1. Controller identity and contact

This privacy statement (“Privacy Statement”) is a commitment by Gede Aditya and Partners (“GAP” or “we”), a law firm based in Jakarta, visiting address at Soho Capital 33rd Floor, Suite 3308, Jl. Letjen S. Parman Kav. 28, West Jakarta 11470, Indonesia, to respect and protect any data containing certain personally identifiable information that can be used to identify or contact an individual that is not available to the public (“Personal Data”) which we collect and process. 

GAP is an Indonesian law firm who represents the Equal Justice Equal Pay Foundation (“the Foundation”) with regards to their work representing the interests of seafarers who are or were citizens of the Republic of the Philippines and/or the Republic of Indonesia who were employed directly or indirectly on a ship or ships registered in the Kingdom of the Netherlands by ship owners or their related entities (including manning agencies) (collectively, the “Ship Owners”) at rates of pay and/or under conditions which were discriminatory and who as a result suffer damages, run a risk of suffering damages and/or (have) suffered damages (the “Support Group”), other than losses, injury or harm arising from accident, illness or death. The Foundation’s work may involve initiating legal proceedings and/or settlement negotiations on behalf of the Support Group against Ship Owners and/or will try to conclude settlements with Ship Owners.

GAP acts as a data importer and separate controller with regard to the processing of your Personal Data described in this Privacy Statement. As lawyers, we have a professional obligation to keep confidential all private information we receive within a lawyer-client relationship. We are committed to protecting the Personal Data we hold. This Privacy Statement outlines how we process your Personal Data, safeguard your privacy, and inform the rights that you have. This Privacy Statement applies to all members of the Support Group, unless covered by a separate privacy statement.

By accepting this Privacy Statement, you acknowledge that you have read and understood this Privacy Statement and you accept its terms. In particular, you agree and consent to us collecting or processing your Personal Data in accordance with this Privacy Statement. In circumstances where you provide us with Personal Data relating to other individuals (such as Personal Data relating to your spouse, family members, colleagues, or other parties), you represent and warrant that you have obtained such individual’s consent for, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of his/her Personal Data by GAP and the Foundation.

Questions or remarks concerning the processing of Personal Data by GAP can be directed to the Managing Partner of GAP, at

A pdf version of this Privacy Statement, to save or print, can be downloaded here


2. Categories of Personal Data processed


2.1. Source of Personal Data processed

GAP processes the Personal Data obtained from:

  • Seafarers who contact GAP and submit the Personal Data to GAP independently;
  • The data provided by the Foundation for the purposes described below;
  • Members of the Support Group who have entered into an Agreement and Deed of Assignment, Exclusive Mandate and Power of Attorney with the Foundation;
  • Members of the Support Group who have registered their potential claim at;
  • Persons who wish to be kept informed.

2.2. Type of Personal Data processed

GAP processes, inter alia, the following Personal Data of members of the Support Group:

  • First name and surname, preposition, title;
  • Address, place and country of residence;
  • Nationality;
  • Email address;
  • Telephone number;
  • Date of birth;
  • Sex;
  • Correspondence with you;
  • Copy of valid ID;
  • Financial data, such as your bank account number/IBAN number;
  • Data with regard to your financial situation, a.o. your work income and or benefits received;
  • Data with regard to your working situation, which may include (parts of) your employment (contract) history, correspondence with your (former) employer, ship employment manuals/guidelines and salary;
  • Ships worked on and routes travelled;
  • Any other Personal Data and evidence that you provide to us or which is required or necessary for purposes described below.


3. Purpose and legal basis of processing Personal Data

GAP processes your data for the following purposes:

Purpose and legal basis


Participation  Our scope of work is to give assistance to the Foundation in acquiring as potential participants the seafarers who worked in Dutch flagged commercial vessels to initiate legal action in the Netherlands to seek back-pay and/or compensation that arises because of discriminatory treatment on wages by the Ship owners.

Legal basis: the performance of the contract with the Foundation.

  • To assist you in member registration to the Support Group;
  • To assist you in claim registration to the Foundation. 



Identification – To establish the identity of the participants.

Legal basis: the performance of the contract with the Foundation.

  • To identify you and to avoid confusion with other people in the Support Group.

Communication  Corresponding with you regarding the Foundation’s activities.

Legal basis: the performance of the contract with the Foundation and the consent between you and the Foundation.

  • To communicate with you and to inform you of topics that are of importance to the representation of your interests;
  • To answer your questions or request if you contact us.

Fraud prevention

Legal basis: the performance of the contract with the Foundation.

  • To avoid that people not suffering damage as a result of the actions of Ship owners join the Support Group and would thus unfairly profit from the activities of the Foundation.


4. Transfer of Personal Data

For transfers of EU Personal Data to GAP for processing by GAP in a jurisdiction other than a jurisdiction in the EU, the EEA, or the European Commission-approved countries providing ‘adequate’ data protection, GAP and the Foundation have agreed to use Module 1 of the Standard Contractual Clauses (“SCC”) for Controller-to-Controller transfers. Your Personal Data will be stored or processed within the EU/EEA by the Foundation and will only be accessed temporarily from outside the EU/EEA by GAP based on the SCC. We do not do onward transfer nor disclose your Personal Data to any other third party against the provisions of the SCC and when we are not required by the law to do so.


5. Your rights

You have the right to obtain a copy of the SCC between GAP and the Foundation. You can exercise these rights by contacting us via You also have the right to lodge a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens ( pursuant to Clause 13 of the SCC.


6. Security

GAP takes appropriate technical and organizational measures to protect your Personal Data against loss or unlawful processing. Additionally, your Personal Data is protected by the law as GAP is a law firm subject to statutory protection against surveillance under the law of the third country, in this case the law of the Republic of Indonesia, where GAP processes the data.


7. Amendments

This Privacy Statement was last updated on 16 September 2022. We may amend this Privacy Statement from time to time. We therefore advise you to consult the Privacy Statement regularly. If there are substantial changes to this Privacy Statement, a clear notification will follow.



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