INFORMATION NOTICE AND CONSENT FORM FOR CANDIDATE CREWMEMBERS

The Company hereby informs you about the processing of your personal data as described in this Notice, in the context of your application, and in accordance with the provisions of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (henceforth “GDPR”) and on the free movement of such data, the applicable provisions of the applicable legislation in relation to personal data, and shipping practice.

1. Data Processing and Data Retention

1.1 The Company processes your personal data collected either from you directly and/or from the Company and/or a third party (e.g. former employers, manning agents or other recruiters, et. al.). More specifically, the Company processes passport, identity and contact information, training and education data, prior and current employment information, information relating to background security checks, photo, information about your application to the Company, as well as any other personal data necessary in connection with the data processing purposes described below.

1.2 The aforementioned data are stored and processed by the Company for a specific time period, determined by the following criteria:

• The compliance of the Company with its legal obligations towards competent authorities, and/or third parties;
• Any applicable law and/or regulatory provisions on data retention periods;
• The duration of the legal consequences stemming from your application to the Company;
• Other legal interests of the Company; and/or
• If you specifically consent thereto, the potential manning needs of the Company in the future.

2. Data processing purposes

The Company processes your data in order to select the appropriate personnel for the position for which you have applied in accordance with its recruitment criteria, as well as to comply with its legal obligations and to protect its legal rights. To the extent that you specifically consent thereto, the Company processes your data in order to select the appropriate personnel for a future position, than that for which you are currently applying.

3. Third party data transfers

We will not transfer your personal data to any third parties to the extent that your application is not successful or unless such transfer is required by law.

4. Legal basis for processing and obligation to provide data

4.1 The processing of your personal data is based upon the following legal bases:

• The processing is necessary for the Company to consider your job application, as a stage of preparation of an employment agreement between you and the Company.
• Your consent, where applicable, and/or
• The processing is necessary for the purposes of the legitimate interests pursued by the Company, such as its legitimate interest to ensure the safety and security of the ships it manages and its premises, to comply with its legal obligations and with industry-specific requirements imposed by Charterers, to secure its legal rights and to identify candidates.

4.2 The provision of some of the above personal data is required by law or by contract. As such, if you do not provide us with this data, we will not be able to process your application to work in the Company.

5. Communication

You can communicate with the Company as follows:

INFORMATION NOTICE AND CONSENT FORM FOR CANDIDATE SHORE EMPLOYEES

The Company hereby informs you about the processing of your personal data, in the context of your employment agreement, and in accordance with the provisions of Reg. (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (henceforth “GDPR”) and on the free movement of such data, the provisions of the applicable regional legislation relevant to the Company and shipping practice.

1. DATA PROCESSING AND DATA RETENTION

1.1 The Company processes your personal data collected either from you directly and/or from the Company and/or a third party (e.g., recruiters, et. al.). More specifically, the Company processes personal, passport/ID and communication information, banking, social security and tax data, information about your education and previous and current employment, photo, information about your location (when you board a ship managed by the Company), your marital status and family information, travel information, your communications with the Company, information about your next of kin, health data (including, as the case may be, information relating to your results in psychometric tests), information relating to background security checks, information about your entry/exit from the Company, e-mails that you send from and receive in your corporate e-mail account, calls you make and receive in your corporate mobile phone and work phone, your corporate mobile phone bill as well as any other personal data necessary in connection with the data processing purposes described below.

1.2 The Company processes your personal data during your employment, while such processing will extend after the completion of such employment, and to the extent required in order for the Company to comply with its legal obligations towards the authorities and/or third parties, to comply to any applicable provisions on the obligatory data retention periods or in order for the Company to support its claims or rights.

2. DATA PROCESSING PURPOSES

The Company processes your data in order to ensure its proper operation in accordance with its employee-related procedures, to fulfill its staffing needs, to comply with its legal and contractual obligations, to identify its employees and to ensure the safety of its staff, of the ships it manages and of its premises and the fitness to work of its employees.

3. THIRD PARTY DATA TRANSFERS

3.1 Your data may be made accessible to the Company’s personnel, as well as to third parties, such as the competent authorities, local agents, travel agents, airlines and other agents employed by the Company, technical contractors, investigators and other legal entities employed by the Company, accountants, auditors, lawyers and legal counsels insurance providers and the P&I Club employed by the Company, as well as the latter’s correspondents, the insurance company providing health and travel insurance to the Company’s employees (if you specifically consent thereto), IT companies providing technical or cloud services or i-storage platforms, banks and the companies owning the ships managed by the Company.

3.2 The Company may also transfer some or all of your data for the above purposes to persons located in third countries, non-members of the European Economic Area (EEA). In case where such countries have not been granted with an adequacy decision by the European Commission, any transfer shall take place under the appropriate safeguards in accordance with the Regulation, such as Standard Contractual Clauses approved by the Commission or by the competent national authority, or appropriate contractual clauses between the Company and the recipient of such data.

4. YOUR RIGHTS

You have the right to:

• Request access to your data and to information relating to the processing of your data by the Company.
• Request corrections and/or completion of your personal data.
• Request the Company to delete your data.
• Request the restriction of the scope of processing, the way that the Company is processing your data, as well as the purposes for which the Company is processing them.
• Receive the personal data you provide to the Company in a structured, commonly used and machine-readable format, transmit them to another data controller, and/or request the Company to directly transmit them to another data controller, if technically feasible.
• Object to the processing of your personal data, on grounds relating to your particular situation, and
• File a complaint before the competent data protection authority.
• So far as the processing relies upon your consent, you have the right to withdraw such consent at any time.

To exercise your rights, please contact the Company as illustrated below at 6.

5. LEGAL BASIS FOR PROCESSING AND OBLIGATION TO PROVIDE DATA

5.1 The Company processes your personal data because the processing is necessary, in order for the Company to:

• Comply with its legal obligations, including among others obligations in the field of employment or tax law, or general shipping law obligations.
• Fulfill its obligations and/ or satisfy its rights deriving from your employment agreement.
• Satisfy its legitimate interests, such as to ensure its proper operation in accordance with its employee-related procedures, to fulfill its manning needs, to comply with its legal and contractual obligations, to identify its employees and to ensure the safety of the ships it manages and of its premises and the fitness to work of its employees.
• Establish, exercise or defend legal claims, and/or
• Process your personal data pursuant to your consent.

5.2 The above processing is required by law or due to a contract executed between you and the Company. Therefore, if you do not provide us with your data, the execution of your employment agreement may not be possible.

6. COMMUNICATION

You can communicate with the Company as follows: