Privacy policy

To conduct our daily business, we strive to ensure that technical security measures are in place to protect your personal data

Contents of the Blue Water Privacy Policy

  1. Introduction
  2. What is personal data?
  3. What is sensitive personal data
  4. General considerations about purposes of processing and legal basis
  5. Retention
  6. Your rights
  7. When you visit our websites such as bws.net
  8. When you visit our social media profiles
  9. When you sign up for our events, webinars, fairs, marketing etc.
  10. Specifics about our partners
  11. Ethics Line
  12. Withdrawal of consent
  13. When you use Blue Water’s online services
  14. When you visit a Blue Water location
  15. When you apply for a job at Blue Water
  16. Sharing, transfer and disclosure of personal data
  17. Questions and complaints

1. Introduction

Group Blue Water ("Blue Water", "we", "us", "our") is committed to protecting your personal data and privacy. We strive to ensure that organisational and technical security measures are in place to protect your personal data.

Blue Water is a global group of companies within the field of global transportation and logistics. To conduct our daily business, the legal Blue Water entities have to exchange personal data on a regular basis. Whether you are for example buying transport and/or logistics services (“services”), receiving newsletters, applying for a vacant position or browsing our websites, we strive to protect the privacy of any individual we are in contact with.

This privacy policy (“policy”) applies to our processing of your personal data as a data controller. It establishes rules and guidelines for the way Blue Water processes your personal data and provides you with the information that you are entitled to receive under applicable data protection laws, including, but not limited to, the General Data Protection Regulation (hereinafter “GDPR”).

This policy is the governing document in Blue Water, respecting the requirements for any local and/or national additional rules and policies implemented where Blue Water is present. 
We encourage you to read this privacy policy before you hand over your personal data.

2. What is personal data?

Personal data is any information that can lead to the identification of a specific person. It can be your name and phone number, but it can also be other types of data such as your email address and invoice details. To manage our business, we need to process certain personal data globally.

As a consequence, we collect and process your personal data when, for example, you visit our website, communicate with us applying for a vacant position, interact with us on social media, subscribe to our newsletter/marketing communication, or use our services such as MyBWS, including any other services that we deliver in connection with our daily operations. 

3. What is sensitive personal data?

Sensitive personal data is a subset of personal data. Sensitive personal data includes information revealing race and ethnic origin, political opinions, religious or philosophical beliefs, membership in trade unions, genetic data, biometric data for unique identification, health information and sexual relations or sexual orientation, cf. GDPR art. 9(1). The processing of such data is subject to more rigorous data protection measures to safeguard any individual's privacy rights.

Blue Water declines to receive any sensitive personal data, both on our website, through emails and through general communications with us, unless we specifically request it and/or there is a legal obligation to do so. Should you nevertheless provide us with sensitive personal data, we will make sure to delete it to avoid processing sensitive personal data unless Blue Water is obligated to process such personal data for a specific and necessary purpose.

4. General considerations about purposes of processing and legal basis

We collect personal data about you and process it to for example fulfil the agreement that you have entered with Blue Water and/or Blue Water Water’s customer and/or suppliers directly/indirectly. Furthermore, we process personal data in order to take steps to provide or assist with your requests when you generally communicate with us for example when you utilise a contact form on any of our websites, contact customer service, send an email, engage in a chat, make a phone call or communicate with Blue Water in any other way. Blue Water processes your personal data such as:

  • Name, email address, phone number
  • What your inquiry is about
  • Date and time of your inquiry
  • Other information you provide in connection with your inquiry

The purpose of processing such data personal is for example:

  • Handling of your inquiry
  • General communication
  • Analysis and statistics

Blue Water processes your personal data in accordance with applicable laws, and the legal basis for the processing of your personal data is either a contract, your consent, legal obligation or Blue Water’s legitimate interest in accordance with the cf. GDPR art. 6,  (1), (a), (b), (c) and (f).

5. Retention

Blue Water will delete your personal data when we no longer need your personal data to fulfil the purposes for which it was collected. However, we may process your personal data for longer in an anonymised form or if we are obliged or entitled to do so pursuant to the legislation.

This means that we have several retention policies in place because of purpose limitation, hence for example deletion may vary depending on the legal basis and context e.g. terms agreed in a contract with you, countries to which the services relate for example national bookkeeping requirements etc. Personal data related to the use of Blue Water’s websites will be deleted after 30 days at the latest, except from cookies, which will be deleted in accordance with Blue Water’s Cookie Policy.

If the processing of your personal data is based on your consent, the personal data will be deleted when you withdraw your consent at the latest, unless applicable law require us to store the personal data for a longer period. You can also read more in our Newsletter policy

6. Your rights

We want to process your personal data not only in accordance with legislative requirements, but also according to our business ethics values. You have the following rights:

  • You have the right to be informed about the personal data Blue Water is processing about you.
  • You have the right to have incorrect or incomplete personal data corrected or completed.
  • You have under certain circumstances right to have your personal data deleted.
  • You have under certain circumstances the right to restrict and limit the processing of your personal data.
  • You have the right to object to the processing of your personal data.
  • You have under certain circumstances the right to request that your personal data is transmitted to another data controller.
  • Any consent that you may have provided to us may be withdrawn at any time by contacting us using the contact details provided below.
  • You have the right to not be profiled. This does not apply if you have given your consent, if we have a legitimate interest, or if it is necessary for entering into or performance of a contract.
  • You always have the right to ask questions or complaint.

You are always welcome to contact us regarding any question you might have regarding data privacy and data ethics. Please contact Blue Water HSSEQ & Compliance at email privacy@bws.dk.

7. When you visit our websites such as bws.net

When you visit any of Blue Water’s websites, we may process your personal data through cookies and pixels. This may include processing of personal data, e.g. IP address, access time and other website and browser information. Further, Blue Water may collect your name and contact information if you use a request form on any Blue Water website. Please note that pop-up consent banners on our websites also provides you with information about our processing of your personal data. Your personal data may be processed for the following purposes:

  • Ensuring our website’s functionality
  • Statistics and analysis
  • Marketing
  • Remembering your settings and preferences

We process your personal data on the legal basis legitimate interests cf. GDPR art. 6(1)(f) and consent, when you for example have given your prior written consent to this via the consent banner on the website, cf. GDPR art. 6(1)(a). 

For more information, please see our Cookie Policy, which can be found when clicking on the cookie icon in the bottom left corner at bws.net.

8. When you visit our social media profiles

When you visit or engage with Blue Water's social media profiles, we process your personal data. Depending on the platform, one or more of the social media sites listed below may act as a joint data controller with Blue Water. As a result, both Blue Water and the respective social media provider share responsibility for processing the personal data collected during your interactions with Blue Water’s social media profiles. This implies that the current privacy policies of the respective social media platforms apply, along with your individual privacy settings and personal interactions.

Blue Water has social media profiles or pages on the following social media platforms:

Additionally, we may occasionally use your personal data to improve your experience with our services, especially concerning emails, visits to our website and similar interactions. Types of personal data which is collected and processed for such purposes may be:

  • Information available on your profile, including your name, gender, workplace, interests and city.
  • Whether you follow or have applied other reactions to our profile.
  • Shared posts.
  • Visits to our profile.
  • Comments you leave on our posts.
  • Messages which you have sent to us.

The purposes for collecting and processing your personal data are for improving our services, analysis and statistics, to communicate with you if you comment on a post, make a review or send us a message, including marketing.

The legal basis we use is legitimate interests enabling communication with you and market us to you on our social media profiles, regarding branding and sales, including improving services, cf. GDPR art. 6(1)(f).

9. When you sign up for our events, webinars, fairs, marketing etc.

When we host webinars, fairs and similar events, we continuously strive to improve our services. Therefore, we may ask participants to provide feedback. To prepare participants who have signed up for a webinar, fairs etc. we send out service emails before the event, detailing the participation process. Additionally, a follow-up email will be sent after the event, which may include information about the specific services. As a result, personal data is processed in this context. For such purposes, Blue Water may collect, process and store your name, phone number, address and email address.

Our purposes are to be able to communicate directly related to you regarding e.g. sales, follow ups and further dialogue in accordance with your interests. The legal basis we use is legitimate interests enabling communication, cf. GDPR art. 6(1)(f).

When you receive or sign up for marketing communications regarding for example specific news about our services, Blue Water collects, processes and stores your personal data for marketing purposes. You subscribe to marketing communications when you for example sign up for a webinar and choose to sign up for e.g. our newsletter as an opt-in or if you are a business partner of Blue Water. Furthermore, Blue Water may occasionally utilise your personal data to enhance your experience with us and our services, particularly in relation to emails, visits to our website and similar.

We process your personal data on the legal basis legitimate interests cf. GDPR art. 6(1)(f) and consent, when you for example have given your prior written consent to receiving marketing newsletters, cf. GDPR art. 6(1)(a), including national legislation such as the Danish Marketing Practices Act. 

10. Specifics about our partners

Our partners such as consultants, newsletter services, IT system providers etc. might have limited access to your personal data. Typically, such partners operate under a binding contract with Blue Water, ensuring that your personal data is processed accordingly. We intend to use your personal data for purposes only for which it was collected.

We will always ask for your consent and inform you about this before proceeding with any such processing where applicable, necessary and relevant, cf. GDPR art. 6(1)(a). You can also read more in our Recruitment privacy policy as well as Newsletter policy. 

11. Ethics Line

If you make a report to our Ethics Line (whistleblower function) or in some other manner are in contact with our Ethics Line, we might process your personal data, including potentially sensitive and/or confidential data, only if absolutely necessary, with the purpose of investigating a reported concern and/or reported violation of for example, but not in particular, rules, guidelines, legislation, laws, governing principles and/or internal policies such as, but not limited to, Code of Conduct and human rights. We process such personal data on the following legal basis:

  • Legitimate interests: We may process your personal data based on our legitimate interests in carrying out assessments of reported concerns, cf. GDPR art. 6(1)(f).
  • Consent: Only when no other legal basis can be applied, Blue Water may ask for your consent to process your personal data, cf. GDPR art. 6(1)(a) for example if we need to proceed in a certain direction with the investigation of a reported concern and only if you have consented to this, cf. GDPR art. 9(2)(a).
  • Legal obligation: We may process personal data only, if necessary, with regards to for example our obligations current and applicable legal obligations under national law, cf. GDPR 6 (1)(c), GDPR art. 9(2)(b).
  • Protection of vital interests: If deemed necessary we will process personal data in connection with the investigation based on this legal basis, cf. GDPR 6(1)(d), GDPR 9(2)(c).
  • Public personal data: If necessary personal data is processed on this legal basis if the personal data are made public by the data subject him/herself, cf. GDPR 9(2)(e).
  • Legal claims: If we need to protect our company or other interests we will process personal data on this legal basis, cf. GDPR 9(2)(f). 

12. Withdrawal of consent

If you have given your consent to for example marketing purposes and wish to withdraw it, you can always use the ‘unsubscribe’-link at the bottom of the email or by writing to us at marketing@bws.net, cf. GDPR art. 7(3). If you wish to withdraw your acceptance of cookies at bws.net, you can opt out by clicking on the cookie icon in the bottom left corner at bws.net.

To avoid any doubt if you decide to withdraw your consent, you will be promptly excluded from our marketing communication mailing list and no longer receive marketing messages. Withdrawing your consent will not invalidate our prior processing of your personal data based on your earlier given consent. Therefore, any revocation of your consent will only apply to our processing activities from the moment you withdraw your consent going forward.

13. When you use Blue Water’s online services

When you use any of the Blue Water’s online services such as MyBWS, we collect and processes your personal data. Furthermore, Blue Water may occasionally utilise your personal data to enhance your experience with us and the services, particularly in relation to emails, visits to our website and similar.

We may collect, process and store the following types of your personal data name and email address, user behaviour, IP address, browser type, browser settings, browser configuration, and plugins, date and time of usage, information about the device you use to access the services, including the type of device you are using, operating system, device settings, application ID and unique device identifiers.

The purposes of such processing are to make the services available to you, analysis and statistics, including communication regarding for example emails with service updates. 
Depending on your use of the service, we process your personal data on the legal basis (i) contractual obligations due to for example the necessity of fulfilling a contract or fulfilling a request from you, cf. GDPR art. 6(1)(b) and (ii) legitimate interests based on our legitimate interest in developing and improving our services and enhancements available to you, cf. GDPR art. 6(1)(f).

If you are an active user of Blue Water’s services, your personal data will not be deleted. If you are no longer an active user, we will retain your personal data, including company contacts, emails and similar information, for as long as we have a legal obligation or legitimate interest to preserve it. If neither of these justifications applies, the data will be securely retained for five years following the termination of the contractual relationship. Additionally, personal data may be retained for longer periods in anonymised form.

14. When you visit a Blue Water location

When you visit our company's physical locations and register in our guest system, we collect and process your personal data to ensure a secure and efficient visit. The information we gather may include your name, contact details, phone number and the purpose of your visit. Our purposes for processing your personal data are to manage and document visitor access, to maintain security, crime prevention and safety within our premises as well as enable a secure evacuation of a building in the event of e.g. a fire.

Your personal data will be stored for 30 days and/or only for as long as necessary to fulfil these purposes or as required by law. The legal basis we use is legitimate interests, enabling Blue Water to have appropriate visitor management in place, including protecting physical locations cf. GDPR art. 6(1)(f).

15. When you apply for a job at Blue Water

When you apply for a job at Blue Water through our Applicant Tracking System (“ATS”), an e-recruitment system hosted by Emply ApS, we process your personal data in accordance with our recruitment process. Blue Water may collect, process and store the following types of your personal data:

  • Personal data which you have disclosed in your job application (e.g., birth date) and resume (CV) as well as any attachments, including information regarding your previous jobs, activities, competencies and/or performance.
  • References from your previous and/or current employers.
  • Additional information you will provide in relation to the recruitment process.
  • Blue Water may administer a personality test and/or logical test.

Your personal data will be processed for the purpose of assessing whether we can offer you a position at Blue Water. We process your personal data on the following basis:

  • Contractual obligations: We process your personal data for the purpose of carrying out measures concerning potential employment at your request prior to entering into an employment contract agreement, cf. GDPR art. 6(1)(b).
  • Legitimate interests: We may process your personal data based on our legitimate interests in carrying out assessments of whether we want to hire you, cf. GDPR art. 6(1)(f).
  • Consent: Only when no other legal basis can be applied, Blue Water may ask for your consent to process your personal data, cf. GDPR art. 6(1)(a) for example if we will collect references from your previous and/or current workplace if you have consented to this, cf. GDPR art. 9(2)(a).
  • Legal obligation: We may process personal data only, if necessary, with regards to for example our obligations under employment and social security and social protection law, cf. GDPR 6 (1)(c), GDPR art. 9(2)(b). 

If you are offered a position at Blue Water, your application and any additional relevant personal data collected during the recruitment process will be stored in your employee file. If you are not offered a position, we will retain your application and any additional personal data collected during the recruitment process for six months after our decision, after which the files will be deleted.

If you are offered a position at Blue Water, we will be contractually obligated to process additional personal data beyond what is mentioned above. This includes your address, working hours, salary information, date of employment and other relevant details. This processing is necessary to prepare your employment contract in accordance with our legal obligations, cf. GDPR art. 6(1)(b).

16. Sharing, transfer and disclosure of personal data

Your personal data is generally not disclosed to a third party without your consent. However, with reference to and in connection with the purposes mentioned above, we may give third parties access to your personal data.

When necessary Blue Water may disclose your personal data to for example service providers and advisors (“third parties”) to fulfil its obligations towards you. Contracted service providers can for example be airlines, consultants, hauliers, shipping lines or public authorities.  Furthermore, this could also be IT suppliers or other suppliers that process your personal data on behalf of us. Such suppliers will only process your personal data in accordance with our instructions and data ethics, ensuring appropriate compliance with the agreed-upon data processing agreements.

We may disclose personal data processed in connection with your use of our websites, your participation in events or when you receive newsletters, including marketing communications or similar. Upon your request, where appropriate, Blue Water can provide you with the identity of such third parties. 

In some cases, we can pass on your personal data to our affiliate companies and legal entities being a part of Group Blue Water to the extent that it is reasonably necessary to the purpose listed in this privacy policy. If your personal data needs to be transferred to data processors or data controllers located outside the EU/EEA, this will only happen once a valid transfer basis is established.

A valid transfer basis is ensured if the company is an active participant in the EU-U.S. Data Privacy Framework. If the company is not certified, the transfer will only proceed after securing an alternative transfer basis, such as the EU Commission's Standard Contractual Clauses (SCCs) and conducting a Transfer Impact Assessment (TIA). If you have any questions about data transfers to countries outside the EU/EEA, please contact us at privacy@bws.dk. In certain circumstances and in accordance with the law, it may be necessary to disclose your personal data to for example lawyers and accountants. cf. GDPR art. 6(1)(c).

17. Questions and complaints

If you have any questions about this privacy policy or if you wish to complain about the way we process your personal data as the data controller, please feel free to contact us:
Blue Water Shipping A/S
Trafikhavnskaj 9
6700 Esbjerg
Denmark
CVR: 40516611
Tel: +45 7913 4144
Email: privacy@bws.dk 

If your complaint is not resolved by us and you want to proceed with the case, you can complain to the Danish Data Protection Agency:
The Danish Data Protection Agency
Carl Jacobsens Vej 35
2500 Valby
CVR: 11883729
Tel: +45 3319 3200
Email: dt@datatilsynet.dk
Webpage: The Data Protection Agency