Políticas de privacidad

1. Data Controller

The controller responsible for the processing of personal data collected through this website and through any other enabled means is:

Corporate Name Stward Corporation
Registered Address Hi Point Building, 24th Floor, Avenida Federico Boyd, Bella Vista, Panama City, Republic of Panama
Email info@stwards.com
Teléfono (+507) 314-0714
Website www.stwards.com

Pursuant to Article 4 of Law 81 of 2019, Stward Corporation acts as the data controller insofar as it determines the purposes, means, and conditions of the processing of personal data.

2. Personal Data We Collect

In compliance with the data minimization principle set out in Article 9 of Law 81 of 2019, Stward Corporation will collect only the personal data that is necessary, adequate, and relevant for the purposes stated in this policy. The data that may be collected includes:

  • Full name and surnames.
  • Email address.
  • Landline or mobile phone number.
  • Name of the company or entity the user represents.
  • Job title or position.
  • Information contained in contact forms, quote requests, or employment application forms.
  • Browsing data: IP address, browser type, pages visited, and session duration, collected automatically through cookies or other tracking technologies.
  • Any other information voluntarily provided by the data subject in communications with Stward Corporation.

The provision of this information by the user is voluntary. However, refusal to provide data that is essential for the provision of a given service may prevent that service from being handled or performed.

3. Purposes of Processing

The personal data collected will be processed in accordance with the purpose limitation principle set out in Article 9 of Law 81 of 2019, exclusively for the following purposes:

  • Responding to inquiries, information requests, requirements, and messages sent through the website.
  • Preparing and sending commercial proposals, quotes, and contractual documents.
  • Managing the pre-contractual and contractual relationship with clients and suppliers.
  • Monitoring contracted maritime and auxiliary services.
  • Complying with applicable legal, regulatory, and tax obligations in the Republic of Panama.
  • Maintaining administrative, accounting, and internal audit records.
  • Improving the quality of services and the browsing experience on the website.
  • Sending commercial communications, corporate news, or information about services, provided that the data subject has given prior, express authorization.

Personal data will not be processed for purposes other than those stated herein without the data subject’s prior, express, and informed consent, unless required or authorized by applicable law.

3.1 Processing of Job Applicant Data

When users voluntarily submit their resume through the website or through any other channel enabled by Stward Corporation, the personal data contained in that document will be processed exclusively for the purposes of evaluating, selecting, and potentially hiring personnel.

The information that may be collected includes, among others:

  • Full name and contact details.
  • Academic background.
  • Work experience and professional history.
  • Professional references.
  • Certifications, licenses, seafarer’s books, or other credentials required for the position.
  • Any other information voluntarily provided by the candidate.

Candidate data will only be accessible to authorized personnel in Stward Corporation’s Human Resources department and will not be shared with third parties, except with the candidate’s express authorization or as required by law.

If the candidate is not selected, Stward Corporation may retain their resume for a maximum period of two (2) years in order to consider them for future openings matching their profile, unless the data subject expressly requests the deletion of their data. Once that period has elapsed, the information will be securely deleted or anonymized.

The voluntary submission of a resume shall constitute an expression of consent to the processing of the data it contains, in accordance with the terms of this policy.

3.2 Special Categories or Sensitive Personal Data

Pursuant to Article 10 of Law 81 of 2019, Stward Corporation does not, as a general rule, collect or process special categories of sensitive personal data, understood as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify a natural person, health-related data, or data concerning a data subject’s sex life or sexual orientation.

In the personnel selection process, certain documents (such as seafarer’s books, medical fitness certificates, or other seafarer credentials) may contain information of a sensitive nature. In such cases, this data will only be processed with the candidate’s express consent, will be strictly limited to the purpose of assessing suitability for the position, and will not be disclosed to third parties without authorization.

4. Legal Basis for Processing

Pursuant to Article 9 of Law 81 of 2019, the processing of personal data is only lawful when one of the following legal bases applies:

  • Free, prior, express, unambiguous, and informed consent of the data subject.
  • Performance of a pre-contractual or contractual relationship to which the data subject is a party.
  • Compliance with a legal or regulatory obligation applicable to Stward Corporation.
  • Protection of the vital interests of the data subject or of a third party.
  • Legitimate interest of Stward Corporation or of a third-party recipient, provided that the fundamental rights and freedoms of the data subject do not prevail, in which case a proportionality analysis must be carried out.

Where processing is based on the data subject’s consent, the data subject shall have the right to withdraw it at any time, without affecting the lawfulness of processing carried out prior to such withdrawal.

5. Data Retention

In strict compliance with the principle of accuracy set out in Article 9 of Law 81 of 2019, we will ensure that your data remains accurate and up to date in accordance with the purposes for which it was collected.

The following guiding criteria will be adopted for retention periods:

  • Contact and communication data: for the duration of the active business relationship and for up to five (5) additional years for purposes of potential claims.
  • Contractual and tax data: in accordance with the minimum periods required by applicable Panamanian tax and commercial law.
  • Data of unselected job applicants: up to two (2) years, unless the data subject requests earlier deletion.
  • Browsing and cookie data: as indicated in Section 8 of this policy.

Once the purpose has been fulfilled or the legal retention period has expired, personal data will be irreversibly and securely deleted or anonymized, with no possibility of recovery or identification of the data subject.

6. Security Measures

Stward Corporation applies appropriate technical, administrative, and organizational measures to ensure a level of security appropriate to the risk posed by the processing of personal data, in compliance with Article 28 of Law 81 of 2019 and Articles 46 through 55 of Executive Decree No. 285 of 2021.

The measures implemented include, without limitation:

  • Logical access controls restricted to authorized personnel.
  • Use of encryption protocols for the transmission and storage of sensitive data.
  • Management and periodic rotation of access credentials.
  • Incident logging and auditing of access to personal data databases.
  • Staff training on personal data protection.
  • Execution of confidentiality agreements with staff and service providers.

In the event of a security incident that compromises personal data and poses a risk to the rights and freedoms of data subjects, Stward Corporation will adopt appropriate mitigation measures and will notify the National Authority for Transparency and Access to Information (ANTAI) within a maximum period of seventy-two (72) hours of becoming aware of the incident, in accordance with Article 57 of Executive Decree No. 285 of 2021. Where the breach poses a high risk to the rights and freedoms of data subjects, they will also be notified without undue delay.

7. Transfer and Disclosure of Data to Third Parties

Stward Corporation will not sell, rent, or otherwise commercialize data subjects’ personal data under any circumstances.

However, personal data may be disclosed or transferred to third parties exclusively in the following cases:

  • To competent judicial, administrative, or regulatory authorities, when required by applicable law or a judicial order.
  • To providers of technology services, web hosting, corporate email, IT support, and other third parties involved in operating the website or providing Stward Corporation’s services, acting as data processors and subject to strict confidentiality and security obligations.
  • To business partners or entities within the same corporate group, only when necessary for the performance of services contracted by the data subject, subject to the data subject’s prior consent where applicable.

Where service providers or third-party recipients are located outside the territory of the Republic of Panama, Stward Corporation will adopt appropriate safeguards to ensure a level of protection equivalent to that required by Law 81 of 2019, in accordance with Article 32 of that law and Chapter VII of Executive Decree No. 285 of 2021, including the execution of standard contractual clauses or verification of a recognized adequacy framework.

8. Use of Cookies and Similar Technologies

The Stward Corporation website may use cookies and similar technologies (tracking pixels, session identifiers, local storage, among others) for the following purposes:

  • Strictly necessary cookies: ensure the technical operation and security of the website. They do not require prior consent.
  • Analytics or measurement cookies: allow analysis of traffic and user browsing behavior to improve site performance. They require consent.
  • Preference or functionality cookies: allow the user’s settings or preferences to be remembered. They require consent.
  • Advertising or marketing cookies: allow relevant content to be displayed. If implemented, they will require prior express consent.

Cookies that require consent (analytics, preference, and advertising cookies) will not be activated until the user grants prior, free, and informed consent through the cookie management panel displayed on the first visit to the website. Users may modify or withdraw their preferences at any time through that panel, and may also configure their browser to reject or delete cookies. Disabling strictly necessary cookies may affect the proper functioning of the site.

Browsing data collected through analytics cookies will be anonymized or deleted within a maximum period of twenty-six (26) months, in accordance with international best practices.

9. Links to Third-Party Websites

The Stward Corporation website may contain hyperlinks to external pages. Stward Corporation is not responsible for the privacy policies, data processing practices, or content of such third-party sites.

Users are advised to review the privacy policy of each external site they visit before providing any personal data through it.

10. Rights of the Data Subject

Pursuant to Articles 17 through 23 of Law 81 of 2019 and Chapter V of Executive Decree No. 285 of 2021, the data subject is entitled to the following rights:

RIGHT DESCRIPTION
Access To know which personal data is being processed, for what purpose, and its origin.
Rectification To request the correction of inaccurate, incomplete, or outdated data.
Cancellation / Erasure To request the deletion of data once it is no longer necessary for the purpose that justified its collection, unless there is a legal obligation to retain it.
Objection To object to the processing of their data in certain circumstances, particularly when processing is based on the controller’s legitimate interest.
Portability To receive the data they have provided in a structured, commonly used, and machine-readable format, when technically feasible.
Withdrawal of Consent To withdraw previously given consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal.
Restriction of Processing To request the temporary suspension of the processing of their data when its accuracy is contested or when processing is unlawful, in accordance with Article 19 of Law 81 of 2019.

10.1 Procedure for Exercising Rights

To exercise any of the rights described above, the data subject or their legal representative must send a written request to the email address info@stwards.com, including at least the following:

  • Full name and a copy of an identity document (national ID, passport, or equivalent), in order to verify identity.
  • A clear description of the right to be exercised and of the data to which the request relates.
  • Any other information or documentation that facilitates locating and handling the request.

Stward Corporation will respond to requests within the periods established in Article 20 of Law 81 of 2019, specifically within a maximum of thirty (30) business days from receipt of the complete request, which may be extended for an equal period when the complexity or number of requests so warrants, upon prior notice to the data subject.

If the data subject believes that their request has not been adequately addressed, they may file a complaint with the National Authority for Transparency and Access to Information (ANTAI), in accordance with Article 21 of Law 81 of 2019.

11. Accuracy and Quality of Information

In compliance with the data quality principle set out in Article 9 of Law 81 of 2019, the data subject guarantees that the personal data provided is truthful, accurate, complete, and up to date.

The data subject agrees to notify Stward Corporation of any change to their personal data that is relevant to the purposes of processing. Stward Corporation will not be liable for any consequences arising from the data subject’s provision of inaccurate, incomplete, or outdated data.

12. Minors

The Stward Corporation website and its services are not directed at persons under eighteen (18) years of age. Stward Corporation does not knowingly collect personal data from minors.

If Stward Corporation becomes aware that it has collected personal data from a minor without the verifiable consent of their legal representative, it will immediately delete such information from its records. In case a legal representative identifies the processing of data belonging to a minor under their care, they may exercise the corresponding rights in accordance with the procedure described in Section 10.1.

13. Changes to This Privacy Policy

Stward Corporation reserves the right to update or modify this Privacy Policy at any time, in order to adapt it to regulatory, technological, or operational changes.

Any changes will be published on the website with an express indication of the update date and will take effect as of that date. If any changes involve substantially different processing of the data subject’s data, Stward Corporation will notify the data subject with reasonable advance notice through the available means, so that the data subject may exercise their right to object or to withdraw consent, as they deem appropriate.

Users are advised to periodically review this policy to stay informed about the processing of their personal data.

14. Supervisory Authority

The authority responsible for overseeing and enforcing compliance with Law 81 of 2019 in the Republic of Panama is the National Authority for Transparency and Access to Information (ANTAI), headquartered in Panama City.

The data subject may contact ANTAI to file complaints regarding the processing of their personal data by Stward Corporation, in accordance with the procedures established in the aforementioned law and its implementing regulations.

15. Contact and Support Channel

For inquiries, requests, or complaints related to this Privacy Policy and the protection of personal data, data subjects may contact:

Controller Stward Corporation — IT Data Protection
Email info@stwards.com
Teléfono (+507) 314-0714
Address Hi Point Building, 24th Floor, Avenida Federico Boyd, Bella Vista, Panama City
Business Hours Monday to Friday, 8:00 a.m. to 5:00 p.m.

Statement of Acceptance

By using the Stward Corporation website, the user declares that they have read, understood, and fully accepted this Privacy, Processing, and Personal Data Protection Policy, in compliance with Law 81 of 2019 of the Republic of Panama.