1. Introduction
Heading One Pte. Ltd. ("Heading One," "we," "us," or "our") is committed to protecting the privacy and confidentiality of personal data entrusted to us by clients, counterparties, website visitors, and business contacts.
This Privacy Policy explains how we collect, use, disclose, and protect personal data when you visit our website, submit an inquiry, engage our ship broking or maritime advisory services, or otherwise interact with us. We operate from Singapore and handle personal data in accordance with the Personal Data Protection Act 2012 of Singapore ("PDPA") and applicable international data protection standards where relevant.
2. Personal Data We Collect
Depending on your relationship with us, we may collect the following categories of personal data:
- Identity and contact information — name, job title, company name, email address, telephone number, and business address.
- Inquiry and transaction information — details you provide regarding chartering requirements, vessel specifications, cargo interests, sale and purchase mandates, or other brokerage-related communications.
- Professional and commercial information — vessel ownership interests, charter party details, and counterparty information necessary to perform broking services, subject to confidentiality obligations.
- Technical and usage data — browser type, device information, pages viewed, and approximate location derived from IP address when you use our website (if locally logged).
- Correspondence records — emails, call notes, and meeting records relating to our business relationship.
We do not intentionally collect sensitive personal data unless required for a specific legitimate business purpose and with appropriate safeguards. We ask that you do not submit sensitive personal data through our general website contact form.
3. How We Use Personal Data
We use personal data for the following purposes:
- Responding to brokerage inquiries and providing ship broking, sale and purchase, newbuilding, and offshore advisory services.
- Facilitating introductions, negotiations, and transactions between shipowners, charterers, buyers, sellers, and other maritime counterparties.
- Managing client relationships, maintaining business records, and fulfilling contractual obligations.
- Complying with legal, regulatory, and anti-money laundering requirements applicable to maritime brokerage activities.
- Improving our website, services, and internal operations.
- Sending relevant market updates or service communications where permitted by law and, where required, with your consent.
4. Legal Basis for Processing
Under the PDPA and comparable frameworks, we process personal data on one or more of the following bases:
- Consent — where you have voluntarily provided information or opted in to communications.
- Contractual necessity — to perform broking mandates, advisory engagements, or pre-contractual steps at your request.
- Legitimate interests — to operate and develop our business, maintain client relationships, and protect our legal rights, balanced against your privacy interests.
- Legal obligation — where processing is required by applicable law or regulatory authority.
5. Sharing and Disclosure
We treat client and counterparty information with strict confidentiality. We may share personal data only where necessary and appropriate:
- With counterparties, shipowners, charterers, shipyards, or advisors involved in a transaction or negotiation you have authorised.
- With professional advisers including lawyers, accountants, and compliance consultants bound by confidentiality duties.
- With service providers who assist our operations (for example, IT support or document management), under contractual data protection obligations.
- Where required by law, court order, or regulatory authority, or to protect the rights, property, or safety of Heading One, our clients, or others.
- In connection with a corporate reorganisation, merger, or acquisition, subject to appropriate confidentiality arrangements.
We do not sell personal data to third parties.
6. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. Retention periods vary depending on the nature of the data and applicable maritime, commercial, and regulatory obligations. When data is no longer required, we securely delete or anonymise it.
7. Data Security
We implement reasonable administrative, technical, and physical safeguards designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. These measures include access controls, confidentiality policies for brokers and staff, and secure handling of transaction-related documentation.
No method of transmission or storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security.
8. Your Rights
Subject to applicable law, you may have the right to:
- Request access to personal data we hold about you.
- Request correction of inaccurate or incomplete personal data.
- Withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing.
- Request deletion or restriction of processing in certain circumstances.
- Lodge a complaint with the Personal Data Protection Commission of Singapore or a relevant supervisory authority.
To exercise these rights, please contact us using the details below. We may need to verify your identity before responding and may decline requests where permitted by law.
9. Cookies and Website Analytics
Our static website is designed to operate without third-party tracking cookies or external analytics services. If optional analytics or similar technologies are introduced in the future, we will update this policy and, where required, obtain consent before deploying non-essential cookies.
Your browser may store standard session or preference data locally. You can manage cookie settings through your browser preferences.
10. International Data Transfers
As a global ship broking firm with offices and counterparties worldwide, personal data may be transferred to, stored in, or accessed from jurisdictions outside Singapore. Where we transfer data internationally, we take steps to ensure appropriate safeguards are in place consistent with applicable data protection requirements.
11. Contact Us
For privacy-related questions, access requests, or complaints, please contact:
Data Protection Contact
Heading One Pte. Ltd.
7030 Ang Mo Kio Avenue 5, #08-61, Northstar @ AMK
Singapore 569880
Email: info@heading-one.sg
Tel: (+65) 6747-2885
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. The revised policy will be posted on this page with an updated effective date. We encourage you to review this page periodically.
See also our Terms & Conditions governing use of this website and our services.