Privacy Policy

1. Who We Are

Centropa Logistics BV is a global logistics and energy transportation company specializing in crude oil shipping, petroleum storage, pipeline transportation, vessel chartering, trucking, and related services.

Legal entity: Centropa Logistics BV
Registered office: Rotterdam, Netherlands
Chamber of Commerce number: [To be inserted]
Data Protection Officer contact: [email protected]

---

2. Scope of This Privacy Policy

This Privacy Policy applies to:

• Visitors to our website centropalogistics.com (including all subdomains)
• Users of our online portals, customer dashboards, and booking systems
• Individuals who contact us via email, phone, contact forms, or social media
• Prospective clients, business partners, suppliers, job applicants
• Any person whose personal data we process in connection with our services

It does **not** apply to personal data processed on behalf of our clients as a data processor (please refer to the relevant client contract or privacy notice provided by your counterparty).

---

3. Personal Data We Collect

3.1 Data You Provide Directly

• Name, title, company name, position
• Contact details (email address, phone number, postal address)
• Login credentials (username, password hashes)
• Business information (company registration number, VAT ID, billing details)
• Correspondence and communications (emails, messages, call notes)
• Job application data (CV, cover letter, references, education, work history)
• Payment information (bank details, invoice references – usually processed by third-party PSPs)

3.2 Data We Collect Automatically

• IP address and approximate geolocation
• Device type, browser type/version, operating system
• Referring/exit pages, time/date of visit, pages viewed, time spent
• Cookies and similar technologies (see our Cookies Policy)
• Interaction data (clicks, form submissions, downloads)

3.3 Data We Receive from Third Parties

• Business partners, intermediaries, agents
• Publicly available sources (company registries, LinkedIn, trade databases)
• Marketing & analytics providers (subject to their privacy policies)
• Credit reference agencies (for credit checks – where applicable)

---

4. Purposes and Legal Basis for Processing

---

5. Sharing Your Personal Data

We may share your personal data with the following categories of recipients:

• Service providers / processors – IT, cloud hosting, analytics, CRM, marketing automation, payment processors, cybersecurity
• Group companies – subsidiaries and affiliates of Centropa Logistics BV for internal administration and service delivery
• Business partners – agents, brokers, subcontractors, vessel owners/operators, terminal operators (only as necessary for performing contracts)
• Authorities & regulators – tax authorities, customs, port authorities, maritime safety agencies, law enforcement (when required by law)
• Professional advisors – lawyers, auditors, insurers, consultants
• Corporate transactions – in the context of mergers, acquisitions, restructuring

All third parties are contractually required to provide an adequate level of data protection and only process data for the purposes we instruct.

---

6. International Transfers

We operate globally. Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including but not limited to:

• United Arab Emirates (Fujairah terminal)
• United States (Houston operations)
• Singapore (Jurong operations)

Whenever we transfer personal data outside the EEA, we ensure an appropriate level of protection is maintained by using:

• European Commission Adequacy Decisions (where applicable)
• Standard Contractual Clauses (SCCs) approved by the European Commission
• Binding Corporate Rules (where applicable within our group)
• Supplementary measures when required (e.g., encryption, pseudonymization)

---

7. Data Retention Periods

We retain your personal data only for as long as necessary for the purposes outlined in this policy or as required by law. Typical retention periods:

---

8. Your Rights

Under the GDPR (and similar laws such as UK GDPR, CCPA/CPRA, etc.), you may have the following rights regarding your personal data:

To exercise any of these rights, please contact us at [email protected]. We will respond within one month (extendable by two months for complex cases).

You also have the right to lodge a complaint with your local data protection authority (in the Netherlands: Autoriteit Persoonsgegevens; in other EU countries: the relevant national DPA).

---

9. Security of Your Data

We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These include:

• Encryption of data in transit (TLS 1.3) and at rest where appropriate
• Access controls and role-based permissions
• Regular security assessments and penetration testing
• Employee training on data protection
• Incident response and breach notification procedures

---

10. Contact Us