Privacy Policy
This Privacy Policy explains what personal data SP SEA-CREW may receive when you use the website, submit a CV, complete a form or contact the Company, why such data is processed, to whom it may be disclosed and what rights may be available to you.
Effective date: . Last updated: .
1. General provisions
This Privacy Policy describes how personal data may be collected, received, used, verified, organised, stored, disclosed, protected, deleted and otherwise processed when using spsea-crew.global .
This Policy applies to website visitors, candidates for maritime vacancies, seafarers, representatives of employers, shipowners, vessel operators, partners, service providers and other persons interacting with the Company.
The personal data controller is SP SEA-CREW, a Free Zone Company registered in the United Arab Emirates, registration number JLT4922, licence number JLT-68458, registered address: Unit 2106, Fortune Tower, Plot No. JLT-PH1-C1A, Jumeirah Lakes Towers, Dubai, UAE, hereinafter referred to as the “Company”, “we”, “us” or “our”.
By using the website, submitting a CV, questionnaire, document, message or other enquiry, the User confirms that they have reviewed this Policy and understand how their personal data may be processed.
2. Applicable law and scope
Personal data is processed in accordance with applicable laws relating to personal data protection, privacy, electronic communications and information security.
Depending on the location of the User, the recipient of the data or the nature of the processing, the requirements of the laws of the United Arab Emirates, the European Union and other relevant jurisdictions may apply.
This Policy applies only to processing carried out by the Company. Independent third-party organisations process personal data in accordance with their own privacy policies.
3. Personal data processing principles
When processing personal data, the Company seeks to observe the following principles:
- lawfulness, fairness and transparency;
- collection and use of data for specified and lawful purposes;
- limitation of the amount of data to what is reasonably necessary;
- maintenance of accurate and current information;
- limitation of retention periods;
- confidentiality and security;
- prevention of use that is incompatible with the original purpose;
- provision of information to Users about how their data is processed.
4. Personal data we may receive
The categories of data received depend on how the User interacts with the Company and the nature of the relevant enquiry.
4.1. Identification data
- surname, first name and middle name, where applicable;
- date and place of birth;
- age;
- gender, where objectively necessary for a particular procedure;
- nationality;
- photograph;
- signature;
- identification or tax number;
- other identification information provided by the individual.
4.2. Contact data
- telephone number;
- email address;
- residential or temporary address;
- country and city of residence or current location;
- messenger contact details;
- preferred method of communication.
4.3. Professional seafarer data
- current or desired position;
- professional specialisation;
- education and qualification details;
- sea-service experience;
- information about previous contracts;
- vessel names and types;
- information about previous employers and shipowners;
- sign-on and sign-off dates;
- information about duties performed;
- professional references;
- interview and professional assessment results;
- English and other language proficiency;
- availability to join a vessel;
- expected contract period and duration;
- expected remuneration;
- other information included in a CV or questionnaire.
4.4. Document data
To assess qualifications, identify suitable vacancies and prepare for possible employment, the Company may receive information from and copies of:
- a national passport or other identity document;
- an international passport;
- a seafarer’s identity document;
- a seaman’s book or sea-service record book;
- certificates of competency and related endorsements;
- educational diplomas and academic transcripts;
- professional certificates;
- flag-state documents;
- visas and permits;
- medical certificates;
- vaccination certificates where required for a specific procedure;
- references, confirmations and other professional documents.
The Company does not request original documents through general website forms. Original documents may be provided only under a separately agreed and verified procedure.
4.5. Health data
To assess professional fitness for work at sea, the Company may receive limited health-related information, including:
- confirmation that a medical examination has been completed;
- the expiry date of a medical certificate;
- a fitness-for-duty conclusion or information about restrictions;
- other information that is objectively necessary for a specific vacancy, required by law or voluntarily provided by the User.
Health data is processed only to the extent necessary for a lawful purpose and is subject to enhanced confidentiality measures.
4.6. Travel and mobility data
- eligibility to cross international borders;
- visa or immigration status;
- current country and city;
- preferred or available departure airport;
- information required for travel and transfer arrangements;
- route and expected travel dates;
- availability to travel.
4.7. Interaction data
- the content of enquiries and correspondence;
- the date and time of communications;
- the status of a candidate’s application;
- the history of vacancies proposed;
- responses received from employers and shipowners;
- information about scheduled interviews;
- records of consent given and withdrawn;
- complaints, requests and the results of their review.
4.8. Payment and contractual data
Where a person orders a separate paid service, the Company may process:
- agreement or order details;
- the amount, date and purpose of a payment;
- an invoice or payment document number;
- payer and recipient information;
- information required for contractual, accounting and tax records.
The Company does not request and should not receive bank card PINs, CVV or CVC codes, banking application passwords or one-time banking verification codes.
4.9. Technical data
When the website is used, the following information may be processed automatically:
- IP address;
- date and time of the visit;
- device type;
- operating system;
- browser type and version;
- browser language;
- website sections and pages visited;
- the source from which the User reached the website;
- technical logs and error messages;
- cookies and similar identifiers.
4.10. Data contained in fraud reports
When a report of suspected fraud is received, the Company may process:
- the reporting person’s contact details;
- screenshots of correspondence;
- telephone numbers and email addresses;
- links to profiles and websites;
- payment details of the suspected recipient;
- copies of suspicious documents;
- other information required to review the report.
5. Sources of personal data
Personal data may be received:
- directly from the User;
- through forms available on the website;
- from CVs, questionnaires, documents and messages;
- during telephone calls, interviews and correspondence;
- from employers, shipowners, vessel operators, crewing partners or previous employers;
- from professional references;
- from official government or professional registers;
- from publicly available sources where such use is lawful;
- automatically when the website is used;
- from another person who has a lawful right to provide the relevant information.
Where a User provides another person’s data, the User confirms that there is a lawful basis for doing so and must inform that person about this Policy.
6. Purposes of processing
The Company may process personal data for the following purposes:
- identifying the User;
- receiving and reviewing CVs, questionnaires and applications;
- creating and maintaining a candidate’s professional profile;
- identifying vacancies that correspond to the candidate’s qualifications;
- assessing education, experience, documents and professional suitability;
- verifying the validity of documents and certificates;
- verifying references and previous employment experience;
- arranging interviews and professional assessments;
- presenting a candidate to a potential employer;
- communicating with shipowners, vessel operators, employers and crewing partners;
- taking steps before entering into a possible agreement;
- arranging joining, travel, transfers or crew changes;
- coordinating medical examinations, professional training or required documentation;
- providing information about current and future vacancies;
- responding to enquiries;
- maintaining contractual, accounting and tax records;
- complying with applicable legal requirements;
- protecting the website and information systems;
- preventing fraud and misuse;
- handling complaints, claims and disputes;
- protecting the rights and lawful interests of the Company and other persons;
- analysing and improving the website;
- producing anonymised statistics that do not identify a particular person.
7. Processing CVs and professional profiles
CVs, questionnaires and professional documents are used to assess a candidate’s suitability for current or future vacancies.
Submitting a CV or creating a professional profile:
- does not guarantee employment;
- does not guarantee an invitation to an interview;
- does not guarantee approval by an employer or shipowner;
- does not automatically result in the conclusion of an agreement;
- does not guarantee joining a particular vessel;
- does not guarantee that a vacancy or previously proposed contract conditions will remain available.
To keep a professional profile current, the candidate should inform the Company of any change to contact details, position, qualifications, experience, availability or document validity.
8. Legal bases for processing
Depending on the circumstances, personal data may be processed on the basis of:
- the User’s consent;
- the need to take steps at the User’s request before entering into an agreement;
- the need to enter into or perform an agreement;
- compliance with a legal obligation of the Company;
- the legitimate interests of the Company or a third party, provided that the User’s rights and interests do not override those interests;
- protection of a person’s vital interests;
- another lawful basis recognised by applicable law.
Where processing is based on consent, the User may withdraw that consent. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
9. Processing special categories of data
Health information and other data requiring enhanced protection are processed only:
- with the User’s appropriate consent;
- for the assessment of professional fitness for work;
- to comply with applicable maritime, employment or immigration requirements;
- to protect vital interests;
- in other circumstances expressly permitted by law.
The User should not submit detailed medical diagnoses or excessive medical information unless it has been reasonably requested for a specific purpose.
10. Mandatory and voluntary data
Providing most personal data through the website is voluntary. However, without certain information, the Company may be unable to:
- identify the candidate;
- review a CV or questionnaire;
- assess suitability for a vacancy;
- verify professional documents;
- present the candidate to an employer;
- prepare or perform an agreement;
- respond to an enquiry.
Mandatory fields may be marked separately in website forms.
11. Verification of data accuracy
The Company may verify information provided in a CV, questionnaire or document through:
- official registers;
- educational institutions;
- certification and medical organisations;
- previous employers;
- shipowners and vessel operators;
- crewing partners;
- government and professional organisations;
- other lawful and reliable sources.
Submission of forged documents or knowingly inaccurate information may result in termination of the candidate review and other consequences permitted by law.
12. Recipients of personal data
Within the purposes described in this Policy, personal data may be made available to:
- authorised employees and representatives of the Company;
- potential employers;
- shipowners;
- shipping companies;
- vessel operators and technical managers;
- crewing and recruitment partners;
- port and agency companies;
- maritime training and simulator centres;
- medical institutions;
- visa and immigration service providers;
- transport companies, airlines and travel agencies;
- insurance companies;
- banks and payment service providers;
- hosting, email and cloud service providers;
- software and technical support providers;
- lawyers, auditors, accountants and other advisers;
- government authorities and courts where required by law;
- other persons where disclosure is necessary for a lawful purpose and has an appropriate legal basis.
Each recipient is provided only with the amount of data reasonably necessary to perform the relevant task.
13. Disclosure of a candidate profile to an employer
To enable a candidate to participate in a selection process, their CV, questionnaire, professional documents and other necessary information may be provided to a potential employer, shipowner, vessel operator or authorised crewing partner.
The information disclosed may include:
- identification and contact details;
- position, qualifications and experience;
- sea-service history;
- copies of professional documents;
- interview and assessment results;
- professional references;
- availability to join a vessel;
- medical fitness information to the extent necessary and lawful.
Where a candidate does not wish their profile to be considered for a specific vacancy or disclosed to a particular employer, they should notify the Company before the disclosure takes place.
14. International transfers of personal data
The maritime industry and seafarer employment are international in nature. Employers, shipowners, vessel operators, agents, educational institutions and other recipients may be located in different countries.
Personal data may therefore be transferred to and processed outside the United Arab Emirates or the country in which the User is located.
The level of legal protection in another country may differ from the protection available in the User’s country.
When transferring data internationally, the Company seeks to:
- verify that the transfer is necessary;
- limit the information transferred to what is reasonably required;
- use appropriate contractual and organisational safeguards;
- take account of the requirements of the relevant jurisdictions;
- apply other appropriate safeguards where required in a particular case.
15. Service providers
To operate the website and conduct its activities, the Company may use providers of:
- hosting and domain services;
- email services;
- cloud storage;
- CRM and candidate-management systems;
- online forms and communication tools;
- spam and cyberattack protection;
- website analytics;
- data backup;
- technical support;
- payment and accounting services.
Such providers may process data only within the authority granted to them, the relevant contractual terms and the applicable lawful purpose.
16. Retention periods
Personal data is retained only for as long as reasonably necessary for the purposes of processing, performance of agreements, compliance with legal requirements and protection of the rights of the Company or other persons.
Unless another period is required by law, an agreement or a justified need, the following indicative periods may apply:
- CVs, questionnaires and professional profiles: up to five years after the last substantive contact, profile update or end of cooperation;
- information submitted for a specific vacancy: for the duration of the selection process and up to three years after it ends;
- correspondence and enquiries: up to three years after the communication ends;
- contract and employment information: during the period of cooperation and up to five years after it ends;
- accounting, tax and payment records: for the periods required by applicable law;
- consent records and records of rights requests: up to five years after the relevant processing ends;
- fraud reports and investigation materials: up to five years after the investigation ends;
- technical security logs: generally up to twelve months;
- backup copies: until scheduled overwriting or deletion under the applicable backup cycle.
Data may be retained for a longer period where necessary:
- to comply with a legal requirement;
- to handle a dispute or claim;
- to protect rights in court or other proceedings;
- to investigate fraud or an information-security incident;
- to comply with a request from a competent authority;
- where another lawful basis exists.
At the end of the retention period, data is deleted, destroyed, anonymised or archived with restricted access.
17. Accuracy of personal data
The User must provide accurate and current information and promptly notify the Company of changes to:
- telephone number or email address;
- position or qualifications;
- sea-service experience;
- availability for work;
- document validity periods;
- visa or immigration status;
- other material professional information.
The Company is not responsible for consequences caused by outdated or inaccurate information provided by the User.
18. Protection of personal data
To protect personal data, the Company may use:
- access controls;
- passwords and multi-factor authentication;
- secure information transfer;
- data backups;
- antivirus and network-security measures;
- security event logging;
- restricted access to documents;
- training for employees and representatives;
- contractual confidentiality obligations;
- information-security incident response procedures;
- other reasonable organisational and technical measures.
However, no method of transmitting or storing information can provide absolute security.
19. User security responsibilities
Users are advised to:
- verify the recipient’s address before sending documents;
- use strong and unique passwords;
- enable two-factor authentication;
- never disclose passwords or verification codes;
- avoid publishing personal documents in public sources;
- avoid using publicly accessible links without access restrictions;
- notify the Company of suspicious communications;
- immediately change passwords where unauthorised access is suspected.
20. User rights
Subject to applicable law, the User may have the right to:
- receive information about the sources from which data was collected;
- receive information about the data controller;
- understand the purposes and methods of processing;
- receive information about categories of recipients;
- request access to their personal data;
- request correction of inaccurate or outdated data;
- request deletion where a lawful basis for deletion exists;
- request restriction of processing in relevant circumstances;
- object to certain types of processing;
- withdraw consent previously provided;
- receive a copy of the data provided, where required by law;
- submit a complaint to a competent supervisory authority;
- apply to a court;
- protect their rights by other lawful means.
Certain rights may be restricted where continued processing is required to comply with a legal obligation, preserve evidence, protect rights in a dispute, prevent fraud or satisfy another lawful basis.
21. Submitting a personal data request
A request for access, correction, deletion, restriction, withdrawal of consent or exercise of another right may be sent:
- by email to office@spsea-crew.global ;
- by post to the registered address: Unit 2106, Fortune Tower, Plot No. JLT-PH1-C1A, Jumeirah Lakes Towers, Dubai, UAE.
The recommended email subject is: “Personal Data Request”.
The request should include:
- the User’s full name;
- contact details;
- the nature and purpose of the request;
- information enabling the Company to locate the relevant data or professional profile;
- information reasonably necessary to verify the identity of the requesting person.
To protect personal data from unauthorised access, the Company may verify the identity of the requesting person and request additional supporting information.
Requests will be handled within the periods required by applicable law.
22. Deletion of a professional profile
A candidate may request that the Company stop actively searching for vacancies, delete their professional profile or restrict its further use.
After receiving such a request, the Company:
- verifies the identity of the requesting person;
- stops using the profile for new vacancy searches;
- deletes or restricts the data where there is no lawful basis for continued retention;
- may retain a minimum amount of information required to confirm compliance with the request or protect lawful rights.
Deletion from active systems may not result in immediate deletion from backup copies. Data contained in backups is deleted in accordance with the applicable overwrite cycle and should not be used in ordinary business activities.
23. Withdrawal of consent
Where processing is based on consent, the User may withdraw it by contacting office@spsea-crew.global .
After withdrawal, processing that depends exclusively on that consent will stop unless another lawful basis exists.
24. Vacancy notifications and communications
The Company may send messages concerning vacancies, application status, documents, interviews and other matters related to the User’s enquiry or professional profile.
Optional information and marketing communications are sent only where an appropriate legal basis exists.
The User may opt out of optional communications:
- by using an unsubscribe option in the message, where available;
- by sending a request to office@spsea-crew.global ;
- by notifying a representative of the Company.
Opting out of marketing communications does not prevent the Company from sending essential messages relating to an active application, security or performance of an agreement.
25. Automated decision-making
The Company may use search, filtering and preliminary matching tools to compare professional profiles with vacancy requirements.
Such tools may take into account:
- position;
- vessel types;
- professional experience;
- document validity periods;
- English-language proficiency;
- availability to join;
- other professional vacancy criteria.
The final employment decision is normally made by the employer, shipowner or another authorised person and not solely by an automated system.
26. Cookies
The website may use cookies and similar technologies. Cookies are small technical files or identifiers stored on the User’s device or transmitted by the browser.
26.1. Essential cookies
Essential cookies support basic website operation, security, preference storage and form functionality. Without them, certain website functions may not operate correctly.
26.2. Functional cookies
Functional cookies help retain the selected language and other User preferences.
26.3. Analytics cookies
Analytics cookies may be used to assess traffic, referral sources, page popularity and technical website performance where the relevant tools are actually enabled.
26.4. Marketing cookies
Marketing cookies may be used to assess the effectiveness of advertising campaigns and display relevant communications only where such tools are actually enabled and an appropriate legal basis exists.
27. Platforms and third-party services
The website may use:
- the Tilda Publishing platform, its technical infrastructure, content-delivery network and standard forms;
- tools used to protect forms against automated spam and technical misuse;
- the embedded GLOAP maritime vacancy catalogue on the vacancies page;
- email and cloud services required to process enquiries;
- analytics and advertising tools only where they are actually enabled on the website.
When embedded third-party content is opened, the relevant platform may independently receive technical information about the User in accordance with its own privacy policy.
28. Managing cookies
The User may:
- accept or reject non-essential cookies through the website interface where such a tool is available;
- change cookie settings in their browser;
- delete previously stored cookies;
- fully or partially prevent the storage of cookies;
- use the privacy settings of the relevant third-party service.
Disabling essential or functional cookies may affect the correct operation of the website and certain forms.
29. Third-party websites and resources
The website may contain links to resources operated by:
- employers and shipowners;
- government authorities;
- educational and medical institutions;
- social media and messenger platforms;
- mapping services;
- payment systems;
- other third parties.
Third-party resources have their own privacy policies. The Company does not determine how independent third-party resources process personal data.
Before submitting information to a third-party website, the User should review its privacy policy.
30. Social media and messenger platforms
When interacting with the Company through a social network or messenger platform, that platform may independently process:
- profile information;
- account identifiers;
- contact information;
- message content;
- technical data relating to the device and interaction.
Such processing is governed by the rules and privacy policy of the relevant platform.
31. Data relating to minors
The website and services related to independent maritime employment are not intended for persons below the age required by applicable law.
Where the law or a particular procedure requires the consent of a parent, guardian or other legal representative, the relevant information is processed only after appropriate confirmation has been received.
Where the Company determines that a minor’s data was received without an appropriate lawful basis, the data may be deleted or its processing restricted.
32. Reporting a security incident
Where a User believes that their documents, account or personal information have been compromised, they should:
- immediately change the relevant passwords;
- terminate unknown active sessions;
- enable two-factor authentication;
- notify the bank where payment information or banking security codes have been disclosed;
- contact SP SEA-CREW at office@spsea-crew.global or by telephone at +7 991 011-56-99 ;
- contact the appropriate law-enforcement authority where necessary.
33. Fraud prevention
When verifying vacancies, representatives, contact details, payment information and suspicious communications, Users should follow the guidance published on the Anti-Fraud page.
SP SEA-CREW does not request passwords, PINs, CVV or CVC codes, one-time banking codes or unrestricted access to the User’s banking application.
34. Reorganisation or change of business ownership
In the event of a reorganisation, change of business ownership, transfer of a business activity or another form of succession, personal data may be transferred to the relevant successor within the scope of the lawful purpose and subject to appropriate confidentiality requirements.
35. Changes to this Privacy Policy
The Company may update this Policy due to changes in:
- applicable law;
- the Company’s activities;
- website functionality;
- categories of data recipients;
- technical services;
- information-security measures;
- internal procedures.
The current version will be published on this page together with the date of the latest update.
Where changes materially affect User rights, the Company may publish a separate website notice or use another available method of notification.
36. Language versions
This Policy may be published in Russian and English. Both versions are intended to communicate the same content.
Where a discrepancy is identified, the language versions should be interpreted in a manner that ensures compliance with applicable law and the fullest implementation of the User’s mandatory rights.
The User may contact the Company for clarification.
37. Contact information
For questions relating to the processing, access, correction, deletion or protection of personal data, please contact SP SEA-CREW:
- legal and commercial name: SP SEA-CREW;
- legal status: Free Zone Company, United Arab Emirates;
- registration number: JLT4922;
- licence number: JLT-68458;
- licence valid until: 27 April 2029;
- business activity: Ship Management & Operation;
- registered address: Unit 2106, Fortune Tower, Plot No. JLT-PH1-C1A, Jumeirah Lakes Towers, Dubai, UAE;
- official website: spsea-crew.global ;
- email: office@spsea-crew.global ;
- main contact telephone: +7 991 011-56-99 ;
- registered office telephone: +971 4 453 9650 .
The recommended email subject is: “Personal Data”.
Last updated: .
