Privacy Policy

Last updated: 18th of November 2025

COLUMBIA blue Services Limited (“we”, “our”, “us”, “Cb”) recognises and respects the rights and privacy of individuals, including applicants, employees, crew members, passengers, suppliers, customers, visitors, and users of our website.

This Privacy Policy explains how we collect, use, process, and safeguard your personal data. The term “processing” includes collecting, storing, using, transferring, and protecting your personal data.

1. Legal Framework

This Privacy Policy complies with the European Union General Data Protection Regulation (GDPR) and all other applicable data protection legislation.

2. Data Controller

COLUMBIA blue Services Limited
COLUMBIA House
21 Spyrou Kyprianou
Germasogeia, 4042
Limassol, Cyprus

Phone: +49 40 36 13 04 – 0
Email: contact@columbia.blue

Passengers should also refer to the privacy policies of their cruise operators, who may act as separate data controllers under EU and UK law.

3. Categories of Data Subjects

This Privacy Policy applies to:

• Employees (shore-based and onboard)
• Seafarers / Crew members
• Job applicants
• Customers and business partners
• Suppliers and service providers
• Passengers on vessels we manage
• Website users
• Visitors to our premises or ships
• Emergency contacts
• Individuals captured in CCTV or company event photos/videos

4. How We Use Personal Data

We process personal data necessary to provide shipmanagement services and conduct our business. This includes:

• Crew and passenger manifest handling
• Employment administration
• AML/KYC compliance
• Claims handling (including medical, P&I, H&M)
• Training and certification management
• Operational and safety management
• Procurement and vendor administration
• Marketing and communication
• Risk management, auditing, and compliance
• IT and security management

5. What Personal Data We Collect

5.1 Crew Members & Employees

We may collect information such as:

• Name, age, contact details
• Education and employment history
• Passport, visa, and identification documents
• Next of kin and emergency contacts
• Bank details and proof of residency
• Photographs, uniform/overalls size
• Sensitive data (where legally required), such as health data, union membership, or criminal records

Photos and videos taken on our premises or during company events may be used for internal or external marketing materials.

5.2 Passengers

To comply with maritime regulations and safety requirements, we process:

• Booking number
• Full name
• Cabin number
• Date of birth
• Passport number and expiration date
• Embarkation information

5.3 Customers

To communicate and fulfil contractual/legal obligations, we process:

• Names and contact information
• Email addresses and phone numbers
• KYC/AML information

5.4 Website Users

We collect limited analytics data to improve your user experience, including:

• IP address
• Frequency of visits
• Pages accessed
• Usage statistics

5.5 Social Media

We maintain social media profiles. When you interact with us or voluntarily provide photos, videos, or comments, we may use this content for marketing purposes on our website and social channels. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

5.6 Suppliers

We collect contact and payment details required for contractual cooperation.

5.7 Visitors

We collect visitor log data and operate CCTV in common areas for safety and security. CCTV footage is stored for up to one month.

5.8 Health Screening (Infectious Diseases)

Where necessary and proportionate, we may request health screening before entry to our premises or ships. Refusal may result in denied entry. Legal basis: Legal obligation and vital interests.

6. Legal Basis for Processing

We process personal data under the following GDPR bases:

• Consent (Art. 6(1)(a))
• Performance of a contract (Art. 6(1)(b))
• Legal obligation (Art. 6(1)(c))
• Vital interests (Art. 6(1)(d))
• Legitimate interests (Art. 6(1)(f))

7. Sharing of Personal Data

We may share personal data with:

• Government and maritime authorities
• Insurers and claims handlers
• Courts and law enforcement
• Healthcare professionals
• Recruitment and training system providers
• IT and security service providers
• Affiliated companies
• Business partners
• Auditors, investigators, and consultants
• Port agents and ship operators

All third parties are bound by confidentiality and data protection agreements.

8. International Data Transfers

Personal data may be transferred to or stored in the EU or other countries where we or our partners operate. GDPR-compliant safeguards (including Standard Contractual Clauses) are applied to all transfers.

9. Data Retention

Data is retained only as long as necessary for:

• Legal and regulatory compliance
• Contract fulfilment
• Operational and safety needs
• Evidence requirements in disputes
• Statistical or historical purposes

10. Your Rights

• Access your personal data
• Rectify inaccurate information
• Request deletion (“right to be forgotten”)
• Restrict processing
• Object to processing (including marketing)
• Data portability
• Withdraw consent at any time
• File a complaint with a supervisory authority

11. What Happens If Data Is Not Provided?

If you do not provide necessary personal data, we may be unable to:

• Communicate with you
• Establish or maintain contracts
• Provide or receive services
• Employ you
• Allow access to certain premises or vessels

12. Automated Decision-Making

We do not use automated decision-making.

13. Cookies

We use session and persistent cookies to improve website functionality and analytics.

Analytics cookies used include:

• _ga
• _gid
• _gat
• __utma
• __utmt
• __utmc
• __utmz

You may manage or delete cookies through your browser settings. More information: AboutCookies.org.

14. Use of SalesViewer® Technology

This website uses SalesViewer® technology from SalesViewer® GmbH based on our legitimate interests (Art. 6(1)(f) GDPR) to analyse marketing, market research, and optimisation data.

A Javascript-based code is used to collect company-related data and website usage information. All collected data is encrypted using a non-reversible one-way function (hashing). The data is immediately pseudonymised and cannot be used to identify website visitors personally.

The data stored by SalesViewer® will be deleted when no longer required and when there are no statutory retention obligations.

You may opt out of data collection with immediate effect by clicking the following link:
https://www.salesviewer.com/opt-out

An opt-out cookie will be stored on your device. If you delete your cookies, you must activate the opt-out link again.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be published on this page. If we intend to process personal data for a new purpose, we will inform you in advance where required.

Contact

For questions, concerns, or to exercise your rights, please contact us at:
Email: contact@columbia.blue
Phone: +49 40 36 13 04 – 0