RightShip Group, which includes RightShip Pty Ltd., Rightship LLC, Rightship Singapore Pte., and RightShip UK Ltd., (“RightShip”, “we”, “us”) is a third party maritime due diligence organization based in Melbourne, Australia. RightShip respects your privacy and is committed to protecting your personal data. This Privacy Notice has been written in compliance with global privacy regulations and applies to personal data collected by RightShip in the course of our business activities.
Last reviewed: September 2022
- Personal Data we collect
- How your personal data is collected
- How we use your personal data
- Disclosures of your personal data
- Privacy Settings/Opt-Out/Changes/Access
- International transfers
- Your legal rights
- Data Protection Officer and EU Data Representative
- Cookies/ Tracking Technologies
- Children’s Privacy Protection
- Data retention
- Data security
- Contact details
2. Personal Data We Collect
Personal data, or personal information, means any information that can directly or indirectly identify you or other individuals. Personal data does not include deidentified or aggregate personal information. We collect different types of personal data depending on your interactions with RightShip.
We may collect, use, store and transfer the following types of personal data:
- Identity Data includes first name, last name, username or similar identifier, 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 products and services you have purchased from us.
- 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, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you 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.
- For ship inspectors, health data includes: [medical history], [current medical conditions], [current medications], and [RightShip to insert specific types of health information as applicable].
3. How Your Personal Data is 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:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- respond to a survey study or participate in a working group or;
- give us feedback or contact us.
- 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 based inside and outside the EU;
- advertising networks based inside and outside the EU; and
- search information providers based inside and outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside and outside the EU.
Identity and Contact Data from data brokers or aggregators based inside and outside the EU or from publicly available sources.
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. The purposes for which we collect and use your personal data varies depending on your relationship or how you interact with us.
Most commonly, we will use your personal data:
- For everyday business purposes, such as entering into a contract with you or a person on whose behalf you act.
- For the purposes of any study or activities of any working group in respect of which you have participated or provided information.
- To operate the RightShip website
- For marketing and analytics purposes
- To provide you with requested information or answer your inquiry
- To provide product/services and to maintain customer relationships
- To comply with legal, regulatory, or contractual requirements;
- If you are working for RightShip to inspect ships, for purposes of documenting and recording details of your physical fitness in relation to inspections.
5. Disclosures of your personal data
At times, RightShip engages third party contractors or service providers to help us accomplish our business objectives. There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities. We may share your personal data with the parties set out below for the purposes stated above.
Internal and External Third Parties as defined in the Glossary.
- Disclosures to Third Parties Assisting in Our Operations: We engage with service providers acting as processors based around the world who provide support and services and professional advisers acting as processors including lawyers, bankers, auditors, and insurers who provide RightShip with consultancy, banking, legal, insurance and accounting services. If the engagement involves the transmission of personal data, we require the service provider to sign a data processing agreement consistent with this notice before any data is disclosed. These companies do not have any independent right to share or use this information.
- Disclosures Required by Law: We may provide information about you, to respond to subpoenas, court orders, search warrants, legal processes or governmental regulations or inquiries, or to establish or exercise our legal rights or defend against legal claims.
- Disclosures to Other Parties with Your Consent or at Your Direction: In addition to the disclosures described in this Privacy Notice, we may share information about you with third parties when you consent to or request such sharing.
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.
6. Privacy Settings/Opt-Out/Changes/Access
We strive to provide you with choices regarding certain personal data uses. You may request access to and correction of the personal data that RightShip has collected, including the removal of your personal data from RightShip’s databases where not otherwise exempted by contacting us at email@example.com or by using our Data Subject Right’s Privacy Request form. Please note that you will be asked to provide two-to-three (2-3) pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf by using our Authorized Agent’s Privacy Request form; however, you will still need to verify your identity directly with us before your request can be processed.
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have opted in to receive marketing communications from us. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us. When you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
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 products, services and offers may be relevant for you. You can opt-out of promotional offers from us at any time by contacting us at firstname.lastname@example.org.
7. International transfers
We share your personal data within the RightShip Group. This will involve transferring your data outside the European Economic Area (“EEA”), Australia and China, to recipients in Singapore, Hong Kong, and United States.
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules". For further details, see European Commission: Binding corporate rules.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, 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 by the European Commission.
- Where we use certain service providers, we may use specific contractual provisions approved by the European Commission which give personal data the same protection it has in Europe.
We may transfer your personal data to the United States (US) when you interact with us. If you are located in the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), please note that the US has not obtained adequacy status from the European Union, and therefore, the level of protection of your personal data is not deemed equivalent to the protection provided data in Europe. However, we provide appropriate safeguards to ensure the same level of protection of your personal data including the use of Standard Contractual Clauses (data transfer agreements), that can be provided to you on request.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you reside or otherwise find yourself in the territory of the European Economic Area (EEA), Switzerland or the United Kingdom (UK), we are committed to facilitate the exercise of your rights granted by the data protection laws of these territories.
For the purposes of the European Data protection law, any personal data you provide to RightShip directly, RightShip Pty Limited and RightShip UK Limited are considered joint controllers of your personal data. You can contact our Data Privacy Manager at email@example.com.
RightShip assigns a legal basis for each data collection and use:
- For our everyday business purposes: legitimate interest to conduct our day-to-day business, communicate with you or to respond to your inquiries.
- Recruitment practices: legitimate interest of RightShip to process and review your resume submission or consent when you directly submit your job application and resume to RightShip.
- Corporate or informational communications: legitimate interest of RightShip to send specific company material, or consent when you directly request this information.
- Compliance with laws and regulations: compliance with legal obligation.
- Protect the rights, property, and safety of RightShip or third parties: legitimate interest of RightShip or other third parties to protect their rights, property, or safety.
- Uses that you specifically authorize us: consent. Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw your consent to at any time by contacting us.
RightShip recognizes your Data Privacy Rights:
- Right to access, rectification, restriction of processing, erasure, and data portability. We provide you with access to your own personal data. In addition, we will rectify your personal data when it is incorrect or inaccurate, and we will ensure the right to erasure, portability, and to restriction of processing when these rights are not incompatible with other legal obligations or conflict with our legitimate interest to process.
- Right to object. When RightShip distributes any promotional or marketing emails, we provide the option for individuals to opt-out anytime and free of charge via an unsubscribe link. The right to object for other processing activities will be balanced to ensure that it is not incompatible with local regulations or our legitimate interests.
- Right to withdraw consent at any time. When we use your information based on your consent, you have the right to withdraw such consent at any time.
- RightShip does not engage in automated decision making, including profiling.
- Right to lodge a complaint with your supervisory authority. If you are not satisfied with our response or how we process your personal data, you can make a complaint to the data protection authority of your habitual residence.
Data Privacy Rights requests should be submitted as follows:
- To exercise your rights, or for any further privacy-related questions or concerns you may have, you can contact us by email at firstname.lastname@example.org or by mail at Level 20, 500 Collins Street, Melbourne, Victoria 3000 Australia. We will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.
- You also have the right to lodge a complaint with a supervisory authority: A list of the European authorities is available here, the contact of the Federal Data Protection and Information Commissioner of Switzerland is available here, and the contact of the Information Commissioner of the United Kingdom is available here. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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.
9. Data Privacy Manager
10. Cookies/ Tracking Technologies
RightShip may use web beacons, pixel tags, cookies, and other tracking technologies on our websites to collect information about our consumers. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns.
11. Children’s Privacy Protection
This website is not intended or directed to minors and we do not knowingly collect personal data from minors. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, please contact us.
12. Data Retention
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.
For ship inspectors based in the US, we will only retain your personal data for 7 years after you cease working for us. Any health data provided by you will be maintained confidentially and separate from your personnel file.
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
In some circumstances you can ask us to delete your data: see the legal rights section above 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.
13. 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. 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 instruction 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 when we are legally required to do so.
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.
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.
15. Contact Details
|Full name of legal entity||RightShip Pty Limited||RightShip UK Limited|
Level 8/ 550 Bourke Street, Melbourne VIC 3000, Australia
|Floor 4, 6 Dowgate Hill,
London EC4R 2SU, United Kingdom
Legitimate Interest means the interest of our business in conducting and managing our business (including hiring inspectors that are able to conduct ship inspections) to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party (or where you are acting on behalf of such a party) or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in the RightShip Group acting as joint controllers or processors and who provide IT and system administration services, undertake leadership reporting, and provide support and services requested by you for your own account and/or on behalf of a third party.
External Third Parties
- Service providers acting as processors based around the world who provide support and services requested by you for your own account and/or on behalf of a third party.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide RightShip with consultancy, banking, legal, insurance and accounting services.
- Regulators, fraud prevention agencies, law enforcement agencies and other authorities based who require reporting of processing activities in certain circumstances.
Your legal rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
|Company Name||Address||Company Number|
|RightShip Pty Limited||Level 8, 550 Bourke Street, Melbourne VIC 3000, Australia||ABN 66 098 279 068|
|RightShip UK Limited||Floor 4, 6 Dowgate Hill,
London EC4R 2SU, United Kingdom
|RightShip Singapore Pte Ltd||20 Cecil Street, PLUS, #13-06 Singapore 049705, Singapore||UEN202010825D|
|RightShip Americas LLC||Suite 140 14141 Southwest Freeway, Sugar Land TX 77478, United States of America|
|RightShip Malta Pty Ltd||The Tower, 3rd Floor, Fortunato Mizzi Street, Ir-Rabat Għawdex VCT 2517, Malta||C102660|