Privacy Notice

1. Who we are?

Legal Entity: Thenamaris Philippines Incorporated

Office Location: 3/F Marbella Manila II, 2071 Roxas Boulevard, Barangay 701, Malate, Manila 1004, Philippines

Nature of Business: Manning Agency

Affiliate Company: Thenamaris (Ships Management) Inc., 16 Athinas Street, Vouliagmeni 16671, Greece

Contact Information: Tel: +63 2 8521 7812

Data Protection Officer: John Carl Dio, dataprotection@thenamarisphilippines.com, Tel: +63 2 8521 7812 loc. 110

2. Scope of This Privacy Notice

This Privacy Notice applies to all individuals for whom TPI collects and processes personal data, including but not limited to internal employees, seafarers, applicants, contractors, and third-party affiliates.

3. Types of Personal Information Collected

TPI collects and maintains certain personal and sensitive personal information from different data subjects, including employees, seafarers, applicants, service providers, and visitors. Depending on your relationship or transaction with TPI, our records may include the following:

Personal Information

• Full Name

• Rank / Position

• Company / Organization

• Address

• Business and Personal contact details

• Height and Weight

• Date and Time of Visit (TPI Office)

• Emergency Contact Details

Sensitive Personal Information

• Date of Birth

• Age

• Marital Status

• Educational Background

• Professional Skills and Training Records

• Professional License Information

• Government-issued identification numbers (e.g., SSS, PhilHealth, Pag-IBIG, TIN, GSIS, passport numbers)

• Seafarer Identification Record Book Number

• Test results during your application

  • CES Test

  • Interview results

• Relative job experience or sea service experience

• Medical conditions or Pre-Employment Medical Records

• Vaccination records

• Payroll and Bank Account Details

• Disciplinary or Performance Records

• Visas

4. Collection Method and Timing of Collection

TPI collect the personal information in the following circumstances;

• By willful submission through an online application form during application

• Employment documentation during onboarding or recruitment

• HR and administrative processes (payroll, benefits, performance management)

• Visitors’ logbooks and electronic access systems

• Training and evaluation records collected through internal systems

Depending on specific circumstances related to the employment or applicable requirements under the Philippine law TPI may collect further information

5. Purpose of the Collected Personal Information and Method of Use

TPI collects and uses personal information in accordance with the lawful principles of collecting and processing personal data;

• That collection and use of personal data is necessary for TPI's pursuit to legitimate interests;

  • To administer application and recruitment procedure

  • Review and validate document, license, and job-related experience

  • TPI uses information about personal skills and training to allocate relevant jobs

  • To review and assess your knowledge, understanding, and competency with respect to the applied position

• That the seafarers have consented the collection and use of their personal data

  • There will be specific circumstances that we will be needing to collect and share your personal information in which you have consented.

• For Local Employees

  • To manage the employment relationship, including recruitment, onboarding, payroll, and benefits administration

  • To monitor attendance, performance, and training

  • To ensure compliance with statutory requirements under Philippine labor and tax laws

  • To maintain employee records for legitimate business operations

  • To facilitate company communications, system access, and IT resource management

  • To uphold workplace safety, security, and data protection

• For Vendors and Suppliers, TPI collects and processes the above personal information for the following purposes:

  • Supplier accreditation and evaluation

  • Communication and coordination with the supplier

  • Execution and fulfillment of contractual and legal obligations

• For visitors, including seafarers, TPI collects personal data to:

  • Record visits for proper documentation and administrative purposes

  • Maintain security and access control within office premises

  • Monitor attendance in training, debriefings, and processing activities

  • Ensure accountability and transparency in visitor transactions

  • Comply with legal and regulatory requirements relating to safety and security

6. Storage Location and Transmission of Personal Information

• Filing Cabinets

  • Bio-Data Forms are stored at the filing cabinet of the Processing Department

  • HR and Processing Department filing cabinets are locked and access-restricted

  • Access are restricted to the Processing Officers only and protected with a key

  • Monitoring are maintained by the HR and Processing Officers

• On-Board Job Application Form (Careers on Board)

  • This is an online application system used during the application period of the employee

  • The Curriculum Vitae you have submitted, and Interview results are stored in this system

  • This system is password protected and restricted only to the ones who handles the application procedures, i.e. TPI CEO, TPI Manager and TSMI Marine Personnel Department

  • It is being managed in Greece

• IT Infrastructure

  • Applications created via careersonboard.thenamaris.com are stored in the Careers on Board Database that is being managed by TSMI

  • Furthermore, all personal and sensitive personal information are kept and maintained in SeaSoft’s database. Seasoft is an integrated application suite addressing exclusively the shipping vertical market

  • Access to this Systems/Database are password restricted

7. Third-Party Transfer

TPI does not share your personal information with any third party that intends to use it for direct marketing purposes unless you have provided specific consent in relation to this. TPI may share your personal information with third party in the following circumstance providing adequate safeguards for the data privacy and security:

• Affiliates

  TPI may provide your personal information to its affiliates and related companies for legitimate business purpose. Below is list of our affiliates:

  • Thenamaris (Ships Management) Inc.
    Address : 16 Athinas Street, Vouliagmeni 16671, Greece
    Tel: +30 21 0890 9000

• Legal Requirements

  • TPI may disclose your personal information if it is required to do so by law or if, in TPI's good faith judgment, such legal disclosure is reasonably necessary to comply with legal processes or respond to any claims.

TPI requires such third parties, based within or outside the Philippines to comply with all relevant information protection laws and security requirements in relation to your personal information, by way of Data Sharing Agreement.

8. Retention Period

TPI will only retain your personal information for as long as it is necessary for the stated purpose, taking into account also our need to answer queries or resolve problems, provide improved and new services, and comply with legal requirements under applicable laws.

TPI will retain your personal data in accordance with UCPI's data retention and disposal procedures.

• Personal Information

  (a) For data entered in the online application form, seafarer has the option to choose between 3, 5, or 10 years of retention.

  (b) If employed, for as long as the seafarer is active.

  (c) Following the termination of the employment relationship i.e. the 60th year of seafarer's age or 20 years (whichever is longer)

  (d) Visitor logs (including seafarer visit records) will be retained for a maximum of 1 year, after which they will be securely deleted, unless a longer retention period is required for compliance with legal, regulatory, or audit requirements.

• Sensitive Personal Information

  (a) For as long as the seafarers are active

  (b) Following the termination of the employment relationship -> 6 years

9. Rights of Data Subject

• TPI's collection and processing of your personal data is necessary to manage and fulfill your employment and commit to uphold your Rights as data subject stated under the law Chapter IV - Sec. 16 of the Data Privacy Act of 2012.

• Right to be informed whether personal data have been processed

• Right to object to the processing of his or her personal data

• Right to reasonable access to upon demand to the personal data collected and used

• Right to dispute the inaccuracy or error in the personal data

• Right to erasure or blocking, suspend, withdraw or order the blocking, removal or destruction of his or her personal data from the personal information controller's filing system

• Right to damages

• Right to Data Portability

10. Rights to Complain

If you wish to have your data rectified, please contact the Data Protection Officer with the below details:

Telephone: +63 2 8521 7812 loc. 110
E-mail: dataprotection@thenamarisphilippines.com

You can use the Data Subject Request Form in filing complaint or request. You may approach any of our employee to assist you in filing a request or complains.

11. National Privacy Commission

You can direct your complaints to the National Privacy Commission with the below details;

Address: 25th-27th Floor, The Upper Class Tower, Quezon Avenue, Corner Scout Reyes Street, Brgy. Paligsahan, Quezon City.
Tel. No.: +63 970 818 0555 (Smart) | +63 905 506 1478 (Globe)
E-mail: complaints@privacy.gov.ph
Web: privacy.gov.ph
Facebook: privacy.gov.ph