Privacy Policy

We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices.

What kinds of personal information about you do we process?

Personal information that we’ll process in connection with all of our services, if relevant, includes:

• Personal and contact details, such as title, full name and next of kin
• Your date of birth, gender and/or age
• Work and education history (if relevant)
• Bank account details relevant for processing payments (if relevant)
• Information for tax purposes including national insurance number and other details required to be disclosed to HMRC (if relevant)
• Other financial information provided by you
• Services you hold with us, as well as have been interested in and have held and the associated payment methods used
• Publicly available information about you from third-party sources
• Your residency and/or citizenship status, if relevant, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in the UK
• Data from correspondence including from letters, email, SMS and telephones.

What is the source of your personal information?

We will collect personal information from the following general sources:

• From you directly, recruiters, legal advisors, agents, associates or beneficiaries of services
• Information generated about you when you use our services
• From a broker or other intermediary who we work with to provide products or services or quote to you
• Union Maritime companies if you already have worked with them.

From other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, HMRC, DWP, public ally available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies.

What do we use your personal data for?

We need all the personal information listed primarily to allow us to perform our contract with you and to enable us to comply with our legal obligations.

We process your personal information for a number of purposes, including:

• For making recruitment decisions
• Establishing a client relationship, including fraud, anti-money laundering, know-your customer and sanctions checks
• Facilitating and/or receiving contractual payments
• Checking credit where we are taking any credit risk
• General client care, including communicating with clients
• Managing insurance claims
• Defending or prosecuting legal claims
• General risk modelling
• Complying with our legal and regulatory obligations.

Some of the grounds for processing will overlap, and in some cases, there will be several grounds which justify our use of your personal information.

What are the legal grounds for our processing your personal information (including when we share it with others)?

We will only process your personal information when the law allows us to.  In most cases, we will process your personal information where it is necessary:

• To perform the contract we have entered into with you (e.g. your bank details in order to pay you)
• To comply with a legal obligation (e.g. know-your customer checks and anti-crime and fraud)
• For our legitimate interests as a business – and your interests and fundamental rights do not override those interests.

Where we rely on the legitimate interests as a reason for processing personal information, we have considered whether those interests are overridden your rights and freedoms and have concluded that they are not.

Where the basis for processing is legitimate interests, the legitimate interest is the purpose for which we process the data – e.g. for data we process during the recruitment process, the legitimate reason for processing that data is recruitment.

We may also process your personal information in the following circumstances, but this is likely to be rare:

• With your specific consent
• Where we need to protect your interests (or someone else’s interests)
• Where it is needed in the public interest.

On occasion we include links to third parties on this website. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data.

When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed above:

• • Union Maritime group companies and service providers
  • Business partners (for example, financial services institutions, insurers and legal advisors), account beneficiaries, or others who are a part of providing our services or operating our business
  • Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, the Information Commissioner’s Office and under the Financial Services Compensation Scheme
  • Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions
  • Credit Reference and Fraud Prevention Agencies.

How and when can you withdraw your consent?

Where we are relying upon your consent to process personal data, you can withdraw this at any time by contacting compliance@unionmaritime.com.

Is your personal information transferred outside the UK or the EEA?

We are based in the UK but sometimes your personal information may be transferred outside the European Economic Area. If we do so we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.

Do you have to provide your personal information to us?

We are unable to provide you with our services if you do not provide certain information to us. In cases where providing some personal information is optional, we will make this clear.

Do we do any monitoring involving processing of your personal information?

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.

We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

What about other automated decision making?

We do not make automated decisions.

For how long is your personal information retained by us?

Unless we explain otherwise to you, we will hold your personal information based on the following criteria:

• For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
• For as long as we provide services to you and then for as long as someone could bring a claim against us and/or
• Retention periods in line with legal and regulatory requirements or guidance.

What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.

• The right to be informed about the processing of your personal information
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• The right to object to processing of your personal information
• The right to restrict processing of your personal information
• The right to have your personal information erased (the “right to be forgotten”)
• The right to request access to your personal information and to obtain information about how we process it
• The right to move, copy or transfer your personal information (“data portability”)
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details above.

Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests.