Oy Sumu Logistics Ltd (“Sumu Logistics”, “we”, “us”) is a tanker brokerage registered in Finland. We are the data controller for the personal data described in this policy.
Oy Sumu Logistics Ltd
Ahotie 12 B, 02940 Espoo, Finland
Business ID (Y-tunnus): 3566076-2
Email: chartering@sumulogistics.com
Telephone: +358 40 965 8851
This policy explains how we handle personal data belonging to:
We do not provide services to consumers, and we do not knowingly process the personal data of children.
Business contact details. Name, employer, job title, business email address, business telephone number and other professional contact information — obtained from you directly, from your employer’s public materials, from our correspondence, or from commercial maritime industry sources.
Business correspondence. The content of business communications between us and our counterparties, including email and business messaging services such as WhatsApp Business. For chartering negotiations this includes messages about vessels, cargoes, positions, dates and commercial terms, together with the time each message was sent and the business number or address it came from.
Website usage data. Basic technical information such as IP address and browser type when you visit our website.
We do not collect special categories of personal data, and we do not process personal data for advertising or profiling.
| Purpose | Legal basis (GDPR Article 6) |
|---|---|
| Negotiating, concluding and performing chartering business | Performance of a contract, or steps taken at your request before entering into one — Art. 6(1)(b) |
| Keeping an accurate record of negotiations, offers, counters and fixtures | Legitimate interests — Art. 6(1)(f): maintaining a reliable commercial record, resolving disputes about what was agreed, and operating the brokerage |
| Complying with legal, accounting and sanctions-screening obligations | Legal obligation — Art. 6(1)(c) |
| Maintaining ordinary business relationships and communications | Legitimate interests — Art. 6(1)(f) |
A note on business messaging. Chartering is negotiated in writing across email and messaging apps, and the record of who offered what, and when, is central to our work. We record business correspondence conducted with us in the ordinary course of that business, including messages exchanged on WhatsApp Business, and store it in our own internal systems. We do this to keep an accurate account of commercial negotiations. We do not record private or personal communications, and we do not use message content for any purpose beyond conducting and documenting our business.
Our systems run on Google Cloud Platform, in data centres located in the European Union (Finland and other EU regions). Business correspondence and contact records are held within the EU.
Where a service provider processes data outside the EU or EEA, we rely on an adequacy decision or on the European Commission’s Standard Contractual Clauses.
We do not sell personal data, and we do not share it for marketing purposes. We share personal data only:
We keep business correspondence and transaction records for as long as needed for the commercial relationship, and thereafter for the period required by Finnish accounting and commercial law and by any applicable limitation period — normally ten years from the end of the relevant transaction. Contact details are kept while the relationship remains active and are reviewed periodically.
Under the GDPR you may ask us to:
To make a request, write to chartering@sumulogistics.com. We answer within one month.
If you are not satisfied with our response, you may complain to the Finnish Data Protection Ombudsman (Tietosuojavaltuutetun toimisto, tietosuoja.fi) or to the supervisory authority in your own country.
Access to our systems is restricted to authorised personnel and protected by authentication controls, with encryption in transit and at rest. Message and correspondence data is held in EU-hosted infrastructure under our own control.
We may update this policy from time to time. The current version is always published at this address, with the date it was last updated shown at the top.