1.1 Gray Page Limited takes your privacy very seriously. We ask that you read this Privacy Notice carefully as it contains important information about what to expect when we collect personal information about you, and how we, and members of the Gray Page Group, will use your personal data.
1.2 The Gray Page Group comprises Gray Page Limited and its subsidiaries, Gray Page Intelligence Services Ltd, Gray Page Marine Systems Ltd, and Gray Page (S) Pte Ltd (together ‘we’, ‘us’ or ‘our’). Contact details for each entity are at clause 11.
1.3 This notice applies to information we collect about:
• Visitors to our website
• Those who register for our newsletters or alerts
• Those who contact us in relation to our services, or as a potential employee or supplier
1.4 Visitors to our website
1.5. Subscribers to our newsletter, articles and briefings, (formerly called Think Tank)
When you register to receive our newsletter (‘Undercurrent’) or articles and briefings from Gray Page we collect your email address, name and organisation details. We use this information to provide you with the email notification. We use a third-party provider (Mailchimp) to store your details and send out the emails. This provider is based in the USA and certified under the EU-US Privacy Shield. Accordingly, your data will only be transferred out of the European Economic Area under safeguards recognised as adequate by the European Commission. You can unsubscribe from receiving the emails at any time by clicking the link at the bottom of any of the emails or by sending an email to firstname.lastname@example.org.
1.6 Subscribers to Maritime Threat Picture email alerts
When you register to receive our MaritimeThreat Picture alerts we collect your name, email address, phone number (optional), job title and organisation details. We use this information to provide you with the Alerts. You can unsubscribe from receiving the alerts at any time by clicking on the link at the bottom of any of the emails or by sending an email to email@example.com.
1.7 Prospective job applicants
If you contact us in relation to prospective employment we will only use the information you provide for the purpose of progressing your application and to fulfil legal or regulatory requirements. We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes. We will use the contact details you provide to progress your application and the other information you provide to assess your suitability for employment with us. If we make a conditional offer of employment we may ask you for further information to carry out any required pre-employment checks. If we employ you, we will retain the information you have provided during the application process as part of your employee file for the duration of your employment plus six years after the end of your employment. If we do not employ you, the information you have provided in your application, or at a later stage of the recruitment process, will be retained for six months.
1.8 Prospective clients
If you contact us in relation to our services, we will only use the information you provide for the purpose of contracting for, and performing, the requested service; to manage and administer our business; and to fulfil any legal or regulatory requirements. We may send you the occasional newsletter, article or industry briefing that we think may be of interest to you. You can opt-out of these communications at any time. We will retain any personal information provided by clients in relation to any services provided insofar as this is necessary to exercise our legal rights in relation to the services. Such information will be held for six years from the conclusion of the services or termination of the contract.
1.9 Telephone calls
If you call the Company on our telephone numbers, or the Company calls you, your call will be recorded for accuracy and training purposes. However, the Company generally does not retain these recordings beyond 72 hours.
1.10 Information collected from third parties
Occasionally we may receive and use information about you from other sources (such as credit reference agencies, referees, professional advisors or other similar bodies) which we will add to the information which we already hold about you in order to help us provide the required services or comply with our legal and regulatory obligations, in particular regarding anti-money laundering, bribery or criminal finances legislation.
2. How we use and share your information within the Gray Page Group
If you apply for a position, request a service, contract with us as a supplier, or register for communications from us, your personal information will be used and shared within the Gray Page Group in accordance with your requirements and our operational arrangements. If your data is transferred to our Singapore entity, Gray Page (S) Pte Ltd, it will be done so under the protections of the European Commission’s standard data protection clauses.
3. How we use and share your information with other parties.
We may share your information with third parties if this is required by law or our insurance requirements. We may also share information with third parties who provide data processing services for Gray Page, but only where such third parties are subject to a contract that prevents them using the data other than as instructed by us, restricts the sharing of the data and requires them to hold the data securely and for the period we instruct.
4. Transfers of Personal Data out of the European Economic Area (EEA)
We will only transfer your personal data out of the EEA as provided in clause 2, or where this is otherwise specifically authorised by data protection law, such as for the exercise of legal claims or for important reason of public interest.
We send our clients the occasional newsletter, article or industry briefing. You can change your preferences or withdraw consent to receive marketing communications at any time by clicking on the link at the bottom of the email, or sending an email to firstname.lastname@example.org.
You can opt-in to receiving our e-newsletter or Maritime Threat Picture email alerts on our website, www.graypage.com
6. How we protect your information
6.1 We have put in place various security procedures and technical and organisational measures to safeguard your personal information including firewall and password protection systems. Our security and privacy policies are regularly reviewed.
6.2 We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
7. Access to your information and updating and correcting your information
7.1 You have the right to request details of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to email@example.com or send a letter to Joe Corless, Operations Director, Gray Page Limited, Willow Barn, Willow Park, Cumnor Road, Oxford, OX2 9TX, United Kingdom. We are entitled to charge a fee for this service if requests are manifestly unfounded, repetitive or excessive.
7.2 We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address or name, please let us know the correct details by sending an email to firstname.lastname@example.org, or send a letter to Marketing Team, Gray Page Limited, Willow Barn, Willow Park, Cumnor Road, Oxford, OX2 9TX, United Kingdom. You may ask us, or we may ask you, to correct information you or we think is inaccurate.
8. Other data subject rights
8.1 You may have other rights in relation to the personal data we hold about you, including, in some circumstances, a right to restrict or object to processing, to seek erasure of your data or transfer your data to another provider. Full details of these rights, and the conditions in which they are available, can be viewed at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. You have a right to complain to the Information Commissioner’s Office if you do not believe we are respecting your rights.
9. Changes to Privacy Notice
9.1 We keep our Privacy Notice under regular review. If we change our Privacy Notice we will post the changes on this page, and place notices on other pages of the website, so that you may be aware of the information we collect and how we use it at all times. This Privacy Notice was last updated on 8 May 2018.
10. Links to other websites
10.1 Our website contains links to other websites. This Privacy Notice applies only to this Company’s website so when you access links to other websites you should read their own privacy notices.
11. Details for the Gray Page Group
Gray Page Limited
Oxford OX2 9TX
Gray Page Intelligence Services Limited
Oxford OX2 9TX
Gray Page Marine Systems Limited
Oxford OX2 9TX
Gray Page (S) Pte Ltd
80 Robinson Road, #02-00
Registration numbers with ICO:
Gray Page Limited, Z8636077
Gray Page Intelligence Services Limited, Z8680304
Gray Page Marine Systems Limited, Z8636063
Contact email for data subjects: email@example.com