Website Privacy Policy

1 Introduction
This Policy applies to the following companies: Navios Ship Management Inc, Navios Tankers
Management Inc., Navios Corporation, Navios Containers Management Inc., Kleimar Ltd. andKleimar NV (hereinafter collectively “Navios”). Navios is committed to protecting the personal
information collected when you use our website and other services. This Website Privacy
Policy pertains to Navios website and sets out Navios’ commitment in protecting Personal
Data and how that commitment is implemented regarding the collection, use, transfer andretention of Personal Data.

2 Personal Data Collection
Navios has designed a standard website contact form to initiate communication with anyinterested individual. This form is used for any inquiries or requests and it directs them to theappropriate department or staff member. Navios has also implemented a digital solution for
the information of investors and the option to use email alerts as well, accordingly to relevantlegislation. In order to handle and respond to your inquiries and requests as well as to informyou we might collect and store your full name, email, phone and any other information you
might provide to us. This information is strictly used to adequately inform you or respond to
your inquiries or requests and will not be disclosed to third parties others than thosementioned in this policy or where disclosure is required or permitted by law. In certain
circumstances, our website may be used by job applicants, in which case the data subject
should refer to the Privacy Notice.
For processing to be lawful under the General Data Protection Regulation (GDPR), we identify
a lawful basis before we can process your personal data. In this case, the legal basis for thedata processing effected by us is the granting of your consent to the processing, by submitting
the consent form only in case you agree with this policy.
Navios is committed not to retain personal data for a longer period than it is necessary
regarding the reasons that the personal data was obtained. For additional information on
retention and deletion periods, please refer to Our Contact Details section below.
Navios may disclose Persona Data collected to our suppliers or subcontractors insofar as
reasonably necessary for dealing with your inquiries or requests. Such transfers will beprotected by appropriate safeguards (e.g. appropriate contractual clauses, data processing
contracts, intra-group disclosures of personal data, etc.). In addition, we may disclose Personal
Data where such disclosure is necessary for compliance with a legal obligation to which weare subject.

2

3 Rights of Data Subjects
In this section Navios addresses the rights deriving from Regulation (EU) 2016/679 and how
these rights can be accessed by the Data Subjects. For any further clarifications please refer
to Our Contact Details section below.

3.1 Individual’s Right of Access or Rectification
Navios assumes that Personal Data collected directly from the individual will be accurate andcomplete. Individuals can access and update their own Personal Data using the Data Subject
Request Form. For a copy, please contact us at dpo@navios.com.

3.2 Individual’s Right to Erasure
The data subject may request that any information held on them is deleted or removed, andany third parties who process or use that data must also comply with the request. An erasure
request can only be refused if an exemption applies. The Right to Erasure can be requested
using the Data Subject Request Form. For a copy, please contact us at dpo@navios.com.
Navios is obligated to erase personal data where one of the following applies:
▪
▪
▪

▪

Personal data is no longer necessary in relation to the purposes for which they werecollected or otherwise processed;
The data subject withdraws consent and no other legal basis for processing exists;
The data subject objects to the processing carried out on the grounds of the Data
Controller’s legitimate interests and there are no other overriding legitimate grounds
for the processing;
The personal data has been unlawfully processed.

If the request to erase Personal Data has been received, identity has been confirmed, therequest meets one of the above requirements and there is no legal contrary reason forprocessing, Navios must delete the relevant data in its entirety. The request will be recordedin the Data Subject Request Log.
If Navios cannot actually delete personal data, Navios will ensure that:▪
▪
▪

It is not able, or will not attempt, to use the personal data to form any decision in
respect of any individual or in a manner that affects the individual in any way;
Does not give any other organization access to the personal data;
Protects the personal data with appropriate technical and organizational security; andcommits to permanent deletion of the information if, or when, this becomes possible.

33.3 Individual’s Right to Object and to Restrict Processing
The data subject has the right to object at any time to processing of their personal data andto obtain from the controller restriction of processing using the Data Subject Request Form.
For a copy, please contact us at dpo@navios.com.
Data Subject Request Form.

3.4 Individual’s Right to Data Portability
Upon request and provided that the relevant requirements stipulated in Article 20 of GDPR
are met, a data subject should have the right to receive a copy of their Personal Data in astructured format using the Data Subject Request Form. For a copy, please contact us at
dpo@navios.com.
These requests should be processed within one month, provided there is no undue burden
and it does not compromise the privacy of other individuals. A data subject may also requestthat their data is transferred directly to another system. This must be done for free.
If Navios cannot respond fully to the request within 30 days, the DPO shall neverthelessprovide the following information to the Data Subject, or their authorized legal representative
within the specified time:
▪
▪
▪

▪
▪
▪

An acknowledgement of receipt of the request.
Any information located to date.
Details of any requested information or modifications which will not be provided to theData Subject, the reason(s) for the refusal and any procedures available for appealing thedecision.
An estimated date by which any remaining responses will be provided.
An estimate of any costs to be paid by the Data Subject (e.g. where the request is excessivein nature).
The name and contact information of the contact person.

4 Amendments
Should Navios elect to change this Privacy Policy we will post the changes here. Whererequired by law, will we obtain your consent to make these changes.

45 Our Contact Details
If you need any further information and/or you have any questions about our Privacy Policy,
please contact us at dpo@navios.com.

5