Privacy policy – Leth Crew Connect
Leth Danish Straits ApS (below referred to as "we" "our" and "us") is providing passage services in the Danish Straits. Our main service consists of crew management. We provide a digital platform (App) catering to the needs of a seafarer on their journey to and from a given vessel, situated in Danish waters. The app " Leth Crew Connect", provides the seafarer with the option to view one’s “Itinerary”, “OK to board” document, chat with Leth support and view one’s profile information.
This privacy policy contains information about how we collect and process your personal data, in accordance with the rules of the General Data Protection Regulation (GDPR) and the Danish Data Protection Act.
1. Data controller (data processing)
Leth Danish Straits ApS is data controller regarding the processing of any personal data collected by Leth Danish Straits ApS in connection with "Leth Crew Connect”.
Leth Danish Straits ApS
Amaliegade 33B, 1st Floor
DK-1256 Copenhagen K, Denmark
Phone: +45 33 32 23 63
Web: lethagencies.com
2. Contact
If you have any questions regarding our processing of your personal data, you are welcome to contact us by phone +45 33 32 23 63 or via e-mail at [email protected]
3. The purposes and legal reference for processing of personal data
We process your personal data in “Leth Crew Connect” with the following purposes:
• Registration and administration: your data is processed when delivering our app to you, including creating you as a user, managing your user, confirming your identity, etc.
• Delivery of services: your data is processed when providing different services via the app “Leth Crew Connect”, including a personal travel plan and uploading's of relevant documents.
• Communication: your data is processed to support you via the chat function in the app “Leth Crew Connect”.
Legal reference
The processing of your personal data is based on consent in Article 6(1)(a) and fulfilment of a contract in Article 6(1)(b) of the General Data Protection Regulation.
Your sensitive information will be processed in accordance with Article 9(2)(a) and Article 9(2)(b) of the General Data Protection Regulation.
4. Types of information collected
Leth Danish Straits ApS collects, the following information in connection with the use of "Leth Crew Connect”
• First name and surname
• Your e-mail
• Nationality
• Passport number
• Seaman´s book number
• Date of birth
• Gender
• Phone number
• Rank
• Booking nr.
Since some of this information is highly sensitive, we are very focused on only requesting the most important information needed.
Leth Danish Straits ApS takes the necessary technical and organizational measures to ensure that data is processed safely and to avoid that information may be accessed by unauthorized persons, is misused, or otherwise processed in violation with the General Data Protection Regulation.
5. Voluntariness
Leth Danish Straits ApS’ collection of personal information, related to the use of our application "Leth Crew Connect" presupposes voluntariness.
When we collect personal information directly from you or third parties, you provide it voluntarily. You are not obligated to provide your personal information to us. The consequence of not providing us with your personal information would be that we cannot accommodate to the purposes described above, thus you will not be able to use "Leth Crew Connect".
Sources:
Via the app, “Leth Crew Connect”, we support the seafarer in connection with a given journey starting at arrival in Denmark up until boarding of vessel or vice versa.
It is necessary that the user of the app provide permission for the use of camera and information about location (GPS coordinates), in relation to utilizing the in-app support functionalities. The user will automatically be asked about permission when using the functions in the app.
Location:
By accepting the use of your location through GPS coordinates, the app uses your current location. Your location will only be used/sent once to us. The app does not store data about your location.
Camera:
The access to your camera through the app enables you to take pictures so we can support you if this is necessary. The use of the camera on your mobile device presupposes voluntariness.
We only use the pictures that you take yourself via “Leth Crew Connect”. We won't share the photos with any third parties. We store your photos in the app for one year, as mentioned in the section regarding storage below.
It is to be mentioned that the pictures are not stored on your phone and your personal information are not collected, processed, and shared with your mobile device.
You can any time remove access to GPS coordinates and or camera access at any time via the settings in your device.
PDF-download:
Documents available in the app will not be stored on your mobile device unless you want to download them yourself.
If you download documents from the app to your mobile device, this is at your own risk. Leth Danish Straits ApS thus renounces all responsibility for misuse of data you download onto your mobile device.
6. Your Rights
According to the General Data Protection Regulation, you have several rights that you may invoke in connection with our processing of your information:
• Right of access; You have the right to access the information we process about you and certain supplementary information
• Right to rectification (correction); You have the right to have any incorrect information about yourself corrected.
• Right to deletion; Under special circumstances, you have the right to have your personal data deleted before the time of our general deletion policy.
• Right to object; In certain cases, you have the right to object to our lawful processing of your personal data.
You may read more about your rights as a data subject on the European Commission´s website.
If you want to make use of your rights, please contact Leth Danish Straits ApS.
However, there may be conditions or limitations to these rights, as Leth Danish Straits ApS may be subject to requirements from other legislation.
7. Disclosure of personal data
Leth Danish Straits ApS shares all necessary information with the Danish Immigration Authorities to start processing the transit visa applications and report crew changes.
To arrange safe transportation and embarkation of crew from and to a vessel Leth Danish Straits ApS provide the service providers with your name.
Upon immigration approval to arrive in Denmark, we share the following information with the seafarer who are on the same flight as you; first- and surname, date of birth, passport number, Seaman’s book number and rank.
Leth Danish Straits ApS has partnered with Copenhagen Contractors A/S to develop and operate the software system. Copenhagen Contractors A/S is responsible for maintaining and updating the platform, which requires access to your personal data. As a result, Copenhagen Contractors A/S acts as a data processor on behalf of Leth Danish Straits ApS.
Apart from the above mentioned Leth Danish Straits ApS does not sell, trade, or share your personal data with any third parties.
8. Storage and deletion of personal data
Copenhagen Contractors A/S, acting as a data processor for Leth Danish Straits ApS, stores your personal data within the EU/EEA.
Your personal information, which is processed in connection with the chat and support function, is stored in a database. The host of the database does not have access to your personal information.
We store your information for as long as we have a legitimate reason or legal obligation to do so. The specific time of deletion depends on the purpose of the collection.
Your user information is stored for fourteen days after estimated time of arrival (ETA), after which it is deleted. However, your user information is copied and anonymized for statistical purposes.
Please note that we store your information processed in connection with the chat and support function for a minimum of one year for statistical purposes.
After this time, we securely delete or anonymizes the data in accordance with our data retention policies and applicable laws.
9. Complaints
If you wish to complain about Leth Danish Straits ApS' processing of your personal data, you may do so to the Danish Data Protection Agency (www.datatilsynet.dk). The Danish Data Protection Agency may be contacted at [email protected] or by following their complaint instructions on their website.
You are always encouraged to contact us before filing any complaints. We would like the opportunity to answer any queries you may have about our processing of personal data and if possible, comply with your wishes if you believe that the processing should be carried out any differently.
10. Changes to this privacy policy
We reserve the right to change this privacy policy in case of significant changes in legislation, new technical solutions, new or improved functions, to improve our digital platforms or in case there are changes in the way we process personal data.
The updated and relevant privacy policy is available in the app “Leth Crew Connect”. In the event of significant changes, you will be notified.
Last updated: 04.04.2023
