Privacy Policy

Just Provisions SAM is committed to safeguarding your privacy while processing your Personal Data under the General Data Protection Regulation. Contact us at [email protected] if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
By using our website, apps or/and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy. This Privacy Policy is a part of our Terms and Conditions and of any contract you may conclude with us; by agreeing to our Terms and Conditions or contracting with us you also agree to this Policy. In the event of collision of terms used in Terms and Conditions, any contract and Privacy Policy, the latter shall prevail.
Some of the services we offer you, such as online payment, are provided by third parties. When using these services, the privacy policies of these third-party providers apply in addition to this Privacy Policy. These third parties may collect your consent to the Processing of your Personal Data prior to using their services.

Table of Contents

1. Definitions used in this Policy
2. Data protectionprinciples we follow
3. What rights do you have regarding your Personal Data
4. What Personal Data we gather about you
5. How we use your Personal Data
6. How long we store your Personal Data
7. Who else has access to your Personal Data
8. How we secure your data
9. Information about cookies
10. Contact information

1. Definitions
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data (including their collection, storage, use, transfer).
Data Subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – one of the companies belonging to the Catalano Shipping group listed above

• 2. Data Protection Principles
  We promise to follow the following data protection principles:
• Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
• Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
• Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
• Processing is limited within a time period. We will not store your personal data for longer than needed.
• We will do our best to ensure the accuracy of data.
  We will do our best to ensure the integrity and confidentiality of data.
•  

3. Data Subject’s rights

The Data Subject has the following rights:

1. Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
2. Right to access – meaning you have the right to access the Personal Data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate, useless, outdated, and/or incomplete. In addition, you may change any information you have provided us with when creating your member account and using our apps.
4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
5. Right to restrict Processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
6. Right to object to Processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one processor to another.
9. Right to lodge a complaint – in the event that we refuse your request in relation to your rights, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us. You are also entitled to lodge a complaint to the supervisory authority.
10. Right for the help of a supervisory authority – meaning you have the right for the help of a supervisory authority named in Article 10 below and the right for other legal remedies such as claiming damages.
11. Right to withdraw consent – you have the right to withdraw any given consent for Processing of your Personal Data. With regard to consent to cookies and/or consent to our newsletters and/or advertising emails you can use the unsubscribe or opt-out mechanism to revoke your consent.

4. Data we gather

Information you have provided us with

This might be your e-mail address, phone number, name, billing address, date of birth, home address, bank details, etc – mainly information that is necessary for delivering you a product/service or to enhance your customer experience with us. We save the information you provide us with, in order for you to comment or perform other activities on the website, on our apps. This information includes, for example, your name and email address.

By giving this information voluntarily, you also agree that we may personalise the content of promotional emails according to your needs and interests according to your profile. If you have also given your consent to the installation of cookies and the tracking of your member activity on our apps, this also includes Personal Data relating to the use of our apps.

You may revoke your consent to the sending of advertising emails or newsletters at any time with effect for the future by blocking the sending of further advertising by clicking on the “unsubscribe” link at the bottom of the advertising emails or newsletters. Revocation does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

Information automatically collected about you

This includes information that is automatically stored by cookies and other session tools. For example, your shopping cart information, your IP address, the browser used by your device, the content and URLs you have accessed, your shopping history (if there is any) etc. This information is used to improve your customer experience and/or for security purposes in particular to prevent cyber-attacks and unauthorised multiple logins. When you use our services or look at the contents of our website and/or apps your activities may be logged.

Before installing our apps or using the location-based content and services in these apps and using certain web browsers (e.g. Google Chrome), you are asked to give us or the web browser consent to process your location Personal Data. If you give such consent, we use the apps and your mobile device or web browser to determine the location of your mobile device or computer based on information from various sources (GSM radio cell, GPS location, surrounding Wi-Fi networks, etc.).

We draw your attention to the fact that the apps may not be installed or our services for which location collection is required may not be used if consent to the collection of Personal location Data has not been given. You may at any time adjust your mobile device or web browser settings to disable the collection of your Personal location Data. Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds.

Publicly available information

We might gather information about you that is publicly available.

Children

We do not intend to collect or knowingly collect information from children. We do not target children with our services.

5. How we use your Personal Data

We use your Personal Data in order to:

• provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
• enhance and secure your customer experience;
  manage your complaints and settle disputes;
• fulfil an obligation under law or contract;

We use your Personal Data on legitimate grounds and/or with your consent.

On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:

• to identify you;
• to provide you a service or to send/offer you a product;
• to communicate either for sales or invoicing;

On the ground of legitimate interest, we Process your Personal Data for the following purposes:

• to send you personalised offers (from us and/or our carefully selected partners);
• to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
• to conduct questionnaires concerning client satisfaction.

As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.

With your consent we Process your Personal Data for the following purposes:

• to send you newsletters and campaign offers (from us and/or our carefully selected partners);
• for other purposes we have asked your consent for.

We Process your Personal Data in order to fulfil obligations rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymize Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymized.

We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
the link between purposes, context and nature of Personal Data is suitable for further Processing; the further Processing would not harm your interests and there would be appropriate safeguard for Processing. We will inform you of any further Processing and purposes.

6. How long we store your Personal Data

We save and store your billing information and other Personal Data gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than 1 (one) year.

7. Who else can access your Personal Data

We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either provide you with the products/ services you ask us to give you/ perform for you or to enhance your customer experience.
We also use external service providers to carry out certain Processing of Personal Data on our behalf and on our instructions. Our subcontractors are asked to manage the technical infrastructure of our website and apps, provide us with web analysis services, auditing services, payment services etcWe only work with Processing partners and subcontractors who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.

8. How we secure your data

We do our best to keep your Personal Data safe. We take all necessary technical and organisational security measures to protect you against loss, unauthorised access, alteration, disclosure and destruction of your Personal Data. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymizing and pseudonymization where suitable. We monitor our systems for possible vulnerabilities and attacks. Access to your Personal Data is limited to those persons for whom access to such Personal Data is absolutely necessary for the purposes described in this Privacy Policy. Such persons are required to comply with applicable laws regarding the protection of Personal Data.

Even though we try our best we cannot guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.

If you have an account with us, note that you have to keep your username and password secret.

9. Cookies and other technologies we use

We use cookies and/or similar technologies to analyse customer behaviour, administer the website and the apps, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us.
A cookie is a tiny text file stored on your computer or your mobile device. Cookies store information that is used to help make sites and apps work. Only we can access the cookies created by our website and apps. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
We use cookies for the following purposes:

Necessary cookies – these cookies are required for you to be able to use some important features on our website and apps, such as logging in. These cookies don’t collect any Personal Data.

Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and email in comment forms so you don’t have to re-enter this information next time when commenting.

Analytics cookies – these cookies are used to track the use and performance of our website, apps and services.

Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed on the website or apps by advertising networks with the website/app operator’s permission. These cookies remember that you have visited a website/app and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

You can remove cookies stored in your computer/mobile device via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.

We use Google Analytics to measure traffic on our website/apps. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

10. Contact Information

Data Protection Officer
If you have any questions regarding Processing your Personal Data, your rights regarding your Personal Data or this Privacy Policy, contact our Data Protection Officer Michel VARINOT at [email protected]

Supervisory Authority
You are entitled to lodge a complaint to the competent supervisory authority which is the following:

If you have contracted with a Monegasque entity:

• Website: www.ccin.mc
• Address: 7 rue Suffren Reymond 98000 Monaco.
• Email: [email protected]
• Phone: (+377).97.70.22.44

If you have contracted with a French entity:

• Website: www.cnil.fr
• Address: 3 Place de Fontenoy 75007 Paris
• Phone: (+377).97.70.22.44

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy in view of the constant development of the services we offer. Any changes to this Privacy Policy will be posted on our website [link to which the Privacy Policy can be found on your websites] and will take effect immediately. We therefore invite you to consult this page regularly to keep abreast of any updates to this Privacy Policy.

Last modification was made 21/02/2023.