Privacy Policy
1. INTRODUCTION
This Privacy Policy describes how Geomar Forwarding Agency Ltd ("we," "us," "our," or "the Company"), a freight forwarding company registered and operating in the Republic of Cyprus, collects, uses, processes, and protects your personal data in compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the Cyprus Data Protection Law 125(I)/2018 ("Data Protection Law").
We are committed to protecting your privacy and ensuring that your personal data is handled in a lawful, fair, and transparent manner. This Privacy Policy applies to all personal data we process in connection with our freight forwarding services, including customs clearance facilitation and warehousing solutions provided through our partner network.
2. DEFINITIONS
For the purposes of this Privacy Policy, the following terms have the meanings set out below:
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"Personal Data" means any information relating to an identified or identifiable natural person ("Data Subject"). An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier, or other factors specific to their identity.
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"Processing" means any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, organization, storage, adaptation, alteration, retrieval, consultation, use, disclosure, transmission, dissemination, restriction, erasure, or destruction.
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"Controller" means the natural or legal person, public authority, agency, or other body which determines the purposes and means of the Processing of Personal Data.
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"Processor" means a natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller.
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"Special Categories of Personal Data" means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or data concerning a person's sex life or sexual orientation.
3. CATEGORIES OF PERSONAL DATA WE COLLECT
3.1 Business Contact Information
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Name, job title, and position within your organization
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Company name and business address
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Email address and telephone number
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Tax identification number and VAT registration number
3.2 Shipment and Transaction Information
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Sender and recipient details (names, addresses, contact information)
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Shipment origin, destination, and routing information
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Freight specifications (weight, dimensions, contents description)
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Customs documentation and declarations
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Commercial invoices, packing lists, and bills of lading
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Payment information and transaction records
3.3 Website and Communication Data
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Information submitted through contact forms, quote requests, or customer inquiries
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Website usage data, including IP addresses, browser type, device information, and pages visited
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Cookies and similar tracking technologies (see Section 11)
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Email correspondence and communication records
3.4 Identity Verification Data
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Identification documents (passports, identity cards) when required for customs or regulatory compliance
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Authorized signatory information for corporate clients
4. SOURCES OF PERSONAL DATA
We collect Personal Data from the following sources:
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Directly from you: When you engage our services, submit inquiries through our website, provide shipping instructions, or communicate with us via email, phone, or other channels.
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From third parties: Including shipping carriers, customs brokers, warehouse operators, and other business partners in our service network who provide us with information necessary to fulfill our obligations.
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From publicly available sources: Such as company registries, business directories, and government databases when verifying business credentials or conducting due diligence.
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Automatically through technology: Via cookies, web beacons, and similar technologies when you visit our website.
5. PURPOSES AND LEGAL BASES FOR PROCESSING PERSONAL DATA
We process your Personal Data only for specified, explicit, and legitimate purposes. We do not process Personal Data in a manner incompatible with those purposes. The purposes and corresponding legal bases for processing are as follows:
5.1 Performance of Contract
Purpose: To provide freight forwarding, logistics, customs clearance facilitation, and warehousing services as requested by you.
Legal Basis: Processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract (Article 6(1)(b) GDPR).
5.2 Compliance with Legal Obligations
Purpose: To comply with legal and regulatory requirements, including customs regulations, tax laws, anti-money laundering legislation, trade compliance, and record-keeping obligations imposed by
Cypriot and European Union law.
Legal Basis: Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(c) GDPR).
5.3 Legitimate Interests
Purpose: To operate and improve our business operations, maintain customer relationships, respond to inquiries, conduct market research, prevent fraud, ensure network and information security, and pursue debt recovery.
Legal Basis: Processing is necessary for the purposes of our legitimate interests or those of a third party, provided those interests are not overridden by your fundamental rights and freedoms (Article 6(1)(f) GDPR).
5.4 Consent
Purpose: To send you marketing communications, newsletters, or promotional materials about our services, where we do not rely on legitimate interests or contract performance.
Legal Basis: You have given explicit consent to the processing of your Personal Data for one or more specific purposes (Article 6(1)(a) GDPR). You may withdraw your consent at any time by contacting us or using the unsubscribe mechanism in our communications.
6. DATA RETENTION
We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal, regulatory, tax, accounting, and reporting requirements.
The retention periods for different categories of Personal Data are as follows:
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Customer and transaction records: Retained for a minimum of seven (7) years from the date of the last transaction or service provision, in accordance with Cyprus tax and accounting legislation.
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Customs and regulatory documentation: Retained for the period required by applicable customs and trade compliance laws, typically between five (5) and ten (10) years.
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Marketing and communication data: Retained until you withdraw your consent or request deletion, or until we determine that the data is no longer necessary for marketing purposes.
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Legal claims and disputes: Personal Data relevant to ongoing or potential legal proceedings will be retained until the conclusion of those proceedings and the expiration of applicable limitation periods.
Upon expiration of the applicable retention period, we will securely delete or anonymize your Personal Data in accordance with our data retention and deletion procedures.
