Privacy Policy | Alfaship

1. Identification and contact details of the Data Controller

Alfaship Shipping Agency, S.L., with registered office at Calle León y Castillo, 367, 1st floor, 35006 Las Palmas de Gran Canaria, Spain, holder of Spanish Tax IdentificationNumber (CIF) B-76093046, and telephone number +34 928 247 978 (hereinafter, “Alfaship”), is the Data Controller responsible for the processing of your personal data.This Privacy Policy explains how Alfaship collects and processes your personal data when you visit or use this website (the “Website”), contact us, request information about our services, submit a job application or otherwise interact with us through the Website. If you have any questions regarding the processing of your personal data, please contact us at: isqc@alfaship.com.

2. Personal data processed, purposes and legal basis

2.1 General browsing of the Website

When you visit the Website, certain technical and browsing information may be processed, including your IP address, browser type, operating system, access date and time, pages visited and other technical information necessary for the operation and security of the Website.

We may also process information through cookies or similar technologies, as explained inour Cookies Policy.

The processing of information strictly necessary for the proper operation and security of the Website is based on Alfaship’s legitimate interest in ensuring that the Website remainssecure, accessible and functional.

The use of non-essential cookies, including analytics or advertising cookies, where applicable, will be based on your prior consent. You may accept, reject or configure these cookies through the cookie management tool available on the Website.

The applicable retention periods depend on the type of cookie or technical information concerned and are described in the Cookies Policy.

2.2 Contact enquiries and service requests

When you contact us through the Website, by email or by any other available communication channel, we may process the information you provide, including:

Your name and surname.
Your email address and telephone number.
The company or organisation you represent.
Your professional position.
The content of your enquiry or request.
Any other information or documentation that you voluntarily provide.

We process this information for the purpose of:

Responding to your enquiry.
Providing the requested information.
Preparing a quotation or service proposal.
Managing a potential business or contractual relationship.
Following up on requests submitted to Alfaship.

The legal basis for this processing is Alfaship’s legitimate interest in responding to enquiriesaddressed to the company.
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Where your request relates to a quotation, proposal or possible provision of services, theprocessing may also be necessary to take steps at your request prior to entering into acontract.

Your personal data will be retained for as long as necessary to respond to and manage your enquiry. Once the enquiry has been resolved, the information may be duly blocked and retained only for the applicable statutory limitation periods or for the establishment, exercise or defence of legal claims.Fields identified as mandatory in any Website form are necessary to process your request. If you do not provide the required information, Alfaship may be unable to respond to or manage your enquiry.

2.3 Job applications

If you apply for a position at Alfaship, whether through the Career section of the Website orby sending your CV to careers@alfaship.com, we may process the information contained inyour application, including:

Your name and contact details.
Your education and professional qualifications.
Your employment history and professional experience.
Language and technical skills.
Information included in your CV or cover letter.
Any other information that you voluntarily provide in connection with your application.

We process this information to:

Manage your participation in a recruitment process.
Assess your qualifications, experience and suitability for the position.
Contact you regarding your application.
Carry out interviews and other stages of the recruitment process.

Where you apply for a current vacancy, the legal basis for the processing is the application, at your request, of pre-contractual measures prior to a possible employment relationship.

Your data will be retained for the duration of the recruitment process and, once it has concluded, for the period necessary to deal with any potential legal responsibilities arising from that process.

If you expressly consent to Alfaship retaining your application for consideration in future recruitment processes, your CV may be kept for a maximum period of 12 months from the date on which it was received.

You may withdraw this consent at any time by contacting isqc@alfaship.com, without affecting the lawfulness of any processing carried out before the withdrawal of your consent.

Please avoid including information in your CV that is not relevant to your application, particularly sensitive personal information.

2.4 Internal Report Channel

Alfaship has an Internal Report Channel through which information concerning possible regulatory breaches or conduct contrary to applicable law or Alfaship’s internal policies maybe submitted.

Reports may be submitted anonymously where permitted by the channel.

Personal data submitted through the Report Channel will be processed for the purpose of receiving, analysing, investigating and, where appropriate, resolving the reported facts, in accordance with Law 2/2023 of 20 February, regulating the protection of persons who report regulatory breaches and the fight against corruption.

The legal basis for this processing is compliance with the legal obligations applicable to Alfaship.

The processing of personal data through the Report Channel is governed by the specific privacy information available within the channel itself.

Reports submitted through this channel will be handled confidentially and in accordance with the applicable legal requirements.

3. Recipients of personal data data

Your personal data will not be sold or transferred to third parties for their own commercialpurposes.

Your personal data may be accessed by service providers that support Alfaship’s activitiesand act on its behalf as data processors, including:

Website hosting and development providers.
Information technology and cybersecurity providers.
Email and communications service providers.
Recruitment support providers, where applicable.
Providers responsible for the management and operation of the Internal ReportChannel.
Professional advisers where their involvement is necessary for the establishment,exercise or defence of legal claims.

These providers may only process personal data in accordance with Alfaship’s instructionsand are subject to contractual obligations concerning confidentiality, security and dataprotection.

Personal data may also be disclosed to courts, public authorities, law enforcement bodies orother competent organisations where required by law or where necessary for the establishment, exercise or defence of legal claims.

4. International data transfers

The Website is developed and hosted using services provided by Webflow, Inc., a company established in the United States.
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Consequently, certain personal data or technical information relating to the use of the Website may be processed or accessed from countries outside the European Economic Area.
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Where personal data is transferred outside the European Economic Area, Alfaship willensure that the transfer is carried out in accordance with the safeguards required byapplicable data protection law.

Depending on the provider and the circumstances of the transfer, these safeguards may include:

An adequacy decision adopted by the European Commission.
The EU–US Data Privacy Framework, where applicable.
Standard Contractual Clauses approved by the European Commission.
Additional contractual, organisational and technical safeguards.

You may request further information about the safeguards applicable to international transfers by contacting isqc@alfaship.com. Webflow’s current data-processing terms contemplate the EU–US Data Privacy Framework, where applicable, and the European Commission’s Standard Contractual Clauses as transfer mechanisms.

5. Retention of personal data

Alfaship will retain your personal data only for as long as necessary to fulfil the purpose for which it was collected.

Once the relevant purpose has been fulfilled, the data will be deleted or duly blocked, unlessits continued retention is required:

To comply with a legal obligation.
To respond to possible contractual, administrative or judicial liabilities.
For the establishment, exercise or defence of legal claims.

The specific retention periods applicable to each processing activity are described in the corresponding sections of this Privacy Policy.

6. Exercise of your rights

You may exercise the following rights in relation to your personal data:

Right of access: You may request confirmation as to whether Alfaship processes your personal data and obtain information about how it is processed.

Right to rectification: You may request the correction of inaccurate personal data or the completion of incomplete personal data.

Right to erasure: You may request the deletion of your personal data where the legal requirements for doing so are met.

Right to restriction of processing: You may request that the processing of your personal data be restricted in the circumstances established by applicable law.

Right to data portability: Where the processing is based on your consent or on a contract and is carried out by automated means, you may request to receive your data in a structured, commonly used and machine-readable format or have it transmitted to another Data Controller, where technically feasible.

Right to object: You may object to the processing of your personal data where the processing is based on Alfaship’s legitimate interests. Alfaship will stop processing your data unless it demonstrates compelling legitimate grounds that override your interests, rights and freedoms, or unless the processing is necessary for the establishment, exercise or defence of legal claims.

Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time. Withdrawal will not affect the lawfulness of any processing carried out before consent was withdrawn.

You may exercise these rights free of charge by sending an email to: isqc@alfaship.com

Your request should indicate the right you wish to exercise and include sufficient information to identify you and locate the relevant personal data. Where Alfaship has reasonable doubts regarding the identity of the person submitting the request, it may ask for additional information that is strictly necessary to confirm their identity.

You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos) if you consider that your personal data has been processed in breach of applicable data protection law: www.aepd.es

7. Automated decision-making

Alfaship does not make decisions that produce legal effects or similarly significantly affectusers based solely on automated processing through the Website.

8. Security measures

Alfaship implements appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

These measures are adopted taking into account the nature, scope, context and purposes of the processing, the state of the art and the risks that the processing may present to the rights and freedoms of individuals.

However, no information system or internet transmission can be guaranteed to becompletely secure. Users should therefore exercise appropriate caution when submitting information online.

9. Personal data relating to third parties

If you provide Alfaship with personal data relating to another person, you confirm that you are authorised to do so and that you have informed that person about the processing of their personal data in accordance with this Privacy Policy.

You must not provide personal data relating to third parties unless it is necessary for the purpose of your communication or request.

10. Minors

Minors may not use the services available through the Website without the prior authorisation of their parents, guardians, or legal representatives, who shall be solely responsible for all acts carried out through the Website by the minors in their care, including the completion of forms with the personal data of said minors and the ticking, where applicable, of the boxes that accompany them.

Alfaship implements appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure oraccess.

These measures are adopted taking into account the nature, scope, context and purposes of the processing, the state of the art and the risks that the processing may present to the rights and freedoms of individuals.

However, no information system or internet transmission can be guaranteed to be completely secure. Users should therefore exercise appropriate caution when submitting information online.

11. Links to third-party websites

The Website may contain links to websites, platforms or services operated by third parties. Alfaship is not responsible for the privacy practices or content of those third-party websites.

Users are advised to review the privacy policies applicable to each external website or service before providing personal data.

12. Changes to this Privacy Policy

Alfaship may update this Privacy Policy when necessary to reflect:

Legislative or regulatory changes.
Changes in the interpretation of data protection rules.
Changes to the Website or the services offered.
Changes to the processing of personal data.
Changes to the service providers used by Alfaship.

The updated version will be published on the Website and will indicate the date of the latestrevision.