PRIVACY AND DATA PROTECTION POLICY OF INTERNATIONAL ANDROMEDA SHIPPING S.A.M.
1. Purpose
International Andromeda Shipping SAM (“IAS SAM”), Monaco, and its affiliated crewing and support office, are committed to protecting the privacy, confidentiality, integrity, and security of personal data entrusted to us by employees, seafarers, applicants, customers, suppliers, contractors, and other stakeholders.
This privacy policy explains what data may be collected by us including via our website at https://www.andromeda-shipping.com/ (“Website”) or other means, what is the purpose and how this data will be processed. It also explains your rights in relation to your personal data and how to contact us in the event you have a complaint. By visiting the site, you are acknowledging and accepting this Privacy Policy.
This Policy establishes our commitment to comply with applicable data protection and privacy laws, including the European Union General Data Protection Regulation (Regulation (EU)2016/679) (“GDPR”), Monaco data protection requirements (The landmark Law No. 1.565), and other applicable national regulations governing the collection, processing, storage, transfer, and protection of personal data.
2. Scope
This Policy applies to all personal data processed by IAS SAM and its affiliated crewing and support office in connection with ship management, crewing, recruitment, commercial operations, technical management, administration, and related business activities.
3. Data Protection Principles
IAS SAM is committed to ensuring that personal data is:
• Processed lawfully, fairly, and transparently.
• Collected for specified, legitimate, and lawful purposes.
• Adequate, relevant, and limited to what is necessary.
• Accurate and kept up to date.
• Retained only for as long as necessary.
• Protected against unauthorized access, disclosure, alteration, loss, or destruction.
• Processed in a manner that ensures confidentiality, integrity, and availability.
4. Personal Data We May Process
Depending on the nature of our relationship, we may process personal data including:
• Personal identification details.
• Contact information.
• Employment and recruitment records.
• Seafarer certification and qualification records.
• Payroll and banking information.
• Medical fitness documentation where required by maritime regulations.
• Travel, visa, and immigration information.
• Training and performance records.
• Business contact information of customers, suppliers, and contractors.
• Website and electronic communication data.
Special categories of personal data, including medical information, may be processed only where legally required, necessary for employment or maritime operations, or with appropriate consent.
5. Purpose of Processing
Personal data may be processed for purposes including:
• Recruitment, employment, and crew management.
• Compliance with maritime conventions and regulatory requirements.
• Contract administration and business operations.
• Payroll, benefits, and welfare administration.
• Safety, security, and emergency response.
• Training, competency management, and performance evaluation.
• Customer and supplier relationship management.
• Legal, regulatory, and audit requirements.
• Protection of company assets, systems, and information.
6. Lawful Basis for Processing
IAS SAM processes personal data only where there is a lawful basis to do so, including:
• Performance of contractual obligations.
• Compliance with legal and regulatory requirements.
• Legitimate business interests.
• Protection of vital interests.
• Consent, where required by applicable law.
7. Data Sharing and International Transfers
Personal data may be shared within the Andromeda Group, including between IAS SAM in Monaco and Andromeda Shipping India Pvt. Ltd. in Mumbai, as necessary for operational, crewing, employment, compliance, and business purposes.
Where personal data is transferred internationally, appropriate safeguards shall be implemented to ensure that personal data remains adequately protected and processed in accordance with applicable data protection laws.
Personal data may also be disclosed to:
• Vessel owners and charterers where operationally required.
• Flag administrations and maritime authorities.
• Classification societies and auditors.
• Medical providers and insurers.
• Government authorities and regulators.
• Service providers acting on behalf of the Company.
8. Data Retention
Personal data shall be retained only for as long as necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, and enforce contractual agreements.
Upon expiry of applicable retention periods, personal data shall be securely deleted, anonymized, or destroyed.
9. Data Security
IAS SAM maintains appropriate technical, administrative, and organizational measures to protect personal data from unauthorized access, misuse, disclosure, alteration, or loss.
These measures include:
• Access controls and user authentication.
• Information security procedures.
• Secure storage and transmission of data.
• Employee awareness and training.
• Incident management and reporting processes.
• Periodic review of security controls.
10. Rights of Individuals
Subject to applicable laws, individuals may have the right to:
• Access their personal data.
• Request correction of inaccurate information.
• Request deletion of personal data where legally permissible.
• Restrict or object to processing.
• Request data portability.
• Withdraw consent where processing is based on consent.
• Lodge a complaint with the relevant supervisory authority.
11. Responsibilities
All employees, seafarers, contractors, and personnel handling personal data are responsible for protecting such information and complying with this Policy and applicable data protection requirements.
Management shall ensure adequate resources, oversight, and continual improvement of data protection practices throughout the organization.
If you have any questions on how we collect and treat personal data (including any complaints that you may have in relation to our handling of your personal data) or would like to exercise any of the abovementioned rights, please send your inquiries to: corporate@andromeda-shipping.com
12. Continuous Improvement
IAS SAM is committed to regularly reviewing and improving its privacy and data protection practices to ensure ongoing compliance with legal requirements, industry best practices, and stakeholder expectations.
Through responsible management of personal data, IAS SAM reaffirms its commitment to safeguarding privacy, maintaining trust, and supporting secure and ethical maritime operations.
