Privacy Policy

Last updated: 17/09/2020

Roles and responsibility

OHT is a specialized heavy transport and installation contractor. OHT Management AS is a daughter company of OHT ASA (OHT) and is responsible for management on behalf of OHT. OHT Management AS carries out its services together with its subsidiaries OHT USA LLC, OHT Renewables UK Ltd. and OHT Management AS (DMCC Branch).

This Site is operated by OHT Management AS and has been created to provide information to our clients and visitors of the Site about our company and its services (‘Services’). When using this Site, OHT Management will be the controller for any Personal Data collected through the use of this Site.

When you use our Services, you may enter into a contract with one or more of our group companies (together with OHT and OHT Management AS referred to as the ‘OHT Group’), depending on the service you need and the location of the contract performance.

Some companies in the OHT Group own a vessel (‘Vessel Company’). If a client is in need of services from one of our vessels, a contract will be entered into between the client and the Vessel Company which owns the ship responsible for the given project. When such a contract is in force, the responsible Vessel Company will be the ‘controller’ concerning the Personal Data collected in order to carry out the terms of the contract.

For the collection and processing of Personal Data outside the Site and not in relation to the Vessel Companies, OHT Management AS will be the controller.

The OHT Group operates worldwide. Because the local practices and legal requirements in the countries we operate in are different, our privacy practices may vary accordingly.

What is Personal Data?

Personal Data is information and assessments regarding an individual that can be traced back to that particular individual. Typical examples are names, e-mail addresses and telephone numbers.

OHT is concerned with protecting the privacy and Personal Data of our clients and visitors/users of the Site and our Services in a responsible way. Should you have any questions regarding how we handle Personal Data, you may send an enquiry to contact@oht.no. If you want to get in touch with any of our offices or companies directly, please follow this link to find the relevant contact information: https://www.oht.no/contact-us/

Purposes, types of information and legal basis

Below, we have listed the purposes for which we will process Personal Data, the legal bases for the processing and the types of information comprised.

Inquiries

The OHT Group processes Personal Data in order to follow up on your inquiry, e.g. about a potential client, supplier- or employment relationship. This may include your contact information; name, postal or e-mail address and phone number, as well as your business contact information; job title, department and name of organisation.

The legal basis for processing your Personal Data is our legitimate interests to operate and improve our business, cf. GDPR Article 6 (1) a) and f).

Access to and usage of the Site and Services

The OHT Group processes Personal Data in order to provide you with quotation/ contract for a project execution of our services.

When you contact the OHT Group, through either e-mail or the contact form on this Site, the OHT Group receives and stores certain information automatically. This can be done automatically, through various technologies, and cannot presently be used to identify you. It can also be done manually. If you choose to fill out the contact form on our Site, we will also collect and process this information about you in order to answer your request and potentially enter into a client or supplier relationship with you. The OHT Group may also store such information in a database, owned and maintained by OHT affiliates in order to provide our services to you.

The legal basis for processing your Personal Data as described in this section is our legitimate interests to operate and improve our business, cf. GDPR Article 6 (1) f).

Project execution

If there is an established client relationship, the OHT Group needs to process certain personal information about the client in order to fulfill contractual obligations. This information is inserted on an online platform operated by OHT Management, and can be accessed by the members of the OHT Group. The information the OHT Group gathers in this respect is necessary to begin, execute and finish projects, and includes Personal Data about the client such as name, address, e-mail, phone number, business contact information, account information and client’s product insurance status.

The legal basis for processing your Personal Data is our legitimate interests to operate and improve our business, cf. GDPR Article 6 (1) f).

Marketing

The OHT Group aims to help you make the most of the offers provided by us. Therefore, both the OHT Group and our affiliates may process Personal Data and other information shared by you to the OHT Group in order to provide, administer and communicate future services we believe will be of interest to you (please see chapter “Your Rights” below). If we use a company or client name in marketing, or client photos where the company name is visible, we ask for your consent first. We use marketing by following up on future projects through e-mail.

The legal basis for processing your Personal Data as described in this section is your consent and our legitimate interests to operate and improve our business, cf. GDPR Article 6 (1) a) and f).

Evaluation

The OHT Group and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and non-identifiable information collected through the Services to help us operate, evaluate and improve the content and functionality of the Services and the Site, to better understand our users, and to improve the Services and this Site.

The legal basis for processing your Personal Data is our legitimate interests to operate and improve our business cf. GDPR Article 6 (1) f).

Laws and regulations, judicial processes or governmental agency

The OHT Group will also process your Personal Data if applicable laws and regulations require it, or if requested by any judicial process or governmental agency having or claiming jurisdiction over the OHT Group or our Related Companies.

The legal basis for processing your Personal Data is compliance with a legal obligation to which the controller is subject, cf. GDPR Article 6 (1) c).

Third party disclosure

You may choose to consent to third parties disclosing information about you to us that those third parties have collected.

The legal basis for processing your Personal Data is your consent, cf. GDPR Article 6 (1) a).

Added information about data subjects

Information about other person(s) than yourself

If you provide OHT with any information or material relating to another person(s), you are responsible for making sure that the sharing with us, and our further use as described to you, are in line with applicable laws at all times.

Access to Personal Data

The OHT Group takes your privacy seriously, and we view this information as a vital part of our relationship with you. We do not sell your information to others. However, the OHT Group may disclose your Personal Data under certain circumstances, as set forth in the following list:

Business Transfers

As the OHT Group develops its business, we reserve the right to transfer the Personal Data we hold in the event of a corporate sale, merger, reorganization, dissolution or similar event relating to all or part of our business. Should such reorganization occur, we will use reasonable efforts to direct the transferee to use Personal Data you have provided to us in a manner that is consistent with our Privacy Policy. Following such an event, you may contact the entity to which we transferred your Personal Data with any inquiries concerning the processing of that information.

Related companies and sub-contractors

In provision of the Services, the OHT Group may also share your Personal Data with other companies within or outside the OHT Group, for purposes consistent with, and subject to, this Privacy Policy.

In order for the Vessel Companies to carry out and fulfill their contractual obligations, the Vessel Companies use support functions in other companies and sub-contractors of the OHT Group. For example, OHT Management, as a party of the OHT Group, carries out such support functions on behalf of the Vessel Companies. These support functions include operating the Site, handling contact forms sent in by potential clients and others, providing client information to the online platform and responding to e-mails from potential or existing clients. In this respect, OHT Management will collect and process your personal information on behalf of the Vessel Company.

The Vessel Companies also use companies and sub-contractors outside the OHT Group. The OHT Group has a sub-contractor that is responsible for technical management and crew management on our vessels (Songa Shipmanagement Ltd, Scotland). During project execution, they will receive client contact information to be able to communicate with client operational departments.

Agents, Consultants and Related Third Parties

OHT retains third party vendors or service providers to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments (“Support Services”).

When we employ another entity to provide Support Services, we only provide them with the information that they need to perform their specific function and authorize them to use or disclose your information only as necessary to perform Support Services on our behalf or comply with legal requirements. We require these service providers by contract to safeguard the privacy and security of Personal Data they process on our behalf.

Legal Requirements

OHT may disclose your Personal Data if:

1. required to do so by EU law; or
2. in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of OHT, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

International Data Transfers

In order for OHT to offer its services, we may need to transfer information, including Personal Data, to OHT offices or servers located in several countries, both within and outside the EU/EEA. Data protection laws and standards vary from country to country. When OHT transfers information to other countries we will, to the best of our ability, protect your Personal Data in line with this Privacy Policy, or as otherwise disclosed to you at the time the data is collected. We comply the EU Standard contractual clauses providing adequate safeguards for the transfer of personal information to countries outside of the European Economic Area (“EEA”) or Switzerland.

Links to Other Web Sites

This Privacy Policy applies only to the Services and this Site. This Site may contain links to other websites not operated or controlled by OHT (the “Third Party Sites”). When you enter such a site, OHT is not responsible for Third Party Sites’ content, any use of the Third Party Sites, or the privacy practices of Third Party Sites. We encourage you to review the Third Party Sites’ own privacy policies if you have questions or concerns regarding how they handle Personal Data.

Security of processing

The protection of Personal Data is important to the OHT Group, and we take reasonable steps to do so with the Personal Data provided via the Services and the Site. We maintain administrative, technical and physical safeguards designed to protect the Personal Data collected by us or provided by you, against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Examples of safeguards used are password-protected invoices, e-mail phishing campaigns to discover unprotected areas within the Company, internal information to employees about security measures and the possibility of controlling and deleting data on stolen or lost employee mobile phones.

However, no Internet or email transmission is ever fully secure or error free. In light of this, you should be mindful whenever you provide information to the OHT Group through e-mail, or whenever you disclose any Personal Data to the OHT Group via the Internet.

Deletion

OHT stores Personal Data only for as long as it is necessary for the fulfillment of the purpose for which the Personal Data was collected. Contact details may be collected for a longer period due to future possible projects. If the storage of Personal Data is required or authorized by EU law, it may also be stored longer. We take measures to destroy or permanently anonymise personal information if required by law, or if the Personal Data is no longer required for the purpose for which we collected it.

Your Rights

We appreciate your feedback. Below, you will find your rights in accordance with applicable laws and regulations. You may assert them by contacting us through e-mail: contact@oht.no.

Remember that you can visit the Site without providing any Personal Data.

Subject to certain conditions, you may have the following rights:

a) Withdrawal of consent: To the extent provided by applicable law, you may have the right to object and withdraw your consent to the processing of your Personal Data.

If we at any point send you marketing communications based on your consent, you can at any point withdraw that consent by “opting out”. Our communications will always contain instructions on how to “opt-out” of receiving future marketing communications. In addition, if you at any time wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, you may at any time withdraw your consent with regard to that processing by directing an enquiry to us.

b) Request access: You are entitled to access the Personal Data we have registered about you, unless legal exceptions apply. To the extent provided by applicable law, you may have the right to obtain confirmation that we hold Personal Data or other information about you, request access to and receive information about the Personal Data we maintain about you and to receive copies of that Personal Data. The right to access Personal Data may be limited in some circumstances by local law requirements. To exercise these rights, please contact us as set forth below.

c) Request rectification or deletion: You may request that we update and/or correct incorrect information that we have about you or ask us to delete Personal Data. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services. Upon your request, OHT will take reasonable efforts to delete all of your Personal Data and non-identifiable information that you have provided to the Services. However, OHT cannot delete any aggregate or otherwise non-indefinable information derived from your Personal Data or from your use of the Services. You may also have the right to have your Personal Data blocked or anonymised.

d) Data portability: If the processing of your Personal Data is based on your consent or is necessary for the performance of a contract to which the you are a party, you have the right to request a copy of the Personal Data you have provided to us in order to transfer the data to another company. If it is technically feasible, such data can be transferred directly to the other company.

e) Complain to supervisory authorities: If you disagree with the way in which we process your Personal Data, you have the right to lodge a complaint to a data protection authority. The relevant body regarding complaints about OHT is the Norwegian Data Protection Authority (Datatilsynet).

Should we fall short of your expectations in processing your Personal Data, or you wish to make a complaint about our privacy practices, we hope you choose to direct an enquiry to us first. You can do this by sending us an e-mail: contact@oht.no. To assist us in responding to your request, please give full details of the issue. We will attempt to review and respond to all complaints within a reasonable amount of time.

Please feel free to contact us if you have any questions or concerns about OHT’s Privacy Policy or the information practices of the Services.

Changes

The Services and our business may change from time to time. As a result, at times it may be necessary for OHT to make changes to this Privacy Policy. OHT reserves the right to update or modify this Privacy Policy at any time. To see when the policy was last updated, please look at the date indicated above. OHT advises you to review this policy periodically, especially before providing any Personal Data. In cases of material changes, we will provide a notice of this.