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In accordance with the provisions of Articles 13 and 14 of Regulation (EU) 2016/679 on the Protection of Personal Data (the “Regulation” or “GDPR”), the following text sets out how we respect the privacy of visitors to this website, describing how we collect, use and protect personal information, their rights and how they can contact us.

Data Controller


Head Office: Le Ruscino – 14 Quai Antoine 1er – 98000 Monaco

Purposes of the Treatment

We collect through our website personal information that visitors are free to provide by filling in forms, orders, questionnaires, donations or requests, or by sending e-mail messages, for the following purposes:

  • To satisfy the specific request submitted by the User;
  • To carry out statistical analysis and market research;
  • To allow the sending of a spontaneous application or for any open positions;
  • Sending news, updates, advertising events and promoting other activities and projects;

This may entail the subsequent acquisition of the sender’s address, which is necessary to respond to requests, as well as any other personal data, including those included in the message.

The provision of data is optional, but it is necessary in order to satisfy the visitor’s request, or to perfect the relationship between the parties.

This processing is based on the principle expressed by Art. 6 of the Regulations, according to which the processing of personal data is lawful if necessary for the performance of the service requested by the data subject.

Type of personal data collected

The personal data collected through the website concern precisely the personal and contact data, and those associated with the payment method, for purposes related to the mutual obligations arising from the relationship with users. In addition to the common data provided directly and intentionally by users, the computer systems and software procedures used to operate this website acquire, during their normal operation, some navigation data whose transmission is implicit in the use of Internet communication protocols. For further information in this regard, please refer to the dedicated Cookie Policy.

Spencer Ship does not deliberately collect any particular data through this web site.

Processing methods

Processing of personal data means the collection, registration, organisation, storage, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, diffusion, cancellation and destruction, or the combination of two or more of said operations, also by means of automated tools designed to store, manage and transmit the data, using instruments that guarantee security and confidentiality.

As far as security is concerned, we inform you that the database is accessible only by the personnel appointed for this purpose by the Data Controller, as well as for the relative operations described above, and that your data will be processed using methods and tools suitable for guaranteeing confidentiality and may be carried out by electronic or automated means and by non-automated means (paper files), both of which are provided with adequate security measures, as provided for by the Regulations, to prevent the loss of data, unlawful or incorrect use and unauthorised access.

Communication of data to third parties

Without prejudice to any communication to fulfil legal obligations, Spencer Ship shall communicate the personal data provided by visitors with care only to suppliers selected to support the requested service, duly appointed as External Data Processors, such as i) commercial and operational partners, in charge of logistics, shipping; ii) banks, for the management of collections and payments, including suppliers of remote electronic payment services iii) consultants and collaborators in charge of providing (by way of example) assistance in tax, accounting and legal matters, it being understood that these subjects will not in turn proceed to communicate user data to third parties; iv) subjects that provide services for the management of the information system and databases and telecommunications networks; and v) subjects that carry out control, auditing and certification of accounting data.

Links to third-party sites

We encourage users to note that the Spencer Ship website sometimes contains links to other sites that are not covered by this privacy statement. Visitors to our site may be directed to third party sites to obtain more information, such as events, content promotions, supplier services; Spencer Ship does not guarantee how user data is stored or used by third party servers. We recommend that you examine the privacy policy of each third party site reached through Spencer Ship in order to understand their use of your personal data.

Using Social Media

You can participate in the platform that Spencer Ship has made available on Facebook, Linkedin, and Youtube. The main objective is to facilitate and enable the sharing of content. However, Spencer Ship cannot be held liable if you share personal data on Social Media that is subsequently misused or misappropriated by third parties. Spencer Ship may also provide links to other social media platforms that lead to servers installed by individuals or organisations over which Spencer Ship has no control. Spencer Ship makes no representation or assumes any responsibility for the accuracy or any other aspect of the information available on these sites. Il collegamento (link) ad un sito di un terzo non può essere inteso come una validazione, né da parte di Spencer Ship né di tale terzo, dei prodotti e servizi di altri o tale terzo. Spencer Ship non rilascia dichiarazioni o garanzie riguardo l’uso o l’archiviazione dei dati dell’utente presso i siti di terzi. Users are invited to carefully examine the privacy policy governing the third party sites linked to our website in order to have a complete view of the possible use of your personal data.

Data Retention

Personal data provided through the website will be kept for the time necessary to fulfil the specific purpose for which it was collected, as indicated in this policy. The personal data provided through the website will be kept for the time necessary to perform the specific purposes for which they were collected, as indicated in this information notice, and in any case the personal data will be kept for a period equal to the duration of the contract (including any renewals) and for 10 years after the termination, cancellation or withdrawal of the same, except in cases where conservation for a longer period is required for any litigation, requests by the competent authorities or under applicable legislation;

Personal data is stored on servers located in Opera (Milan) at Via Eugenio Montale, 19/21 within the European Union.

Rights of the data subject

As a data subject, you have the rights set out in Article 15 GDPR, namely the rights to:

– obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet recorded, and their communication in intelligible form;

– obtain information on: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the event of processing carried out with the aid of electronic instruments; d) the identity of the data controller, data processors and the representative appointed pursuant to art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, data processors or persons in charge;

– obtain: a) the updating, rectification or, when interested, the integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;

– to oppose, in whole or in part: a) for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of collection; b) the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or mail. Please note that the data subject’s right to object to direct marketing by automated means extends to traditional marketing methods and that, in any case, the data subject may exercise his/her right to object even partially. Therefore, the data subject may decide to receive only communications by traditional means or only automated communications or neither of the two types of communication.

Where applicable, you also have the rights set out in Articles 16-21 GDPR (right to rectification, right to be forgotten, right to restrict processing, right to data portability, right to object), as well as the right to complain to the Supervisory Authority.

You may exercise your rights at any time by sending:

Le Ruscino – 14 Quai Antoine 1er
98000 Monaco

or an e-mail to: info@spencership.com

Changes to this policy

Spencer Ship reserves the right to modify this information as necessary. We invite you to check this page periodically in case you want to keep an eye on changes.