Privacy Policy

Data controller

DistressedCargo.org is a website and industry-information platform operated by Pommer & Partners International Trading Limited, registered in Ireland, CRO No. 609274. That company is the controller for personal data processed through this website.

Registered office: 77 Camden Street Lower, Dublin 2, D02 XE80, Ireland.

Contact for data protection matters: contact@pommerpartners.com.

Categories of information processed

Contact and identification details you provide: name, company, role, email address, telephone or messaging number and preferred contact method.

Case information: cargo and commodity details, quantity and cargo form, vessel, container, port, terminal, country and location information, incident and condition details, customs or regulatory status, urgency, survey and laboratory information, statements about authority to sell, and free-text case description.

Documentation you reference or supply in connection with a case, which may include survey reports, laboratory analyses, bills of lading, invoices, packing lists, photographs, customs documents and correspondence. Such documents may incidentally contain personal data of other individuals.

Limited technical information generated by the request itself, used for security, abuse prevention and rate limiting. The submission process derives a non-reversible fingerprint from the connection's IP address and browser user-agent for that purpose.

Purposes of processing

Receiving and assessing submitted cargo cases; structuring the submitted information; identifying missing information; assessing potential commercial recovery routes; and communicating with you about the case.

Where a case proceeds commercially: preparing or requesting commercial offers, considering direct purchase, and remarketing or recovery coordination.

Compliance activities where applicable, including sanctions, export-control, counterparty and authority-to-sell checks; IT security and abuse prevention; and establishing, exercising or defending legal claims where necessary.

Lawful bases

Where you submit a case with a view to a possible commercial engagement, processing of your contact and case information is carried out to take steps at your request prior to entering into a contract, and, once an engagement exists, for the performance of that contract.

Processing of case documentation, security and abuse-prevention data, and information used for compliance screening and for establishing, exercising or defending legal claims is carried out on the basis of legitimate interests — namely assessing and handling submitted cargo cases, operating the platform securely, and protecting the operator's legal position — balanced against your interests and rights.

Where a legal obligation applies, for example in relation to sanctions or record-keeping requirements, processing is carried out to comply with that obligation.

The assessment form does not rely on consent as its lawful basis; no consent checkbox is used to legitimise the processing described above. Where consent is genuinely required for a specific additional purpose, it will be requested separately and may be withdrawn at any time.

Recipients

Information may be made available to categories of recipients where reasonably necessary for the purposes above: IT and hosting providers; database and email service providers used to operate the platform and deliver internal case notifications; professional advisers; and competent authorities where legally required.

Depending on the case, and only where reasonably necessary and limited to what the specific step requires, information may also be shared with surveyors or laboratories, logistics or recovery providers, and prospective commercial counterparties.

Submitted cargo information is not automatically or routinely disclosed to prospective buyers. Any such disclosure is case-dependent and limited to what is reasonably necessary for the step being taken.

Confidentiality

Submitted case information is handled on a need-to-know basis and is not published as part of the public website.

Confidential handling does not create legal professional privilege, litigation privilege or any other professional privilege. Information may be disclosed where reasonably necessary to service providers, professional advisers, potential commercial counterparties or competent authorities, subject to applicable law and the purpose for which the information was submitted.

International transfers

Some service providers used in connection with the website or the cargo-assessment process may process personal data outside the European Economic Area. Where such transfers occur, Pommer & Partners International Trading Limited will apply the safeguards required under applicable data protection law.

The specific service providers, processing locations and applicable transfer mechanisms depend on the actual technical configuration and are being confirmed. No particular transfer mechanism is claimed here before it has been verified. If you require that information before submitting a case, please request it at contact@pommerpartners.com before you submit.

Retention

Case information is retained for as long as necessary to assess the case, communicate with you and pursue or conclude any resulting commercial matter, and thereafter only for as long as a legal obligation or a legitimate business need — such as the possibility of a claim — requires.

No fixed retention periods have been set for each category of information. Defined periods are under review and will be published in this policy once adopted.

Your rights

Subject to the conditions in applicable data protection law, you may request access to personal data relating to you, its rectification or erasure, restriction of processing, and portability where applicable. You may object to processing carried out on the basis of legitimate interests. Where processing is based on consent, that consent may be withdrawn at any time without affecting prior processing.

Requests can be made to contact@pommerpartners.com.

You also have the right to lodge a complaint with a supervisory authority. For this controller the competent authority is the Irish Data Protection Commission, and you may alternatively complain to the supervisory authority of your habitual residence or place of work.

Automated decision-making

The assessment workflow does not take decisions producing legal effects concerning you, or similarly significantly affecting you, solely by automated means. Submitted information is structured and assessed to support commercial evaluation; commercial decisions are taken by people.

Changes

This policy may be updated as the platform develops. The current version is always the one published on this page.