Privacy Policy

1. Who We Are

CrewManning is a digital maritime crew management platform operated by All Freight Support Services Ltd, incorporated in Nigeria under the Companies and Allied Matters Act (CAMA 2020), Registration Number RC 241763. We connect seafarers with ship owners and crewing agents, facilitating the end-to-end process of crew recruitment, contract management, and certification verification. This Privacy Policy explains how we collect, use, store, and protect personal data in accordance with the Nigerian Data Protection Act (NDPA) 2023.

By registering on or using the CrewManning Platform, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy.

2. Data We Collect

We collect and process the following categories of personal and corporate data:

3. How We Use Your Data

We process your data only for lawful, defined, and legitimate purposes:

• To create and manage your account and verify your identity
• To match seafarers with suitable employment opportunities and crewing agents
• To facilitate contract creation, interview scheduling, and crew placement
• To verify and authenticate professional certificates, licenses, and documents against regulatory standards
• To comply with NIMASA, NPA, ISM Code, STCW Convention, and other applicable maritime regulatory obligations
• To comply with applicable anti-money laundering (AML) and Know Your Customer (KYC) requirements
• To send account notifications, status updates, and platform communications
• To improve platform functionality, detect fraud, and maintain system security
• To respond to enquiries, disputes, or regulatory requests

We do not sell, rent, or trade your personal data to third parties for commercial or marketing purposes.

4. Legal Basis for Processing

Under the NDPA 2023, we rely on the following lawful bases for processing your data:

• Contractual necessity: Processing required to provide our crew management services
• Legal compliance: Processing required by maritime regulations, labour laws, and Nigerian statutory obligations
• Legitimate interests: Fraud prevention, platform security, and service improvement
• Consent: Where you have voluntarily provided data beyond what is operationally necessary

5. Data Sharing

We may share your data in the following limited circumstances:

• Between seafarers and agents: Profile and document data shared only when a seafarer applies for or is matched to a vacancy, or where a contract has been initiated
• Regulatory authorities: NIMASA, NPA, Nigerian Ports Consultative Council, or other authorities where required by law or regulatory mandate
• Service providers: Trusted technology and infrastructure partners processing data on our behalf, bound by data processing agreements
• Legal proceedings: Courts, law enforcement, or dispute resolution bodies when required by a valid legal process

All data sharing is conducted on a need-to-know basis with appropriate safeguards in place.

6. Data Retention

We retain your personal data for as long as your account is active and for a period thereafter as required by law. Professional certificates and employment records may be retained for up to 7 years after your last active engagement, in compliance with maritime employment regulations and CAMA 2020 record-keeping obligations. Where you request deletion of your account, we will erase your data except where retention is required by law, regulatory obligation, or active dispute proceedings.

7. Data Security

We implement industry-standard technical and organisational security measures including encryption of data in transit and at rest, role-based access controls, secure authentication protocols, continuous monitoring, and intrusion detection. All staff and contractors with access to personal data are subject to confidentiality obligations. While we take all reasonable steps to protect your data, no digital system is entirely risk-free, and you are responsible for maintaining the security of your account credentials.

8. Your Rights Under the NDPA 2023

As a data subject, you have the following rights under Nigerian data protection law:

• Right of access: Request a copy of personal data we hold about you
• Right to rectification: Request correction of inaccurate or incomplete data
• Right to erasure: Request deletion of your data, subject to legal retention obligations
• Right to object: Object to processing based on legitimate interests
• Right to data portability: Request your data in a portable format
• Right to lodge a complaint: With the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng

To exercise any of these rights, email us at info@allfreightsupportservices.com.

9. Cookies

We use essential session cookies to keep you logged in and functional cookies to remember your preferences. We do not use advertising, analytics, or third-party tracking cookies. See our Cookie Policy for full details.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify you by email or via a platform notification. Continued use of the Platform after the effective date of any changes constitutes your acceptance of the updated Policy.

11. Contact Us