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Privacy Policy

 

 

                   a.       Service Description

 

The Doehle Shipmanagement Phils. Corp. respects the privacy of all of its clients, employees and associated parties and is therefore committed to protecting all personal data collected and processed.

 

We have both a legal and a moral responsibility to ensure that we treat your personal data with the same level of privacy and confidentiality as we expect our own data to be treated and in line with all legal and regulatory requirements.

 

Although every effort has been made to ensure that data privacy policy is as easy to understand and as ‘jargon’ free as possible, there are times that we must use industry standard wording and if at any point you feel you do not fully understand the contents of this privacy policy or wish to discuss any points with us, please refer to our Glossary here (or on the upper right side of this page) or you can contact the Doehle Group Data Protection Officers here.

 

We know that data protection can often be quite a specialist subject and we make things as simple as possible as part of our obligation to you, to assist you in understanding exactly how and why we process your personal data, furthermore, we must ensure that you are aware of how the Doehle Group holds and processes your personal data.

 

We believe that the key for data protection regulation was to adhere to the principles of transparency, legitimate purpose and proportionality and have therefore worked hard to ensure that all of our processing activities adhere to these principles.

 

For further details on the specific processing activities we carry out as well as the lawful basis under which we process the data, please see the relevant sections of this privacy policy.

 

For further details on the data processing activities relevant to you, please see related items of this page.

 

Please kindly note that as a business, we process personal data for numerous purposes in order to service the diverse nature of our clients and therefore the processing, collecting, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

 

Who we are


“Doehle Group”, “we, “us” and “our” refers to the Doehle companies in Manila Philippines and this privacy policy covers all Doehle Group entities, a list of all Doehle Group entities is outlined in our list of Doehle Group data controllers section.

Doehle Shipmanagement Phils. Corp. is a part of the Doehle Group.

Who you are


When “you” or “your” are used in this privacy policy, we are referring to you as the individual who is the subject of the personal data we hold and process.

b.      Personal Information that are collected

 

If you apply for employment within the Döhle Shipmanagement Philippines Corp. (DSPC), we will collect from you only data, which is necessary to process this application. We will not supply your name and address without your consent to any third party, which is not a member of the Doehle Group.

 

Data Security is of the upmost importance to the Doehle Group and to that end, we have put in place appropriate security measure to protect and prevent your personal data from being accidentally lost, used or accessed by any unauthorized parties.

 

c.       Collection method

 

Access to your personal data is limited to authorized employees, insurers, service providers and other third parties who require access for the fulfillment of a contract

or agreement or are providing services to you or us.

 

d.      Timing of collection

 

Timing of collection is as needed by the business and engagement with the Doehle Group and data subjects are notified with the purpose of collection.

 

e.       Purpose of collected personal information

 

If you apply for employment within the Döhle Shipmanagement Philippines Corp. (DSPC), we will collect from you only data, which is necessary to process this application. We will not supply your name and address without your consent to any third party, which is not a member of the Doehle Group.

 

f.        Storage and transmission of personal information

 

With the instruction of Doehle Shipmanagement Phils. Corp., data being collected is being stored to our offsite facilities and we have the legal terms of business and engagements in place between the Doehle Group and these third parties. Third parties are not allowed to process technically our data and strictly follow our instructions and they are subject to a duty of confidentiality.

 

g.       Method of use

 

Doehle Group had placed policies, procedures and security to protect related personal data.

 

h.      Location of personal information

 

Personal information is placed on secured environment and is being accessed only by authorized employees, insurers, service providers and other third parties who require access for the fulfillment of a contract or agreement or are providing services to you or us.

 

i.        Third party transfer

 

Third party transfer with the instruction of Doehle Shipmanagement Phils. Corp., have the legal terms of business and engagements in place between the Doehle Group and these third parties. Third parties activities strictly follow and process technically our data as with the instruction of Doehle Shipmanagement Phils. Corp. in relation to business requirement and they are subject to a duty of confidentiality.

 

j.        Retention period

 

Data will be retained for 10 years as directed by our principal from Doehle Isle of Man.

 

You have the right to request erase of the personal data that we hold about you, commonly referred to as “Right to ERASURE or BLOCKING.

 

Examples of why you may wish to exercise this right include, but are not limited to;

 

·         The personal data is no longer necessary in relation to the purposes for which it was originally collected and processed by us;

·         The legal grounds for us processing your data is consent, if you withdraw consent then we have no other lawful basis for the processing;

·         Our legal grounds for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to our processing and we do not have overriding grounds;

·         You object to our processing for direct marketing purposes;

·         Your personal data have been unlawfully processed; or

·         Your personal data must be erased to comply with a legal obligation to which we are subject.

 

However 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 your request although the most common reasons for this include complying with the local or international regulations and requirements in relation to:

 

·         Preventing financial crime, money laundering and the funding terrorism;

·         Identifying political or commercially exposed persons, or those with a significant exposure to the media;

·         FATCA/CR (“AEOI”) international tax reporting; and

·         Employment law in the relevant jurisdiction

 

If you wish us to exercise your “Right to ERASURE or BLOCKING and if you are unsure whether or not we are able to erase your data, please contact Data Protection Officer (Please see DATA CONTROLLER CONTACT INFORMATION)

 

k.       Participation of data subject

 

You have the legal rights as set out below:

 

Right to be INFORMED

 

                As a data subject, you have the right to be informed that your personal data shall be, are being or have been processed.

 

                The right to be informed is a basic right as it empowers you as a data subject to consider other actions to protect you data privacy and assert your other privacy rights.

 

                This right also requires personal information controllers (PICs) to notify you if within a specific period of time if your data has been compromised, i.e. in the case of a personal data breach.

               

Right to ACCESS

               

                Concomitant to your right to be informed, you also have a right to gain reasonable access to your personal data.

 

You may request access to the following:

 

·         Contents of your personal data that were processed;

·         Sources from which they were obtained;

·         Names and addresses of the recipients of your data;

·         Manner by which such data were processed;

·         Reasons for disclosure to recipients, if there were any;

·         Information on automated processes where the data will or likely to be made as the sole basis for any decision which would significantly affect you;

·         Date when your data was last accessed and modified; and

·         Name and address of the personal information controller

 

Right to OBJECT

 

                You have a right to object to the processing of your personal data, including processing for direct marketing, automated processing or profiling.

 

                You likewise have the right to be notified and given an opportunity to withhold consent to the processing in case of changes to the information given to you regarding the processing of your information.

 

Right to ERASURE or BLOCKING

 

                Under the law, you have the right to suspend, withdraw or order the blocking, removal or destruction of your personal data. You can exercise this right upon discovery and substantial proof of the any of the following:

               

1.       Your personal data is incomplete, outdated, false or unlawfully obtained;

2.       It is being used for purposes you did not authorize;

3.       The data is no longer necessary for the purposes for which they are collected;

4.       You decided to withdraw consent, or you object to its processing and there is no overriding legal ground for its processing;

5.       The data concerns personal information prejudicial to the data subject – unless justified by freedom of speech, of expression, or of the press; or otherwise authorized;

6.       The processing is unlawful; or

7.       The personal information controller, or the personal information processor, violated you rights as a data subject.

 

Right to DAMAGES

                You may claim compensation if you suffered damages due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, considering any violation of your rights and freedoms as data subject.

 

Right to FILE A COMPLAINT        

                If you are the subject of a privacy violation or personal data breach, or who are otherwise personally affected by a violation of the DPA, may file complaints with the Doehle Group which will then be investigated thoroughly and we will report to National Privacy Commission.

 

Right to CORRECT/RECTIFY

                You have the right to dispute any in accuracy or error in your personal data and have the personal information controller correct it immediately, unless the request is vexatious or unreasonable. Once corrected, the PIC should ensure that your access to both new and retracted information and simultaneous receipt of the new and the retracted information by the intended recipients thereof.

               

Right to DATA PORTABILITY

                Where your personal information is process by electronic means, you have a right to obtain from the personal information controller a copy of your personal data a copy of such data in an electronic or structured format that is commonly used and allows for further use.

 

                The purpose of this right is to empower you and give you more control over your personal data. This is right, which applies subject to certain conditions, supports user choice, user control and consumer empowerment.

 

                It enables the free flow of your personal information across organizations according to your preference. This is importantly especially now that several organizations and services can reuse the same data.

 

                Data portability allows you to manage your personal data, and to transmit your data from one personal information controller to another. As such, it promotes competition that fosters better services for the public.

 

l.        Inquiry


DATA SUBJECT ACCESS REQUEST

 

How to make a data subject access request

 

To make a data subject access request, in the first instance please contact the Data Protection Officer who can assist you with this process.

 

Fees

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 we believe your request is clearly unfounded, repetitive or excessive.

If we believe that your request is clearly unfounded, repetitive or excessive, we may refuse to comply with your request in these circumstances and will report our reasoning, as well as the details of your request, to the National Privacy Commission – Privacy Commissioner.

Information we need from you

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 to speed up our response.

Our response

We are required to respond to your request within 30 calendar days of receiving it. We will provide confirmation to you that we have received your request as well as the date we must have to respond by. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and provide you with a reasonable time frame for our response.

Follow up

If you are not happy with our response to your data subject access request you have the right to make a complaint and may contact the Data Protection Officer – Please see Data Controller Contact Information.

CHANGES TO THIS PRIVACY POLICY

From time to time regulations and requirements may change and we may need to update this privacy policy accordingly. To ensure transparency we will always detail when this policy has been updated.

This privacy policy was updated: 06 August 2019

DATA CONTROLLER CONTACT INFORMATION

The contact details for the primary Doehle Group Data Protection Officer are:

Data Protection Officer
Doehle Shipmanagement Phils. Corp.
5/F Doehle Haus Manila, 30-38 Sen. Gil Puyat Avenue Barangay San Isidro 1234 Makati City

Email address: dataprotection@doehle-mnl.com ; inquiry@doehle-mnl.com

 

        OTHER INFORMATION COMMISSIONER CONTACT DETAILS

 

B.V.I.

http://www.bvifsc.vg/

GERMANY

https://www.bfdi.bund.de/

GUERNSEY

https://odpc.gg/

MALTA

https://idpc.org.mt/

PHILIPPHINES

https://privacy.gov.ph/

POLAND

https://www.uodo.gov.pl/

ROMANIA

http://www.dataprotection.ro/

U.K.

https://ico.org.uk/

 

DISCLAIMER

 

Whilst every effort has been taken to ensure the accuracy of the information on this Website, any and all liability which might arise from your use or reliance on the information or links contained on the Website are excluded.

The content of this privacy policy is provided for general information purposes only, to inform you about the Doehle Group’s data protection activities. It does not constitute legal advice (or any other type of advice) and should not be relied on for this purpose.

This Website contains links to other websites. The Doehle Group does not endorse, and accepts no responsibility or liability for, any material supplied by or contained on any third party website which is linked from or to this Website or any use of personal data by such third party.

This privacy policy is set out primarily in accordance with Republic of the Philippines Republic Act 10173 - Data Privacy Act of 2012 in conjunction with the E.U. General Data Protection Regulation.

 

 

DOEHLE GROUP DATA CONTROLLERS

Details of the Doehle Group’s data controllers and their contact details are outlined below:

B.V.I.

Levanto International Limited
Mill Mall, Suite 6, Wickhams Cay, Road Town, Tortola, BVI
Email: dataprotection@doehle-iom.com

GUERNSEY

Levanto (Guernsey) Limited
Ground Floor, 2 Grange Place, St Peter Port, Guernsey, GY1 2QA
Email: dataprotection@doehle-iom.com

ISLE OF MAN

Döhle (IOM) Limited | Döhle Corporate and Trust Services Limited | 
Döhle Private Clients Limited | Döhle Yachts Management ServicesLimited | 
Midocean (IOM) Limited | TREXX Insurance Company Limited | TREXX Insurance Management Limited
Fort Anne, South Quay, 
Douglas, Isle of Man, IM1 5PD
Email: dataprotection@doehle-iom.com

MALTA

DCTS (Malta) Limited | Döhle Services (Malta) Limited | Levanto (Malta) Limited
SmartCity Malta, SCM002, Unit 301, Ricasoli, Kalkara, Malta, SCM1001
Email: dataprotection@doehle-iom.com

ROMANIA

Döhle Manning Agencies S.R.L.155 Mamaia Boulevard, Constanta, 900575, Romania
Email: dataprotection@doehle-iom.com

PHILIPPHINES

Doehle Shipmanagement Phils. Corp.                                                              Doehle Haus (Manila)                                                                                           30-38, Sen. Gil Puyat Avenue, Barangay San Isidro, Makati City                  1234, Philippines
Email: dataprotection@doehle-mnl.com

POLAND

Döhle Marine Services Europe Limited
Alfa Plaza, 1 Floor, Batorego 28-32, 81-366 Gydnia, Poland
Email: dataprotection@doehle-iom.com

U.K.

Döhle Yachts Technical Services Limited
25 Barnes Wallis Road, Segensworth, Fareham, Hampshire, UK, PO15 5TT
Email: dataprotection@doehle-iom.com

 

If you require any more information, please contact the respective Data Protection Officer.