PRIVACY & COOKIE POLICY
Last Updated: 26 August 2026

1. INTRODUCTION

Vortex Shipbrokers Ltd. (“Vortex Shipbrokers”, “Vortex”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal data and privacy of individuals who visit or use our website and interact with our services.

This Privacy & Cookie Policy explains how we collect, use, disclose, store and protect personal information when you:

• visit or use our website;

• contact us by email, telephone or through our website;

• communicate with our employees, brokers or representatives;

• engage with us in connection with our shipbroking and maritime services; or

• otherwise interact with Vortex Shipbrokers.

This Policy also explains our use of cookies and similar technologies on our website.
Vortex Shipbrokers processes personal data in accordance with applicable data protection and privacy legislation, including, where applicable, the EU General Data Protection Regulation (Regulation (EU) 2016/679 – “GDPR”), as well as applicable national legislation.

By using our website, you acknowledge that you have read and understood this Policy.

2. WHO WE ARE

The data controller responsible for the processing of personal data described in this Policy is:
Vortex Shipbrokers Ltd.
[Registered Address]
[City, Country]
Email: [info@vortexships.com]
Website: [www.vortexships.com]
For any questions concerning this Privacy & Cookie Policy or the processing of your personal data, please contact us using the details above.

3. INFORMATION WE COLLECT

Depending on how you interact with us, we may collect different categories of personal information.

3.1 Information you provide directly
We may collect information that you voluntarily provide to us, including:

• full name;

• business or company name;

• job title or position;

• business email address;

• telephone and mobile numbers;

• business address;

• country of residence or business;

• correspondence and communications with us;

• information contained in enquiries, requests or other communications;

• information provided in connection with our shipbroking services; and

• other information you voluntarily provide to us.

We generally process business contact information in the context of professional and commercial relationships.

3.2 Information collected automatically
When you visit our website, certain technical information may be collected automatically. This may include:

• IP address;

• browser type and version;

• operating system;

• device type;

• language preferences;

• referring website or URL;

• pages visited;

• date and time of visits;

• duration of visits;

• approximate geographical information;

• interactions with our website; and

• other technical or usage information.

This information may be collected through server logs, cookies and similar technologies.

3.3 Information received from third parties
Where appropriate and lawful, we may receive business contact information or other relevant information from third parties, including:

• clients and prospective clients;

• shipowners and ship managers;

• charterers;

• other brokers and intermediaries;

• agents and representatives;

• business partners;

• maritime service providers;

• publicly available sources;

• professional databases; and

• other persons or organisations involved in a maritime transaction or business relationship.

Where required by applicable law, we will ensure that such information is processed lawfully.

4. HOW WE USE PERSONAL DATA

We may use personal data for the following purposes:

4.1 Providing our services
We may process personal information in order to:

• provide shipbroking and related maritime services;

• communicate with clients, owners, charterers, brokers and other counterparties;

• facilitate commercial negotiations and transactions;

• coordinate enquiries and business opportunities;

• administer and manage business relationships;

• prepare and exchange commercial information and documentation; and

• perform obligations arising from contracts or other business arrangements.

4.2 Communications
We may use your contact information to:

• respond to enquiries;

• provide information you have requested;

• communicate regarding ongoing business relationships;

• communicate regarding transactions or potential transactions; and

• provide relevant business or maritime information.

4.3 Business development and marketing
Where permitted by applicable law, we may use business contact information for legitimate business development and marketing activities, including sending information regarding our services, market developments and other relevant maritime or commercial information.
Where consent is legally required, we will obtain such consent before sending marketing communications.
You may unsubscribe from marketing communications at any time.

4.4 Website operation and improvement
We may process technical and usage information to:

• operate and maintain our website;

• improve website functionality;

• understand how visitors use our website;

• analyse website performance;

• identify technical problems;

• improve security; and

• develop and improve our services and online presence.

4.5 Legal and regulatory compliance
We may process personal information where necessary to:

• comply with applicable laws and regulations;

• comply with legal or regulatory requirements;

• respond to lawful requests from authorities;

• establish, exercise or defend legal claims;

• prevent fraud or other unlawful activity; and

• protect our legal rights and legitimate business interests.

5. LEGAL BASES FOR PROCESSING

Where the GDPR applies, we rely on one or more of the following legal bases for processing personal data:

• Contract

Processing may be necessary for entering into or performing a contract or taking steps at your request before entering into a contract.

• Legitimate Interests

We may process personal information where this is necessary for our legitimate business interests, provided that those interests are not overridden by your fundamental rights and freedoms.

Our legitimate interests may include:

• conducting and developing our business;

• managing commercial relationships;

• communicating with business contacts;

• providing and improving our services;

• protecting our business and systems;

• maintaining website security; and

• preventing fraud and misuse.
  
  Consent

Where required by law, we will rely on your consent for specific processing activities, including certain forms of electronic marketing or non-essential cookies.
You may withdraw consent at any time.

Legal Obligations
We may process personal information where necessary to comply with a legal or regulatory obligation applicable to us.

6. DISCLOSURE OF PERSONAL INFORMATION

We do not sell personal information.
We may, however, disclose personal information where reasonably necessary for the purposes described in this Policy.

Recipients may include:

• group companies and affiliated entities;

• clients, shipowners, charterers and other commercial counterparties;

• brokers, agents and intermediaries;

• professional advisers;

• lawyers, accountants and auditors;

• IT, hosting and technology providers;

• website analytics and service providers;

• communication and email service providers;

• insurers and financial institutions;

• regulators, governmental authorities and law-enforcement agencies; and

• other third parties where disclosure is necessary to provide our services or conduct a transaction.

We require service providers processing personal data on our behalf to handle such data appropriately and, where required, under appropriate contractual arrangements.

7. INTERNATIONAL TRANSFERS

Due to the international nature of the shipping industry, your personal information may be processed or accessed in countries outside your country of residence and, in certain circumstances, outside the European Economic Area (“EEA”).
Where personal data is transferred outside the EEA, we will take appropriate measures to ensure that the transfer is carried out in accordance with applicable data protection law.

Depending on the circumstances, these measures may include:

• an adequacy decision of the European Commission;

• Standard Contractual Clauses approved by the European Commission;

• appropriate contractual safeguards; or

• another legally recognised transfer mechanism.

8. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to:

• provide our services;

• maintain business and commercial records;

• comply with legal, accounting or regulatory requirements;

• resolve disputes;

• establish, exercise or defend legal claims; and

• protect our legitimate business interests.
   

The appropriate retention period will depend on the nature of the information and the purpose for which it is processed.
When personal information is no longer required, we will delete it, anonymise it, or otherwise securely dispose of it where appropriate.

9. DATA SECURITY

We take reasonable technical and organisational measures designed to protect personal information against:

• unauthorised access;

• accidental loss;

• destruction;

• alteration;

• disclosure; and

• other unlawful or unauthorised processing.
   

However, no method of transmission or electronic storage can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect personal information, we cannot guarantee absolute security.

10. COOKIES

Our website may use cookies and similar technologies.
A cookie is a small text file stored on your device when you visit a website. Cookies allow websites to recognise a device and remember certain information about a visitor.

We may use cookies for purposes including:

• ensuring that the website functions correctly;

• maintaining website security;

• remembering preferences;

• understanding how visitors use our website;

• measuring website performance;

• improving website functionality; and

• analysing website traffic.

11. TYPES OF COOKIES

11.1 Strictly Necessary Cookies
These cookies are necessary for the website to function properly.
They may support functions such as:

• website security;

• page navigation;

• session management; and

• basic website functionality.

Because these cookies are necessary for the operation of the website, they may not always be capable of being disabled through our cookie-management system.

11.2 Analytics Cookies
Analytics cookies help us understand how visitors interact with our website.
They may provide information such as:

• the number of visitors;

• pages visited;

• time spent on pages;

• traffic sources; and

• general website usage patterns.

Where required by law, analytics cookies will only be used following the user's consent.

11.3 Functional or Preference Cookies
These cookies may allow the website to remember choices or preferences made by visitors and provide enhanced functionality.

11.4 Marketing Cookies
Where used, marketing or advertising cookies may be used to measure advertising activity or provide content that is more relevant to visitors.
Such cookies will be used only where permitted by applicable law and, where required, with your consent.

11.5 Third-Party Cookies
Some services incorporated into our website may place cookies or similar technologies on your device.
These may include third-party providers used for analytics, embedded content, security, communications or other website functionality.
The use of such technologies is subject to the relevant third party's own privacy and cookie policies.

12. MANAGING COOKIES

You can control or delete cookies through your browser settings.
Most browsers allow you to:

• view cookies;

• delete cookies;

• block cookies;

• accept cookies only from certain websites; or

• receive a notification before a cookie is stored.

Please note that disabling certain cookies may affect the functionality or availability of parts of our website.
Where applicable, you may also manage non-essential cookies through the cookie-consent mechanism available on our website.

13. YOUR DATA PROTECTION RIGHTS

Where the GDPR applies, you may have the following rights in relation to your personal information:

• Right of Access

You may request a copy of the personal information we hold about you.

• Right to Rectification

You may request that inaccurate or incomplete personal information be corrected.
Right to Erasure
In certain circumstances, you may request that your personal information be deleted.

• Right to Restriction

In certain circumstances, you may request that processing of your personal information be restricted.

• Right to Data Portability

Where applicable, you may request that personal information you have provided to us be supplied in a structured, commonly used and machine-readable format, or transferred to another controller.

• Right to Object

You may object to certain processing activities, including processing based on our legitimate interests.
You may also object to direct marketing at any time.

• Right to Withdraw Consent

Where processing is based on your consent, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.
These rights are subject to applicable legal limitations and exceptions.

14. HOW TO EXERCISE YOUR RIGHTS

If you wish to exercise any of your data protection rights or have any questions regarding our processing of your personal information, please contact us at:
Vortex Shipbrokers Ltd.
[Registered Address]
[City, Country]
Email: [info@vortexships.com]
We may need to request additional information to verify your identity before responding to certain requests.
We will endeavour to respond to valid requests within the period required by applicable data protection legislation.

15. RIGHT TO LODGE A COMPLAINT
If you believe that your personal information has been processed unlawfully, you have the right to lodge a complaint with the competent data protection supervisory authority.
Where applicable to you, this may include the supervisory authority in the country where you live, work, or where you believe an infringement has occurred.
For Greece, the competent supervisory authority is the:
Hellenic Data Protection Authority (HDPA)

16. THIRD-PARTY WEBSITES
Our website may contain links to websites operated by third parties.
We are not responsible for the privacy practices, security or content of third-party websites.
We recommend reviewing the privacy policies of any third-party websites that you visit.

17. CHILDREN'S PRIVACY

Our website and services are intended primarily for business and professional users.
We do not knowingly collect personal information from children through our website.
If you believe that a child has provided personal information to us, please contact us so that we can take appropriate action.

18. CHANGES TO THIS POLICY

We may update this Privacy & Cookie Policy from time to time to reflect changes in:

• our services;

• our business practices;

• applicable laws and regulations;

• technology; or

• our use of cookies and other technologies.

Any updated version will be published on our website with a revised “Last Updated” date.
We encourage you to periodically review this Policy to remain informed about how we process personal information.

19. CONTACT US

If you have any questions, concerns or requests regarding this Privacy & Cookie Policy or the way Vortex Shipbrokers processes personal information, please contact:

Vortex Shipbrokers Ltd.
[Registered Address]
[City, Country]
[Country]
Email: [infoi@vortexships.com]
Website: [www.vortexships.com]

© 2026 Vortex Shipbrokers Ltd. All Rights Reserved.