This Privacy Policy explains what personal data Supramarine collects, for what purposes and on what legal basis we process it, whom we may share it with, and what rights you have. It covers this website (the quote-request and job-application forms) and the freight-forwarding services we provide.
1. Data Controller
The controller of your personal data is SUPRAMARINE LLC, EDRPOU code 40753286, registered at: 65012, Odesa region, Odesa city, 15 Vidradna St., premises 4, floor 2. Offices: Odesa city, 15 Vidradna St. and Kyiv city, 17 Mykhaila Boichuka St. Contacts — see Section 12.
2. Personal data we process
- Quote-request form: name, phone, email and your shipment-request details.
- Job-application form: name, phone, email and an uploaded CV file and its contents.
- Marketing (attribution) data: campaign parameters (UTM) and ad click-identifiers stored in first-party cookies and attached to your request.
- Technical data: IP address, browser/device type, cookies — collected automatically to run and secure the site.
- Operational forwarding data: to perform our contracts we may process data of shippers/consignees, drivers, and data from shipping and customs documents.
- Business-contact data: names, roles and contact details of representatives of clients, partners and suppliers.
- Data received from third parties: to arrange a shipment we may receive some data not from you directly but from our clients or partners (e.g. data of consignees, drivers or contact persons involved in the shipment).
3. Purposes and legal bases
- Performance of a contract / steps at your request — handling requests, quotes, arranging and supporting shipments.
- Recruitment — communicating with candidates and making hiring decisions (steps prior to an employment contract / your consent).
- Compliance with legal obligations — accounting, tax, customs and other statutory requirements.
- Compliance & sanctions screening — checking counterparties and shipments against sanctions and export-control requirements (legal obligation / legitimate interest).
- Legitimate interests — operating and securing the site, measuring advertising effectiveness (attribution), communicating about your shipments, protecting our rights.
- Consent — marketing messages and non-essential (marketing/attribution) cookies; withdrawable at any time (for mailings, via the link in the email or by contacting us).
We do not sell your personal data.
4. Cookies
We use cookies and similar technologies (e.g., localStorage) to ensure the stable operation of the website and to analyze the effectiveness of our marketing channels. Cookies are categorized as follows:
- Necessary (Technical) Cookies — these are critically important for the proper functioning of the website. In particular, we use the pll_language cookie and data in your browser's localStorage to remember your preferred interface language. These data do not identify you personally and do not require prior consent, as the website cannot function properly without them.
- Marketing and Attribution Cookies — used to determine the source from which you navigated to our website (e.g., Google advertisements, social media, or partner resources). We store data regarding transition sources (UTM tags, advertising identifiers) for a period of up to 30 days. The processing of this data is carried out exclusively subject to your voluntary consent provided via the cookie banner on the website.
- Infrastructure Provider Cookies — our website uses protection and optimization services (e.g., Cloudflare). These cookies are necessary to identify safe traffic, protect against cyberattacks, and speed up content delivery.
Please note: As of the current date, the website does not use analytical cookies (such as Google Analytics) to track your behavior on the pages. Should analytical tools be implemented in the future, this section will be updated, and a corresponding request for your consent will appear on the website.
Managing Cookies: You may withdraw your consent or change your cookie settings at any time through your browser settings (blocking or deleting files). However, please note that disabling necessary cookies may result in the website not displaying correctly.
5. Recipients
- Our CRM — requests are forwarded there for handling by our managers.
- Providers acting on our behalf (processors): website hosting, email delivery, Cloudflare (CDN/security).
- Third-party services that load content on the page (and therefore receive your IP): Google (Google Fonts and an embedded Google Map on the offices page), Unsplash (images), and technical content-delivery services.
- Carriers, agents, partners and customs/public authorities — as needed to arrange your shipment and comply with law.
All recipients must keep the data confidential. We do not sell data.
6. International transfers
Given the international nature of our activities and the use of modern information technologies, your personal data may be transferred to and stored outside of Ukraine or the European Economic Area (EEA).
1. Use of international services: Some of the services we use (including, but not limited to: Google for corporate email and documents, Cloudflare for website protection, Unsplash for visual content) are located in the USA and other countries. We select providers that ensure a high level of security and use recognized international data protection mechanisms.
2. Logistics activities and foreign representative offices: To facilitate international transportation, we transfer necessary data (driver data, supporting documents for the cargo, recipient contact details) to our partners and representative offices abroad. Specifically, transfers may be made to countries such as: Poland, Bulgaria, the United Arab Emirates (UAE), and China.
3. Safeguards for transfer: Any transfer of data outside of Ukraine or the EEA is carried out exclusively subject to the availability of appropriate safeguards provided by law:
- Adequacy decision: For EU countries (e.g., Poland, Bulgaria) and other countries whose level of protection is recognized as adequate.
- Standard Contractual Clauses (SCCs): We use model contract terms approved by the European Commission in agreements with partners from countries that do not have an adequacy decision (specifically, the UAE and China).
- Specific consent: In certain cases (e.g., a one-time shipment on a non-standard route), the transfer may be carried out based on your separate, explicitly expressed consent for such a transfer.
We take all reasonable measures to ensure that your data is processed in these countries with the same level of protection that you have in Ukraine.
7. Retention
We store your personal data only for the period necessary to achieve the purposes defined by this Policy, or for the period established by the current legislation of Ukraine.
Specifically, the following retention periods apply:
- Applications for logistics services and requests for cost calculation that did not lead to a contract — 12 months from the date of the last communication (to allow for consultation and seasonal demand analysis).
- Resumes of candidates who were not hired — 6 months after the decision to reject or closure of the vacancy (after which the data is deleted unless the candidate has provided separate consent to be included in the talent pool).
- Data on the execution of transportation and transport documentation (copies of Consignment Notes/TTN, CMR, route data, driver and vehicle data) — 3 years from the moment of trip completion (based on the statutes of limitations for claims regarding service quality and loss/damage to cargo).
- Contract data, accounting and tax documents — during the period established by law for the storage of primary documentation and confirmation of tax obligations, but not less than 1095 days (3 years) from the end of the reporting period.
- GPS monitoring and cargo tracking data — 6 months (a period sufficient for the resolution of operational disputes regarding delivery terms).
After the completion of the specified periods or in case of your withdrawal of consent to data processing (if storage is not mandatory by law), we undertake to delete your data or anonymize it (transform it into anonymous data that does not allow for identifying the person).
8. Security
We apply organisational and technical measures (access controls, encryption of transmission channels, internal security policies) to protect data against unauthorised access, loss, alteration or disclosure.
9. Your rights
You have the right: to know about the sources of your data collection and the purpose of processing; to access and a copy of data; rectification; erasure ("the right to be forgotten"); restriction of processing; objection to processing; data portability; withdrawal of consent. We consider requests regarding your rights within 30 calendar days. We do not make decisions with legal consequences solely on the basis of automated processing. A complaint can be filed with the Ukrainian Parliament Commissioner for Human Rights.
10. Children
The Website and services of the Company are not addressed to persons under 18 years of age. We do not knowingly collect or process personal data of minors. If we become aware that we have received personal data of a person who has not reached the age of 18 without the consent of parents or legal representatives, we will take measures to immediately delete such information from our servers.
11. Changes to this Policy
We may update this Policy; the current version and effective date appear at the top of the page. We will communicate material changes by available means.
12. Contact
For privacy matters and to exercise your rights: [email protected], phone +380 63 180 13 03. Offices: 15 Vidradna St., Odesa; 17 Mykhaila Boychuka St., Kyiv.
13. Governing law
Processing is carried out in accordance with the Law of Ukraine "On Protection of Personal Data", as well as the General Data Protection Regulation (EU General Data Protection Regulation, GDPR), if you are located in the territory of the European Union or if our services are provided to data subjects in the EU.
