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Privacy Policy of AS-Tech Solutions s.c.

This document contains information about the processing of your personal data in connection with the fact that (i) that you have a contract for providing a service related to taking up employment abroad (intermediation in employment) and / or (ii) you are a registered user of the website O! JA (Online! Job Application) administered by AS-Tech Solutions sc

Obligation to inform on the basis of article 13 of the GDPR

The obligation results from art. 13 para. 1 and par. 2 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46 / EC (hereinafter referred to as GDPR).


Who is the administrator of your personal data?


The administrator, which is the entity deciding how your personal data will be used, is AS-Tech Solutions s.c. with headquarters in Gdynia, ul. Orna 6/3 (hereinafter "AS-Tech") licensed Employment Agency (license No. 5637) administrator of the online portal "Online! Job Application "available at https://as-tech.odms.eu (hereinafter " O!JA ").

How to contact us for more information on the processing of your personal data?

Write to the administrator of personal data e-mail address: gdpr@as-tech.plor a personal data inspector designated by us. Here is his contact details: e-mail address:  rodo@apmar.org.pl, postal address: Data Protection Supervisor AS-Tech Solutions s.c. 81-574 Gdynia, ul.Orna 6/3

Where did we get your data from?

We received it from you during the creation of an account at O! JA by submitting applications, as well as later, in connection with the provision of abroad employment services provided for you.

What is the purpose and legal basis for the processing of your personal data by AS-Tech?


We process your personal data because it is necessary to perform the contract concluded with you, including:

- the purpose of current and future job placement for e foreign shipowner's recruitment and employment process, including for purposes necessary to perform a seafarer employment contract and its financial security, as required by MLC 2006. We process data based on your consent (legal basis : GDPR Article 6 (1) a)).

- the purpose of handling complaints and any other claims. The basis for processing is the legally legitimate interest of AS-Tech (Article 6 paragraph 1 letter F of GDPR) consisting in securing information about cooperation (including, inter alia, the history of brokering in your employment, communication with us) to handle any claims;

You can withdraw your consent to the processing of personal data at any time in the same way as you have expressed it. We will process your personal information until you withdraw your consent.


Do you need to provide us with your personal details?

Providing personal data is a prerequisite for participation in recruitment, and failure to do so prevents the use of job placement. Personal data such as: name, position, address, telephone number, contact details, information about previous employment and qualification documents will be collected and used to contact you as part of activities aimed at your employment abroad,
If for some reason you do not provide this personal information, unfortunately we will not be able to conclude a contract with you and as a consequence you will not be able to use our job placement services.


What are your rights to AS-Tech regarding the data being processed?


We guarantee the fulfillment of all your rights under the general Data Protection Regulation, i.e. the right to access, rectify and delete your data, limit their processing, the right to transfer them, not be subject to automated decision making, including profiling, and the right to object to the processing Your personal data.

You can use these powers when:
• regarding the request for data rectification: you will notice that your data is incorrect or incomplete;

• regarding the request to delete data: your data will no longer be necessary for the purposes for which it was collected by AS-Tech; you will withdraw your consent to data processing; you object to the processing of your data; Your data will be processed unlawfully; data should be deleted in order to fulfill the obligation arising from the law;

• regarding the request to limit the processing of data: you will notice that your data is incorrect - you may request restricting the processing of your data for a period allowing us to check the correctness of this data; Your data will be processed unlawfully, but you will not want to be removed; We will no longer need your data, but you may need to defend or claim it; or you object to the processing of the data - pending determination of whether the legitimate grounds on our side override the grounds of objection;

• in relation to a request for transfer of data: the processing of your data takes place on the basis of your consent or the contract concluded with you and when this processing takes place automatically.


You have the right to lodge a complaint regarding the processing of your personal data to the supervisory body, ie the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych - Prezes UODO, address: 2 Stawki Street, 00-193 Warsaw).


In what situations can you oppose the processing of your data?

You have the right to object to the processing of your personal data when:

• the processing of your personal data is based on a legitimate interest or for statistical purposes, and the opposition is justified by the particular situation in which you have found yourself,

• Your personal data is processed for direct marketing purposes, including profiling for this purpose.


Do we process your personal data automatically (including through profiling) in a way that affects your rights?


Your personal data may be processed to some extent in an automated manner (including in the form of profiling), however, it will not cause any legal consequences to you or substantially affect your situation.

The profiling of personal data by AS-Tech involves the processing of your data (also in an automated way), by using them to assess certain information about you, in particular to analyze your professional experience and qualifications in accordance with the information you provide. This is described in the recruitment regulations provided in the

Company Policy Declaration – Recruitment

Who we share your personal information with?

We provide your personal data to foreign employers as part of recruitment conducted by them for job placement (maritime enterprises seeking employees), and entities supporting us in providing you with job placement services, that is, entities that provide courier, transport, communication, hosting services, port agents and visas, hotels, etc. Personal data of persons who have taken up work on the ship through us can be made available to the competent maritime administration bodies on the basis of applicable law. We may pass on your personal data to public authorities fighting against fraud and abuse.


Do we pass your data to countries outside the European Economic Area?


Your personal data will be transferred to third countries for which the European Commission has not issued a decision stating the appropriate level of protection under GDPR art. 45, 3.

Personal data will be transferred to the above-mentioned countries on the basis of your consent, despite the possible risks of such transfers resulting from the lack of GDPR regulations (GDPR art.49, 1 (a)).

This applies to both maritime companies seeking workers as well as visa agents, embassies, port agents, airlines and other entities related to international maritime transport, which you deal with on a daily basis as part of your work on a sea-going ship.


How long do we keep your personal data?


We store your personal data for the duration of the contract concluded with you, or until you withdraw your consent to the processing of your personal data and after its termination for the purposes of:

• pursuing claims in connection with the performance of the contract,

• performance of obligations resulting from legal regulations, including in particular tax and accounting,

• preventing abuse and fraud,

• statistical and archiving,

• for a maximum of 10 years from the date of completion of the contract.

We store your personal data for the duration of the contract or until you object to such processing, whichever occurs first

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© 2009 AS-Tech Solutions s.c. | ul. Orna 6/3 | 81-574 Gdynia | Poland | Tel. +48 58 660 97 31 | e-mail: solutions@as-tech.pl
Projekt: Zink Studio | Wykonanie: NOVATI