1. Introduction
This privacy notice describes how EC3 Marine Ltd collect, use, share and retain the personal information you provide and informs you of your choices regarding use, access and correction of your personal information. EC3 Marine Ltd remain committed to safeguarding the privacy of personal data collected and processed whilst conducting our business in accordance with applicable data protection laws. This may also include data collected from our website, or any other applicable communications, media and/or from third parties.
2. Definitions
References to “we”, “us” or “our” contained in this privacy notice refers to EC3 Marine Ltd. Any terminology used throughout this document (such as data controller, data processor or personal data) are as defined in the EU GDPR and/or the UK Data Protection Act 2018.
3. Who are EC3 Marine Ltd
EC3 Marine Ltd is a limited company incorporated on 18 October 2012 whose principal place of business is at 6 Bevis Marks, London EC3A 7BA offering claims handling, survey and recovery services.
4. EC3 Marine – Data Processor for Client Claims Data
As part of our claims handling and our other related services we provide to our clients,
EC3 Marine Ltd is generally the data processor of the personal information handled during the course of our business. We only process such personal information on behalf and under the instruction of our clients in accordance with applicable data protection laws. Our respective clients are the data controllers of the claims data. How we process this personal data on behalf of our clients is subject to the service agreements we have in place with clients and their respective privacy policies, and not this Privacy Notice. This Privacy Notice also does not cover any third-party websites or services. Any requests made to us in relation to processing of data where EC3 Marine Ltd are not the data controller will be promptly relayed to the party controlling the data.
5. Personal information we process about you
In order for us to carry out our work and provide our services you may be required to provide personal data. To identify you as a client we record the following personal information which is restricted to:
• your name and contact details
• role title and associated company name (where applicable)
• bank details (where applicable and in order to make payments to you and to retain adequate records for legal/accounting purposes)
• previous correspondence (to keep track of claims)
When EC3 Marine Ltd is not the data controller, as detailed above, the responsibility rests with the data controller to obtain the necessary consent from you, allowing us to process your data in accordance with the applicable service agreement.
6. Personal information we collect about you and the lawful basis for processing
EC3 Marine Ltd may collect personal information to settle claims and recoveries and also for business analysis/planning purposes. We may need to process your personal information throughout its connection with a claim and for as long as deemed necessary thereafter. This includes the collection, storage, retrieval, alteration, disclosure or destruction of the data.
The lawful basis for processing your data is the legitimate interests of EC3 Marine to support our client insurer and to encourage ease of doing business. It is also a legitimate interest of you, as our client, to be included on the client base to facilitate communication between yourself and EC3 Marine Ltd regarding potential claims, surveys and recoveries.
Please be advised that we conduct regular reviews of the personal information collected and retained to ensure there is a business or legal reason for doing so. As data controller, we will inform you when we require your consent to process your personal data and request it from you accordingly.
From time to time, EC3 Marine Ltd may also use your personal information to inform you of our products/services available and may also contact you to carry out research via surveys to improve its services.
7. Sharing of your data
For the necessary purposes of the claim assessment process and/or where legally obliged to do so, we may make personal data available to other parties. These parties may include, service providers, agents or other insurance or distribution parties with a legitimate interest in the claims assessment process. We will not otherwise share personal information with third parties.
8. Security
EC3 Marine Ltd will take all appropriate reasonable organisational, legal and technical measures to ensure your personal information is kept secure and in full compliance with applicable privacy and data security laws, including measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your personal information, please advise us immediately. Whilst we will do our utmost to best protect your personal information, we cannot guarantee the security of all data transmitted to us via the Internet or similar connection. As such we will not be held liable for loss or security breach of personal information that has been brought about by your own actions.
9. Retention of your data
In order to fulfil the relevant purposes as noted in this Privacy Notice, we will retain your personal information for as long as is deemed reasonably necessary. The retention period will primarily be determined by relevant legal and regulatory obligation and/or duration of our business relationship with you, your employer or another associated party. Our data retention policy and data retention schedule are regularly updated and maintained and we will securely delete/erase your personal information if there is no valid business reason for retaining it.
In exceptional circumstances, e.g., if we reasonably believe there is a prospect of litigation; in the event of a complaint; or there is another valid business reason that the data will be needed in the future, we may retain your personal information until such times as these circumstances change.
10. Transfers of information outside the EU
EC3 Marine Ltd operates on a global basis and as such, there is a possibility that your data may be transferred, stored or processed on systems and/or offices located outside the UK. When this is necessary we undertake to ensure that your data remains subject to equivalent levels of data protection and security which applies within the UK.
11. Your rights
As an individual, you have certain rights which you may exercise in relation to the personal information we hold about you and if such a request is made we reserve the right to ask for proof of identify. We will acknowledge your request as soon as possible and will address your query within one month of it being made. Your rights are as noted below:
• The right to access
You are entitled to a confirmation whether we are processing your data, to ask for a copy of your data, and information about purposes of processing, to whom we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, where we obtained your data from and how you can make a complaint.
• The right to restrict processing (retain but not use)
You can ask us to restrict your personal data, but only:
– to allow us to check its accuracy where it has been contested;
– where it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims;
– the processing is unlawful, but you do not want it erased;
– you have exercised the right to object, and verification of overriding grounds is pending.
Following a request for restriction, where we have your consent we may continue to use your personal data in order to establish, exercise or defend legal claims, or to protect the rights of another natural/legal person.
• The right to rectification
You can request for the personal data we hold about you to be rectified if you believe it to be incomplete or inaccurate.
• The right to data portability
If we collected your information under your consent or as part of our claims handling service, you can request us to transfer your personal information to provide it to another third party of your choice.
• The right to object
You have the right at any time to object to the processing of your personal data. Where processing is necessary for the performance of a task carried out in the public interest, in the exercise of an official authority vested in the controller, or for the purposes of the legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms (in the event that a child in terms of the definition provided by The United Nations Convention on the Rights of the Child (UNCRC) is reading this).
• The right to be forgotten
If you withdraw your consent, terminate a contract with us or you believe the personal information is no longer necessary for the purposes for which it was collected, you may request your data to be deleted. Please note that there may be certain regulatory obligations which mean we are unable to comply with your request.
• The right to withdraw consent
If we process your personal information with your consent, you can withdraw your consent at any time. We do not have to comply with a request where it would adversely affect the rights and freedoms of other individuals.
Any questions you may have relating to data protection that you believe we will be able to answer, please contact:
Data Protection Officer
EC3 Marine Ltd
57 Windmill Street
Gravesend
Kent DA12 1BB
United Kingdom
12. Careers – EC3 Marine
We collect personal information submitted to us electronically during and outside of our recruitment campaigns. CV/Resumes may be retained at the consent of the sender for no longer than 2 years and thereafter be deleted or anonymised. The personal information submitted by successful candidates will be stored and processed in accordance of this privacy notice. EC3 Marine Ltd does not accept unsolicited CVs from third party recruitment agencies nor are we responsible for any fees related to unsolicited CVs sent to us.
13. ICO Registration
As a Data Controller, EC3 Marine Ltd is registered with the UK Information Commissioners Office (ICO), Registration No. ZA540490. Registration details and expiry date can be viewed via the ICO website (https://ico.org.uk).
14. Complaints
If you are not satisfied with our response or believe we are not processing your personal data in accordance with legal requirements you can make a complaint to the UK Information Commissioner’s Office (https://ico.org.uk/concerns/).
15. Privacy Notice Updates
This privacy notice is reviewed on a regular basis and as such we reserve the right to revise this notice to accommodate changing business, legal and compliance requirements. The most recent version of the notice is made available via our website and your continued use of our website and other services will constitute an acceptance of the revised notice.