiting our website or using any of our services, you indicate your agreement to our use of your personal information as set out in this Notice.

If you have any questions regarding this Notice, please contact dataprotection@braemar.com.

2.    CONTROLLER

Braemar is made up of different legal entities around the world. This Notice is issued on behalf of the entire Braemar Group. Braemar Shipbroking Limited is the controller and responsible for this website.

3.    WHAT INFORMATION WE COLLECT, USE AND WHY

When do we collect information and why?

We may collect, use, store and transfer different types of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes addresses, email address and telephone numbers.
• Financial Data includes shareholder data and bank account details.
• Technical Data includes 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, device ID and other technology on the devices you use to access this website.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

4.      HOW IS YOUR PERSONAL DATA COLLECTED?

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

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • hold shares with us;
  • apply for a job with us;
  • enter a competition, promotion or survey; 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 and other similar technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out:
  • Technical Data is collected from the following parties:
    • analytics providers such as Google based outside the UK;
    • information from Worldcheck and other similar “know your customer (KYC)” applications; and
    • advertising networks such as LinkedIn or TradeWinds based inside the UK.
  • Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.

5.    HOW WE USE YOUR PERSONAL DATA

LAWFUL BASIS

Data Protection Legislation requires us to have a legal basis for collecting and using your personal data. We rely on the one or more of the following lawful bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

6.    PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use the various categories of 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.

7.    INTERNATIONAL TRANSFERS

We may share your data within the Braemar Group. This may involve transferring your data outside of the UK to our overseas offices in:

• Australia
• China
• Germany
• Greece
• India
• South Korea
• Singapore
• Spain
• Switzerland
• United Arab Emirates (UAE)
• United States of America

Whenever we transfer your personal data out of the UK to countries which have not been deemed by the UK to provide an adequate level of protection for personal data, we will always ensure that a similar degree of protection is afforded to it through relevant data transfer mechanisms.

IF PERSONAL DATA IS TRANSFERRED OUTSIDE THE UK TO SERVICE PROVIDERS:

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.

8.    DIRECT MARKETING

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

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which services may be of interest to you so that we can then send you relevant marketing communications

9.    OPTING OUT OF MARKETING

You can ask to stop receiving marketing communications at any time by sending an email to: dataprotection@braemar.com.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or service purposes.

10. COOKIES

Please see our cookie policy which can be found by clicking the “Cookie Settings” button at the bottom of this page.

11. DATA RETENTION

Braemar is committed to only keeping your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this notice, and for as long as we are required or permitted to keep it by law.

We retain copies of our customer contracts in order to enable us to deal with any legal issues in addition to the information provided to us for identification verification checks, financial crime and anti-money laundering checks (as required by law) for 5 years after termination or expiry of our contract with you. We retain details of complaints for 5 years from the date of receipt.

12. DATA SECURITY

We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure.

13. YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal data (commonly known as a “Data Subject Access Request”).

Your right to rectification – You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal data in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal data in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.

Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.

You do not usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.

To make a Data Subject Access Request, please contact us by:

• Email: dataprotection@braemar.com
• Post: One Strand, Trafalgar Square, London, WC2N 5HR

14. HOW TO COMPLAIN

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.

15. 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.