This policy describes the information privacy practices that Vivo Energy (VE, “we”, “us”, or “our”, if not explicitly referring to the company) follow when handling personal information that we collect or receive in conducting our business, including through our services, products, websites, employee(s) and user application(s).
Definition of personal information
Personal Information means any information relating to an identified or identifiable natural person (known as the data subject). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location information, an online identifier or by one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of the natural person. Personal information does not include information that is truly anonymised, i.e. where the data subject is no longer identifiable. Personal information also does not include corporate information that relates to an organisation but not to an individual, such as a corporate name, corporate address or general corporate phone number.
Vivo Energy Data Privacy Contact Information
The data controller of your personal information is Vivo Energy plc, The Peak, 5 Wilton Road, London, SW1V 1AN, United Kingdom.
Our Data Protection Officer / Head of Ethics and Compliance is Rita Bouwer of Teleportboulevard 110, 1043 EJ Amsterdam, also contactable at [email protected].
COLLECTION OF PERSONAL INFORMATION
Personal information you provide to us.
We collect personal information that you provide to us through our websites, and in connection with business dealings we may have with you, and/or where we are legally obliged to as part of a contractual agreement. This includes information that you may provide to us in employment contracts, applications for employment, service agreements, KYC processes or any loyalty or payment card applications.
The personal information you provide includes basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address. It may also include information on the products or services you have shown interest in and/or purchased from us. If you use a payment card (debit and/or credit card) to purchase a product or service from us, we also may collect information necessary to process the card transaction, such as the card type, number, expiration date and any other information required to processes your request.
We may also collect information you provide to us through recruitment processes such as name, date of birth, gender, age, contact information, identification / passport / social security number, professional and educational history etc. We may also collect and retain background check information as permitted by applicable law and our KYC policy.
Website information you provide to us.
Information we may receive from our counterparties.
We may receive personal information about you from our counterparties who may recommend or suggest that we contact you for business purposes. This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address. It may also include information on the products or services you have shown interest in or may be interested in purchasing from us, as well as information on other companies or individuals with whom you do business with. We may also obtain personal information about you from our counterparties in connection with business transactions you initiate with us, such as through credit verification or other processes related to the transaction.
We do not knowingly collect or use any personal information from children younger than the age of sixteen (16), or from children, who do not have the necessary ability to foresee the consequence of their personal information being processed without obtaining the appropriate consent, as required by applicable law.
USE OF PERSONAL INFORMATION
For business use
We use your personal information to facilitate our ongoing and proposed business dealings with you. This includes:
- To process business transactions with us;
- To establish and maintain counterparty (includes customer(s)) accounts so that we may provide products or services of ours requested by you or your company;
- To register you as a user of these products or services so that you may access them through our websites (includes any web portals), operational site(s) or otherwise;
- To communicate with you about updates, maintenance, outages or other technical matters concerning these products or services;
- To provide you with training regarding usage of these products or services;
- To notify you about changes to any of the policies and procedures for use of these products or services;
- To verify the accuracy of account and technical contact information we have on file for you and your company in relation to these products or services; and
- To respond to questions or inquiries that you or your company may have about our products or services.
We may use your personal information as required for us to comply with relevant laws and regulations relating to the products or services that we provide in any of the jurisdictions in which we or our affiliated operating units operate.
With your consent or as otherwise permitted by applicable law, we may use your personal information for purposes relating to the marketing of our products and services, or those of our business partners. This means we may from time to time:
- Send you newsletters, press releases, event announcements and other similar communications regarding the products or services that we offer;
- Market or promote our products or services to you, including by offering you trial or limited access to certain of our products or services;
- Solicit input from you regarding improvement of our products or services;
- Inform you of third-party offerings that we think you or your company may be interested in which relate to our products or services;
- Send you announcements or requests on behalf of other customers of ours who believe you would benefit from use of our products or services; and
- Use your personal information for other purposes that we disclose to you at the time we obtain your consent.
If you no longer wish to receive this type of communication from us, you can contact us at [email protected].
Automated decision making / profiling
We use software to help us better understand how you like us to communicate with you and whether you may be interested in our products and services. For example, based on our records that you recently shown interest in a certain product, our software helps us identify related products and services that may interest you. We may then use this to contact you about these by post, telephone, SMS text messaging or email. If you no longer wish to receive this type of communication from us, you can contact us at [email protected].
From time to time, we may receive personal information about you from counterparties who recommend or suggest that we contact you for business purposes. We may receive such personal information because you have consented towards the relevant counterparty that they might share your personal information with businesses like for these purposes. If we use that information to contact you, it will only be to see if you are interested in our products or services, or those of our business partners. We will not use this information for other purposes without your consent. In addition, if you inform us that you are not interested in these products or services, we will stop using the information to contact you.
You are responsible for the accuracy of all personal information that you provide to us. We will use reasonable efforts to maintain the accuracy and integrity of your personal information, and to update that information as appropriate. We will take reasonable steps to ensure that the personal information we collect from you is relevant to its intended use, and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorised by you.
We may use your personal information you provide to us through job applications, using our online website, email or via fax solely for the purposes of processing your job application for the position you have shown interest in, in accordance with this privacy notice and applicable law. This may also include data we collect from third parties such as professional recruiting firms, your references, prior employers and educational history in order to identify and evaluate candidates for potential employment. We may conduct vetting for specific job roles, which may include criminal background checks and credit checks, as permitted by local laws. We may retain a record of your job application and references for a period of time, in order to ensure compliance with legal requirements. If you do not wish for us to retain a copy of your job application, you may opt-out at any time by emailing, [email protected].
Internal within Vivo Energy
VE is a company that transacts business internationally. From time to time we may share your personal information within VE and its subsidiaries. Such information may be used by each entity for internal business, operational and investigation purposes, as well as for purposes consistent with the purpose for which the information was originally collected or subsequently authorised by you.
The personal information that we collect from you may be transferred to, and stored at, a destination outside of the country where the personal information was collected. It may also be processed by members of staff operating outside of the country where the personal information was collected who work for us or one of our service providers.
If your personal information is held by us within the European Economic Area (or the UK), it will only be transferred to (i) other countries that are within the European Economic Area (or the UK) or deemed adequate by the European Commission; and (ii) the country where the personal information was collected under an intra-group agreement incorporating the terms of the approved standard data protection clauses. A copy of the relevant agreement can be obtained by contacting us at [email protected].
External…outside of Vivo Energy
We will not share your personal information with third parties outside of VE for their marketing purposes without your consent. However, we may share such information with our counterparties as described for the purposes disclosed to you at the time you provided the information, or as subsequently authorised by you or as permitted by applicable laws. From time to time, we also may offer you the option of sharing your personal information with third parties in order to receive information and/or marketing offers from them or other persons. If you consent to the sharing of your personal information for these purposes, it will be subject to the privacy policies and business practices of those third parties. If you later decide that you no longer want us to share personal information with such third parties, please contact us at [email protected].
We may offer various promotions through our operational sites, websites or elsewhere that may require registration with your personal information. If you choose to enter or otherwise participate in a promotion, your personal information may be disclosed to third parties in connection with administration of the promotion, such as in connection with winner selection, prize fulfilment and as otherwise required by law. By entering into a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. These rules will be displayed to you during the registration process, and you will be asked for your consent to the respective data processing at that time.
Legal Protections and Law Enforcement
We may access, use, preserve, transfer and disclose to our counterparties your personal information for the following purposes:
- To satisfy any applicable law, regulation, subpoena, or legal or regulatory process, if in our opinion such is required or permitted by law or reasonably requested by a regulatory authority (including any listing authority or stock exchange);
- To detect, prevent or otherwise address fraud, security issues or breaches, or technical issues. This may include allowing third parties, such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, to access and use your personal information in order to identify you. We may take any of these steps without notice to you to the extent permitted by law.
Your additional rights
As a data subject, you have rights regarding the processing of your personal information, including rights to, in certain circumstances:
- Withdraw any consent you have given, or are deemed to have given, in relation to our collection or use of your personal information;
- Request access to any personal information held about you by us and details of the processing of your personal information by us;
- Have inaccurate personal information amended or erased, and to have incomplete personal information completed;
- Request the erasure of your personal information;
- Object to or restrict the processing of your personal information (including profiling), including where the processing is unlawful or no longer necessary;
- Receive your personal information in a format suitable for transmission to another data controller;
- Object to processing of your personal information for direct marketing. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information. You can also exercise the right at any time by contacting us at [email protected].
- Prevent processing that is likely to cause unwarranted substantial damage or distress to yourself or anyone else;
- Object to any decision about you based solely on automated processing (including any profiling) that produces legal effects or otherwise significantly affects you; and
- Complain to the relevant data protection supervisory authority, if you think that we are not complying with our obligations in relation to our processing of your personal information.
You can make a request to us in relation to these rights at any time by contacting us via email at [email protected]. All requests will be dealt with promptly and any information to which you are entitled will be provided within a reasonable timeframe, subject to the exemptions stipulated in applicable data privacy laws.
We will take appropriate security measures to protect your personal information in our possession from loss, misuse, and unauthorised access, disclosure, alteration or destruction. We will make reasonable efforts to keep your personal information reliable for its intended use, accurate, up to date and complete. As necessary, we will take additional precautions regarding the security of particularly sensitive information, such as payment card information. While we strive to secure your personal information, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control.
We will not retain personal information for longer than is necessary for the purposes for which it was collected, except where retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.