Introduction
This General Privacy Notice explains what we do with your personal data.
It applies to any Prospective Customers, Customers, Business Partners, Prospective Vendors, Vendors, any Company Website Visitors, Ship Owners’ Personnel, Operators, Managers, Charterers, Port Authorities, Port Agents and any Software Platform Users of whom we process personal data.
It describes how we collect, handle, and process your personal data.
This notice is layered. So, if you wish, you can easily select any processing activity to see what to expect us to do with your personal data.
The Data Controller
TruePort Limited (the “Company”) is the controller for the personal data that it processes. You can contact TruePort Limited in a number of ways, which are set out below:
TruePort Limited
Address: Archiepiskopou Leontiou A, 183, 3020, Limassol, Cyprus
Email: contact@true-port.com
The Data Protection Officer (DPO)
If you wish to contact the Data Protection Officer of TruePort Limited in relation to the processing of your personal data by TruePort Limited, you can do so by contacting contact@true-port.com .
Processing Activities
Port Cost Management
Data Subject
This section applies to the personal data of Ship Owners’ Personnel, Operators, Managers, Charterers, Port Authorities, Port Agents and any Software Platform Users.
Purpose of Processing
Where you provide us with your personal data, we shall process them for port cost management purposes only.
Categories of personal data
This includes your personal identification details, contact information, company data, login credentials and transactional data related to port cost management (where applicable).
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(b). This allows us to process personal data when it is necessary for the performance of a contract to which the data subject is party.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required port cost management, we shall not be able to fulfil our contract with you.
Recipients
The only recipients shall be our third party service providers:
- Cloud Hosting Providers;
- Analytics Providers;
- Customer Support Providers;
- Payment Providers;
- Port Service Providers; and
- Customer ERP Systems (i.e. any Customer System interfacing with the TruePort platform).
They shall be assisting with the necessary formalities for this matter. They are located globally*.
(*Some of our external third parties or our staff are based outside the European Economic Area (EEA), therefore, their processing of your personal data may involve transfers of your personal data outside the EEA.)
Where they are based outside the EEA, these include, but are not limited to:
- United Arab Emirates (UAE); and
- Singapore.
We rely on GDPR Article 46(2)(c) for cross-border transfers. This allows us to transfer personal data to such recipients based on the Standard Contractual Clauses adopted by the EU Commission.
We also rely on GDPR Article 49(1) (c) for cross-border transfers. These transfers are for specific situations where the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the Company as controller and another natural or legal person.
Retention Period
We shall store such personal data for a period of 5 years or until termination of subscription, whichever is earlier, after which the user accounts shall be deactivated and any personal data shall be deleted or anonymized.
Communication Management
Data Subject
This section applies to the personal data of Prospective Customers, Customers, Business Partners, Prospective Vendors, Vendors and any Company Website Visitors.
Purpose of Processing
Where you provide us with your personal data, we shall process them for communication purposes only.
Categories of personal data
This includes your personal identification details and contact information.
Legal Basis
The legal basis we rely on to process your personal data is GDPR Article 6(1)(f). This allows us to process personal data when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
If legitimate interest, it must be identified
The legitimate interest pursued by us is the internal communication with us regarding our services.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, we shall not be able to communicate with you.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
We shall store such personal data for a period of 10 years from our last communication with you.
Cookie Management
Data Subject
This section applies to the personal data of Company Website Visitors.
Purpose of Processing
Where you provide us with your personal data, we shall process them for cookie management purposes only.
Categories of personal data
This includes your browsing information.
Legal Basis
The legal basis we rely on to process your personal data for necessary cookies is GDPR Article 6(1)(f). This allows us to process personal data when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
The legal basis we rely on to process your personal data for non-necessary cookies is GDPR Article 6(1)(a). This allows us to process personal data when the data subject has given consent, subject to the applicable conditions, to the processing of his or her personal data for the specified purposes.
If legitimate interest, it must be identified
With regard to necessary cookies, the legitimate interest pursued by us is maintaining the integrity of our IT systems and the continuity of our business.
PD required by law (statutory) or by contract or necessary to enter into a contract and the possible consequences of failure to provide same
If necessary personal data is not provided, allowing us to conduct the required cookie management, we shall not be able to track visitor behaviour, maintain the integrity of our IT systems, maintain the continuity of our business and measure site performance.
Recipients
There are no recipients of your personal data for these purposes.
Retention Period
We shall store such personal data for the periods below depending on the type of cookie as from the Cookies’ activation:
- Necessary cookies shall be stored for 1 year;
- Performance cookies shall be stored for:
- _ga_xxxxxxxxxx for a few seconds;
- _ga for 1 year;
- Functional cookies shall be stored for:
- _wpfuuid for 10 years
Cookies
Our use of cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We use necessary cookies to make our website work. We would also like to set analytics cookies that help us make improvements by measuring how you use the website.
Necessary cookies
Necessary cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts, and payment processing. Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions.
We use necessary cookies to enable certain functions on our website.
Performance cookies
Performance cookies track how you use a website during your visit. Typically, this information is anonymous and aggregated, with information tracked across all website users. They help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. We would like to set Google Analytics cookies to help us improve our website by collecting and reporting information on how you use it. The cookies collect information in a way that does not directly identify anyone. These shall be off by default and set only if you accept.
We use performance cookies on our website.
Functional cookies
Functional cookies are used to collect information about your device and any settings you may configure on the website you are visiting (like language and time zone settings). With this information, websites can provide you with customised, enhanced, or optimised content and services. These shall be off by default and set only if you accept.
We use functional cookies on our website.
Data Subject Rights
We shall respond without undue delay to requests made by Data Subjects to exercise their rights in relation to the personal data we process.
Under certain circumstances, data subjects have certain rights, including:
Access
Data subjects have the right to obtain the following from the Company:
- Confirmation that the Company is processing their personal data;
- Copy of their personal data;
- Other supplementary information which is already included in the Company’s General Privacy Notice
Rectification
Where personal data is inaccurate, data subjects have the right to request that it be corrected and incomplete personal data be completed based on information they may provide.
Erasure
The right to erasure is also known as “the right to be forgotten.” It applies only in certain circumstances.
Restriction on Processing
Data subjects may request from the Company the restriction of processing of their personal data.
Object to Processing
Data subjects have the right to object to the processing of their personal data in some circumstances. However, data subjects have the absolute right to object to the processing of their personal data for direct marketing purposes.
Portability
Under certain circumstances, data subjects have the right to receive personal data in a structured, commonly used and machine-readable format. This allows data subjects to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.
Right to withdraw consent if processing is based on consent
Where the legal basis for processing is the consent of data subjects, the GDPR entitles data subjects to the right to withdraw their consent at any time.
Right to lodge a complaint with a supervisory authority
Data subjects have the right to complain if they have concerns about the way the Company is handling their personal data.
Automated decision making
Data subjects have the right not to be subject to a decision which is based on automated decision making or profiling, without the involvement of human intervention.
We do not use automated decision making.
How do I exercise my rights?
You can contact us in the ways set out in the relevant section at the beginning of this notice.
Changes to the General Privacy Notice
If any changes are made to the General Privacy Notice, these shall be posted on this page. Please check back frequently to stay informed of any updates or changes.
Where we intend to further process your personal data for a purpose other than that for which the personal data were collected, we shall provide you, prior to that further processing, with information on that other purpose and with any relevant further information.
