Privacy policy

4. COLLECTION OF PERSONAL INFORMATION

4.1. Personal information you provide to us

We collect the personal information you provide to us through our websites, business applications, and during any business interactions with you. We also collect personal information when required by a vivoenergy.com contract or by law. In some cases, we collect your information based on your consent or when you show interest in our products or services. This includes:

• Employment engagements and application for employment via our recruitment processes;
• Know Your Counterparty (KYC) process when performing due diligence checks on potential partners, vendors, suppliers and customers;
• Vendor, Supplier or customer agreements for the provisioning of products and services;
• Loyalty programmes;
• Use or viewing our websites via your browser’s cookies;
• Voluntarily via promotional offers, community events and engagements held at our operational sites.

4.2. What data do we collect

Personal information you provide will be specific to the relevant business dealing we have with you. Where relevant, this may include:

• basic contact information about you, such as your name, username, company name, title, occupation, gender, work and residential address, phone number, and email address,
• Unique identifiers such as personal identification numbers (including date of birth), passport numbers, tax numbers, company registration numbers, VAT Numbers, location data, IP address; biometric data;
• Information on the products or services you have shown interest in and/or purchased from us;
• Financial information such as the card numbers, banking details, transactional information (payments made and received), tax certificates;
• Images and video footage where permitted and collected through CCTV Footage
• Usage data through interactions with our websites,

Information you provide to us through recruitment processes will include:

• name, date of birth, gender, age, contact information, identification/passport/social security number, professional, educational and employment history.

Sensitive Personal Information we be collected in specific circumstances and as permitted under applicable law. This may include:

• Biometric information on our employees for user authentication and security access purposes to our physical and digital assets;
• Health information on our employees as part of our health and safety programme where necessary to determine the individual’s health status at the start of and during their employment with Vivo Energy.
• Race or ethnic origin on our employees where legally required under specific jurisdictions to monitor diversity and inclusion;
• Information about criminal proceedings or offenses committed or alleged to have been committed as part of our Know Your Counterparty (KYC) due diligence process.

4.3. Website information you provide to us

Cookies are small data files stored on your device. They help us understand your preferences, analyse how you use our website, and make your experience easier and more personalised. For more details, please see our Cookie Policy. You can control and manage your cookie preferences by adjusting your browser settings or managing cookie preferences on our websites.

Our websites and business applications may include forms where you voluntarily provide personal information. Any information you submit will be handled according to this Privacy Policy.

Website usage data is often anonymous, but if it is combined with information that identifies you, or if the law considers it personal information, we will treat it as personal information under this Privacy Policy.

4.4. Information we may receive from our counterparties

From time to time, we may receive personal information about you from counterparties who suggest that we contact you for business purposes. Such personal information may include basic contact information about you, such as your name, company name, title, address, phone number, and email address.

We may receive such personal information because you have given your consent to the relevant counterparty to share your personal information with businesses like ours. 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.

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.

You have the right to opt out at any time and upon receipt of our first engagement with you if you do not wish to receive any further communication from us.

5. USE OF PERSONAL INFORMATION

5.1. For business use

We use your personal information to facilitate our ongoing and proposed business dealings with you. This may include one or more of the following legal bases:

• To process your business transactions with us;
• To fulfil contractual obligations with you or our counterparties;
• To establish and maintain counterparty, and key account/contact information (including customer accounts so that we may provide our products or services as 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 (including any web portals, mobile applications), operational sites or otherwise;
• To communicate with you about changes/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 respond to questions or inquiries that you or your company may have about our products or services;
• To conduct due diligence checks on companies and their directors to establish the legal status of all potential new business partners to ensure we do business with reputable, honest and qualified business partners and agents;
• To comply with relevant laws and regulations relating to the products or services that we provide in any of the jurisdictions in which we operate;
• To conduct recruitment and hiring process;
• General administration of our counterparties, including employees, suppliers, vendors and customers.
• For certain legitimate interests pursued by relevant Vivo Energy companies, except where such interests are overridden by the rights and freedoms of individuals;
• Under certain conditions based on your explicit consent where legally required.

5.2. Marketing Purposes

With your consent, or where allowed by law, we may use your personal information to market our products and services, or those of our business partners when you have shown interest. This may include:

• Sending you newsletters, press releases, event updates, and similar communications;
• Promoting our products or services, including offering trials or limited access;
• Asking for your feedback to help improve our products or services;
• Sharing information about third-party products or services related to ours that may interest you or your company;
• Sending announcements or messages on behalf of other customers who believe our products or services could benefit you; and
• Any other marketing purposes for which we have obtained your consent.

You can opt out of marketing communications at any time by updating your preferences in the relevant portal or website where you registered, or by contacting our local office.

5.3. Data Integrity

You are responsible for the accuracy of all personal information 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 and when requested by you. 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 only used in ways that are compatible with the purposes it was collected for or otherwise authorised by you.

5.4. Recruitment

We may use the personal information you provide to us for 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 and in accordance with this privacy policy and applicable law. This may also include data we collect from third parties such as professional recruiting firms, your references, prior employers, educational history and where applicable psychometric tests 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 in our countries of operation. We may retain a record of your job application and references for a period of time, in order to ensure compliance with legal requirements.

6. INFORMATION SHARING

6.1. Internal within Vivo Energy

We transact business internationally and may therefore share your personal information with other companies within our Group. This helps us deliver our services, manage our operations, and support internal business functions. All intra-group sharing is done under formal data sharing agreements that require each company to protect your information in line with this Privacy Policy and applicable data protection laws, ensuring appropriate safeguards are put in place in respect of the transfer. Processing of your personal information by any subsidiaries will be used by each entity consistently with the purpose for which the information was originally collected or subsequently authorised by you.

6.2. External outside of Vivo Energy

We may share your personal information if our company goes through a merger, restructuring, sale, or other major business changes. In these cases, this Privacy Policy will still apply to how your information is used and shared.

We also share your personal information with partner companies and service providers for these reasons:

• Where services are outsourced with service providers/third parties for hosting data, managing websites, sending emails, processing orders, running promotions or events, providing analytics, and other administrative work. Before sharing your information with them, we make sure they agree to protect your data according to this Privacy Policy and in compliance with applicable data protection law through standard contractual safeguards.
• If you enter a promotion or competition we run, we may share your information with third parties who help manage it, such as selecting winners and delivering prizes. The official rules governing these promotions/competitions will be communicated through official website channels.
• We will not share your personal information with third parties for their marketing purposes.
• We will not sell your personal information

6.3. 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 protect and/or defend this Privacy Policy or other Vivo Energy policies or terms of use applicable, including investigations of potential violations thereof, ensuring the protection of the safety, rights, property or security of Vivo Energy or any of our counterparties;
• 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.

7. DATA PROTECTION

7.1. Your Data Protection Rights

As an individual (also referred to as a data subject), you have rights regarding the processing of your personal information under data protection law, including rights to, in certain circumstances:

• Withdraw any consent you have given for us to use your data.
• Request access to the personal information we hold about you and how we use it.
• Correct or update any inaccurate or incomplete information we have about you.
• Request that we delete your personal information.
• Object to or limit how we process your personal data, including profiling, especially if it is unlawful or unnecessary.
• Receive your personal data in a format you can transfer to another organisation.
• Opt out of receiving marketing communications from us by checking the relevant boxes on our forms or contacting us.
• Stop processing that could cause you or others significant harm or distress.
• Object to decisions made about you solely by automated processes (like profiling) that have legal or significant effects on you.
• File a complaint with a data protection authority if you believe we are not handling your personal information appropriately.

You can make a request to us in relation to these rights at any time by submitting a request via our online portal accessible at https://dsr.vivoenergy.com/ All requests will be dealt with promptly and any information to which you are entitled will be provided within a reasonable timeframe, subject to any exemptions stipulated in applicable data protection laws.

If you feel that any attempts to resolve the matter are inadequate, you may lodge a complaint with an appropriate data protection regulator in your jurisdiction.

7.2. Data Security

We take protecting your privacy seriously and recognise we have a duty of care to the individuals whose data we hold. As a result, we will only collect and process data as necessary to support the purposes outlined in this policy and will take all reasonable security measures to protect your personal information in our possession from loss, misuse, and unauthorised access, disclosure, alteration or destruction. We will take additional precautions regarding the security of Sensitive Personal 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.

7.3. Data retention

We will keep your personal information for as long as you continue to engage with us. 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 defense of legal claims. Our retention periods will vary between our countries of operation and are aligned to applicable laws. Once the time period for retention has expired as permitted, we will securely dispose of your data.

8. CONTACT INFORMATION AND COMPLAINTS

We are committed to responding to and resolving questions, requests and/or complaints about your personal information and our collection or processing of your personal information. We have an appointed Data Privacy Officer who is responsible for overseeing this Policy and such matters and who you may contact via email to [email protected].

We will investigate and will do our best to resolve any complaints or disputes you bring to our attention within a reasonable timeframe and as guided under applicable data protection law. Contact details of all Vivo Energy subsidiaries and affiliates (Vivo Energy Group Companies) are available on our website at: https://www.vivoenergy.com/en/contacts

9. POLICY CHANGES

We reserve the right to update this Privacy Policy at any time, without prior notice to you, to the extent permitted by applicable law. We will notify you of the changes that we make by posting the revised Privacy Policy on our websites, and such changes will be effective immediately unless otherwise stated. We encourage you to check this Privacy Policy periodically for any changes where you continue to engage with us and have business dealings with us where you will be deemed to have accepted the updated Privacy Policy.

Vivo Energy Privacy Policy last updated on 09 December 2025