Privacy Policy & GDPR Compliance Statement

CBT Ventures ("we", "our", or "us") is a specialist maritime recruitment firm dedicated to sourcing, vetting, and placing elite maritime professionals from the OECS into positions aboard luxury yachts and cruise liners globally.We are committed to protecting the privacy and security of the personal data we collect from our candidates, clients (including yacht operators, cruise lines, ship agents, and governments), and website visitors. This Privacy Policy explains how we collect, use, process, and protect personal data in accordance with international data protection standards, including the General Data Protection Regulation (GDPR) and the UK GDPR  .

As a recruitment firm, collecting personal data is essential to our operations. We only collect data that is strictly necessary for legitimate recruitment purposes .

To facilitate career placement, we may collect:•Identity and Contact Information: Name, email address, phone number, physical address, and nationality.•Professional Background: Resumes/CVs, employment history, references, and interview notes.•Maritime Compliance Data: Seafarer certifications (e.g., STCW, MLC), flag state documents, passport copies, visas, and medical fitness certificates (ENG1).•Assessment Data: Results from our proprietary vetting frameworks (including RARE© and HER© assessments), cultural alignment evaluations, and service orientation notes.

For yacht operators, cruise lines, and ship agents, we collect:•Business contact details, corporate billing information, vessel specifications, and operational requirements.

We collect personal data through the following channels:•Directly from candidates applying through our website, via email, or during interviews.•From professional networking sites (e.g., LinkedIn) where candidates have made their information publicly available, under the basis of "legitimate interest"  .•From third-party references provided by the candidate.•From client communications regarding crew requirements.

Under GDPR, we must have a lawful basis for processing personal data . We process data based on the following grounds:Purpose of ProcessingLegal Basis under GDPRRecruitment and Placement: Assessing candidate suitability, verifying maritime credentials, and presenting profiles to luxury yacht and cruise operators.Legitimate Interest & Consent: Candidates explicitly consent to their data being shared with prospective employers.Compliance and Vetting: Verifying STCW, medical fitness, and background checks required by international maritime law.Legal Obligation: Necessary to comply with maritime employment regulations (e.g., MLC 2006).Communication: Contacting candidates regarding potential roles, interviews, and onboarding.Legitimate Interest: Necessary to facilitate the recruitment process.Business Operations: Managing client contracts, billing, and workforce planning pipelines.Performance of a Contract: Necessary to fulfill our service agreements with operators and agents.

We do not sell personal data. To facilitate maritime recruitment, we share candidate data exclusively with:•Prospective Employers: Luxury yacht operators, cruise lines, ship agents, and management companies seeking to hire crew.•Government Partners: Where applicable, in connection with OECS workforce development initiatives.•Service Providers: Trusted third-party applicant tracking systems (ATS), cloud storage providers, and compliance verification agencies. We ensure all third-party providers are strictly GDPR-compliant .Note regarding international transfers: Because our clients operate vessels globally, candidate data may be transferred outside the OECS or the European Economic Area (EEA). We ensure such transfers are protected by appropriate safeguards, such as standard contractual clauses.

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected.•Active Candidates: Data is retained while the candidate is actively seeking placement or engaged in a crew pipeline.•Sourced Candidates: If we source a candidate's data under legitimate interest, we will contact them within 30 days. If they do not consent to join our network, their data is deleted .•Placed Candidates: Data is retained in accordance with maritime employment record-keeping regulations and our contractual obligations to clients.

Under the GDPR, individuals have specific rights regarding their personal data . CBT Ventures fully supports these rights:•The Right to Access: You have the right to request a copy of the personal data we hold about you.•The Right to Rectification: You have the right to request that we correct any inaccurate or incomplete information.•The Right to Erasure ("Right to be Forgotten"): You have the right to request the deletion of your personal data, provided there are no overriding legal or maritime compliance obligations requiring us to retain it.•The Right to Restrict Processing: You have the right to request that we limit the processing of your data.•The Right to Data Portability: You have the right to request that we transfer your data directly to another organization.•The Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.To exercise any of these rights, please contact us at tamu@cbtventures.org. We will respond to all legitimate requests within one month  .

We implement robust technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. This includes secure cloud storage, restricted access controls, and regular reviews of our data handling practices.

We may update this Privacy Policy periodically to reflect changes in legal requirements, maritime regulations, or our business practices. The updated policy will be posted on our website with a revised "Effective Date."

If you have any questions regarding this Privacy Policy, how we handle your data, or if you wish to exercise your data protection rights, please contact our Data Protection representative:CBT VenturesBasseterre, St. KittsEmail: tamu@cbtventures.org