I. General information on Data Protection

I.1 Information about the Data Controller:

Intership Navigation Co. Ltd
32 Miltonos Street
CY-3050 Limassol, Cyprus

We attach particular importance to protecting your personal data. Your personal data is processed in accordance with the data protection regulations, in particular the General Data Protection Regulation of the European Union (GDPR) and the German Federal Data Protection Act (BDSG).

The following information provides an overview of the nature, extent and purpose of collecting, processing and transferring personal data as well as the safety measures deployed to protect these data.

Personal data are individual information on personal or factual circumstances of an identified or identifiable natural person such as e.g. your name, address, telephone number, your date of birth as well your e-mail and IP address.


I.2. Legal basis for the processing of personal data

  • As far as we obtain a consent of the data subject for the processing of personal data, Art. 6 (1) a GDPR serves as legal basis. You can withdraw this processing at any time in accordance with Art. 7 (3) GDPR.
  • Art. 6 (1) b GDPR serves as legal basis for the processing of personal data required for the performance of a contract or for the execution of pre-contractual measures.
  • If processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) c GDPR serves as legal basis.
  • If the processing is necessary for the preservation of the legitimate interest of our company or of a third party and if the fundamental rights and freedoms of the person concerned do not predominate, Art. 6 (1) f GDPR serves as legal basis for processing. In this case, you have the right of objection according to Art. 21 GDPR.


I.3. Data deletion and storage period

Personal data will be deleted as soon as the purpose for storage no longer applies. In addition, storage may take place if this is required by statutory retention obligations to which our company is subject.


I.4. Your Rights

Upon written request, we will inform you in accordance with Art. 15 GDPR and in accordance with our legal obligation under Art. 12 GDPR whether and which of your personal data is processed or stored by us. Furthermore, you have the right to have incorrect data corrected in accordance with Art. 16 GDPR, data transferability in accordance with Art. 20 GDPR, blocking and deletion of your personal data in accordance with Art. 17 GDPR - provided that there are no legal storage obligations to the contrary - as well as the right to restrict processing in accordance with Art. 18 GDPR. In addition, you have the right to contact the competent supervisory authority pursuant to Art. 77 GDPR.

IN ADDITION, YOU HAVE THE RIGHT TO OBJECT PURSUANT TO ART. 21 GDPR, PROVIDED THAT THE PROCESSING RELATES TO LEGITIMATE INTERESTS ACCORDING TO ART. 6 (1) F GDPR.

If you have given us your consent to process your data, you may of course withdraw this consent for the future at any time in accordance with Art. 7 (3) GDPR.

If you have any questions regarding the processing of your personal data, you can contact our data protection contact person, who is also available to you in the event of requests for information, suggestions or complaints.

Data protection contact person
Intership Navigation Co. Ltd

32 Miltonos Street
CY-3050 Limassol, Cyprus

E-mail: data.privacy(at)intership-cyprus.com


I.5. Changes to our Privacy Statement

We reserve the right to make changes to our privacy statement to ensure that our privacy statement is always up to date with the current legal regulations. This applies also when the privacy statement needs to be adjusted due to new or redesigned services. The new privacy statement will then take effect the next time you use our services.

This privacy policy is dated 2023.

II. Privacy Policy Website

II.1. Provision of the website

Use of hosting service providers

Our website is hosted on servers of a hosting provider, which is located in the EU, based on an order processing according to Art. 28 GDPR. Within the scope of its services, the hosting service provider may have access to personal data of our users, in particular to technical data, which arise within the scope of the technical communication between you and our website (e.g. server log files). However, he may not use them for his own purposes. The use of a hosting service provider is based on our legitimate interests pursuant to Art. 6 (1) f GDPR in the provision of infrastructure and platform services, computing capacity, e-mail dispatch and security services.


Server Logs

When you visit our website or use our services the device used for accessing the site automatically transmits log data (connection data) to our servers. The relevant information consists of:

  • The browser and its version number,
  • The operating system and its version number,
  • The referrer URL, which is the website you visited before switching to our website,
  • The date and time of access to our website,
  • The name of the subpages,
  • The corresponding IP address,
  • The amount of data transmitted.

The data collected are used exclusively for evaluating the data statistically to ensure operation and safety and to optimise processing of the offer. For security grounds, however, we reserve the right to inspect log files retroactively if we have sufficient grounds to suspect illegal usage. The data will not be stored for longer than necessary. This collection is carried out on the basis of our legitimate interest under Art. 6 (1) f GDPR.


Cookies

In several areas of the website we use so-called “cookies”, for example to identify the preferences of the users and thus to optimally design the website. This allows for easier navigation and a high degree of user-friendliness of the website. The processing by cookies for the technical provision of the website constitutes a legitimate interest pursuant to Art. 6 (1) f GDPR / § 25 (2) TTDSG.

Cookies are small files, which are stored on the visitor’s hard disk drive. Cookies do not damage your computer and do not contain viruses. Most cookies used on the website are so-called “session cookies”. They are automatically deleted after the end of your visit. Other cookies stay on your devices and make it possible for your browser to be recognised the next time you visit. These files can be used, for example, to display information on the page that is specifically tailored to your interests.

You can change the properties of your browser so that it informs you of the placement of cookies. In this way, the use of cookies is made transparent. If you fully oppose the use of cookies, you may not be able to use individual functions of this website.


Security of Your Data

We deploy technical and organisational security measures to adequately protect the data that you have made available to us from being unintentionally or intentionally manipulated, lost, destroyed or accessed by unauthorised persons. Therefore, we are using SSL encryption for the transmission of confidential content e.g. enquires which you send to us as the site operator. An encrypted connection can be recognised when the web address changes from "http://" to "https://" and a padlock symbol is shown in your browser bar. When SSL encryption is activated, third parties cannot read the data that you transmit to us. Our security measures are kept up-to-date.


II.2. Contact us

If you contact us (e.g. via contact form, e-mail, telephone), your personal data will be stored and processed by us for the purpose of processing the enquiry and any related follow-up questions pursuant to Art. 6 (1) b GDPR (within the framework of pre-contractual / contractual measures) or pursuant to Art. 6 (1) f GDPR (general enquiries). This data is not transferred to third parties without your consent.

The data entered into the contact form remain with us until you request that they be deleted, you withdraw your consent to the storage of your data, or the purpose of the data storage is no longer given (i.e. after the successful processing of your request), provided there are no legal storage obligations to the contrary.


II.3. Links to websites of third Parties

Based on the legitimate interest of the provider according Art. 6 (1) f GDPR, it may occur that contents, services and benefits of third parties are integrated which complement our service offerings. When you access web pages which are linked on this website, information such as your name, IP address, browser details etc. can retrieved again. This Privacy Statement does not govern the collection, dissemination or the processing of personal data by any third parties. In this regard, please also pay attention to the individual privacy statements of the respective third-party providers and service providers to which we link on our website.
 

II.4. Social Media

We maintain publicly accessible online presences in social networks to communicate with the customers and interested parties active there and to present our services.

We would like to point out that user data may be processed outside the area of the European Union. Furthermore, user data is usually processed for market research and advertising purposes. To the best of our knowledge, the providers also use cookies, which store your usage behaviour (even across different end devices). This enables us to play out targeted advertising within our own platform as well as on third-party sites.

The processing of users' personal data is carried out on the basis of our legitimate interests in providing users with effective information and communicating with users in accordance with Art. 6 (1) f GDPR. If the users are asked by the respective providers of the platforms for consent to data processing or if the user voluntarily sends information to our online presences, the legal basis for processing is Art. 6 (1) a GDPR in conjunction with Art. 7 GDPR. If such information contains contract-relevant contents, Art. 6 (1) b GDPR serves as the legal basis.

For a detailed representation of the respective processing and the possibilities of objection (Opt-Out), we refer to the following linked information of the providers.

Also, in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and give information. Should you nevertheless need help, you can contact us.

Facebook and Instagram

By interacting with our social media pages on Facebook and Instagram (commenting, liking posts or sending us a message), your data will be stored by us. These social networks are operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (hence: Meta).

The operation of a company profile on these channels is a joint responsibility under data protection law pursuant to Art. 26 GDPR for Meta and our company. Accordingly, we have entered into an agreement with Meta that governs the respective obligations under the GDPR: https://www.facebook.com/legal/terms/page_controller_addendum.

Meta provides the profile operators with statistics and insights into the types of actions of our profile visitors ("page insights"). We have no influence on the fact that this data is collected by Meta. According to Meta, this data is only provided to us anonymously, so that the user cannot be identified from the information.

Personal data is deleted as soon as the purpose for which it was stored no longer applies. Storage can also take place if this is provided for by statutory retention obligations to which our company is subject.

Please note that when you use and access our Facebook and Instagram page, your personal data will also be processed by the provider Meta. Meta is operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland as well as the parent company located in the USA. Meta processes your data in addition to the processing mentioned above for analysis and advertising purposes. To the best of our knowledge, Meta also uses cookies that store your usage behavior (also across different end devices). This allows Meta to display targeted advertising within its own platform as well as on third-party sites. For more information, please see Facebook's privacy policy: https://www.facebook.com/about/privacy/, Instagram https://help.instagram.com/519522125107875. Facebook and Instagram also offer the option to object to certain data processing; information and opt-out options in this regard can be found at: https://www.facebook.com/settings?tab=ads and https://www.instagram.com/accounts/privacy_and_security/.  Please note that according to the Meta Privacy Policy, user data is also processed in the USA or other third countries. Meta transfers user data only to countries for which an adequacy decision has been issued by the European Commission pursuant to Art. 45 GDPR or on the basis of appropriate safeguards pursuant to Art. 46 GDPR.

With regard to data processing via our Facebook and Instagram page, you also have the option of asserting your data subject rights against Meta. Further information on this can be found in Meta's privacy policy: https://www.facebook.com/about/privacy/.
 

II.5. Minors

We principally address adult persons with our online offer. Personal information of persons under 16 years of age may only be made available to us with the explicit consent of their legal guardian (Art. 8 GDPR). Processing without the consent of the legal guardian is not permitted. We therefore reserve the right to delete all data relating to minors unless we have the consent of a parent or guardian.

III. Information for business partners


III.1. Purpose and legal basis for the collection and processing

The primary purpose of data processing is the creation, execution or termination of the contractual relationship. The primary legal basis for this is Art. 6 (1) b GDPR. Without this type of use of your data, the business relationship existing between you and us cannot be carried out.

We also process your data on the basis of Art. 6 (1) f GDPR to protect our legitimate interests or those of third parties (e.g. public authorities). This may be necessary, for example, to maintain IT security and IT operations or for purposes of corporate management, internal communication and other administrative purposes. You can object to this processing by giving special reasons in accordance with Art. 21 GDPR.

In addition, we process your data to fulfil legal obligations, such as regulatory requirements, commercial and tax law storage obligations or documentation obligations. The legal basis for this is Art. 6 (1) c GDPR in conjunction with the nationally applicable laws.

In individual cases, it may also happen that we process your data on the basis of your separately granted consent in accordance with Artt. 6 (1) a, 7 GDPR (e.g. in the context of publishing photo and video recordings). You are always free to decide whether you wish to give your consent. Once you have given your consent, you can withdraw it at any time with effect for the future. To do so, please send corresponding enquiries to the contact address given above.

Should we process your personal data for a purpose not mentioned above, we will inform you of this in advance. 


III.2. Recipient of your data

Within our company, only those persons receive your personal data who need it to fulfil our contractual and legal obligations. In addition, we sometimes use different service providers to fulfill these obligations, so that it may be necessary to transfer your personal data to other recipients outside the company to the extent necessary to fulfill our contractual and legal obligations. These third parties can be, for example, authorities, financial institutions, suppliers, etc.

To process your data technically, we sometimes use external service providers. It is possible that we may transfer and process your data outside the country in which you have your residence / company headquarters or in one of the countries in which we operate. These may also be located outside the European Economic Area. If we transfer personal data to service providers or companies outside the European Economic Area (EEA), the transfer will only take place if the third country has been confirmed by the EU Commission as having an adequate level of data protection or if other appropriate data protection guarantees (e.g. binding internal company data protection regulations or EU standard contractual clauses) are in place. You can also request detailed information by using the contact information above.


III.3. Storage of your data

We store your personal data only as long as they are necessary for the above-mentioned purposes. After termination of the contractual relationship, your personal data will be stored for as long as we are legally obliged to do so. This regularly results from legal obligations to provide evidence and to retain data. The storage periods thereafter are up to ten years. In addition, personal data may be stored for the time during which claims can be made against us (statutory limitation period of three or up to thirty years).