Alberta Shipmanagement Ltd. is committed to provide world-class sea transportation of goods that meet or exceed safety, environmental and customer requirements and its employees with a working environment that is safe and healthy. Each Company member is individually responsible for working in a manner which protects human health, safety and environment.

To succeed in our mission our Top Management has undertaken the responsibility and commitment to:

• Establish, maintain, monitor, review and continuously improve operating procedures that ensure the safety of our daily operations in all fields
• Establish, Promote, Monitor and Review Health Safety and Environmental performance standards – targets. Benchmark our performance against our competitors
• Identify and adopt Best Industry Practices as mandatory requirements
• Assess continuously all identified risks for the Personnel, the Environment and the Ship as property and counteract establishing safeguards
• Provide adequate resources to maintain a safe and pleasant working environment for all personnel
• Lead by Example and motivate Personnel to promote Health Safety and Environmental protection practices
• Train and Educate all personnel in excess of the Industry mandatory standards
• Be prepared for emergencies by conducting frequent drills and continuous training
• Adopt and implement a “Just Culture” and “No Retaliation” policies for those voluntarily reporting Incidents and Near Miss Incidents. The same stands for personal complaints of any kind.
• Adopt and implement ‘Zero Tolerance Policy’ for deliberate violations of National or International regulations or the company’s internal procedures. The same stands for acts of retaliation against those reporting such violations
• Cooperate in full with any Authority investigating Incidents or Violations of any kind
• Prohibit any discrimination against employees because of the individual’s race, color, religion, gender, sexual orientation, national origin, age, disability, or any other characteristic protected by law
• Always conduct business in compliance with all laws and trade restrictions imposed by United Nations, United States, European Union and other national and supranational authorities and legislators

To implement this policy, Alberta Shipmanagement Ltd. operates and maintains a Management System, in accordance with the requirements of the ISM Code & ISO 14001:2015.

Alberta Shipmanagement Ltd. is committed to provide safe and environmentally friendly sea transportation services of the highest quality and focus on working with reputable Companies who control cargoes and cooperate according to Alberta’s standards.

Alberta’s philosophy and business strategy are focused on modern and efficient vessels operated with sophisticated management systems, having safe operations at the core of all our activities.

Health, safety, environmental and security excellence are our prime operational targets and have officially set the following long-term aspirations and targets:

• Zero incidents
• Zero accidents
• Zero spills or releases to the environment
• Zero customer complaints
• Operations at a stage of excellence

Alberta Shipmanagement is committed to provide world-class sea transportation of goods that meet or exceed safety, environmental and customer requirements and its employees with a working environment that is safe and healthy. Each Company member is individually responsible for working in a manner which protects human health, safety, and environment.

It is the Company policy to promote safety at sea and in the workplace and to avoid damage to the environment. Equally, the health of Company’s employees is a top priority, seeking to ensure that all employees execute their work under healthy and hygienic conditions.

With the aim to comply with this Policy, the Company spares no effort to identify, manage and eliminate the risks and hazards associated with its activities.

Company’s principal objectives are to:

• Prevent pollution of the Environmental, eliminate injuries and illness to its employees by ensuring implementation of the health, safety and environmental procedures, rules and regulations through review, auditing, and training. Zero Accidents, Zero Incidents, Zero Spills, or releases to the environment.
• Have a positive social and environmental impact through eco-efficiency, responsible sourcing, working conditions as per Regulatory Standards, gender balance, social equity, human rights, employee and community relations and anti-corruption measures.
• Maintain the highest technical, operational and health standards.
• Fulfil contractual requirements and meet customers expectations.

For accomplishing the above objectives, the Company:

• has developed and established an HSEM system which promotes safety, environmental protection, continuous improvement, and enhancement of personnel skills,
• employs personnel that have the required hard, soft skills and experience and provides continuous training,
• abides by all applicable legal and regulatory requirements, mandatory rules and regulations, codes, guidelines, and standards recommended by the Company, classification societies and maritime industry organizations as same may be related to safety, occupational health, and environmental protection,
• regularly reviews, amends, and updates its policies and procedures to ensure suitability and efficiency,
• has established safeguards against identified risks, unsafe conditions, and practices,
• maintains emergency response procedures and conducts regular drills to ensure emergency preparedness,
• benchmarks its performance and takes corrective actions when necessary,
• adopts new technologies consistent with its strategic goals and its commitment to protect the environment.
• Communicate this Policy to all Company personnel and the interested public

To maintain an alcohol and drug free working environment:

• We have adopted a ZERO ALCOHOL No alcohol will be supplied or allowed on board.
• No Company personnel shall undertake his / her duties whilst under the influence of drugs or alcohol.
• Alcohol max blood content is set as 40mg/100ml for people off duty and 0mg/100ml for people on or about to take over duty. Anything above these values will be considered as intentional –serious- violation of Company’s policy.
• Misuse of legitimate drugs or the use, possession, distribution, or sale of un-prescribed drugs is strictly forbidden.
• The Master is responsible for enforcing the company’s Drug and Alcohol policy onboard and he must ensure that all crew members are fully aware of and understand the company’s Drug and Alcohol policy.
• The company is responsible for reporting any possession/use of illegal or misuse of legal (un-prescribed) drugs to the local authorities and / or to the Flag state and will fully cooperate in any investigation concerning alcohol or drugs on board our ships.
• It is everybody’s responsibility to immediately report violations to the management onboard or ashore;
• Crew members are only allowed to receive non-alcoholic beverages during their service onboard;
• Flag, Port or Customer requirements exceeding this policy shall be taken into consideration. OCIMF guidelines for control of D & A onboard are recognized as a part of the Company policy.
• During port stay, the consumption of alcohol 4 hours’ prior his scheduled watch/duty is prohibited.
• Any misconception of the level of alcohol concentration does not exclude disciplinary and legal action;
• Disciplinary action up to and including dismissal in case of non-compliance with this policy;
• D&A tests are to be carried out in accordance with tests procedures as these described in VOP-G-6.
• Personnel on prescribed drugs must declare this to the Master on joining the vessel, or upon prescription if prescribed during the period of service onboard. The Master should report to the Company respectively.

Stop- Work Authority is granted to all Alberta’s Shipmanagement Ltd. Employees, contractors and guests to suspend individual tasks or group operations when there is an imminent danger (i.e. any condition or behaviour that could reasonably be expected to cause death or serious injury, or environmental harm). It is our Policy that:

• All team members have the authority and responsibility to stop any task or operation where concerns or questions regarding the control of the Health, Safety or Environmental risk
• No work will resume until all stop-work issues and concerns have been effectively and appropriately addressed by the responsible officer.
• Any form of retribution or intimidation directed at any member for exercising their outlined in this policy, will not be tolerated.

Situations that require STOP Work Authority to be implemented are:

• A change: a modification or alteration that deviates from the way the assigned task is normally performed or may cause unsafe work actions or conditions
• An unplanned event: an unplanned event that distracts crew from the assigned task being performed which may cause unsafe work actions or conditions.
• An observation with Health, Safety and Environmental impact: Whenever it is observed a condition or situation that has an impact on health, safety and environment.
• An incomplete understanding: Whenever a crew does not completely understand instructions, procedures or on-going activities.
• New hazards observed or arise unexpectedly: Whenever a risk is encountered that have not been addressed during pre-job briefing, job hazard analysis or Risk assessment.
• A need to ask for support/ assistance: whenever a job requires additional people, or the experience level of the person performing the assigned task requires support, an unsafe work action or condition may occur.

The Stop-Work Authority process involves a Stop, Notify & Investigate, Correct, Communicate, Re-evaluate, Investigate, Share Lessons Learnt and Resume approach for the resolution of a perceived unsafe condition, act, error, omission or lack of understanding that could result in uncontrolled Health, Safety and Environmental risks. All employees and contractors have the authority and obligation to stop any task or operations where concerns or questions regarding the control of Health, Safety and Environmental risks exist.

Alberta Shipmanagement Ltd. is committed to the protection of the environment and will strive for continual performance improvement to every aspect, including pollution prevention.

The Company’s Environmental Campaign emphasizes source reduction, including funding and human resources necessary to effectively maintain and repair the systems, equipment and components found in machinery and cargo (deck) spaces of the vessels.

The Company’s policy is to manage and operate vessels so as to avoid damage to the environment and to achieve Zero-Spills or releases to the environment and Zero Incidents.

Alberta Shipmanagement Ltd. is committed to:

• Ensure compliance with the applicable rules, regulations, standards and other requirements.
• Provide all necessary resources required to achieve all environmental objectives and the goals set forth in this policy.
• Constantly strive to minimize its environmental impact through comprehensive environmental protection programs and practices.
• Ensure continuous improvement in environmental performance.

The Company’s Management:

• Is totally committed to improve environmental standards.
• Will actively encourage and promote the demanded levels of awareness.
• Will respond positively to recommendations from both shore and sea staffs that propose changes in policy, practices or equipment necessary to improve standards.

Furthermore:

• All incidents concerning an environmental impact (or potential impact) will be immediately investigated and recommendations communicated through line management and the DPA.
• Alberta Shipmanagement Ltd. has a strict policy against incentive or bonus programs based on minimizing operational costs associated with the operation, maintenance and repair of systems, equipment and components without ensuring that efficiency and performance is maintained at the highest level. Employees must not sacrifice environmental compliance to save costs.
• Failure to notify the Company of a violation of the Environmental Campaign, or other Environmental protection law or requirement constitutes grounds for discipline and / or dismissal.
• Consequences for failure to comply with the Company’s operating procedures and this Policy include termination of employment and liability for criminal, civil, and administrative penalties resulting from such non-compliance.
• Company’s personnel ashore and aboard, must NOT retaliate against a subordinate, co-worker, employee, or crew member for their reporting of any violation of this Policy. Failure to comply with this policy will subject to disciplinary action up to and including termination of services.

Alberta Shipmanagement Ltd. Is committed to conduct its business in a responsible and lawful manner with respect for the wider economic, social, and environmental impact of its activities, respecting the following principles:

• Being committed to ethical, honest, transparent and sound Business Conduct, by applying high standards of legal and moral ethics, to the best interest of all our Stakeholders, while at the same time protecting information that may be of value to the Company.
• Support of free enterprise and competition in a fair and ethical manner.
• Respect of national and international human and labour rights as set forth in the United Nations Universal Declaration of Human Rights, ILO Conventions, IMO Conventions and MLC 2006.
• Make sure that Alberta Shipmanagement Ltd does not take part in children’s exploitation and will not tolerate the use of child or forced labour, nor exploitation of children in any of its operations.
• No discrimination based on race, colour, religion, gender, age, national origin, sexual orientation or any other characteristics protected by applicable laws regarding recruitment, development and advancement of employees.
• Building a diverse and inclusive workplace that values differences, respect human rights, provides equal opportunities and treats all employees fairly.
• Protecting the Health and Safety of Alberta’s employees and contractors and preventing incidents through carefully planning operations, identifying potential hazards, and managing risks.
• Respect, consider and respond to the interests of the Company’s stakeholders and employees.
• Transparency and accountability for the organization’s impact on society and the environment.
• Operating responsibly towards the society and the environment.
• Committed to drive continual improvement in Health & Safety, Human & Labour rights and Environment while adhering to the principle of respect for the rule of law
• Operating in a manner that complies with applicable laws and is consistent with the international norms of behaviours.
• Integrating sustainability throughout the Company and practicing it in relationships that are within the Company’s control or sphere of influence.

Social responsibility encompasses our Company’s responsibility for the impact of our activities and decisions on the environment, society, and the economy. As such, our social responsibility is the Company’s contribution to sustainability. Sustainability is the capability of the Company to transparently manage its responsibilities for environmental stewardship, social well-being, and economic shared value.

Our commitment to Social responsibility is embedded to our Company by making sustainability and the responsibilities associated with sustainability, part of the daily work instructions and operational control of everyone in Alberta Shipmanagement Ltd.

We aim to integrate sustainable thinking and corporate social responsibility into all our business process and business relationships.

We recognize that our operations have a global influence, as such we work diligently with our employees, local communities, and internationally recognized bodies to ensure that sustainable and responsible approach is inherent in our purpose.

Alberta Shipmanagement Ltd. Is committed to conduct its business in an ethical and honest manner, and is committed to achieving the highest standards of ethical conduct and professional integrity and to implementing and enforcing systems that ensure bribery and corruption is prevented. The Company has zero-tolerance for bribery and corruption.

Alberta Shipmanagement is committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever it operates.

This anti-bribery and anti-corruption policy apply to all employees at any level, consultants, contractors, trainees, seconded staff, agents and any other persons associated with the Company.

Any arrangements the Company makes with a Third Party, is subject to clear Contractual Terms, including specific provisions that require Third Party to comply with minimum standards and procedures relating to anti-bribery and corruption.

Bribery refers to the illegal act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage, in order to induce or influence an action or decision.
Corruption is the abuse of entrusted power for private gain.

Gifts and Hospitality: The Company will accept appropriate gestures of hospitality and goodwill as long as the offered gift meets the following requirements:

• It is not made with the intention of influencing an action or decision, to obtain or reward the retention of a business or a business advantage.
• Is not made with the expectation of a return-favour.
• It is in compliance with Local Law.
• It is given in the name of the Company, not the Individual’s name
• It does not include cash or cash equivalent ( i.e vouchers)
• It is appropriate for the circumstances (i.e small gifts around Christmas) but of not excessive value.
• It is given and received openly, not secretly
• It is not selectively given to Key & influential Persons of the Company, clearly with the intention of directly influencing them.

The intention behind the gift being given /received should always be considered.
Where it is inappropriate to decline the offer of a gift (i.e when meeting with an individual of a certain religion/culture who may feel offended by the decline) the gift may be accepted, as long as this is declared to the Managing Director.

Facilitation Payments: The Company does not accept and will not make any facilitation payments with the purpose of expediting routine governmental actions.
Political Contributions: The Company will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates since such donations may be perceived as an attempt to gain an improper business advantage.

Charitable Contributions: The Company accepts and encourages the act of donating to charities – whether through services, knowledge, time, or direct financial contributions– and agrees to disclose all charitable contributions it makes, as long as it ensured that they are not used to facilitate and conceal acts of bribery.

Employee Responsibilities
All Company Employees are equally responsible for the prevention, detection and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to or imply a breach of this anti-bribery policy. If any employee has reason to believe or suspect that an instance of bribery or corruption has occurred or is about to occur, he/she should report it at once to the Company. The Company reserves the right to terminate a contractual relationship with an employee if this Policy is breached.

1. Field of Scope

This privacy notice lays out the way “ALBERTA SHIPMANAGEMENT LTD” (hereinafter referred to as “ALBERTA SHIPMANAGEMENT LTD” or “the Company”) collects, uses, processes, stores, manages, and protects the personal data (hereinafter referred to as “Personal Data”), of clients, suppliers, outsourcers, sub contractors, candidate employees suppliers and website visitors, so as to meet the data protection standards of the company and comply with the applicable law. Your personal data includes any information on paper or electronic means, which may lead, either directly or in combination with other ones, to your unique identification as an individual (e.g., name, VAT number, telephone numbers, etc.), according to the provisions of the General Data Protection Regulation (GDPR 2016/679), of law 4624/2019, of the current Greek legislation as well as the orders of the Hellenic Data Protection Authority (DPA).

This privacy policy shall apply to all information (i) related to clients (hereinafter referred to as the Client”) within the framework of the Company’s business activity or business development, (ii) that relates to personal data obtained through its business relationship or provision of services with suppliers or to the market evaluation process (iii) pertaining to candidate employee data collected during the recruitment process iv) pertaining to visitors and clients of the Company’s website https://albertashipmanagement.com/ (hereinafter referred to as the “Website”) v) related to customer data obtained during the customer care process  vi) related to visitor data collected at the premises

The Company is bound to protect the privacy of visitors’/clients’/suppliers’/candidate employees’ and of other data subjects and to adhere to the local and European Data Protection legislation currently in effect, implementing the key principles of the GDPR (lawfulness, fairness and transparency, Purpose limitation, data minimisation, accuracy., storage limitation, integrity, confidentiality and accountability). The above apply without discrimination and apply to all processings we perform either independently or through our affiliates.

2. Categories & Types of Collected Data

Data Collected:

1. Candidate data evaluation process: Full name, gender, date of birth, telephone number, address, e-mail, nationality, education, working experience, desired salary,
2. Client’s data obtained through the Company’s business activity

Company name, telephone number, address, e-mail, VAT number, bank account numbers

1. Suppliers’/Third party data obtained through the Company’s business activity

Full name/Company name, telephone number, address, e-mail, VAT number, bank account numbers

1. Website visitor’s contact process

1) Cookies: data subject’s consent settings, usage data, behavior and  preferences data, browser data.

1. Visitor data (on premises) obtained through the use of CCTV / physical access control

Declaration Regarding The Processing of Personal Data By “ALBERTA SHIPMANAGEMENT”  (by its capacity as Data Controller and Processor – in accordance with the General Data Protection Regulation EU 679/2016)

Data Processing Purposes – Legal Basis For The Processing of Data

The Company’s  statutory purpose is inter alia,  the maritime transport of various cargoes.

The legal basis for the processing of personal data in this context, is the performance of the contract (e.g. ship management services), the legitimate interest of the Company (indicatively during data processing in cases of crew members & company employees) and in some cases the consent of data subjects (obtaining visitor data through the website, newsletter use).

In some cases, the Company processes personal data of customers/suppliers/employees etc. in compliance with legal obligations (such as in the case of informing authorities about payments to suppliers, customers, partners, employees etc.).

In addition, the Company may collect personal data of candidate employees who are interested in working with the Company for the sole purpose of examining the possibility of a future collaboration – employment. The legal basis for the aforementioned data collection is the consent of the data subject who provides the necessary information.

Information automatically collected when visiting and interacting in the Website:

The Company Website uses a) necessary cookies and b) statistics cookies.

For a full description of the cookies used and the type of data collected through them, please refer to section Cookies & other technologies.

The Company does not manage, collect or process geolocation data, which are collected and processed exclusively by the companies providing operating systems for each device you use (in case of use of iOS-Apple Inc or in case of android – Google Inc). The Company  does not have access to the positioning refresh rate of GPS.

3. Data Collection Points

1) Sole proprietorship companies, clients -B

2) Sole proprietorship companies -suppliers, outsourcers, subcontractors – C

3) Candidate employees -Α

4) CCTV system – Ε

5) Website – D

4. Transfer of Data to Third Parties

The Company reserves the right to disclose the data subject’s personal data to any member of its affiliate/subsidiary companies (parent company and its subsidiaries) or other third parties which in any case apply all appropriate technical, environmental, legal and administrative measures to safeguard the data from loss, unfair use, amendment, unauthorised access and transmission pursuant to Article 32 of GDPR,  to the extent it is reasonably necessary for the purposes determined in this notice and in particular:

• Data subject’s data will be transferred to the Company’s departments  that are competent for the smooth and trouble-free provision of services, the operation of the Website as well as for the provision of customer services (evaluation and management of customer complaints/requests)
• Data subject’s data may be transmitted and become accessible by legal entities (suppliers, subcontractors, etc) with which we have entered from time to time into contractual agreements for the purpose of fulfilling our company’s statutory purpose (e.g. marketing services) on the basis of our legitimate interest. Our Company selects reliable providers and we try to set contractual restrictions on third parties who receive your personal data, in order to ensure their lawful use. However, we can not guarantee that they will not use or disclose this data without your permission. For this reason, we recommend that you carefully review the privacy practices of any third party providers / products whose products or services you purchase through our websites
• In addition, our website may contain links that lead to other websites of third parties, independent entities, such as telecommunications companies, content providers, transport service providers, payment service providers, etc. which are operated and maintained solely by them, and which we do not control, as mentioned above and therefore bear absolutely no responsibility for their content, actions or policies. Please read the respective privacy policies on the websites you visit carefully, as they may differ significantly from ours
• Personal data related to the invoicing processes, may be transmitted and become accessed by bank institutions with which we cooperate in order to process our employees and suppliers payments, as well as to the competent state authorities in compliance with legal obligations. In particular, such third parties may be official state and supervisory bodies (eg prosecutors, Cybercrime Division, Data Protection Authority, Hellenic Telecommunications and Post Commission, Independent Authority for Public Revenue etc), in case we are called upon to comply with the law and prevent harm illegal actions against us and our customers (eg telecommunications fraud, insult, insult of personality, etc.)
• Data subject’s personal data may be disclosed to cloud hosting providers for the purpose of storing and safeguarding the data with the appropriate technical and security measures
• During all data transfers, we always take all appropriate measures so as to ensure that the transmitted data are the minimum required for the intended processing purpose and that the conditions for legitimate and lawful processing will always be met. Company’s partners to whom the personal data may be transferred, have signed the necessary data processing agreements or have made specific guarantees around transfers of personal data by implementing in their agreements Standard Contractual Clauses (Model Clauses).

5. Personal Data Retention Period

The data retention period depends on the lawful basis of processing, as set out in detail below:

• In case the lawful basis for processing is the exercise of legitimate interest, the processing of personal data is carried out for as long as it is considered necessary for the achievement of the intended statutory purpose of the Company  and until such time the limitation period of any related claims has expired
• In case the personal data of the Client Information are provided under their own consent such as in the case of submitting a CV or submitting a near miss form on our website, we shall retain their data until the granted consent by the data subject has been withdrawn. In case the consent is withdrawn for any valid reason, we shall retain them for as long as it is required until the limitation period of any related claims expires
• In case the lawful basis for processing is the performance of the contract, we shall retain your data for as long as you retain the contractual relationship with us in hard copy and in electronic form or we shall retain them for as long as it is required until the limitation period of any related claims expires
• In case where the processing of the personal data is based on a legal obligation (Article 6 of GDPR), the data retention period is set in accordance with the pertinent legislation and the limitation period for any inspections that may be performed by competent authorities

In any case, the exact data retention periods for each individual data processing process are recorded in the Company’s personal data retention registry in compliance with the provisions of GDPR. Additional information in relation to the exact data retention periods, may be provided by requesting access in accordance with the procedure set out in this policy

6. Rights of the Data Subjects

You may exercise, as the case may be, the rights deriving from the applicable Greek Legislation and the General Data Protection Regulation (Regulation (EU) 2016/679) which are as follows: (a. the right of information (article 13), b. the right of access (article 15), c. the right to rectification (article 16), d. the right to erasure “right to be forgotten” (article 17), e. the right to restriction of processing (article 18), f. the right to data portability (to receive your personal data in a structured and commonly used format – article 20 where applicable) and g. the right to object (article 21) which applies to certain data processing activities.

• These rights may be exercised only in cases where the Company acts as a controller, and in particular: (a) the processing of personal data of prospective employees for the purpose of assessing the likelihood of possible professional cooperation (b) the processing of personal data relating to pursuit of its intended statutory purposes (maritime service provision) (c) processing the data of suppliers/subcontractors for invoicing purposes (d) processing the personal data of Website visitors (e) the processing of data through CCTV system.
• These rights shall be exercised free of charge for you by sending a relevant letter to the Company’s Data Protection Officer (DPO): 26a Ioannou Apostolopoulou Str. 15231, Chalandri, tel: +30 2111047400 or via e-mail to: dpo@albertashipmanagement.com.

Alternatively you may submit your request in writing by sending it to complaints/customer service department: info@albertashipmanagement.com or write to: 26a Ioannou Apostolopoulou Str. 15231, Chalandri,  tel: +30 2111047400

In case however the aforementioned rights are exercised excessively and without good cause thus causing us administrative burden, we may charge you with the cost related to the exercise of the respective right

• In case you exercise any of your rights, we will take all appropriate measures available for the satisfaction of your request within thirty (30) days following the receipt of the relevant request. We may either inform you on the acceptance of your request or on any objective grounds that hinder the processing of your request.
• Notwithstanding the above, you may at any time object to the processing of your Personal Data, by withdrawing your consent (article 7, par. 3 of the GDPR 679/2016) by sending a letter to the Company’s Data Protection Officer (DPO): 26a Ioannou Apostolopoulou Str. 15231, Chalandri, tel: +30 2111047400 or via e-mail to dpo@albertashipmanagement.com. This right applies only in cases where the lawful basis for the data processing is the consent of the Data Subject.

7. Data Processing by the Company

The Company applies throughout the data processing procedure, the appropriate technical, physical, and administrative security measures for the protection and security of the personal data from loss, misuse, damage or modification, unauthorised access and disclosure, in compliance with article 32 of the GDPR 679/2016, in order to ensure the appropriate security level against those risks. Those include, among others, as the case may be: a) application of encryption protocols b) the ability to ensure confidentiality (article 90 GDPR 679/2016), integrity, availability, and resilience of processing systems and  services on an ongoing basis, c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident, d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

Moreover, the Company shall take measures so as to ensure that any natural person acting under the authority of the data controller, who has access to personal data, shall not process those data except on instructions from the data controller and limits access to your personal information to authorised employees.

Indicative security measures applied by the Company are as follows:

A. Organizational Measures

1. Company DPO appointment
2. Employee management process – assignment of roles to all individuals involved in data processing activities
3. Information system management
4. Employee training on the protection of personal data, information provided to all employees regarding the company’s policies/processes
5. Monitoring of data processors
6. Setting up of a deletion/destruction of data process
7. Monitoring of data breach incidents
8. Monitoring of controls/security measures

B. Technical Measures

1. Access controls
2. Backup data process
3. Modification of workstations
4. User log files, security incident logs
5. Communications security
6. Management and protection of portable data storage assets
7. Software and applications safeguards
8. Amendment controls

Γ. Environmental Security Measures

1. Physical access controls
2. Environmental security – protection from natural disasters
3. Document exposure to threats
4. Protection of portable data storage assets

8. Cookies

1.What is a cookie and why does the Company uses them. A cookie is a small data file, often including a unique identifier, which consists of data and numbers, which is stored in the browser (Chrome, Mozilla Firefox etc) used by the user/client, allowing among other things the more efficient operation of the website. Cookies do not in any way harm users’ computers or files stored on them. The information stored in cookies is used for identification purposes. This is how we manage to operate the Website efficiently.

2. Under no circumstances do the cookies store personal information or information which will allow any third party to contact the Website’s visitor through telephone, via e-mail etc. In addition the use of cookies does not allow access to your computer files or documents.

3.What cookies do we use? The cookies described below may be stored in your browser. You can view and manage cookies in your browser (however mobile browsers may not offer this visibility). Of the different types of cookies available, the Company uses the following:

4. The essential cookies are of primary importance for the proper operation of the Website, as they allow you to browse it and make use of its functions. These cookies do not reveal your identity. Without these cookies, we cannot properly operate the Website
5. As long as the user/client accepts the use of cookies, the above described statistical analysis cookies will be activated. Mandatory acceptance of cookies is not a condition for entering our website. You may, in any case, navigate freely by checking and accepting or not the cookies, either ours or those of third parties, the use policy of which is determined exclusively by them, without our involvement and legal responsibility.
6. In case you do not wish to use cookies: You may deactivate or delete cookies used by the company through the settings menu of your browser. For instance if you are using chrome, you may choose “Menu/Settings/Privacy/Content Settings” and opt to configure your cookie settings in accordance with your preferences.
7. You may also refer to the webpage www.allaboutcookies.org/ manage-cookies / index.html for all information related to the most frequently used browsers. Please be advised that in case you opt to deactivate cookies, certain Website applications may not function as intended
8. The Website software is designed to ensure the highest level of security and trust. All information contained in requests submitted through the Website is equally secure and confidential. Only authorized personnel who are trained in the handling of Client / Visitor personal data will have access to this information and only when necessary for the purposes of servicing them or performing contractual obligations.

9. Submission of Complaint – Appeal

• For any issue regarding the processing of your personal data, you may contact us via e-mail at dpo@albertashipmanagement.com.
• Moreover, you shall always be entitled to contact the Hellenic Data Protection Authority, which may accept the submission of relevant complaints in writing at its protocol in its offices at 1-3, Kifisias Street, Postal Code 115 23, Athens or by e-mail (complaints@dpa.gr) in accordance with the instructions indicated on its website.

10. Amendments

This policy may be renewed from time to time, due to amendments to the related legislation or change to the Company’s corporate structure. Thereby, we encourage the Clients to periodically visit this site so as to be informed regarding recent information of privacy practices. In any case, the Clients may be informed via email or a notice in our Website regarding any amendments to this policy.

1.1 Scope

This policy applies to all Alberta Shipmanagement systems, people and processes, including board members, directors, employees, contractors and other third parties who have access to Alberta Shipmanagement information systems.

1.2 Policy

Alberta Shipmanagement has adopted the Information Security Policy and is committed for the effective implementation and provision of resources for the improvement of the Information Security Management System (ISMS).

• The Information Security Policy aims to ensure:
  – Continuous protection of information against unauthorized access.
  – Continuously ensuring the confidentiality of Alberta Shipmanagement’s information, clients and partners.
  – Continuously maintaining the integrity of Alberta Shipmanagement’s information, clients and partners.
  – Continuous assurance of the availability of information and business transactions.
  – Monitoring and compliance with the legislative and regulatory requirements concerning Alberta Shipmanagement.
  – The Business Continuity Plan is maintained and tested for its effectiveness.
  – Adequate training of the Alberta Shipmanagement employees in information security issues.
  – Confirmed or suspected information security breaches are reported to the Information Security Officer and are thoroughly investigated and dealt in time and effectively.
• Appropriate procedures and information security policies are in place to support the Information Security Policy, including technical and organizational measures of protection.
• Compliance with the legislation and requirements of ISO 27001: 2022 is ensured and with the ongoing monitoring of the implementation of the ISMS.
• The Information Security Officer is responsible for maintaining the Information Security Policy and for providing support and advice in its implementation.
• Alberta Shipmanagement’s top management is responsible for the implementation of the Information Security Policy as well as for ensuring the compliance of the supervised personnel.
• Compliance with the Information Security Policy is mandatory for all parties that have been or are cooperating with Alberta Shipmanagement.
• Any violations of the Information Security Policy are subject to disciplinary actions. The decision depends on the nature and impact of the violation.

The Alberta Shipmanagement Top Management approves the development and documentation of analytical procedures and the creation of the necessary infrastructure to ensure the continuity of business operations through an organized and integrated Business Continuity Management System (BCMS) in the event of a downtime of Alberta Shipmanagement Information Systems and business processes.

The Alberta Shipmanagement Top Management provides the necessary resources for the development, implementation and maintenance of the BCMS. The BCMS covers all necessary and critical operations of Alberta Shipmanagement.

Alberta Shipmanagement maintains a Business Continuity Strategy in order to ensure that its services both to its external and internal customers are offered uninterruptedly.
For the proper design, implementation and maintenance of the BCMS, the Alberta Shipmanagement Top Management is committed to conduct Business Impact Analysis and Risk Analysis with the aim of identifying and analyzing the processes/services, assets/subsystems of Information Systems, their criticality, and the assessment of the consequences (e.g. operational impacts) of any business process downtime.

The BCMS must be periodically tested in a simulation environment to ensure that it can be implemented in case of emergency and that management and all Alberta Shipmanagement employees will understand how to implement it.

Appropriate processes are in place for monitoring and compliance with the applicable legislative and regulatory requirements.

Business Continuity objectives are established, monitored, communicated, reviewed and updated as appropriate in order to ensure BCMS effectiveness and its continuous improvement.

All personnel will be aware of the BCMS and their respective duties on it.

The BCMS must be reviewed and renewed to take account of changing circumstances.