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At BMS United Bunkers Ltd. (”BMS United”, ”we”, ”us” or ”our”) confidentiality and data protection is a high priority. This privacy policy applies for our processing of personal data and provides you with the information you have the right to receive according to applicable data protection law. You must read the privacy policy before submitting your personal data to BMS United.

Data controller and contact information

The data controller for your personal data is:
BMS United Bunkers Ltd
Address: 8 Spatharikou Str., 4004 Mesa Yeitonia, Limassol, Cyprus
Company registration no.: 295960
Email: marketing@bmsunited.com

Users of website

This section sets out the policy of BMS United’s processing of personal data collected from users of BMS United’s website bms.kommigraphics.com.

Collection of personal data

BMS United may collect, process and store personal data about you in the following instances:

• When you visit and browse our websites
• When you communicate with BMS United
• When you make use of other functions and services offered by BMS United

Categories of personal data

BMS United may collect, process, and store the following personal data about you:

• Identification data (such as name, e-mail address, telephone number and similar)
• Communications with you
• Interests
• Digital footprints (such as Information about your usage of our websites, IP address, MAC-address, the type of browser you are using, operating system and version, connection to Wi-Fi SSID, device name, location data and time zone)

Purposes of the processing

Your personal data may be processed for the following purposes:

• Promotional marketing in general
• Completion of requests received from you
• General communication
• Support
• Product and service development
• Statistics and analysis

Legal basis

BMS United will mainly process your personal data based on one or more of the following legal bases:

• Legitimate interests: In most cases, the processing of your personal data will be based on our legitimate interest in, for instance, being able to reply to your inquiries, conducting statistics, analysis, marketing activities (where consent is not required), providing support as well as improving and developing our products and services (Article 6 (1) (f) of the General Data Protection Regulation).

Retention period

Your personal data will be retained for 6 months and are then stored in a manner that makes it impossible to identify you.

Cookies

We use cookies on our websites. You can read more about the use of cookies in our Cookie Policy, which you can find at the following link: https://bms.kommigraphics.com/cookie-policy/.

Links to other websites

Our websites may contain links to other websites. We are not responsible for the content of other companies’ websites or their practices in collecting personal data. When you visit other websites, you are advised to read the owner’s policy for protection of personal data and other relevant policies.

Contact Persons at suppliers and other business partners

This section sets out the policy of BMS United’s processing of personal data collected from owners of sole proprietorships or contact persons at customers, suppliers and other business partners who collaborate with BMS United.

Collection of personal data

BMS United may collect, process and store personal data about you in the following instances:

• When your company or the company you are employed with enters into an agreement with BMS United
• When you have shown an interest in BMS United’s products or services, e.g. by providing your business card to BMS United
• When you collaborate and communicate with BMS United

Categories of personal data

BMS United may collect, process, and store the following personal data:

• Identification data (such as name, e-mail address, telephone number and similar)
• Individual data, such as preferred language
• Organizational data, such as company name, company address, job position, business area, primary work location and country
• Contractual data, such as purchase orders, invoices, contracts, and other agreements between your company (or your employer) and BMS United, that may include e.g., your contact information and communications with you
• Legitimation papers such as passport or drivers’ license if we are obliged to carry out ‘know your customer’ procedures
• Financial data, such as payment terms, bank account details and credit ratings
  Such information may be provided directly by you (primarily via e-mails and other correspondence) or by a third party such as your employer.

Purposes of the processing

Your personal data may be processed for the following purposes:

• Generally, to plan, perform and manage the business relationship, including any contracts
• Administration, such as processing payments, evaluation of credit ratings, performing accounting, auditing, billing, as well as providing support services
• Newsletters and other promotional communication
• Completion of requests received from you
• General communication
• Product and service development
• Statistics and analytics
• Compliance and regulatory purposes, such as fulfilling our legal and compliance-related obligations to prevent illegal activity or our obligation to carry out ‘know your customer’ procedures
• Dispute handling

Legal basis

BMS United will mainly process your personal data based on the following legal bases:

• Contractual obligation: The processing of your personal data will in some cases be necessary for the performance of a contract (Article 6 (1) (b) of the General Data Protection Regulation).
• Legitimate interests: We may process your personal data pursuant to our legitimate interest in, for instance, to manage daily operations according to lawful and fair business practices, including planning, performing, and managing the business relationship or our legitimate interest in e.g., conducting credit ratings, statistics, analysis, marketing activities (where consent is not required), providing support as well as improving and developing our products and services. The processing may also be necessary for our legitimate interests in preventing fraud or establish, exercise, or defend legal claims (Article 6 (1) (f) of the General Data Protection Regulation).
• Legal obligation: The processing of your personal data will in some cases be necessary to comply with legal obligations, such as our obligations to prevent illegal activity (Article 6 (1) (c) of the General Data Protection Regulation).
• Consent: In exceptional cases and only when no other legal basis can be applied, BMS United may ask separately for your consent to process your personal data (Article 6 (1) (a) of the General Data Protection Regulation). BMS United will, for instance, only use your personal data to send you product information, newsletters, and other marketing material via e-mail if you have provided your prior and explicit consent hereto, unless applicable legislation allows us to contact you without such consent.

Retention period

Your personal data will be retained for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements or until we are requested to delete them.

Information to job applicants

This section sets out the policy of BMS United’s processing of personal data in relation to recruitment.

Collection of personal data

BMS United may collect, process and store personal data about you as a part of the handling of your application and in relation to the recruitment process.

Categories of personal data

BMS United may collect, process, and store the following personal data:

• Personal data which you have disclosed in your job application and CV as well as any attachments
• Personal data you disclose during any job interviews
• Information about you, including information regarding your previous jobs, activities, competencies, performance, as well as your general appearance, which is publicly available on the internet, including on social media.
• Results of personality tests etc.
• Criminal records
• References from your previous and/or current employers
• Credit information and rating if the position you have applied for involves financial responsibilities (e.g., bookkeeping or accounting)

Purposes of the processing

Your personal data will be processed for the purpose of assessing whether we can offer you a position.

Legal basis

BMS United will mainly process your personal data based on the following legal bases:

• Request to enter into an employment contract with us: We may process your personal data on the basis of your request to enter into an employment contract with BMS United (Article 6(1)(b) of the General Data Protection Regulation).
• Legitimate interests: We may process your personal data on the basis of our legitimate interests in carrying out further assessments of whether we want to hire you, including on the basis of personality tests, publicly available information on the internet and – if the position entails a financial responsibility – credit information and rating (Article 6(1)(f) of the General Data Protection Regulation).
• Consent: In exceptional cases and only when no other legal basis can be applied, BMS United may ask separately for your consent to process your personal data (Article 6 (1)(a) of the General Data Protection Regulation). BMS United will, for instance, only take references from your previous and/or current employers or collect your criminal records if you have consented to this.

Retention period

If you are offered a position with BMS United your application and additional relevant personal data obtained during the recruitment procedure will be stored in your employee file.
If you are not offered a position, we will store your application and any additional personal data obtained during the recruitment procedure for a period of 6 months following our rejection, unless you have provided your consent to the storage hereof for a longer period.
If we have collected your criminal records, we will delete them immediately after we have received and reviewed them.

Newsletter signup

This section sets out the policy of BMS United’s processing of personal data in relation to management of newsletters.

Collection of personal data

BMS United may collect, process and store personal data about you when:

• You sign up for our newsletters
• You interact with newsletters we have sent to you

Categories of personal data

• Identification data (such as name, e-mail address, company, telephone number and similar)
• Interests
• Click behaviour
• Information concerning your consent to receive newsletters

Purposes of the processing

Your personal data may be processed for the purpose of sending you newsletters and other marketing material regarding our products and services.

Legal basis

BMS United will mainly process your personal data based on the following legal bases:

• Consent: BMS United uses your personal data to send you product information, newsletters, and other marketing material via e-mail based on your prior and explicit consent hereto (Article 6 (1)(a) of the General Data Protection Regulation), unless applicable legislation allows us to contact you without such consent.
• Legitimate interests: We may process your personal data on the basis of our legitimate interests in adjusting our marketing material to you on the basis of your click behaviour (Article 6 (1)(f) of the General Data Protection Regulation).

Retention period

Your personal data will be retained until you unsubscribe from our Newsletter. Once you have unsubscribed we may retain your data for up to 6 months to ensure that your data has been deleted or anonymised in all locations.

Disclosure to other data controllers and transfer to data processors

To fulfil the above purposes, we may provide access to your personal data for third parties who, based on a contractual relationship with BMS United provide relevant services, e.g., IT-providers, customer service centres, invoicing providers, email providers, marketing providers and affiliated companies Such service providers will only process personal data in accordance with our instructions pursuant to agreed data processing agreements.

In connection with BMS United’s development, the company structure may change, e.g., through a full or partial sale of BMS United. In case of a partial hand over of assets containing personal data, the legal basis for the related disclosure of personal data is, primarily, Article 6(1)(f) of the GDPR, as BMS United has a legitimate interest in handing over part of its assets as well as making commercial changes.

Aside from above, it is a general rule that your personal data is not disclosed to a third party without your permission. However, under certain circumstances and in accordance with applicable law, we may need to disclose your personal data to

• Police
• Advisors such as lawyers and auditors
• Courts
• Public authorities
• Prospective buyers
• Affiliated companies

If your personal data is transferred to data processors or data controllers established in countries outside the EU/EEA which does not have an adequate level of protection, such transfer will in general be based on the EU Commission’s standard contracts.

Your rights

• You have the right to access the personal data we process about you
• You have the right to object to our collection and further processing of your personal data
• You have the right to have your personal data rectified and deleted, with certain statutory exceptions, including applicable bookkeeping and anti-money laundering legislation
• You have the right to request us to restrict the processing of your personal data
• Under certain circumstances you may also request to receive a copy of your personal data as well as the transmission of your personal data which you have provided us with to another data controller (data portability)
• You may, always, withdraw any consent you may have given. We will then delete your personal data unless we can continue the processing on another basis. Our newsletter can be unsubscribed by clicking the link at the bottom of the newsletter. Please be aware that withdrawal of your consent does not affect the legality of the processing based on your consent prior to the withdrawal.

Questions or complaints

If you have any questions in relation to this privacy policy or if you wish to make a complaint in connection to our processing of your personal data, please contact us:

BMS United Bunkers Ltd
Address: 8 Spatharikou Str., 4004 Mesa Yeitonia, Limassol, Cyprus
Email: marketing@bmsunited.com

If your complaint is not resolved by us and you wish to proceed with the case, you can send your compliant to the supervisory authority in your country.

Changes to the privacy policy

We reserve the right to make changes to this privacy policy from time to time. When updated, the date at the bottom of the privacy policy will be updated accordingly.

Approved
29/11/2021