The protection of your personal data is a special concern to us. Therefore we only process your personal data (in short, “data”) on the basis of legal provisions. This data privacy statement is intended to provide you with information about the processing of your data in our company and the claims and rights that you have under data protection law within the meaning of art. 13 of the European General Data Protection Regulation (EU-GDPR).
1. Who is responsible for data processing and whom can you contact?
The data controller is
MINSHIP Shipmanagement GmbH & Co. KG
Am Ruttmann Kai 1
Phone: 09622 84800
The acting data protection officer is
Projekt 29 GmbH & Co. KG
Phone: 0941 2986930
2. What data is processed and what are the sources of this data?
We process the data that we receive from you as part of initiating or executing the contract, based on consent or in the context of your application or employment with us.
Personal data includes:
Your reference/contact data, which for customers includes first and last name, address, contact information (e-mail address, phone number, fax), bank details etc.
For applicants and employees, this includes first and last name, address, contact information (e-mail address, phone number, fax), date of birth, data from CV and employer’s references, bank details, religious affiliation, pictures etc.
For business partners, this includes the name of your legal representative, company, commercial register number, VAT ID no., company registration number, address, contact information for point of contact (e-mail address, phone number, fax), bank details etc.
For those visiting our company, this includes name and signature.
For journalists, this includes first and last name, e-mail address, fax number.
For contest participants, this includes first and last name, e-mail address.
We also process the other following personal data:
- information about the nature and content of contractual data, order data, sales and document data, customer and supplier history and consultation materials,
- advertising and distribution data,
- information from your electronic traffic with us (such as IP address, login info),
- other data that we have received from you in the context of our business relationship (such as in customer meetings),
- data that we generate ourselves from reference/contact data or otherwise, such as through analysis of customer needs and customer potential,
- documentation of your consent form for receiving newsletters, etc.,
- photos taken at events.
3. For what purposes and on what legal basis is data processed?
We process your data in compliance with the provisions of the General Data Protection Regulation (GDPR) and the 2018 Federal Data Protection Act in its current valid form:
- to fulfil (pre-)contractual obligations (art 6(1)b GDPR):
Your data is processed online or in one of our branches in order to process the contract for your employment in our company. In particular, data is processed when business is initiated and contracts are implemented with you.
- to fulfil legal requirements (art 6(1)c GDPR):
It is required to process your data for the purpose of fulfilling various legal requirements, such as from the commercial code or tax code.
- to safeguard legitimate interests (art 6(1)f GDPR):
Due to a balancing of interests, data may be processed beyond the actual fulfilment of the contract in order to safeguard our legitimate interests or those of third parties. Data will be processed to safeguard legitimate interests in the following cases, for example:
– advertising or marketing (see no. 4),
– measures for business management and further development of services and products;
– keeping a group-wide customer database to improve customer service
– as part of prosecution
– sending non-promotional information and press releases.
- in the context of your consent (art 6(1)a GDPR):
If you have given us your consent to have your data processed, e.g. to send our newsletter, publish photos, contests etc.
4. Processing of personal data for advertising purposes
You may object to the use of your personal data for advertising purposes at any time, in whole or to individual actions, without incurring costs other than those for transmission based on the base rates.
According to the statutory conditions under § 7(3) of the Unfair Competition Act, we are entitled to use the e-mail address that you provided us when concluding the contract for direct advertising of our own similar goods or services. You will receive these product recommendations from us regardless of whether you have subscribed to a newsletter.
If you do not wish to receive any recommendations like this via e-mail, you can object to the use of your address for this purpose at any time, without incurring costs other than those for transmission based on the base rates. Notification in text form is sufficient for this. Each e-mail will also always include a link to unsubscribe.
5. Who receives my data?
If we use a service provider in the sense of processing an order, we will still be responsible for protecting your data. All order processors are contractually obliged to handle your data as confidential and only to process it in the context of rendering services. The order processors we commission will receive your data where this is necessary in order to fulfil the respective service. This includes IT service providers whom we require for the operation and security of our IT system, as well as advertising and address publishers for our own ad campaigns.
Your data will be processed in our customer database. The customer database helps to improve the data quality of existing customer data (duplicate cleansing, removed/defunct registration numbers, address corrections) and allows it to be supplemented with data from public sources.
This data is made available to the companies in the group where necessary for executing a contract. Customer data is stored on a company basis and separately, whereby our parent company acts as a service provider to the individual participating companies.
If there is a legal requirement or as part of prosecution, authorities, courts and external auditors may be recipients of your data.
Insurance companies, banks, credit agencies and service providers may also be recipients of your data for the purpose of initiating and fulfilling contracts.
6. How long will my data be stored for?
We process your data until the end of the business relationship or until the valid legal retention periods have expired (e.g. from the commercial code, the tax code or the Working Hours Act); additionally, until the end of all legal disputes in which the data is needed as evidence.
7. Will personal data be transmitted to a third country?
We do not transmit any data to third countries as a general rule. Data will only be transmitted in isolated cases based on an adequacy decision by the European Commission, standard contractual clauses, applicative warranties or your express consent.
8. What are my data protection rights?
Any at time, you have the right to obtain information, correction, erasure or restriction of the processing of your stored data, right to object to processing and the right to data portability and to lodge a complaint under the conditions of the data protection law.
Right to information:
You may request information from us on whether and to what extent we process your data.
Right to correction:
If we process your data and it is incomplete or inaccurate, you may request that we complete or correct it at any time.
Right to erasure:
You may request that we erase your data if we are processing it unlawfully or the processing of it unreasonably infringes on your legitimate interests. Please note that there may be reasons that preclude immediate erasure, e.g. in the event of retention periods regulated by law.
Regardless of whether you exercise your right to erasure, your data will be immediately and completely erased if there are no contractual or statutory retention periods that preclude this.
Right to the restriction of processing:
You may request the restriction of the processing of your data if:
– you dispute the accuracy of the data, and for a period that allows us to review the accuracy of the data.
– your data is processed unlawfully, but you decline its erasure and instead request that its use be restricted,
– we no longer need data for its intended purpose, but you still require the data to assert or defend legal claims, or
– you have lodged an objection to the processing of data.
Right to data portability:
You may request that we provide the data you have given us to you in a structured, common and machine-readable format and that you may have us transmit this data to another controller without hindrance if:
– we process this data based on the revocable consent granted by you or to fulfil the contract between us, and
– processing is completed by automated means.
Where technically feasible, you may request that we directly transmit your data to another controller.
Right of objection:
If we process your data for legitimate interests, you may object to this data processing at any time. We will then no longer process your data unless we can demonstrate compelling reasons for processing that are worthy of protection and outweigh your interests, rights and freedoms or unless processing serves the purpose of asserting, exercising or defending legal claims. You may object to the processing of your data for the purpose of direct advertising at any time without stating reasons.
Right to lodge a complaint:
If you believe that we have violated German or European data protection law in processing your data, we ask that you contact us so that we can resolve the issues. You naturally also have the right to contact your responsible regulatory authority, the respective state office for data protection supervision.
If you wish to assert one of the rights above against us, please contact our data protection officer. In case of doubt, we may request additional information to confirm your identity.
9. Am I obligated to provide data?
The processing of your data is necessary to conclude or fulfil your contract with us. If you do not provide us with this data, we will generally have to refuse to conclude the contract or we will no longer be able to implement an existing contract, and subsequently terminate it. However, you are not obligated to consent to the processing of data that is not relevant to contractual fulfilment or not legally required.