PHSE UK Limited and its subsidiaries are committed to protecting and respecting your privacy. The current data protection regime is governed under UK law by the Data Protection Act 1998 but with effect from 25th May 2018, this was replaced by the EU General Data Protection Regulation and this will affect the way companies and other organisations keep information.

1          What is a Privacy Policy?


This Privacy Policy explains what personal information PHSE UK Limited and its subsidiaries collect from you, or that you provide to us and how it will be used. PHSE UK Limited and its subsidiaries promise to respect any personal data you share with us,

or that we get from other organisations and keep it safe.

2          What is our lawful basis for using your personal data?

2.1       The GDPR only permits us to process your personal data to the extent that one of the lawful bases set out there in applies to that processing. In processing your personal data, we rely principally on the following lawful basis, namely that

processing is necessary for the purposes of our legitimate interests, and those are not overridden by your interests or your fundamental rights or freedoms. When we say “legitimate interests”, we mean our (or a third party’s) interests in

enabling us to provide our services to you as efficiently and securely as possibly.

2.2        In certain circumstances, we may rely on one of the following lawful bases for our processing, namely:

2.2.1    processing is necessary for the performance of a service or contract entered into between us, or to be entered into between us; or

2.2.2    processing is required for compliance with a legal obligation of ours; or

2.2.3    the data subject has given consent to the processing of his or her personal data.

2.3       We may process your personal data relying on more than one lawful basis depending on the specific purpose for which we are using your data.

3          What information do we hold about you and why?

3.1       The provision of our services often requires the processing of personal data. The processing of personal data may be necessary both prior to the conclusion of a service (e.g., in order to provide you with a quotation) and during the

implementation of a service with you. Such data may include but are not limited to:

Individual and business-contact information (such as name, company name, physical address, email address, and telephone or fax number)
Information relating to the service being provided by the Star Cargo subsidiary.
Names, email addresses and telephone numbers of others to whom we are asked to send information
Payment information and financial information (such as bank account, company and VAT registration numbers)
Other personal information that may be provided to us to obtain a service.

3.2       If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

Give consent on his/her behalf to the processing of his/her data
Receive on his/her behalf and data protection notices
Give consent to any transfer of his

4          Who do we share your personal information with?

We may only disclose information about you and contact details when this is required for us to provide our service to you (for example, to our suppliers). Other than this, we will not sell or pass your personal information to third parties unless

you have given us permission to do so. We may also be obliged to disclose information to meet any legal or regulatory requirements.

5          Information from third parties

5.1       Occasionally, we may receive information from other sources (such as credit reference agencies), which will be added to the information already held in order for us to help supply our services and products to you.

5.2       We use credit reference agencies to make fair and informed decisions on whether to offer our products and services to you. We use them as part of our application process and ongoing monitoring on the account.

5.3       We do not perform a credit check on the individual, therefore a credit check footprint will not be left on a personal credit file.

6          Where we store your information and data security

6.1       We process data and store it on servers managed by our hosting provider. Those servers are located in the UK and our server environment is highly secure and there is very limited personnel access.

6.2       We operate secure data networks protected by industry standard firewall and password protection. We have security measures in place to attempt to protect against the loss, misuse and alteration of your user date under our control.

6.3       We try to ensure that we do not send data outside the EEA, however, this is not possible in all cases. In relation to a very small number of our suppliers or data processors, the data that we collect from you may be processed by staff

operating outside the EEA who work for them. However, by submitting your personal data, you consent to this transfer, storing or processing. We will ensure that suitable safeguards are in place before personal information is

transferred outside the EEA and we will ensure that your data is treated securely.

6.4       We will do our best to protect your personal data, however, the transmission of information via the internet can never be 100% secure. We cannot guarantee the security of your data transmitted to us and so any transmission is at your

own risk.

7          How long do we hold your information?

We keep information for as long as we need it for the purposes for which it was collected. This will vary on the type of information. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

The data may be deleted in the following circumstances:

You have withdrawn your consent to data processing.
The original purpose for processing the data is no longer relevant or cannot be performed any more.
The data is no longer up to date or accurate.

8          Marketing and opting out

If you have provided your consent to receive news, special offers or promotions from us, we may contact you by mail, telephone, SMS or e-mail, about our products, services or promotions that may be of interest to you. If you prefer not to

receive any further direct marketing communications from us or our business partners, you can opt out at any time.

9          Use of cookies

Cookies are small text files, which we may store on your computer to track your activity on our homepage. When you visit our website, information about you is collected and it is used to adjust and improve your experience. If you do not want information about you to be collected, you should delete your cookies and/or avoid visiting our website.

Cookies are stored on your computer, mobile phone or similar with the purpose of recognising it, remember settings, make statistics. Cookies cannot contain damaging content, such as virus. It is possible to delete or block cookies. If you delete or block cookies, ads maybe become less relevant to you and occur more often.

10       What are your rights?

10.1     Individuals from the European Economic Area and individuals located in the EEA have statutory rights in relation to personal data. Subject to any exemptions provided by law, you have the right to be informed, request access to

information, as well as to seek to update, delete or correct this Information, alongside the right to restrict processing, to object and request the portability of the data (i.e. requesting that we move, copy or transfer your personal

information to another organisation). If you wish to exercise any of these rights, please contact us.

10.2     You have the right to access personal information held about you through a subject access request made in writing.

11        Complaints


If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection Laws you have the right to lodge a complaint at the Information Commissioner’s Office