Personal Data Protection Policy

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Information notice and consent form for crew members

1. I have completed familiarization with Company’s IMS and policies which I have understood and with which I will fully comply. I am aware that Company’s policies result in continuous improvement in terms of safety, security, health, quality and protection of the environment and I confirm my intention to work towards this direction. I have also been briefed, have understood and fully accept the Company’s Code of Ethics & Code of Conduct.

2. I authorize any doctor, nurse, qualified medical technician, clinic, laboratory or medical facility appointed by the Company, to collect blood, urine or breath samples from me for alcohol and drug screening, as required during pre-employment and periodical examinations. This authorization is contingent on the release of the test results if requested.

3. I authorize the release of medical information to the Company. This authorization is limited only to information regarding results and evaluation of all alcohol and drug screening tests performed. The use of this authorization is limited to assisting Management in making an employment or administrative decision.

4. I am aware of and will comply with the Company’s policies regarding Internet Acceptable Use, Use of Email Service, Corporate Device, Bring Your Own Device and Removable Media that are contained in the Company’s IMS Cyber Security procedures.

5. I am aware of the Company’s Zero Tolerance policy and I will report any case that falls under my attention and will cooperate fully during any necessary relevant investigations. I will promote Mental and Physical Health/Wellbeing both onshore and onboard to the best of my abilities as per the Company’s relevant policy.

6. I am aware of all my duties and responsibilities. I understand and will fully implement all policies/regulations related to my line of service and will undertake any actions under my responsibility to ensure that the safety, security, health, quality and protection of the environment are maintained. I am also aware of Company’s Travel Policy and Guide.

7. I am aware that the proper disposal of all oily wastes, including bilge and sludge, by the proper use of the equipment on board ships or by discharging them ashore into appropriate reception facilities is of very high importance. I am also aware that noncompliance with relevant IMS policies and procedures may render the Company liable for breach of regulations and I will also be at risk of criminal prosecution, which could result in my imprisonment. I will never instruct any person to violate the above policies and procedures and if I become aware of any problem that may lead to or allow a violation of Company’s policies and procedures or international regulations, I will immediately contact the DPA or the Company’s Top Management.

8. I am aware of the Company’s commitment to environmental protection which includes the absolute and total prohibition of the use of “magic pipes” i.e., the surreptitious change to a ship’s waste-handling equipment, which allows waste liquids to be discharged in contravention of pollution regulations. I will report immediately any use or suspicion of use of such prohibited practices to the Master or the DPA or the Company’s Top Management and I am aware that I am required and authorized to immediately stop by any means necessary any violation, even if this is carried out by one of my superiors, without fearing that my career or employment may be jeopardized. I am also aware that reporting any suspected violation will not be subject to disciplinary action or otherwise retaliation by the Company against me.

9. I am aware of the Company’s Open Reporting System and I understand that the Company’s policy prohibits retaliation against or in any way treating adversely any subordinate, co-worker, employee or crew member for their reporting of any safety, environmental, health or integrity violation.

10. I am aware that the Company does not provide any bonus for reducing operational, maintenance and repairs budget for the machinery space systems, and seeks to ensure that employees will not sacrifice environmental compliance in order to obtain a prescribed bonus.

11. I will not make or instruct any person to make false entries in the Oil Record Book, as well as in the Garbage Record Book and other ship’s logs/records, nor will I conceal any such act if it comes to my attention, and I understand that doing so is a violation of law and will result in my dismissal. In case I become aware of such false entries, I will immediately report them to the Company.

12. I have provided the Company with accurate personal information (identification card, contact details, address) and with all certificates and licenses which I hold, which are genuine.

13. I understand that any data (whether in electronic form or not) containing information regarding the operation of the Company (including inter alia information of financial or technical nature, personal data of people employed by the Company or onboard the ships managed by the Company and information regarding incidents, accidents, near misses or claims) is confidential unless marked otherwise. I will not copy such information or disclose such to parties outside the Company without permission. I will not use such information for any purpose other than to fulfill my work duties and I will take any action necessary to protect such information from unauthorized access, disclosure or destruction. I will notify the Company immediately about any known or suspected breach of confidentiality. I will not take any property (keys, ID cards, laptop, company’s mobile etc.) belonging to the Company, without prior written permission to do so.

14. I am aware of the Harassment, Bullying, Sexual Assault and Sexual Harassment policy and commit to not undertake any actions of harassment, bullying, sexual assault or sexual harassment against any person while on board the above ship. I also will refrain from any act, negative or hostile behavior which creates feelings of unease, humiliation, embarrassment, intimidation, or discomfort to the recipient. I shall report any harassment, bullying, sexual assault or sexual harassment incident, including those affecting others, as per Company’s reporting procedures.

15. I am aware of all potential consequences for deviating from or failing to comply with the above specified policies and procedures.

16. All items contained in my Seafarer’s Employment Agreement (SEA) have been explained to me and I am aware of them.

17. A full sample SEA incorporating all terms and conditions to apply (including the Collective Bargaining Agreement (CBA)) has been provided to me prior to entering into the Agreement.

18. I was given adequate time to review the SEA and seek advice on the terms and conditions contained in it.

19. I freely entered into the Agreement with a sufficient understanding of my rights and responsibilities.

20. I was given an original set of my SEA which I must carry with me on board (or a copy).

21. No fees or other charges for my recruitment or placement or for providing employment to me have incurred directly or indirectly, in whole or in part.

22. No joining advances or any other exploitation has incurred with regard to my employment.

23. The Company’s Complaint procedure has been explained to me and I am fully aware of the process to be followed and the record to be used.

24. The terms and conditions of employment and any particular conditions applicable to the job for which I am engaged have been explained to me.

1. Data Processing, Data Retention and Processing Purposes

1.1 The Company, in its capacity as a data controller, processes your personal data collected either from you directly and/or from the Company and/or a third party (e.g. recruiters, et. al.) in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), the applicable legislation in relation to personal data and shipping practice. More specifically, we process 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 vessel 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 information relating to your results in psychometric tests), 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, as well as any other data necessary in connection with the purposes described below.

1.2 The Company processes your data during your employment, while such processing may be extended after the completion of such employment, in order for the Company to comply with its legal obligations towards the competent authorities or third parties, due to applicable provisions on data retention periods or in order for the Company to establish, exercise or defend legal claims.

1.3 We process your data in order to ensure it our s proper operation in accordance with our employee-related procedures, to fulfil our manning needs, to comply with our legal and contractual obligations, to identify our employees and to ensure the safety of our staff, of the vessels we manage and of our premises and the fitness to work of our employees.

2. Third party data transfers

2.1 We will transfer your data to third parties, such as the competent authorities, local agents, travel agents, airlines, technical contractors, investigators and other agents, accountants, auditors, lawyers, insurance providers, the P&I Club employed by the Company and 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 vessels managed by the Company.

2.2 We may also transfer some or all of your data to persons located in countries outside 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 GDPR, 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.

3. Your rights

You have the right to: (a) request access to your data and to information relating to the processing of your data, (b) request corrections and/or completion of your data, (c) request deletion of your data, (d) request the restriction of the scope of processing, the way that we are processing your data, as well as the purposes for which we are processing them, (e) receive the data you provide to us in a structured, commonly used and machine-readable format, transmit them to another data controller, and/or request us to transmit them to another data controller, if technically feasible, (f) object to the processing of your data, on grounds relating to your particular situation, and (g) 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 us as stated below at 5.

4. Legal basis for processing and obligation to provide data

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

(a) comply with its legal obligations, including among others obligations in the field of employment or social security law;

(b) perform your employment agreement;

(c) pursue its legitimate interests, such as to comply with its employee-related procedures, to fulfil its manning needs, to comply with its legal and contractual obligations, to establish, exercise or defend legal claims, to identify its employees and to ensure the safety of the vessels it manages, of its staff and of its premises, as well as the working capacity of its employees; and/or

(d) establish, exercise or defend legal claims.

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 performance of your employment agreement may not be possible.

5. Communication

You can communicate with the Company as follows:

Webulk Denizcilik İşletmeleri A.Ş. Crew Manager -

ACKNOWLEDGEMENT OF RECEIPT - I hereby acknowledge the receipt of the above information from the Company for the processing of my personal data