Hafnia Group (as defined in paragraph 1) is subject to the General Data Protection Regulation (GDPR) and the relevant local data protection regulation, for which reason you are entitled to be informed of the personal data that Hafnia Group processes about you and your rights under the regulation.

1. JOINT DATA CONTROLLERS

Jointly referred to as “Hafnia Group”.

Contact info:
Hafnia Group, Hans Bekkevolds Allé 7, 2900 Hellerup, Denmark, phone +45 3369 9000, email: info@hafniabw.com

2. PERSONAL DATA, DATA PURPOSE AND LAWFUL PROCESSING

Application for position

To evaluate your application for a position at Hafnia Group, Hafnia Group must process and store the following personal data (to the necessary extent):

• Your name, address, email address, and phone number
• Date of birth (if you choose to include it)
• Your employment history, including current occupation
• Your résumé, cover letter, and other documents you choose to enclose with your application
• Any photos and/or videos you choose to submit in addition to your application
• IP address/cookie

Contact form (Partnerships & Open innovation)

To evaluate your submission to ‘new ideas’ It is necessary for Hafnia Group to process and store the following personal data (to the necessary extent):

• Name and email address.
• IP address/cookie.

Customers & business associates

It is necessary for the management of our cooperation that Hafnia Group pro­cesses and stores the following personal data:

• Your name, home address, email address, and phone number.
• A copy of your national health insurance card, passport, driving license, or other photo ID – these are needed to observe regulations in the Danish Anti-Money Laundering Act, legitimize your use of a power of attorney, or book travel.
• IP address/cookie.

Vendors

In order to manage our cooperation with you as a vendor, we need to pro­cess and store the following personal data:

• Your name (contact for the vendor), email address (work) and phone number (work).
• IP address/cookie.

All the data referred to above will be processed in full confidentiality in accord­ance with the General Data Protection Regulation.

Hafnia Group’s authority to process the personal data derives from Hafnia Group’s legitimate interest (i) in the customer relationship and (ii) in our cooperation with you as a vendor, see article 6 (1) (f) of the General Data Protection Regulation, as well as the natural necessity of possessing personal data relating to the contract prior to entering a contract or cooperation with you. Furthermore, Hafnia Group’s authority to process the personal data derives from its obligation to collect and store national health insurance cards, passports, driving licenses or other photo ID to comply with the Danish Anti-Money Launder­ing Act, see article 6 (1) (c) of the General Data Protection Regulation and § 11, stk. 2, no. 1 of the Danish Data Protection Act. Hafnia Group also has a legitimate interest, see article 6 (1) (f) of the General Data Protection Reg­ulation, in collecting and storing national health insurance cards, passports, driving licenses or other photo ID in order to legitimize your use of a power of attorney is­sued by Hafnia Group and to book company travel for you. Your CPR no. (civil registration number) will be processed based on your consent; see article 6 (1) (a) of the General Data Protec­tion Regulation.

Hafnia Group’s legal basis for processing your personal data as an applicant derives from the legitimate interest that Hafnia Group has in assessing your application, and the obvious need for Hafnia Group to evaluate the professional and personal qualifications of an applicant before entering an employment contract with him or her; cf. article 6 (1) (f) of the General Data Protection Regulation.

Hafnia Group may share your personal data internally in the Hafnia Group if Hafnia Group has a legitimate interest in so doing; cf. article 6 (1) (f) of the General Data Protection Regulation.

When visiting Hafnia Group’s website and accepting cookies, Hafnia Group processes your IP address. Hafnia Group uses cookies to ensure the website’s functionality and generate statistics. In addition, Hafnia Group uses cookies to analyze the website’s traffic for marketing purposes. Hafnia Group briefly processes your IP address when Hafnia Group uses cookies. In some cases, your IP address will be shared with Hafnia Group’s partners in analytics, social media and advertising. Based on this, Hafnia Group has a legitimate interest, cf. the General Data Protection Regulation, article 6, subsection 1 (f) in processing your IP address. Please also refer to Hafnia Group’s cookie policy, where you can read more, hereunder how to remove cookies.

3. RECIPIENTS AND PROCESSORS OF YOUR PERSONAL DATA

Your personal data will be processed by Hafnia Group, unless other processing is relevant to the nature of the given task. Your data may be transferred to our coop­erative partners or to authorities if such a transfer is necessary in connection with your cooperation with us. Passport data will be forwarded to travel agencies if Hafnia Group needs to book company travel for you.

Your data may be transferred to our data processors, including but not limited to Microsoft and RecuiterPal. Your personal data may also be forwarded internally in the BW Group.

We normally receive the above-mentioned data directly from you. However, in cer­tain situations, we may have obtained the information through websites in the pub­lic domain, public phone registers or network associates. In such cases, you will naturally be informed during our initial contact.

4. TRANSFER TO A THIRD COUNTRY

Hafnia Group has parent and sister companies (within the BW group) and data pro­cessors in the EU, US, Monaco, and Singapore. Accordingly, your personal data may be transferred to a third country as part of our regular procedures.

Hafnia Group has ensured that appropriate and suitable safeguards have been im­plemented to protect your personal data. Either Hafnia Group has agreed on the EU Commission’s standard clauses with the recipients of your personal data, or a similar applicable standard. You can ask Hafnia Group for a copy of the agreed provisions.

5. RIGHT TO ACCESS, RECTIFICATION, ERASURE, RESTRICTION, DATA PORTABILITY AND OBJECTION

You are entitled to insight into the personal data Hafnia Group has registered about you. If you wish to be granted such insight, Hafnia Group will send you a copy of the registered data. Electronic requests will be answered electronically, and if you request several copies of your personal data, you should expect Hafnia Group to charge you a reasonable fee for the related expenses paid by Hafnia Group.

You are entitled to object to any processing of your personal data.

You are furthermore entitled to demand the rectification or erasure of any of your per­sonal data as well as the restriction of the processing of your personal data.

In some cases, you are entitled to have your personal data returned or transferred to another data processor.

Under the provisions of the General Data Protection Regulation, certain specific situations may exclude Hafnia Group from the obligation to comply with the above-mentioned rights.

If you want to exercise your above-mentioned rights, you should contact Hafnia Group either by emailing info@hafniabw.com or by calling +45 3369 9000.

6. DURATION OF STORAGE OF YOUR PERSONAL DATA

Your personal data will be erased seven years after the termination of the contract relationship/cooperation with Hafnia Group. Hafnia Group will store your data ac­cordingly, to comply with the Danish Bookkeeping Act and ensure documentation if claims are raised against Hafnia Group in connection with the relationship. Photo ID, including copies of passports that have been received in connection with the verification of powers of attorney, will be stored for a maximum of three years from the signing of the power of attorney. Passport data needed for booking com­pany travel and for verification in relation to banks, lawyers and accountants will be stored for a maximum of 12 months, after which they will be deleted.

Your personal data as an applicant will be erased 6 months after your application has been received unless you specifically agree to a longer period of storage.

7. COMPLAINTS

You may complain against the processing of your personal data. Your complaint may be submitted to the Danish Data Protection Agency, Borgergade 28, 5^th floor, 1300 Copenhagen K, Denmark, dt@datatilsynet.dk or online at https://datatilsynet.dk/english/file-a-complaint

If you have any questions about GDPR you are welcome to send an email to info@hafniabw.com or to our Danish GDPR lawyer Gabriel L. K. Martiny at glm@wtc.dk

There might be local rules about data protection in Singapore that also applies.