Data Protection is of high concern to the management of Hugo Stinnes Schiffahrt GmbH (“HSS”). Please read this Privacy and Data Protection Policy carefully to get a clear under-standing of how HSS collects, processes, stores, protects and deletes personal data in compliance with applicable data protection laws (in particular the EU General Data Protection Regulation (“GDPR”)).
Contact details of HSS
Hugo Stinnes Schiffahrt GmbH
Phone: +49 381 458 4300
Name and address of Data Protection Officer
Mr Stefan Winkelmann (DPO)
Hugo Stinnes Schiffahrt GmbH
Phone: +49 381 458 4300
1. When, why and what personal data does HSS collect from the people that visit the web-site and on which legal basis?
b) Server log-files
For technical reasons HSS collects information data from you when you access the website or enter information on the site. This data, transmitted by your browser, is stored in so-called server log-files. In detail this includes the name of your provider, your IP address, your browser type and version, browser language, your operating system, the page where the request comes from and the time of the server enquiry, time zone difference to Greenwich Mean Time (GMT), access status/http status, amount of data transmitted in each case, name of requested files and session cookies.
The IP address of your computer and data linked to this IP address may be seen as personal data. The server log files are stored for a limited period of time (maximum 1 week). Thereafter, the log files are deleted or anonymized. The legal basis for the processing (in particular: collection and use) of the server log-files is Art. 6 para. 1 sentence 1 lit. f) GDPR, since it is necessary in order to enable the use of the website and for data security purposes.
HSS uses no tools and generally has no means to attribute the aforementioned data to specific individuals, insofar ruling out the possibility of personal identification.
c) Contact Form, Rate Request Form, Tools
In case you contact HSS to send certain requests, HSS collects the following details as far as provided by you:
- rate request: contact data such as company, name, phone and e-mail; requested shipping details such as precarriage, port of loading, port of discharge, oncarriage; cargo details such as commodity, weight, number of packages, container type, hazardous goods (yes/no), remarks on harbor and direction of travel
- VGM submission: booking reference ,TAN, IP-Address, verified gross mass, name of the shipper and the person signing the VGM submission as well as any further information voluntarily provided by you if you so choose
- tracking & tracing request: B/L number and container number
- request on services and terminals: starting harbor, destination and line
- quick contacts: your name, your e-mail and you message, selected office
If your request takes place in the context of an agreement to which you are a party, the legal basis of the collection of the aforementioned data is Art. 6 para. 1 sentence 1 lit. b) GDPR. In other cases, namely requests in the context of a service provided for free, the legal basis is Art. 6 para. 1 sentence 1 lit. f) GDPR. If you contact us via the HSS website contact form, the legal basis for the use of your name, e-mail address and the selected office as well as the content of your message including voluntarily given information such as address and telephone is Art. 6 para. 1 sentence 1 lit. f) GDPR.
Storage of the IP-Address alongside the VGM data is based on your consent, Art. 6 para. 1 sentence 1 lit. a) GDPR.
All data mentioned above will be processed only for the purpose of fulfilling your request. Thus, HSS temporarily stores such data for the required duration necessary to achieve the purpose of your request (e.g. order processing). VGM data will be stored for 6 months after the relevant container has been delivered. Data will be stored longer if legally required (e.g. tax purposes in which case the storage period will usually be 10 years) and/or if we enter into a business relationship for which the data is relevant.
2. Third Party Disclosure
a) Google Analytics
The HSS website uses Google Analytics, a web analysis service of Google, Inc. ("Google"). The use is based on Art. 6 para. 1 sentence 1 lit. f) GDPR. Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the website. The information generated by the cookies concerning your use of this website is usually sent to a server of Google in the USA and stored there.
This applies in particular to information about browser type/version, operating system used, referrer URL (the previously visited page), host name of the accessing computer (IP address) and time of the server request. HSS has activated IP anonymisation on its website so that Google will reduce your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area before transferring it to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
HSS uses Google Analytics including the functions of Universal Analytics. Universal Analytics allows HSS to analyze the activities on the pages across devices (e.g. for access via laptop and later via a tablet). This is made possible by the pseudonymous assignment of a user ID to a user. No personal data will be forwarded to Google. Even if Universal Analytics adds additional features to Google Analytics, this does not mean that it restricts privacy measures such as IP masking or the browser add-on. Further information on data protection in connection with Google Analytics can be found in the Google Analytics Help:
HSS uses the video sharing platform YouTube, a service by YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066, USA, represented by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. YouTube is a platform that enables the playback of audio and video files.
When you access a page of the HSS website on which a YouTube-Plugin is embedded, YouTube's affiliate player will connect to YouTube to ensure a technical transmission of the video or audio file. We have embedded the videos hosted by YouTube in a way that ensures data is only transferred to YouTube when you click on the video to view it. When you connect to YouTube, data is transferred to YouTube. This includes information about the individual webpages you have visited on our website. If you are logged in as a member of YouTube, YouTube assigns this information to your personal account. In case you click the start button of the video, this information is also assigned to your YouTube-Account. You can prevent this connection by logging out of your personal YouTube-account and other personal accounts of the companies YouTube LLC and Google Inc. and deleting the corresponding cookies of these companies. For embedded videos, HSS uses YouTube‘s extended data protection mode, which prevents YouTube from analyzing the user behavior for the purpose of personalization via cookies.
HSS will not sell or otherwise market your personal data to third parties. HSS does however transfer data to website hosting partners and other parties who assist HSS in operating the website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. In case you make a request and it emerges that this request relates to an associated company, HSS may forward your request to this company on the basis of Art. 6 para. 1 sentence 1 lit. f) GDPR in order to respond to your request. HSS may also release your information when believed release is appropriate to comply with the law, to enforce HSS’ site policies, or protect HSS’ or others' rights, property, or safety. HSS does not allow any other third party to conduct behavioral tracking.
The HSS website may contain hyperlinks, e.g. electronic cross-references giving access to the web pages of other companies. This Privacy and Data Protection Policy does not apply to these pages.
3. Your rights as a data subject within the meaning of Art. 4 No. 1 GDPR
As a data subject within the meaning of Art. 4 No. 1 GDPR, you have numerous rights towards HSS, about which HSS would like to inform you below:
- Right to information: You have the right to obtain information from HSS as to whether and which data HSS processes about you. In addition, HSS can provide you with a copy of this data.
- Right to rectification: You have the right that HSS immediately rectifies information about you that is incorrect or no longer applicable. You may also request that your incomplete personal data be completed. If this is required by law, HSS will also inform third parties about this correction if your data was passed on to them.
- Right of deletion: You have the right to request HSS to delete your personal data immediately if one of the following reasons apply:
- your data is no longer necessary for the purposes for which it was collected or otherwise processed, or the purpose has been achieved;
- you revoke your consent and there is no other legal basis for the processing;
- you object to the processing and there are no overriding legitimate grounds for processing;
- your personal data has been processed unlawfully;
- the deletion of your personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which HSS is subject.
Please note that your right to cancellation may be restricted by law. These include in particular the restrictions listed in Art. 17 GDPR and § 35 Bundesdatenschutzgesetz (in the version applicable from 25 May 2018).
- Right to restrict processing (blocking): You have the right to request HSS to restrict the processing of your personal data if one of the following conditions is met:
- You deny the accuracy of your personal data for a period of time that enables HSS to verify the accuracy of the personal data;
- the processing is unlawful and you refuse to delete the personal data and instead request to restrict the use of your personal data;
- HSS no longer needs your personal data for the purposes of processing, but you do need it to assert, exercise or defend legal claims, or
- you have filed an objection against the processing as long as it is not yet clear whether HSS’ justified reasons outweigh yours.
If you have obtained a restriction on processing as set out above, HSS will notify you before the restriction is lifted.
- Right of objection: If HSS processes your data on the basis of legitimate interests, legitimate interests of third parties or in the public interest, you have the right to object to the processing of your data. Furthermore you have the right to object to processing of your personal data by HSS at any time on grounds relating to your particular situation.
- Right to revoke consents: You can revoke your consent given to HSS at any time with effect for the future. This revocation can take place in the form of an informal notification to the above contact addresses . This also applies to consents that you have given HSS before the validity of the GDPR (before 25 May 2018). If you revoke your consent, the legality of the data processing carried out up to then will not be affected. As a rule, the consequence of a revocation is that you can no longer or not use in full the services covered by consent.
- Right to data transferability: You have the right to receive personal data concerning you that you have provided to HSS in a structured, common and machine-readable format and to transmit this data to others. Details and restrictions can be found in Art. 20 GDPR. Exercising this right does not affect your right to erasure ("right to be forgotten").
- Right of complain to the supervisory authority: If you believe that the processing of your data by HSS violates applicable data protection law, you have the right of appeal to one of the competent supervisory authorities, e.g. in particular the State Office for Data Protection Supervision (Rostock) or the respective supervisory authority in the member state of your place of residence, your workplace or the place of presumed data protection violation.
Reference to your right of objection under Art. 21 GDPR
As mentioned in this privacy and data protection policy, we in some cases base the processing of your data on the fact that it is necessary to protect our legitimate interests or those of a third party without your interests or fundamental rights and freedoms prevailing (Article 6(1)(1)(f) GDPR). In these cases, you have the right to object to the processing of your data at any time for reasons arising from your particular situation.
You also have the right to object to the processing of your data at any time, if we process your personal data for direct advertising (e.g. in the context of our newsletter).
Details of your rights can also be found in Articles 15 to 21 of the GDPR and Sections 32 to 37 BDSG (in the version applicable from 25 May 2018).
To assert your rights, please contact HSS (by e-mail, postal mail or even informally) under above contact details.
4. Data security
HSS takes technical and organizational actions to protect your stored and processed data against manipulation, loss of confidentiality, destruction and against access by unauthorized persons. HSS’ security measures are continuously improved in accordance with technological developments.
Last Edited on 2018-09-17