The policy summarises the different types of cookies we, The China Navigation Company Pte. Ltd., use on our website, together with their respective purpose and duration (i.e. how long each cookie will remain on your device).

What are cookies?

Cookies are files or pieces of information that may be stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website. A cookie will usually contain the name of the website from which the cookie has come from, the "lifetime" of the cookie (i.e. how long it will remain on your device), and a value, which is usually a randomly generated unique number.

What do we use cookies for?

We use cookies to make our websites easier to use and to better tailor our websites and our products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on our websites. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our website and to help us improve their structure and content. We cannot identify you personally from this information unless you have specifically logged into the site with a username at some time.

What types of cookies do we use?

We use both first-party and third-party cookies. First-party cookies are cookies issued from our Swire domain and are generally used to improve the user experience on the website and make the information presented more relevant.

Third-party cookies belong to and are managed by other parties such as our service providers. These cookies may be required to submit certain forms, such as the submission of a job application, or to provide services within the website that are delivered by a third party.

There are generally two types of cookies:

  • Session cookies – these are temporary cookies that remain on your device until you leave our website.
  • Persistent cookies – Persistent cookies remain on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or "lifetime" of the specific cookie and your browser settings). We use these cookies to analyse user behaviour to establish visit patterns so that we can improve our website functionality for you and others who visit our website(s). These cookies allow us to remember selections and preferences from previous visits to the website to avoid these having to be provided each time and therefore provide a more relevant experience.

How can I control or delete cookies?

You can choose to reject or block all or specific types of cookies applicable when you visit our website by clicking on the cookie preferences, as such option is appropriately worded (e.g. Remember me), on our website(s) that require explicit login. You can also change your preferences for our websites and/or the websites of any third parties by changing your browser settings. Please note that most internet browsers are initially set up to automatically accept cookies. You can change the settings to block cookies or to alert you when cookies are being sent to your device. Please refer to your browser settings to adjust or modify your cookie preferences.

If you disable the cookies that we use, you will still be able to visit our website but this may impact your experience while on our website, for example you may not be able to visit certain areas of our website or you may not receive personalised information when you visit our website.

If you use different devices to view and access our website (e.g. your computer, smartphone, tablet etc.) you will need to ensure that each browser on each device is adjusted to suit your cookie preferences. Please visit for more details on how to delete or reject cookies and for further information on cookies generally.

1 Overview

The China Navigation Company Pte Ltd ("CNCo") and all its subsidiaries (hereinafter collectively referred to as the "CNCo Group" and each a "Company") value the privacy of the personal data of its job applicants and are committed to protecting the privacy and security of your personal data in accordance with applicable privacy laws.

This Policy provides job applicants with an overview on the types of personal data the Company collects (whether directly from you or third party sources) and shares with third parties and your rights in respect of such data processing under the applicable laws.

2 Application

2.1 Data Protection Principles

The Company is committed to ensuring that personal data is processed by the Company in accordance with applicable data protection laws. This requires the Company to process personal data in accordance with the following principles:

  • We will only use your personal data in a lawful, fair and transparent way;
  • We collect personal data only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  • We only collect such personal data as is necessary for the purposes we have informed you and process the personal data only for those purposes;
  • Your personal data is kept accurate and up to date;
  • Your personal data is kept only as long as is necessary for the purposes we have informed you about; and
  • Your personal data is kept secure.

2.2 Personal data held by the Company

The Company collects your personal data through the following means: during our application, recruitment and on-boarding processes, either directly from you or sometimes from an employment agency or background-check providers. As part of our recruitment process, we may also collect additional information from former employers, credit reference agencies or other background check agencies.

The data that we collect, the legal bases and purposes of processing such data as well as the other third parties whom we disclose such data to are as follows:

DATA collected LEGAL BASIS AND PURPOSE of processing DISCLOSURE to whom

Personal information such as:

  • Your name, address and contact details


  • Your nationality, date of birth, marital status, place of residence
  • Social security number, passport number or other national identification number

In general, prior to employment, we will collect the Personal data in the 1st column on the following legal grounds:

  • For our legitimate business interests:
  • To assess your suitability for employment with us and communicating with you about the recruitment process and/or your application.
  • To verify your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job.
  • To determine the terms on which you work for the Company (where applicable).
  • To comply with the CNCo Group’s own internal policies such as equal opportunity, modern slavery and human trafficking policy.
  • To comply with applicable laws, regulations, legal processes or governmental requests – these may include but are not limited to minimum age labour laws, local content or employment requirements.
  • With your consent – where none of the above legal basis applies, we will process your personal data based on your explicit written consent. If so, we will provide you with full details of the information that we would require and the reason we need it, so that you can carefully consider whether you wish to consent.

Prior to employment, your personal data are shared with the following third parties:

  • Third party agencies for verification of work experience, qualifications and background;
  • Referees indicated in CV or during job application / interview for further references.
  • Where applicable, companies within the Swire Group* for other potential career opportunities.

*"Swire Group" refers to all companies owned or controlled in part or in whole and whether directly or indirectly, by John Swire & Sons Limited.

Prior work experience information such as:

  • CV, employment history, reference information and/or information received from background checks (where applicable). Such information may be provided to us by third parties e.g. recruiters.
  • Professional qualifications and certificates.
  • Education history and transcripts.
  • Information from interviews,

Do note that if you are offered and you accept employment with us, the information collected during your application and recruitment process will become part of your employment record.

2.3 Consequences of not providing us with your personal data

If you fail to provide certain information when requested, please note that we may not be able to adequately evaluate your application for a job with us or we may be prevented from complying with our legal obligations.

2.4 Your rights in connection with your personal data

Under certain circumstances, by law, you have the right to:

  • request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
  • request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. Please note that it is your obligation to inform us if your Personal data changes during your working relation with us;
  • request erasure of your personal data (where it is no longer required for the Company’s legitimate business purpose). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.

A formal request from an individual for information that the Company holds about them must be made in writing. You will not ordinarily be required to pay a fee to access your personal data (or to exercise any of the other rights), but we may charge a reasonable fee for any additional copies of the materials we provide. Where your request is unfounded or excessive, we may also charge a reasonable fee or alternatively, we may refuse to comply with the request.

Please contact us at in relation to any such request(s).

2.5 Right to withdraw consent

In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in accordance with the law. If we have another legitimate basis for processing information in accordance with the law, we may still process the same data and we will not require your consent to do so.

2.6 How do we keep your personal data secure?

The Company values the privacy of your personal data and has put in place appropriate security measures and procedures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

All our third party service providers and other entities within the CNCo Group are required to take appropriate security measures to protect your personal data in line with our policies, as are any parties to corporate transactions. We only permit them to process your personal data for specified purposes and as appropriate, in accordance with our instructions.

The Company has put in place reasonable security arrangements to maintain the security of all personal data to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to your personal data. We have also put in place procedures to deal with any suspected data security incidents and will notify you and any applicable regulatory authority of a suspected breach where we are legally required or it is appropriate to do so.

2.6 Transfer of personal data to countries outside where the Company is located

Where your personal data is transferred outside where the Company is located (including outside of the EU), the Company implements organizational, contractual and legal measures to ensure that your personal data is processed only for the above specified purposes in accordance with our instructions, and that there are adequate levels of protection to safeguard your personal data. These measures include European Commission-approved transfer mechanisms for transfers to recipient countries which are not deemed to provide an adequate level of protection for personal data due to an absence of an adequacy decision by the European Commission in respect of such recipient countries. You can request a copy of these measures by contacting the Company’s Data Protection Officer (DPO).

3 Contact details

The DPO can be reached as follows:

Upon receipt of any complaint from an individual, the DPO shall investigate the complaint thoroughly and respond to you within 3 days of the complaint or if more time is required, to inform you when your complaint will be duly addressed.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority or the local data protection authority where the Company is based to seek further assistance. If you require your local data protection authority’s contact details, you may likewise write to the Company to obtain the same.

4 Changes to Policy

The Company reserves the right to amend this policy at its sole discretion and will continue to review the effectiveness of this policy to ensure it is achieving its stated objectives, taking into account changes in the law and organisational and/or security changes.

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The China Navigation Company Pte Ltd (“CNCo”) and all its subsidiaries (hereinafter collectively referred to as the “CNCo Group” and each a “Company”) value the privacy of the Personal Data we collect from our business customers, suppliers and partners and are committed to protecting the privacy and security of your personal data in accordance with applicable privacy laws. This is the CNCo Group’s data protection and privacy policy that explains why and how we process your personal data, your rights and how to contact us if you need to.

Our contact details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

A. Information we collect about you

We may process your personal data if:

  • You or the company you work for are a customer or a supplier of ours.
  • Your or the company you work for use our products or services.
  • You work for a customer or a supplier of ours, or for someone who uses our products or services.
  • You are someone (or you work for someone) to whom we want to advertise or market our goods or services.

Information we collect from you or from a third party

We may process your personal data that we have either obtained from you, or obtained from somewhere else. Personal data which is not collected directly from you may be collected:

  • From your employer in connection with your job and how it relates to us.
  • If you use any websites operated by us.
  • From third parties we work closely with (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers).

Personal data relating to you that we process may include:

  • Your name.
  • Who you work for, and your job function or department.
  • Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the company that you work for).
  • Information about you that you give us by communicating with us by phone, by e-mail, via our website, via social media or otherwise. It includes information you give us or that we obtain when you use our website, obtain or subscribe to our goods or services, supply us with goods or services, enquire about a product, place an order, enter a competition, promotion or survey, or contact us to report a problem, or do any of these things on behalf of the person that you work for.
  • Information relating to transactions with us involving you or the company you work for (for example, details of goods or services that we have supplied to, or obtained from, you or the person you work for).
  • Other information relating to you which it is necessary for us to process in order to enter into or perform a contract with you or the company you work for (for example, right to work information and information obtained from credit references agencies where this is necessary to enable us to carry out appropriate checks in relation to contracts with you or someone else that you work for or are otherwise related to).
  • Information about events to which you or your colleagues are invited, and your personal information and preferences to the extent that this information is relevant to organising and managing those events (for example, your dietary requirements).
  • Information relating to you that you give us or we otherwise obtain when you visit us (for example, if you sign in or are recorded on CCTV while visiting us, or you give us the registration details of your vehicle).

Information that we obtain from you when you use our website and/or business systems/applications may include:

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
  • Location data - we collect information through our website as to your real time location to provide location services where requested or agreed to by you in order to allow check-in, to deliver content, advertising that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the website.

Delivery of location services will involve reference to one or more of the following:

  • the coordinates (latitude/longitude) of your location;
  • look-up of your country of location by reference to your IP address against public sources; and/or
  • your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier. See our Cookie Policy for more information on the use of cookies and device identifiers on the site.

B. Cookies and other technologies

Our use of cookies and other similar technologies to process personal data is explained in our Cookie Policy, which you should please read.

C. How we use your information

Information you give to us:

We will use this information to:

  • Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you or the company you work for and us including:
    • conducting credit checks;
    • supplying goods and services to you or the company you work for or receiving them from you or the company you work for, as the case may be;
    • administering your/your company's account with us;
    • verifying and carrying out financial transactions in relation to payments you make in your own capacity or on behalf of your company;
    • notifying you about changes to our service.
  • Provide you with information about our products or services we feel may interest you or the company you work for, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See 'Our promotional updates and communications' as set out below.
  • Ensure in our legitimate interests that:
    • content from our site is presented in the most effective manner for you and for your computer;
    • we provide you or the company you work for with the information, products and services you request from us.

Information we collect about you from your use of our website and/or business systems/applications:

We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:

  • To administer our site and/or business systems/applications and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • To keep our site and/or business systems/applications safe and secure.
  • For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
  • To improve our site and/or business systems/applications to ensure that content is presented in the most effective manner for you and for your computer.
  • To allow you to participate in interactive features of our service, when you choose to do so.

Information we receive from other sources:

We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Legal bases for processing your personal data in summary

In summary, your personal data is processed:

  • in order to take steps at your request prior to entering into a contract;
  • where it is necessary to comply with a legal or regulatory obligation to which the Company is subject to;
  • where it is necessary for the purposes of the legitimate interests pursued by the relevant Company, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual/s; or
  • with your explicit consent (when legally required).

D. Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email as well as social media platforms (such as LinkedIn) about our services.

You can object to further marketing at any time by sending us an email to to unsubscribe from all our marketing and promotional update communications. You can also request that we send marketing material to a non-personal email address instead of one which identifies you as an individual.

E. Who we give your information to

We may share your personal data with:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
  • Appropriate third parties including:
    • our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
    • our auditors, legal advisors and other professional advisors or service providers;
    • credit reference agencies for the purpose of assessing your credit score where this is in the context of us entering into a contract with you or the person that you work for.
    • Payment processing providers who provide secure payment processing services.
  • In relation to information obtained via our website and/or business systems/applications:
    • our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy;
    • analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.

Other disclosures we may make

We will disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
  • If CNCo or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you or the company you work for; or to protect the rights, property, or safety of CNCo, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

F. Where do we store your information?

The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.

We may transfer your personal information outside the EEA:

  • In order to store it.
  • In order to enable us to provide goods or services to and fulfil our contract with you or the company your work for. This includes order fulfilment, processing of payment details, and the provision of support services.
  • Where we are legally required to do so.
  • In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

We may transfer your personal information to countries outside the EEA.

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.

G. How we protect your information

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website and/or any business systems/applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and/or business systems/applications, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

Our website may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

H. How long we keep your information

We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for seven years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

I. Your rights

You have the right under certain circumstances:

  • to be provided with a copy of your personal data held by us;
  • to request the rectification or erasure of your personal data held by us;
  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  • to object to the further processing of your personal data, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section;
  • to request that your provided personal data be moved to a third party.

Your right to withdraw consent:

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section;

How to exercise your rights

You can also exercise the rights listed above at any time by contacting us at

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

J. Changes to this policy

There may be changes this privacy policy from time to time. This policy was last updated on 24 May 2018.

K. Contact us

Our full details are:

The China Navigation Company Pte. Ltd.
300 Beach Road, #27-01, The Concourse,
Singapore 199555