PRIVACY

Name and contact details of the Controller and of the data protection officer:

Fairplay Schleppdampfschiffs-Reederei Richard Borchard GmbH

Ludwig-Erhard-Str. 22

20459 Hamburg

Tel. +49 – 40-30 70 68 – 100

Fax +49 – 40-30 70 68 – 299

info@fairplay-towage.group

The company data protection officer is available via the above-mentioned address, Att. Data protection officer, or by e-mail: datenschutz@fairplay-towage.com.

• Collection, Storage and Erasure of Personal Data as well as Type and Purpose and their use:

• When visiting the website:

When you visit our website https://www.fairplay-towage.group/, the browser you are using on your terminal device automatically sends information to the server of our website. This information will be temporarily stored in a so-called log file. The following information will be recorded without your intervention and stored until automated deletion:

• IP address of the requesting computer,
• date and time of access,
• name and URL of files accessed,
• website from which access has been made (Referrer-URL),
• the browser used and, if applicable, your computer´s operating system, and your access provider´s name.

We will be processing the above-mentioned data for the following purposes:

• ensuring a smooth connection of the website,
• ensuring comfortable use of our website,
• evaluation of system and stability,
• for other administrative purposes.

The legal basis for this processing is Article 6 para 1 lit. f GDPR. Our legitimate interest follows from the purposes listed above. In no case we will use the collected data for the purpose of drawing conclusions about your person.

• When contacting us:

We provide various contact information (e.g. e-mail address and telephone number) on our website that you can use to contact us.

If you choose to use them, we process your personal data (in particular name, e-mail address or telephone number, and all content provided in the course of communication) exclusively to answer your inquiry.

The legal basis for this data processing is Article 6 para 1 lit. f GDPR. Our legitimate interest follows from wanting to process your request to your satisfaction. In view of your proactive contact, it is not apparent that this interest would conflict with any of your interests.

If you contact us aiming to conclude a contract with us, the legal basis for this data processing is Article 6 para 1 lit. b GDPR.

If you contact us applying for a job with us, please note the following information.

• When applying for job offers:

Under the category “Jobs” on our website, you have the opportunity to apply for open positions.

If you send us your application, we will collect the following data:

• Your name;
• Your e-mail address;
• Your telephone number;
• Your cover letter, your CV and other documents submitted by you (e.g. references), including the personal data contained therein.

Your personal data will be processed exclusively for the purpose of processing your application for a specific job advertisement or as a speculative application. We process your data for the purpose of assessing your suitability for the advertised position or for the position for which you have submitted an unsolicited application based on Article 6 para 1 lit. b GDPR.

In the event of non-employment, your data will be deleted six months after non-employment. If you are hired, your data will be stored in your personnel file and only deleted after the employment relationship has ended and all foreseeable claims have become time-barred (three years at the end of the year, starting at the end of the calendar year in which the employment relationship was terminated). By way of exception, we will deviate from these regular deletion periods if we are obliged to store data for a longer period of time in accordance with Art. 6 para. 1 sentence 1 lit. c GDPR due to tax and commercial law storage and documentation obligations (from HGB, StGB or AO) or if you consent to further storage in accordance with Article 6 para 1 lit. a GDPR.

• When creating and using a MyFairnet user account:

You also have the option of creating a user account on our website. This requires you to enter your e-mail address and a password. Depending on which functionalities of the user account you use, we also process other personal data provided by you in this context.

We process this data in order to carry out the functionalities requested by you or, if necessary, to process the existing contractual relationship between us.

The legal basis for data processing is therefore Article 6 para 1 lit. b GDPR and Article 6 para 1 lit. f GDPR. Our legitimate interest follows from the purposes explained above. Under no circumstances do we use the data collected for the purpose of drawing conclusions about your person.

• When ordering goods in our online store:

If you order goods in our online store, we process your name, address data, order data, payment information, contact information (e-mail address and telephone number) and, if applicable, other information that you provide to us via the comment function for your order in order to fulfil the relevant contract. The legal basis for data processing is Article 6 para 1 lit. b GDPR.

Payment information is collected in encrypted form and transmitted to the relevant service provider exclusively for processing the corresponding transaction. We use PayPal, a service of PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. Information on data protection at PayPal can be found at https://www.paypal.com/myaccount/privacy/privacyhub.

• Cookies:

We use Cookies on our website. Cookies are small files that are automatically created by your browser and stored on your terminal device (laptop, tablet, smartphone or similar) when you visit our site. Cookies do not cause any damage to your terminal device and do not contain any viruses, Trojans or other malware. Information is stored in the cookie that is related to the specific terminal device used. However, this does not mean that we gain direct knowledge of your identity.

Most browsers accept cookies automatically. You can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, completely deactivating cookies may mean that you cannot use all the functions of our website.

• Google Analytics:

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google”), to personalize and continuously optimize our website.

We only place this cookie if you have given your express consent in accordance with Article 6 para 1 lit. a GDPR. In this respect, our website uses the cookie consent technology “Complianz” to obtain your consent to the storage of certain cookies on your end device and to document this in compliance with data protection regulations. The provider of the technology is Complianz BV, CoC 717814475, Kalmarweg 14-5, 9723 JG, Groningen (NL).

Google Analytics creates pseudonymized user profiles and transmits these to Google for storage. The information generated by the cookie about your use of this website contains information such as

• browser type/ version,
• used operating system,
• Referrer URL (the previously visited page),
• the accessing computer’s host name of (IP address),
• time of server request.

The information is used to evaluate the use of our website, to compile reports on website activity and to provide other services relating to website activity and internet usage for the purposes of market research and the needs-based design of our website. In addition, this information may be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymized so that they cannot be assigned (IP masking).

Furthermore, you can prevent recording of data generated by the cookie relating to your use of the website (including your IP address) and its processing by Google when downloading and installing a browser-add-on https://tools.google.com/dlpage/gaoptout?hl=de&

Further information on data protection in connection with Google Analytics can be found at https://www.google.com/analytics/terms/de.html.

• Google Tag Manager:

We also use Google Tag Manager in connection with Google Analytics. This is an organizational tool that enables us to centrally manage code sections of various tracking tools that we use on our website.

Google Tag Manager does not carry out any independent analyses, does not store any cookies and does not create any user profiles. Its use and the associated data processing are technically necessary in order to be able to technically implement your consent to the use of individual analysis tool, and thus also for the presentation of our website.

• Cookies in other respects:

Otherwise, the use of cookies is necessary from a technical point of view and serves to make the use of our website more pleasant for you. We only use so-called session cookies, which save your language settings, for example. The cookies are automatically deleted after you leave our site. The data processed by cookies is required for the purposes mentioned to safeguard our legitimate interests in accordance with Article 6 para 1 lit. f GDPR.

• Links to the service of third parties:

We have included links on our website to third-party websites or to content hosted on such third-party websites. In detail, this involves the following:

• www.youtube.com (a service of the Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland);
• www.facebook.com (a service of the Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland);
• www.instagram.com (a service of the Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland);
• www.linkedin.com (a service of the LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland); and
• www.x.com (a service of the Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland).

The integration of the relevant content or links as such does not result in any processing of personal data. However, if you click on one of these buttons, you will be redirected to the respective website. We are not responsible for the processing of your personal data there. Information on the processing of your personal data can be found in the data protection information there.

• Disclosure of data:

Your personal data will not be transferred to third parties for purposes other than those listed below.

We only pass on your personal data to third parties if:

• you have given your express consent in accordance with Article 6 para 1 lit. a GDPR,
• the disclosure pursuant to Article 6 para 1 lit. f GDPR is necessary for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data,
• in the event that there is a legal obligation for the disclosure pursuant to Article 6 para 1 lit. c GDPR, and
• this is legally permissible and necessary for the processing of contractual relationships with you in accordance with Article 6 para 1 lit. b GDPR.

• Rights of Data Subjects:

You have the right:

• to obtain access to your personal data processed by us in accordance with Article 15 GDPR. In particular, you may obtain access to the purposes of the processing, the category of personal data, the categories of recipients to whom your data have been or will be disclosed, the envisaged storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the source of your data, if these have not been collected by us, and the existence of automated decision-making including profiling and, if applicable, meaningful information on their details;

• to request the immediate rectification of inaccurate or completion of incomplete personal data stored by us in accordance with Article 16 GDPR;

• to request the erasure of your personal data stored by us pursuant to Article 17 GDPR, unless the processing for the exercise of the right to freedom of expression and information, for the fulfilment of a legal obligation, for reasons of public interest or for assertion, exercise or defense of legal rights is required;

• to demand the restriction of the processing of your personal data pursuant to Article 18 GDPR, as far as the accuracy of the data is contested by you, the processing is unlawful, but you reject its erasure and we no longer need the data, but you require this, for the exercise or defense of legal claims or you objected to processing pursuant to Article 21 GDPR;

• to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with Article 20 GDPR. or to demand transmission to another controller;

• to object to your consent given pursuant to Article 7 para 3 GDPR at any time. As a result, we are no longer allowed to continue processing data based on this consent in the future and

• to lodge a complaint with a supervisory authority pursuant to Article 77 GDPR. As a rule, you can contact the supervisory authority of your habitual residence or place of work or place of business.

• Right to object:

If your personal data are processed based on legitimate interests pursuant to Article 6 para 1 lit. f GDPR, you have the right to object to the processing of your personal data pursuant to Article 21 GDPR, provided that there are reasons on grounds relating to your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right of objection, which we will implement without specifying a particular situation.

If you would like to make use of your right of revocation or objection, simply send an e-mail to info@fairplay-towage.com.

• Data security:

We use the most common SSL (Secure Socket Layer) method in connection with the highest level of encryption supported by your browser. Usually this is a 256 bit encryption. If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. Whether a single page of our website is transmitted in encrypted form can be seen from the closed display of the key or lock symbol in the status bar of your browser.

We make use of the rest of the adequate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

• Date and amendments to this privacy policy:

This privacy policy is currently valid and is dated January 2025.

Due to further development of our website and offers or due to changed legal or official requirements, it may become necessary to change this privacy policy.