Privacy Policy

Privacy Policy
Last updated: 3 November 2025
1. About us
2020 BULKERS LTD. (organisation number 930 263 672, S.E. Pearman Bldg., 9 Par-la-Ville Road, Hamilton HM11, Bermuda) and 2020 BULKERS MANAGEMENT AS (organisation number 921 059 450), Tjuvholmen allé 3, 0252 Oslo are the data controllers for the processing of your personal data. You can contact our data protection officer, [Christian Dahll], at the details below.
Contact us:
• Email: [cd[at]2020bulkers.com]
• Telephone: [+47 400 39 670]
• Postal address: Tjuvholmen allé 3, 0252 Oslo
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2. Types of personal data
Personal data is information that can be linked to you as an individual, directly or indirectly. We process the following categories:
Contact information: Name, email address, telephone number, address, when such is submitted to us.
Identification: National identity number (only when required by law), identification documents obtained from both our systems and publicly available information.
Technical data: IP address, cookies, browser type, device information obtained from our systems.
Communication: Correspondence, feedback, complaints submitted to us.
Transaction data: Purchase history, payment information, invoices from our systems.
The data processed is obtained through customers, employees, suppliers and investors.
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3. Why and how we process your personal data
All processing of personal data must be lawful, fair and transparent. We process personal data for specific purposes and with a legal basis:
Purpose Legal basis
Deliver services you have ordered, typically on behalf of your employer Performance of contract (GDPR art. 6(1)(b))
Customer service and support Performance of contract (GDPR art. 6(1)(b))
Process recruitment applications Consent or legitimate interest (GDPR art. 6(1)(a)/(f))
Improve our services and websites Legitimate interest (GDPR art. 6(1)(f))
Marketing Consent (GDPR art. 6(1)(a))
Comply with the Accounting Act and other legislation Legal obligation (GDPR art. 6(1)(c))
Prevent fraud and abuse Legitimate interest (GDPR art. 6(1)(f))
When we base processing on legitimate interest, we have assessed that our interests do not override your rights and freedoms. The legitimate interests we base our processing of the data on are the need to prevent fraud, the need to control information and the systems in connection with the services offered.
All information will be kept as long as deemed necessary in light of the purpose of the processing.
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4. Whether you must prove personal data
For certain purposes, it is necessary that you provide personal data:
• Mandatory: To enter into and perform a contract, you must provide name, address and email. Without these, we cannot deliver the service.
• Voluntary: Information for marketing and newsletters is voluntary. You can use the service without receiving marketing.
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5. Sharing of personal data
We only share personal data when necessary:
Data processors: We use suppliers who process personal data on our behalf, such as IT suppliers, payment services and customer service systems. These have entered into data processing agreements with us.
Public authorities: We disclose information to public authorities when legally required to do so.
Group companies: We may share information with companies in the same group for administrative purposes.
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6. Transfer of personal data outside the EEA
Personal data is primarily processed within the EEA. When transferring to countries outside the EEA, we ensure that appropriate safeguards are in place:
• EU standard contractual clauses: We use the EU’s standard agreements approved by the EU Commission
• Adequacy decision: Transfer to countries the EU Commission has approved as safe
You can obtain a copy of the safeguards by contacting us.
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7. How we secure personal data
We have implemented technical and organisational security measures appropriate to the risk, including:
• Encryption of sensitive data
• Access control and authentication
• Regular security backups
• Ongoing testing and evaluation of security measures
• Training of employees in privacy and information security
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8. Your rights
You have several rights relating to your personal data:
Right of access (art. 15)
You have the right to obtain confirmation as to whether we process personal data about you, and if so, to obtain access to it.
Right to rectification (art. 16)
You have the right to have inaccurate information corrected and to have incomplete information completed.
Right to erasure (art. 17)
You have the right to have personal data erased when it is no longer necessary for the purpose, or when you withdraw consent. The right to erasure does not apply when processing is necessary to comply with legal obligations or to establish, exercise or defend legal claims.
Right to restriction (art. 18)
You have the right to request restricted processing in certain situations, for example whilst we assess whether the information is correct.
Right to data portability (art. 20)
You have the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format, and to transmit this to another data controller. This applies when processing is based on consent or contract and is carried out by automated means.
Right to object (art. 21)
You have the right to object to processing based on legitimate interest.
Object to marketing: You always have the right to object to the processing of personal data for direct marketing purposes, including profiling. When you object, we will no longer process the information for such purposes. You can opt out by contacting us in accordance with sec. 13 and inform us that you object.

Automated decisions (art. 22)
You have the right not to be subject to decisions based solely on automated processing which produces legal effects concerning you or similarly significantly affects you.
Withdraw consent
When processing is based on consent, you have the right to withdraw consent at any time. It shall be as easy to withdraw consent as to give it. Withdrawal does not affect the lawfulness of processing before consent was withdrawn.
How to exercise your rights: Contact us in accordance with point 13. We normally respond within one month. In complex cases, the deadline may be extended by two months, and we will then inform you of the reason for the delay.
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9. Right to complain
You have the right to complain to the Norwegian Data Protection Authority if you believe the processing of personal data about you is in breach of data protection regulations:
Norwegian Data Protection Authority (Datatilsynet)
• Postal address: Postboks 458 Sentrum, 0105 Oslo, Norway
• Visiting address: Tollbugate 3, Oslo
• Telephone: +47 22 39 69 00
• Email: postkasse@datatilsynet.no
• Website: www.datatilsynet.no
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10. Cookies
We use cookies and similar technologies to improve user experience, analyse traffic and customise content.
Types of cookies:
• Necessary: Ensures basic functionality
• Statistics: Helps us understand how the website is used
• Marketing: Used to display relevant advertising
You can manage cookies in your browser settings. Note that certain functions may be limited if you block cookies.

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12. Changes to the privacy policy
We may update this privacy policy. Significant changes will be notified on our website. Last updated: 3 November 2025.
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13. Contact us
Data controller: 2020 BULKERS LTD. and 2020 BULKERS MANAGEMENT AS
Contact information:
• Email: [cd[at]2020bulkers.com]
• Telephone: [+47 400 39 670]
• Address: Tjuvholmen allé 3, 0252 Oslo
Data protection officer: [Christian Dahll]