Privacy Policy

Last reviewed: 24 August 2026

Your personal information, provided for the purpose of registering on SEAJOBS as a candidate or company, will be held and processed by Liberty Dreams LTD — Carpenter Court, 1 Maple Road, Bramhall, Stockport SK7 2DH, United Kingdom. Liberty Dreams LTD is the data controller for this information. This also includes situations where the data is collected or processed by third parties on our behalf.

The Data Protection Officer (DPO) can be contacted at: oliver@libertydreams.co.uk.

This Privacy Policy describes how and why we collect data for the purposes of SEAJOBS, how your data is used, and your rights.

1. Categories of data subjects

SEAJOBS processes personal data of three categories of data subjects:

• Maritime candidates — professionals who register to access company profiles and embarkation offers.
• Companies — shipping companies and maritime operators registered to consult candidate profiles.
• Website visitors — anyone browsing seajobs.libertydreams.co.uk.

2. Data we collect

2.1. From maritime candidates

• Identification data: first name, last name, date of birth, nationality, national ID number (DNI/NIF or equivalent).
• Contact data: email address, phone number, postal address, city, country.
• Professional data: qualifications, years of experience, STCW certifications, medical fitness certificates, Seaman's Book, languages.
• Documentation: photograph, curriculum vitae, criminal record certificates where applicable.
• Usage data: applications submitted, messages exchanged with companies, ratings received.

2.2. From companies

• Company identification data: legal name, address, country, website, tax identification number.
• Account contact person data: first name, last name, email address, phone number.
• Logos and descriptions: voluntarily provided by the company.
• Billing data: managed externally through WHMCS (GoCardless, PayPal); see Annex A — Data processors.

2.3. From website visitors

• Technical data: IP address, browser type, operating system, language, pages visited, time on page.
• Cookies: only with your prior consent (except strictly necessary); see our Cookie Policy.

3. Purposes of processing

Liberty Dreams LTD collects, processes and shares personal data for the following purposes:

• Managing user registration and account on SEAJOBS.
• Facilitating intermediation between qualified candidates and registered shipping companies, in accordance with the Maritime Labour Convention (MLC) 2006 and the STCW Convention.
• Verifying the professional suitability of candidates (review of certifications and documents).
• Managing billing and collection of services contracted by companies, through WHMCS.
• Sending operational communications related to the service (notifications, certificate alerts, application messages).
• Complying with legal and tax obligations (HMRC, Companies House, ICO).
• Improving the website through aggregated usage analytics (only with consent for cookies).

4. Lawful basis for processing

Under UK GDPR, the lawful bases for processing your personal data are:

4.1. Consent (art. 6.1.a)

For non-essential cookies, marketing communications and any processing requiring opt-in under PECR.

4.2. Performance of a contract (art. 6.1.b)

For provision of the matching service, account management and any action necessary for the performance of the terms and conditions accepted at registration.

4.3. Compliance with a legal obligation (art. 6.1.c)

For tax obligations (HMRC), company law obligations (Companies House), cooperation with authorities, and compliance with MLC 2006 and STCW in verifying maritime certifications.

4.4. Legitimate interests (art. 6.1.f)

For operational communications, platform security, fraud prevention and basic suitability checks. In these cases, Liberty Dreams LTD has conducted a Legitimate Interests Assessment (LIA) documenting that the legitimate interest is not overridden by the data subject's rights and freedoms.

4.5. Special categories of data

Where we process special category data (e.g. medical certificates, criminal records), we rely on:

• Art. 9.2.b UK GDPR — obligations and rights in the employment context.
• Art. 9.2.g UK GDPR — substantial public interest reasons, under Schedule 1 part 2 of the Data Protection Act 2018.

5. Recipients and data processors

SEAJOBS currently works with shipping companies and maritime service providers registered in the United Kingdom and the European Union. Transfers to companies located outside these territories require a separate Data Processing Agreement signed on a case-by-case basis, in accordance with UK GDPR art. 46.

Your personal data may be shared with the following data processors, with whom Liberty Dreams LTD maintains the corresponding Data Processing Agreements (DPAs):

Annex A — Data processors

Processor	Purpose	Location
Krystal Hosting UK	Database and file hosting	United Kingdom
Mautic (self-hosted)	Email marketing and campaign tracking	United Kingdom (own server)
WHMCS (billing platform)	Client, subscription and invoice management	United Kingdom
GoCardless (payment processor)	Direct debit (IBAN, address)	United Kingdom / Ireland
PayPal (payment processor)	Card / PayPal account payments	United States (SCCs adopted by EU/UK)
Google Analytics 4 (web analytics)	Aggregated usage statistics	United States (SCCs adopted by EU/UK)
Registered shipping companies	Access to approved candidate profiles	United Kingdom and European Union

We do not sell or transfer your personal data to third parties for our own commercial purposes.

6. International transfers

Transfers of data to processors in the United States (PayPal, Google Analytics) are covered by the Standard Contractual Clauses (SCCs) adopted by the European Commission (Decision 2021/914) and recognised by the United Kingdom (International Data Transfer Agreement and UK Addendum).

Transfers to recipient companies not located in the United Kingdom or the European Union will require a specific Data Processing Agreement before any access to personal data.

7. Storing your information

Data category	Retention period
Inactive candidate account	36 months from last activity, then anonymisation
CV, photograph and certificates	30 days after account anonymisation
Inactive company account	48 months from last activity
Billing data	7 years (HMRC tax obligation)
Job applications	5 years or while the account is active
Platform messages	36 months
STCW / MLC certificates	7 years
Audit and access logs	24 months
Backups	3 months rotation
GDPR request tickets	6 years (defence of claims)

Once the indicated periods have elapsed, the data is irreversibly deleted or anonymised.

8. Your rights

Under UK GDPR, you have the following rights:

8.1. Right of access (art. 15)

To request a copy of the personal data we hold about you. This right is commonly known as a Subject Access Request (SAR). You can exercise it through our Data Rights form or by writing to tickets@libertydreams.co.uk.

8.2. Right to rectification (art. 16)

To correct inaccurate or incomplete data. You can do this directly from your profile or by emailing us.

8.3. Right to erasure / "right to be forgotten" (art. 17)

To request deletion of your data where applicable. Please note that we may retain certain data where we have a legal obligation to do so (e.g. billing data for 7 years).

8.4. Right to restriction of processing (art. 18)

To request that we limit processing in certain circumstances (e.g. while the accuracy of data is being verified).

8.5. Right to data portability (art. 20)

To receive your data in a structured, commonly used and machine-readable format (JSON). Authenticated candidates can download their data directly from Export my data.

8.6. Right to object (art. 21)

To object to processing based on legitimate interests, including direct marketing communications.

8.7. Right not to be subject to automated decision-making (art. 22)

Not to be subject to decisions based solely on automated processing without human intervention. SEAJOBS does not make automated decisions with legal effects on you.

8.8. Right to withdraw consent (art. 7.3)

Where processing is based on your consent, you may withdraw it at any time, without retroactive effect. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, write to tickets@libertydreams.co.uk indicating which right you wish to exercise and attaching a copy of an identity document. We will respond within a maximum period of one month from receipt of your request. If your request is complex, we may extend this period by a further two months, informing you of the extension within the initial one-month period.

9. Complaints to the ICO

If you consider that our processing of your personal data infringes data protection legislation, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk/make-a-complaint
• Telephone: 0303 123 1113
• Postal address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom

You may also lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.

10. Changes to this policy

Liberty Dreams LTD reserves the right to modify this Privacy Policy to reflect legal, technical or commercial changes. When material changes occur, we will notify you through a visible notice on the platform and, where appropriate, request your consent again. We recommend reviewing this page periodically. The date of the last review is indicated at the top of this document.

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Last reviewed: 24 August 2026.