Privacy Policy

1.     Introduction to the Privacy Policy

This website (the "Web page") is owned and operated by WORKBOAT SERVICES S.L.U. which is responsible for the processing of the personal data to which reference is made in this privacy policy.

Contact information:

• Ribera de Axpe, 50 – 5ª Planta – 48950 ERANDIO (Biscay)
• Email: rgpd@zubicar.es 

The purpose of the Privacy Policy of this website is to comply with the duty of information and transparency set forth in Article 12 of EU Regulation 2016/679 on the Protection of Personal Data. Likewise, in cases where the duty of information has been exercised by means of basic information called “first layer” pursuant to that set forth in Article 11 of Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights, this privacy policy corresponds to the additional information considered as “second layer” where the complementary elements prescribed in Articles 13 and 14 of EU Regulation 2016/679 on the Protection of Personal Data are described.

2.     Processing of personal data

The operations or set of operations undertaken as regards your personal data are identified by means of processing. WORKBOAT SERVICES S.L.U. sets out below the detailed information on each processing operation pursuant to the guidelines prescribed by the Spanish Data Protection Agency:

1. PERSONNEL SELECTION Processing, the purpose of which is to manage the selection of persons to work in any of the WORKBOAT SERVICES S.L.U. companies
   1. Category of data: identify data, employment history and curriculum vitae.
   2. Lawfulness of processing: Consent of the data subject (Art. 6.1.a) in the case of self-candidacy (and/or unsolicited applications) and in all other cases, pre-contractual relationship (Art. 6.1.b)
   3. Validity of the data: The data shall remain valid for three years.
2. CORPORATE MANAGEMENT Processing, the purpose of which is to manage the data of the company's shareholders and administrators in order to comply with obligations derivative from mercantile and tax legislation, including the keeping of the Shareholders’ Register, the minutes book and the entering of notes or inscriptions required by the Mercantile Register.
   1. Category of data: identifying data, position held and financial data.
   2. Lawfulness of processing: Processing necessary for compliance of legal obligations to which the data controller is subject (Art. 6.1.c).
   3. Validity of the data: The data shall be retained for the duration of the office of Administrator and the status of Shareholder, as well as for the time necessary for compliance of the purpose for which the data was collected and to determine any possible liabilities which may be derivative from said purpose and the processing of the data.
3. ADMINISTRATIVE MANAGEMENT AND CONTACT PERSONS Processing, the purpose of which is the administrative and commercial management of the contact details of persons working for clients and suppliers, both active and potential, as well as companies and all types of organisations associated with WORKBOAT SERVICES S.L.U. in order to maintain business and commercial relationships.
   1. Category of data: identifying data.
   2. Lawfulness of processing: where appropriate, legitimate interests based on the requirement to maintain commercial and business relationships (Art. 6.1.f RGPD and Art. 19 of the LOPDGDD), the requirement of compliance of legal obligations to which the data controller is subject. (Art. 6.1.c)
   3. Validity of the data: The data shall be retained for the duration of the contractual, business or interest relationship. Likewise, the time necessary for compliance of the purpose for which the data was collected and to determine the possible liabilities which may be derivative from said purpose and the processing of the data shall be considered. The provisions set forth in the mercantile and tax legislation shall apply.
4. OPERATIONS Processing, the purpose of which is the management of the contact details of persons working for clients and suppliers, both active and potential, as well as for companies and all types of organisations for the purpose of carrying out maritime or consignment operations.
   1. Category of data: identifying data.
   2. Lawfulness of processing: where appropriate, legitimate interests based on the requirement to maintain commercial and business relationships (Art. 6.1.f RGPD and Art. 19 of the LOPDGDD), the requirement of compliance of legal obligations to which the data controller is subject. (Art. 6.1.c).
   3. Validity of the data: The data shall be retained for the duration of the contractual, business or interest relationship. Likewise, the time necessary for compliance of the purpose for which the data was collected and to determine the possible liabilities which may be derivative from said purpose and from the processing of the data shall be considered. The provisions set forth in the mercantile and tax legislation shall apply.
5. COMMUNICATION AND MARKETING Processing, Dissemination activities, events, press releases, news and any other activity for dissemination and promotion purposes.
   1. Category of data: identifying data, image and voice.
   2. Lawfulness of processing: where appropriate, the data subject has given consent to the processing of personal data (Art. 6.1.f) and legitimate interest based on the need to promote products and services to clients.
   3. Validity of the data: The data shall be retained provided that the right to erasure of the data is not requested as regards contact persons or the employee revokes his/her consent to the processing of the image or voice. Periodically, within a period not exceeding 5 years, the databases shall be reviewed to maintain the quality of the information and obsolete data shall be deleted.
6. VIDEO SURVEILLANCE Processing, the purpose of which is the perimeter security of the premises, as well as of the property and persons within the premises.
   1. Category of data: image recorded by camera.
   2. Lawfulness of processing: Legitimate interest based on the requirement to maintain the security of the facilities (Art. 6.1.f RGPD and Art 22 LOPDGDD).
   3. Validity of the data: The data remains valid for a maximum of 30 days. Once this period has expired, the data shall be erased.

3.     Disclosure of personal data to third parties

Personal data may be disclosed to the following recipients:

1. Within our group of companies, in compliance with the common mission and the established commercial and legal obligations;
2. To suppliers which provide services necessary for the management and operation of the business;
3. To legal and other professional advisors and auditors;
4. To public administrations, regulatory authorities, courts and government agencies in order to comply with legal or statutory requirements;
5. To State law enforcement agencies when required in the processing of video surveillance;
6. To clients and organisations necessary for vessel provisioning operations;

International data transfers:

WORKBOAT SERVICES S.L.U. uses the following applications in its management systems which entail an international transfer of personal data to the United States:

• Quickbase Inc. application owned by Quickbase Inc for which a licence is available that includes the guarantees of international transfers offered by the provider.

4.     Security of personal data

We endeavour to use appropriate technical and physical security measures to protect personal data which is assigned, stored or otherwise processed from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access in relation to our Website. These measures include IT safeguards and secured files and facilities. Our service providers are likewise carefully selected and must use appropriate safeguards on the website. We use industry standard SSL encryption to protect data transmissions. Most current browsers support the level of security required to use these areas.

5.     Your rights under data protection legislation

You have several rights under data protection laws. These may include (where applicable):

• Any person one has the right to know and obtain confirmation as to whether or not we at WORKBOAT SERVICES S.L.U. are processing personal data in relation thereto;
• the right to request access to personal data, which entails to be told what personal information we hold as regards yourself;
• the right to rectification, including the right to require us to correct inaccurate personal data;
• the right to request limitation of the processing as regards yourself or to object to the processing of your personal data,
• the right to request the erasure of your personal data where it is no longer necessary for the purposes for which same was collected;
• the right to object to the processing of your personal data where you have not given your prior consent and where there are no compelling legitimate grounds or the defence of possible claims;
• the right to data portability, including obtaining personal data in a commonly used machine-readable format in certain circumstances, provided that the processing is automated;
• the right to withdraw your consent to any processing for which you have previously given such consent.

You may request your rights by writing to the email address provided for this purpose rgpd@workboat.es or by making enquiries in relation to your rights using the contact channels identified in the introduction.

In order to process the rights application, it shall be necessary to verify the identity of the applicant and ascertain that he/she is the owner of the data, reason why in said notification the name, surname(s), specific request of the application and the address where you wish to be notified of the reply must be included. If necessary, a copy of the document proving your identity may be requested.

WORKBOAT SERVICES S.L.U. may forward to anyone who requests same an appropriate form to assist in making the rights application pursuant to that set forth in Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights.

In the event that requiring the enforcement of your rights, the supervisory authority is the Spanish Data Protection Agency, whose website is www.aepd.es and with address at Calle Jorge Juan 6, Madrid, post code 28001.

6.     Links

The WORKBOAT SERVICES S.L.U. website may include hyperlinks to other sites which are not operated or controlled by WORKBOAT SERVICES S.L.U. Therefore, WORKBOAT SERVICES S.L.U. does not warrant, nor shall be held responsible for, the legality, reliability, usefulness, accuracy and up-to-dateness of the content of such websites or their privacy practices. Please be aware that prior to providing your personal information to these websites extraneous to WORKBOAT SERVICES S.L.U., please take into consideration that their data protection compliance may differ from ours.

7.     Updates and changes to this Privacy Policy

The text of this privacy policy has been updated as at December 2021.

WORKBOAT SERVICES S.L.U. may amend its Privacy Policy without prior notice pursuant to the legislation applicable at any given moment and as per changes to its privacy management system.