NYK Privacy Policy (GDPR)

NYK (“NYK”, “we”, “us”, or “our”), recognizes the importance of your personal information and privacy. In this privacy policy (the "Privacy Policy") we describe to our staff, job applicants, customers and third-party service providers how we collect and use your personal information in accordance with applicable privacy laws.

  1. 1Background
    As an employer and business entity, we maintain certain information about you (“Personal Data”) which we need to process to be compliant with our relevant legal obligations (e.g. employment laws), our contractual obligations with you or in fulfilment of legitimate interests. We are required by law to provide you with certain information about the data we maintain about you, how we use the said data, and what safeguards are in place to ensure its security. This Privacy Policy is designed to provide you with essential information.
  2. 2Purposes and legal basis of our processing of your Personal Data
    NYK is a data controller in relation to your Personal Data we process for the following purposes (“Purposes”):
    1. (1) Business negotiations with us, execution and performance of contracts, and management of other transactions;
    2. (2)Provision of information related to our operations and services and those of our group companies, and procedures related thereto;
    3. (3)Operation of vessels owned or chartered by us;
    4. (4)The provision of information related to, or the conducting of, advertising campaigns, training, social events, and other events hosted by us, as well as the analysis and reporting of results of the same;
    5. (5)Communications with us and notifications and social greetings by us in accordance with social customs;
    6. (6)Investigations, analysis, research and auditing related to our business operations;
    7. (7)Communications with organizations related to our business operations;
    8. (8)Administrative procedures related to our stock;
    9. (9)Our investor relations (IR) activities and corporate social responsibility (CSR) activities;
    10. (10)Public relations activities of ourselves and our group companies;
    11. (11)Management of access to (entering/exiting) our facilities, management of security for our facilities;
    12. (12)Responding to inquiries of all types;
    13. (13)Procedures related to employment activities and other management of human resources;
    14. (14)And for the proper and smooth operation of our business operations.
    Additionally, in some cases, we may provide Personal Information that we have collected to third parties outside of our company for negotiations involving NYK, or for the execution of contracts or fulfilment of obligations thereunder, or otherwise to manage transactions;

    The legal basis for our use of your Personal Data will generally fall into one or more of the following:

    1. a)As a data subject, you have given consent to the processing of your Personal Data for one or more specific Purposes;
    2. b)Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
    3. c)Processing is necessary for compliance with a legal obligation which we are subject to as a controller;
    4. d)Processing is necessary in order to protect your vital interests as a data subject or of another natural person;
    5. e)Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us as a controller; or
    6. f)Processing is necessary for the purposes of the legitimate interests pursued by us as a controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you as a data subject which requires protection of Personal Data, in particular where you, the data subject, are a child.
  3. 3Types of Personal Data we process
    The types of Personal Data we maintain and process about you as an employee or as our customer or business partner are listed in the Annex attached.
    We may collect some of the afore-mentioned Personal Data directly from you. We may also collect Personal Data from other sources such as public databases made available by the government, law firms and tax offices.
  4. 4Categories of potential recipients of your Personal Data
    From time to time, as an employer and a business partner, we will share your Personal Data with the NYK group affiliates, advisers, and service providers so that they can help us properly discharge our obligations and exercise our rights. Such advisers and service providers currently include:
    • Cloud computing service providers;
    • Third party software providers;
    • Third party benefits providers; and
    • Legal service providers.

    In each case, we will only share your Personal Data to the extent that we consider the information is reasonably required to discharge our obligations and exercise our rights.
    The service providers referred to above may use your Personal Data to execute their functions as well as for business administration and other regulatory purposes. They may also provide your Personal Data to other third parties where the transfer of such information is reasonably required for a legitimate purpose.
    Where requested, or if we consider that it is reasonably required, we may also provide your Personal Data to government and law enforcement agencies, which may use the Personal Data to execute their respective functions.
    In some cases, recipients of your Personal Data may be outside the EU. In other words, your Personal Data may be sent to jurisdictions that may not offer a level of protection equivalent to what is required in EU countries. In such cases, we will require appropriate safeguards to be in place for protecting your Personal Data in accordance with applicable laws. Please use the contact details below if you have any questions regarding the safeguards currently in place.
    We do not carry out any automated processing or decision-making, including profiling, and will not share your Personal Data with anyone for the purpose of marketing to you or anyone else.

  5. 5Data storage
    We exercise reasonable care in our collection and use of your Personal Data and have implemented internal security procedures to protect your Personal Data. We also require our third-party service providers to do the same.
    We will only keep your Personal Data for as long as we need to in order to fulfil the Purpose(s) for which it was collected and only for so long afterwards as we consider may be required to deal with any questions or complaints that we may receive, unless the law requires us to keep it for a longer period. We also require our third-party service providers to do the same.
  6. 6Your rights
    You have a right to access to, and obtain a copy of, your Personal Data that we process and to ask us to correct your Personal Data if there are any errors or if it is outdated. You also have a right to restrict or object to the processing of your Personal Data or to request a transfer or erasure of your Personal Data. You can obtain further information about these rights from the European Commission’s website.

    If you wish to exercise any of these rights, please contact us as indicated below. You also have the right to lodge a complaint in relation to this Privacy Policy or our processing activities to a competent data protection supervisory authority at any time.
    Your Personal Data which we process is used only for the Purpose(s). We may from time to time ask for further Personal Data from you to fulfil these Purposes. If you do not provide the Personal Data, or if you request your Personal Data we have been processing to be deleted or restricted, it may render NYK unable to provide certain benefits and services to you.

  7. 7Updates
    We may update this Privacy Policy periodically, with notice to you of the update and effective date thereof.
  8. 8Contacting us
    Please address any questions, comments and requests regarding our data processing practices to our Personal Information Helpdesk

    Personal Information Helpdesk
    NYK line Legal & Fair Trade Promotion Group - Compliance Team

Last update: April 1, 2021
Nippon Yusen Kabushiki Kaisha (NYK Line)