Privacy Policy

Last updated: October 2025

This Privacy Policy explains how JPN Agency Ltd (the Company, we, us) collects, uses, shares, and protects personal data when you visit our website, contact us, submit a CV, or engage with our crewing, payroll, recruitment, or yachting services. We process personal data in accordance with the EU General Data Protection Regulation 2016/679 (GDPR) and applicable national laws.

1. Controller and Contact

Controller: JPN Agency Ltd
Website: www.jpnagency.com
Contact for privacy matters: info@jpnagency.com
If a Data Protection Officer is appointed, the details will be provided here.

2. Scope and Who This Applies To

This Policy applies to clients, candidates, website visitors, suppliers, and other business contacts whose data we process in connection with our operations.

3. Categories of Personal Data

• Identity data - name, surname, date of birth, ID or passport number.
• Contact data - email address, telephone number, country of residence.
• Application data - CV and resume content, education, qualifications, licenses and certificates, references, employment history, right to work checks.
• Employment data - position, compensation details, schedules, evaluations, training records, compliance documentation.
• Technical data - IP address, device identifiers, browser type, pages visited, cookies and similar technologies.
• Communications data - inquiries, emails, messages, and notes of communications.
• Compliance data - information needed for due diligence, sanctions checks, prevention of fraud or abuse, and legal claims.

4. Sources of Personal Data

We obtain personal data directly from you, from your CV or application, from publicly available sources such as LinkedIn, from references you provide, from clients in the context of assignments, and from service providers that support our operations.

5. Purposes and Legal Bases

We process personal data for the purposes below and on the indicated legal bases under Article 6(1) GDPR:

• Recruitment, placement, and talent management including evaluating applications and conducting interviews - performance of a contract or steps prior to a contract (Art. 6(1)(b)) and legitimate interests (Art. 6(1)(f)).
• Service provision to clients including crewing, payroll, and yachting services - Art. 6(1)(b) and Art. 6(1)(f).
• Compliance with legal obligations including labor, tax, maritime, and safety regulations - Art. 6(1)(c).
• Security, fraud prevention, and protection of rights and property - Art. 6(1)(f).
• Website operation, analytics, and service improvement - Art. 6(1)(f); where required, consent for analytics cookies - Art. 6(1)(a).
• Marketing communications where permitted by law with an opt out at any time - Art. 6(1)(a) or Art. 6(1)(f), as applicable.

6. Special Categories of Data

We do not intentionally collect special categories of personal data. If processing is strictly necessary, such as medical fitness certifications in maritime contexts, we will rely on an appropriate legal basis under Article 9 GDPR and apply enhanced safeguards.

7. Children

Our services are not directed to children. If we learn that we have collected data from a child, we will take appropriate steps to delete it.

8. Disclosures and Recipients

We may share personal data with: hosting and IT providers, communications platforms, HR and payroll processors, compliance and background check providers, professional advisers, and competent authorities where required by law. We require recipients to process data securely and in accordance with our instructions and applicable law.

9. International Transfers

Where personal data is transferred outside the European Economic Area, we ensure an adequate level of protection using lawful transfer tools such as adequacy decisions or the European Commission Standard Contractual Clauses. Supplementary measures may be applied where appropriate.

10. Retention

We retain personal data only for as long as necessary for the purposes stated in this Policy, including to satisfy legal, accounting, or reporting requirements. Indicative periods: general inquiries up to 24 months; CVs and job applications up to 12 months unless you consent to a longer period; employment records for the statutory period required by law.

11. Security

We implement appropriate technical and organizational measures to protect personal data, including access controls, encryption where appropriate, staff training, confidentiality undertakings, and incident response procedures.

12. Your Rights

Under GDPR, you may have the following rights subject to conditions: access, rectification, erasure, restriction, objection, and data portability. Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal. You also have the right to lodge a complaint with a supervisory authority.

13. How To Exercise Your Rights

To exercise your rights or raise concerns, contact us at info@jpnagency.com. We may need to verify your identity before responding. We aim to respond within one month as required by law.

14. Cookies and Similar Technologies

We use cookies to operate the website, remember preferences, and analyze usage. Where required, we will obtain your consent before setting non-essential cookies. For details, see our Cookie Policy.

15. Changes to this Policy

We may update this Policy periodically. Significant changes will be posted on this page with an updated Last updated date.

16. Contact

For privacy inquiries, contact: info@jpnagency.com.