Protecting Your Privacy

Sullivan Maritime Limited (“Sullivan Maritime” or “We”) strongly values your privacy and are committed to protect your personal data (i.e. information that identifies you) as though it is our own.

If you have any questions about how we protect your privacy, get in touch here: T: +356 2299 5110, E info@sullivanmaritime.com.

One of your rights under EU law – the GDPR – is that you must be informed when your personal data – also known as personal information – is processed (collected, used, stored) by any organisation. You also have the right to know the details and purpose of that processing.

This privacy policy describes our practices relating to the personal data of visitors on our website  www.sullivanmaritime.com who make use of our online facilities.

 For all our services, the data controller — the company that is responsible for your privacy — is Sullivan Maritime Limited with its address at 21/22 St Barbara Bastions, Valletta.

We assure you that We will only use and disclose any personal data collected from you in accordance with the manner set out in this Privacy Policy.

Navigating this Privacy Policy (Contents)

• Information which we collect
• How & Why we use your information
• Children Under 18
• Sharing your information
• Marketing Messages
• Seeing our adverts online
• Cookies
• Your rights
• Security of your Personal Data
• Changes to how we protect your privacy
• Links to other websites
• How to contact us

Information we collect

Most personal information which we collect about you through this website is given to us only if you choose to give it to us.

Such personal information may be requested from you when you fill in a field (e.g. to obtain our services or to get a quote). If you send us emails, then the personal data we process will depend on what you send us in the email.

The information we collect from you may include the following, depending on how you use the website:

1. Name & Surname;
2. Contact Details;
   1. Email address
   2. Home Address
   3. Telephone Number
   4. Mobile number
3. Date of Birth;
4. IP Address
5. Information obtained through your emails or enquiries ;
6. Information about your device (phone or laptop) with which how used our website;

Check out the next sections to understand how and why we use this information.

Some other information is given to us because you accessed this website (e.g. logs, recorded through cookies).

Children Under 18

If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to us.

We will need to process personal data relating to parents or guardians in that case – and we may also need to request for verification documentation to ensure that consent is given or authorised by the holder of parental responsibility.

Sharing your information

We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or credit card information. It is not our business to do so – and we want to earn your trust and confidence.

• However, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this statement:
  1. Our present principals Grimaldi Group SpA, Hoegh Autoliners Holdings AS, Sloman Neptun Schiffahrts and any of their group companies or representatives in order to provide you with the shipping services you book through our agency, and any other future principal for which we act as agents from time to time.
  2. Other companies that are involved in the process of getting your shipments to you, such as payment service providers, warehouses, order packers, and delivery companies.
  3. In case of shipments from outside the EU, we may also be obliged at law to pass on your contact details and personal data to the Customs Department for their mandatory checks,
  4. In cases where you need access to collect your shipped goods, to Terminals including Valletta Gateway Terminal (VGT), Malta Freeport Terminals (MFT), Mediterranean Maritime Hub (MMH) and other terminal operators in order to provide you with access to the Valletta Port terminal
  5. Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud or organized crime
  6. In some cases we may also be requested to provide certain information to Transport Malta and we will need to do this to comply with our obligations at law
• In most circumstances we will not disclose personal data without consent. However there may be occasions where we might have to – e.g. with a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, re-organisation, dissolution or similar event involving us and/or our subsidiaries and related entities.
• When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended – again, we don’t want you to have any surprises.
• We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous.
• If we ever have to share data with entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements established by the GDPR.

Marketing Messages

We would normally communicate to you about products or services in which you have shown interest – we understand that you would be interested in receiving this information as it is of use with the product or service. But rest assured, you can ask us to stop.

Also, if you have said we can (i.e. you gave us your clear confirmation), we will send you marketing messages by email or SMS, to keep you aware of what we’re up to and to help you see and find our products.

How to stop marketing messages from us

You can stop receiving marketing messages from us at any time through any of the following methods:

• By contacting our Customer Care team on info@sullivanmaritime.com
• By replying to an email and stating that you want to stop receiving marketing messages.

Once you do this, we will update your profile to ensure that you don’t receive further marketing messages. Please note that, it might take a few days for all our systems to be updated, so you might get messages from us while we process your request.

If you ask us to stop marketing messages this will not stop service communications (such as order updates). This may be necessary of us to communicate to you as part of our services from our contract.

Seeing our adverts online

We engage in online advertising, also to keep you aware of what we’re up to and to help you see and find our products using targeted ads which may appear when you are on other websites and apps that offer such digital marketing services.

We use a range of advertising technologies like ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks, such as Facebook’s Custom Audience service.

The banners and ads you see will be based on information we hold about you, or your previous use of our website (for example, your search history, and the content you read) or on banners or ads you have previously clicked on.

Your Rights

You enjoy several rights relating to your personal information:

1. 1. The right to be informed about how your personal information is being used; We need to be clear with you about how we process your personal data. We do this through this Privacy Policy, which we will keep as up to date as possible.
   2. The right to access the personal information we hold about you; You can access the personal data we hold on you by contacting us info@sullivanmaritime.com or +356 2299 5110. To process your request, we will ask you to send us proof of identity so that we can be sure we are releasing your personal data to the right person.We will carry out our best efforts to process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your personal data in electronic format.If we consider the frequency of your requests as being unreasonable, we may refuse to comply with your request. In those circumstances, if you disagree, you can complain to the data protection authority – in Malta, the Information and Data Protection Commissioner.
   3. The right to request the correction of inaccurate personal information we hold about you; We appreciate feedback from you to ensure our records are accurate and up-to-date.If you think that the information we hold about you is inaccurate or incomplete please ask us to correct it by contacting us here info@sullivanmaritime.com or +356 2299 5110
   4. The right to request that we delete your data, or stop processing it or collecting it; You can ask us to delete your personal data; however, this is not an absolute right.In spite of a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation (for instance, we are required by personal data for VAT reporting purposes); and (ii) in relation to the exercise or defence of any legal claims.When you ask us to delete your personal data, we assume that you do not want to hear from us again. To ensure that we do not send you any special offers in the future (for example, if we purchased your details from a third party list), we will retain just enough of your personal data solely for suppression purposes.Other than as described above, we will always comply with your request and do so promptly. We would carry out our best efforts to notify any third parties with whom we have shared your personal data about your request so that they could also comply.
   5. The right to stop direct marketing messages;
   6. The right to object to certain processing based on legitimate interest; You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated means.
   7. The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;
   8. The right to withdraw consent for other consent-based processing at any time;
   9. The right to request that we transfer or port elements of your data either to you or another service provider; You have the right to move, copy or transfer your personal data from one organisation to another. If you do wish to transfer your personal data we would be happy to help.If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation.Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the personal data we provide.When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.
   10. The right to complain to your data protection regulator — in Malta – the Information and Data Protection Commissioner (IDPC)

If you want to exercise your rights, have a complaint, or just have questions, please contact us here info@sullivanmaritime.com or +356 2299 5110

Please appreciate that the rights must be exercised within some limitation – for example, if you ask us for information we can only give you what relates to you and not what relates to other persons. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification (we would not want to disclose information to the wrong person). Unreasonable requests may be subjected to a reasonable fee or refusal to respond.

Securing of your Personal Data

Security of your personal data is very important to us.

Where it’s appropriate, our website uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.

You may complete a registration process when you sign up to use parts of the websites. This may include the creation of a username, password and/or other identification information. Any such details should be kept confidential by you and should not be disclosed to or shared with anyone.

Where you do disclose any of these details, you are solely responsible for all activities undertaken where they are used.

Whenever you create a password, then to protect your account you should choose a strong password, meaning it should be lengthy and include a mixture of letters and numbers with mix of CAPS.

We do our best to keep the information you disclose to us secure. However, we cannot guarantee or warrant the security of any information which you send to us.

Security measures which have implemented to secure information transmitted over our website or stored on our systems include the following:

1. Use of secure servers; load balancers, SSH access, Package Managements
2. SSL Certificates
3. Code and Database Backups
4. Uptime Monitoring;
5. Regular Updates to WordPress Core and Plugins

Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.

Changes to how we protect your privacy

Our website is continually under review – new functions and features are periodically added and improved to interface, thus changes to our privacy policy may be required from time to time.

We therefore encourage you to check our privacy policy on a frequent basis.

Links to Other Websites

This privacy notice does not cover the links within this site linking to other websites which are not controlled by us. We are not responsible for the collection or use of your personal information from these third-party websites.

Therefore, we encourage you to read the privacy statements on the other websites you visit.

How to contact us

We are always happy to hear from you, whether to make a suggestion but especially if you feel we can do better.

If you have any questions about this Privacy Policy, or if you wish to make a complaint about how we have handled your personal information, please contact us at:

Sullivan Maritime Ltd.

21/22, St Barbara Bastion, Valletta VLT 1961, Malta

For more information please contact us on info@sullivanmaritime.com or +356 2299 5110