Privacy Policy

Protecting your privacy is very important to IFCHOR ClearBlue Oceans. We are committed to maintaining the security of all Personal Information provided to IFCHOR ClearBlue Oceans, whether by individuals with whom we do business, visitors to and users of our websites or otherwise. This Privacy Policy details how we collect, use and manage this Personal Information.

For the purposes of this Privacy Policy and applicable data protection and privacy laws:

“Personal Information” is defined as information and data, whether recorded in a material form or not, relating to an identified or identifiable natural person that is processed by or on behalf of IFCHOR ClearBlue Oceans, whether or not by automated means; and

IFCHOR ClearBlue Oceans is considered the “data controller” in respect of the Personal Information that it collects, uses and manages in connection with this Privacy Policy.

Whose information do we collect?

IFCHOR ClearBlue Oceans collects Personal Information from a range of individuals in the context of its business activities, including:

  • representatives of our suppliers, customers, sponsors and business partners;
  • contractors;
  • industry association representatives;
  • users of the IFCHOR ClearBlue Oceans website; and
  • job applicants.

What information we collect and why we collect it

We collect Personal Information from you where it is relevant for our legitimate business (defined as ‘Legitimate Interests’ under GDPR) purposes as further detailed below.

Business use

IFCHOR ClearBlue Oceans may collect a range of information in a business context, such as your name, gender, job title, photographic identification, email address, home address and other contact details, details of your business and other interests, experience and/or academic and professional qualifications, third party references, communications with you (including notes from meetings and telephone call recordings), feedback or survey responses that you provide to us, financial and payment information, and information collected from clearance questionnaires and/or interviews.

IFCHOR ClearBlue Oceans uses information collected from you for legitimate business-related purposes, including negotiating, concluding and performing contracts, managing business relationships, administering licences, recruitment, conducting clearance procedures, managing accounts and records, direct marketing, communicating with you and third-party contacts, supporting corporate social responsibility activities, security, legal, regulatory and internal investigations.

By ‘Legitimate Interest’ we mean the interest of IFCHOR ClearBlue Oceans in managing and conducting our activities to provide you with the best possible service and/or products in the best and most secure way. When using your personal information for our legitimate interests, IFCHOR ClearBlue Oceans does so considering any positive or negative impact on you and your rights under data protection laws.

IFCHOR ClearBlue Oceans assumes to have a relevant and appropriate relationship with you as you are a current, past or potential client. Unless otherwise advised, IFCHOR ClearBlue Oceans believes that you have reasonable expectations that your data will be processed and used by us to communicate with you.

Our website

When you use our website, IFCHOR ClearBlue Oceans collects certain standard information that is sent by your browser to our website. This includes technical information, such as your IP address, browser type, operating system, language, time zone setting, access times and any referring website addresses.

IFCHOR ClearBlue Oceans uses this information to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. IFCHOR ClearBlue Oceans also collects certain information to provide users with a personalised experience when visiting our websites. Through the use of a ‘cookie’, IFCHOR ClearBlue Oceans records information about your visit to our website including the clickstream to, through and from our site (including date and time), the pages visited, page interaction information and methods used to browse away from the page. This information is used anonymously and in aggregate and is collected and logged for statistical purposes. Through analysis of these records, IFCHOR ClearBlue Oceans is able to provide an improved service when users revisit our websites. See below for further information on our use of cookies and related technologies.

Other than as stated in this Privacy Policy, no attempt is made to identify our website users or their browsing activities except:

where a law enforcement agency exercises a warrant to inspect logs or any such information is otherwise required to be produced by IFCHOR ClearBlue Oceans to authorities or regulators; or

where IFCHOR ClearBlue Oceans believes it is required to collect and produce relevant electronic documentation to fulfil its obligations to third parties, including statutory organisations under local law.

Access to other websites via hyperlink

Other websites that may be accessible via hyperlinks from the IFCHOR ClearBlue Oceans website are owned and operated by third parties and are not subject to the IFCHOR ClearBlue Oceans Privacy Policy. IFCHOR ClearBlue Oceans has no control over the content of those websites. Please review the privacy policy of each individual website you access and assess whether the policy is satisfactory to you before you use the other websites.

Cookies & Related Technologies

Our websites and mobile applications (“apps”) use cookies. A cookie is a small text file that is placed on your computer or mobile device when you visit a website or use an app. Cookies collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or app. A cookie cannot read data from your hard disk or read cookie files created by other websites.

IFCHOR ClearBlue Oceans uses cookies and other technologies to facilitate your internet sessions and use of our apps, offer you services according to your preferred settings, track use of our websites and apps and to compile statistics about activities carried out on our web sites and/or through our apps.

You may set up your web browser to block cookies or remove cookies stored from your computer or mobile device. However, if you do so, you may not be able to use certain features and functions of our websites and apps.

Providing Personal Information

At times, IFCHOR ClearBlue Oceans may ask you to voluntarily supply Personal Information, such as your name, email address, location, telephone number and preferred means of communication, for purposes such as subscribing to IFCHOR ClearBlue Oceans news alerts, reports or requesting further information from IFCHOR ClearBlue Oceans including through the Contact us form available on our website.

Where we ask you to voluntarily supply Personal Information, we will use it to provide you with the information or services that you have requested from us.

Sensitive Personal Information

Sensitive Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or medical conditions, genetic or biometric information, sexual orientation, or criminal convictions and offences may be processed by IFCHOR ClearBlue Oceans if such processing is necessary to comply with laws and regulations or where you provide this information voluntarily or otherwise consent for us to do so.

Email monitoring

IFCHOR ClearBlue Oceans may monitor emails sent to and from its workforce, which may contain Personal Information relating to third parties. The information contained in such emails may be used for legitimate business-related purposes. Although IFCHOR ClearBlue Oceans endeavours not to review the contents of personal emails, there may be occasions on which this is necessary, for example, to investigate a breach of security within IFCHOR ClearBlue Oceans, or in the context of legal proceedings.

The legal basis for IFCHOR ClearBlue Oceans processing your Personal Information

To comply with applicable data protection and privacy laws, IFCHOR ClearBlue Oceans is required to set out the legal basis for the processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for IFCHOR ClearBlue Oceans processing your Personal Information will typically be one of the following:

Your consent;

the performance of a contract that we have in place with you or other individuals;

IFCHOR ClearBlue Oceans or our third-parties’ legitimate business interests; or

compliance with our legal obligations.

Disclosure of the information we collect

IFCHOR ClearBlue Oceans may share your Personal Information with people within the company who need to know that information for business or legal reasons, for example, in order to carry out an administrative function such as processing an invoice, or to direct a query that you have submitted to the relevant department within IFCHOR ClearBlue Oceans.

We may disclose your Personal Information to third parties including the authorities, IFCHOR ClearBlue Oceans’ advisors, suppliers of IT services and third parties engaged by IFCHOR ClearBlue Oceans for the purpose of providing services requested by you; to protect any intellectual property rights in any materials displayed on or otherwise available from IFCHOR ClearBlue Oceans’ website; for the purposes of seeking legal or other professional advice; to respond to a legal request or comply with a legal obligation.

We may disclose your Personal Information to third parties in the event we sell, buy or merge any business or assets, including to the prospective seller or buyer of such business or assets. IFCHOR ClearBlue Oceans may also disclose the Personal Information you provide to us via the IFCHOR ClearBlue Oceans job vacancy website to IFCHOR ClearBlue Oceans HR practitioners, IFCHOR ClearBlue Oceans Hiring Managers and to IFCHOR ClearBlue Oceans’ recruitment advisors for the purpose of considering you for career opportunities with IFCHOR ClearBlue Oceans.

Because IFCHOR ClearBlue Oceans operates globally, we may share the Personal Information you submit to us with any entity within the IFCHOR ClearBlue Oceans group worldwide. These entities are required to maintain the confidentiality of this information and are restricted from using it for any purpose other than the purposes set out in this Privacy Policy.

Transfer of your Personal Information to other countries

Please note that any person to whom IFCHOR ClearBlue Oceans may disclose your Personal Information under this Privacy Policy may be situated in a country other than your own and that such country may provide a lower level of data protection requirements than your own country. By agreeing to this Privacy Policy, you consent to the transfer of your Personal Information to a country other than your own.

Whenever we transfer Personal Information across borders, we take steps to put in place adequate safeguards to protect your Personal Information and to make sure it is treated in accordance with this Privacy Policy. If you are located in the European Economic Area or the UK, you can request a copy of the safeguards which we have put in place to protect your Personal Information and privacy rights in these circumstances, using the Contact us form available on our website.

Access to IFCHOR ClearBlue Oceans e-business websites

Access to certain IFCHOR ClearBlue Oceans e-Business websites or portals may be provided to IFCHOR ClearBlue Oceans’ customers, or suppliers in order to conduct e-commerce transactions or for supplier management purposes. Users of IFCHOR ClearBlue Oceans e-Business websites or portals may be required to register with the membership database by providing their e-mail address; their name, company name, office name; their business address, business phone; and a valid IFCHOR ClearBlue Oceans internal contact name.

IFCHOR ClearBlue Oceans will collect details in the membership database that are relevant to the use of the e-Business website. While IFCHOR ClearBlue Oceans will use the registration details for demographic analysis and to personalise your web experience, IFCHOR ClearBlue Oceans will not make membership details available to external parties.

Retention of Personal Information

IFCHOR ClearBlue Oceans’ aim is to keep your Personal Information for no longer than is necessary for regulatory or IFCHOR ClearBlue Oceans business reasons. The amount of time that records are kept for varies depending upon the type of Personal Information they contain.

Your rights in relation to your Personal Information

If you would like to access or obtain a copy (which may be in machine-readable form) of the Personal Information IFCHOR ClearBlue Oceans holds about you, please send a request to ‘General Enquiries’ on the Contact us form available on our website.

IFCHOR ClearBlue Oceans endeavours to ensure that the Personal Information it holds about you is complete, accurate and up to date. If you consider that your Personal Information is incomplete, inaccurate or out of date, you have the right to require us to correct it. To correct, erase or limit the processing of any of the Personal Information we hold about you, again please send a request via the form on our website.

If you have a live account with our job vacancy website, and we continue to process your Personal Information in connection with that account (see the section headed ‘Job vacancy website’ above for information regarding retention timeframes), you can at all times complete, update or otherwise rectify your Personal Information by logging into your account via the applicant login section of our website.

You may remove any Personal Information you provided to us via IFCHOR ClearBlue Oceans’  job vacancy website at any time.

If you do not provide us with the information sought in the required fields we may be limited in our ability to provide you with services.

Complaints and Concerns

If you have a concern or complaint about how IFCHOR ClearBlue Oceans has used your Personal Information, as a first step, you should raise this in writing with IFCHOR ClearBlue Oceans, using the contact details available on our website or via the Contact Us form.

If you are not satisfied with the handling of your concern or complaint by IFCHOR ClearBlue Oceans, you can escalate this to your national Data Protection Authority.

Changes to this Privacy Policy and Contact

Any changes IFCHOR ClearBlue Oceans may make to this Privacy Policy in the future will be posted on this page. Questions, comments and requests regarding this Privacy Policy are welcomed and should be submitted via the Contact Us form available on our website.

Who we are

References to IFCHOR ClearBlue Oceans in this Privacy Policy mean IFCHOR SA – Rue de l’Horloge 10, c/o BSB Service SA, 1164 Buchillon, Switzerland and ClearBlue Markets Europe B.V., Aquamarijn 6, 1382KJ, The Netherlands.

Use of ‘Google Analytics’

This website uses ‘Google Analytics’, a web analytics service provided by Google Inc. (‘Google‘). ‘Google Analytics’ uses ‘cookies’ that allow an analysis of the use of the website by you.

The information generated by these ‘cookies’ is usually transmitted to and stored by Google on servers in the USA.

However, this website uses ‘Google Analytics’ with the extension ‘_anonymizeIp ()’. As a result, IP addresses are processed in a shortened form, which means that direct personal contact information is not stored.

In addition, you may prevent the collection by Google of the data generated by the ‘cookie’ and related to your use of the website (including your IP address) as well as the processing of this data by Google. To prevent Google collecting your data you will need to download the browser plug-in available under the following link and install it on your computer:…

The use of ‘Google Analytics’ is in accordance with the conditions that the local data protection authorities agreed with Google.

Google Dublin, Google Ireland Limited
Gordon House, Barrow Street
Dublin 4
Fax: +353 (0) 1436 1001……

Google Inc.
1600 Amphitheatre Parkway
Mountain View
CA 94043
Fax: +1 650 253 0001

Usage of Social Media Plug-ins

We do not use social media plug-ins.

Transmission of data in the Internet

Although every effort is made to protect data transmission, we point out that data transmission on the Internet can suffer security breaches. A complete protection of the data is not possible and cannot be guaranteed.

Governing law, jurisdiction

The English substantive law will be applicable to the exclusion of the clauses referring to foreign law provided in the law on international private law. The place of jurisdiction will be London, UK.

Last updated on 6 April 2021