Customers, Suppliers, Counterparts And Partners
Headquartered in Singapore, the Pavilion Energy group of companies, “PavEnergy”, “us”, or “we”, form an integrated energy business with a focus on natural gas and liquefied natural gas (“LNG”). Active in global markets and with offices in Singapore and Europe, the main activities of the group include importation, distribution, trading and sale of LNG and natural gas.
As part of the normal course of our business, we must often collect certain personal information from our counterparties, customers, suppliers, partners and their representatives. This information, among other things, enables us to adhere to anti money laundering legislation, to implement adequate trade controls for the protection of our own and our counterparties’ trade processing, and for the purposes of servicing our contractual relationships.
When working with personal information we have opted to implement a control structure which is maximum harmonising across all of the countries and jurisdictions we operate in. In practice, this means that our policies and procedures are designed to meet the highest requirements imposed upon us from both the Singapore Personal Data Protection Act 2012 (“PDPA”) and the EU General Data Protection Regulation 2016/679 ("GDPR").
- the PavEnergy entity, or entities, responsible for processing your personal data;
- the personal data we collect from you and/or from other third parties about you;
- the purposes for which personal data is processed and our reasons for doing so (also referred to as our “legal bases”);
- how your personal data may be stored and shared by us;
- how long your personal data is retained by us and
- your rights in relation to our processing of your personal data, and how you can exercise these rights.
PavEnergy consists of several entities which our counterparties, customers, suppliers, partners and their representatives may engage with and which may be involved with the collection and/or processing of personal data. These include:
- Pavilion Energy Pte. Ltd.
- Pavilion Energy Singapore Pte. Ltd.
- Pavilion Energy Spain S.A.U.
- Pavilion Energy Trading and Supply Pte. Ltd.
Our full contact addresses and company registrations are included at the end of this notice.
The PavEnergy entity, or entities, to which you, the business you represent or are associated with, provided your personal data to will be a “Controller” of your personal data. The exact entity, or entities, will depend on the products traded and location these products are serviced from, and you will be made aware of this in the associated contractual agreements you sign when becoming a customer of ours.
In addition, where processing of personal data is undertaken by another member of the PavEnergy group of companies for their own purposes, these affiliates may also be data controllers of your personal data.
PavEnergy have appointed a Data Protection Officer to safeguard and manage our use of personal data. They may be contacted electronically at the following email address: firstname.lastname@example.org, or in writing at either of the following addresses:
- Singapore: The Office of the Data Protection Officer, Pavilion Energy, 12 Marina Boulevard, #37-02, Marina Bay Financial Centre Tower 3, 018982, Singapore.
- Spain: The Office of the Data Protection Officer, Pavilion Energy, Torre de Cristal, Paseo de la Castellana 259C, Planta 21 Sur, 28046 Madrid.
We process personal data from, and in relation to, counterparties, customers, suppliers, partners and their representatives in the following categories:
- Private contact and identification information: Such as name, personal postal address, personal e-mail address, personal phone number, personal electronic messenger information, ID documentation, date and place of birth, nationality only if necessary;
- Business contact and other information: Such as job title, business postal address, business e-mail address, business phone number, business electronic messenger information;
- Records connected with our relationship or interaction with you (including former relationships and interactions): This may include notes and records of agreements, interactions, meetings, conversations and correspondence with us including recordings of telephone calls and electronic messages.
This information may be processed manually and/or with the support of computerised means. In addition, we may carry out screening on existing and potential counterparties, customers, suppliers, partners and their representatives pre-contract and, on a periodic basis, post-contract. This may include processing data required for anti-money laundering checks, background checks and monitoring, as well as information to enable us to establish and meet applicable reporting and other regulatory requirements, and to identify any conflicts of interest. As part of this we may process data relating to person’s family members and associates.
This screening may also involve the use of information legitimately gathered from open sources accessible to the public such as government issued sanctions lists and media sources.
We process personal data covered by this Privacy Notice for the following purposes:
- Business execution: Including developing products and services with, or for, our counterparties, customers, suppliers, partners and their representatives. Concluding and executing related agreements, legal contracts, and supporting documentation as required.
- Managing our ongoing relationships: Such as maintaining and promoting contact with existing counterparties, customers, suppliers, partners and their representatives, to ensure we continue to service these relationships effectively.
- Meeting our own Legal, Regulatory and Compliance obligations: Which may include a number or combination of the following areas:
- Performing Know Your Customer, anti-money laundering, and other due diligence checks at the beginning of an engagement and on an ongoing basis.
- Performing prudential and regulatory compliance checks at the beginning of an engagement and on an ongoing basis.
- Performing account and transaction monitoring, transaction reporting, tax reporting and investigating and preventing fraud and other crime.
- Making disclosures to, and complying with requests from, regulators, tax authorities, governmental and public authorities’ bodies and law enforcement agencies.
- To the extent permitted or required by law, recording telephone conversations, emails and electronic messenger communications.
The legal basis for collecting and processing personal data is constituted by the implementation of pre-contractual measures or by the legitimate interest pursued by us.
As a global business which is active in many countries in the world, we may need to transfer personal data between our different offices and locations to ensure we can service our counterparties, customers, suppliers, and partners effectively. We may also need to use authorised third-party companies or other parties to support the delivery of our business.
When we transfer personal data between companies within the PavEnergy group and/or to authorised third parties outside of our group, we take organisational, contractual and legal measures to ensure that your personal data is processed exclusively for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data.
We apply these same high standards to all transfers of personal data. These measures include Binding Corporate Rules for transfers among the PavEnergy companies and specialist transfer mechanisms for transfers to third parties in countries which have not been deemed to provide an adequate level of data protection to both Singapore and the European Union, as well as any additional local legal requirements.
Personal Data processed for the purposes described above will be stored in compliance with the principles of proportionality and necessity. We will store such data for varying time periods in order to maintain contractual relationships, to assist us in complying with legal and regulatory obligations, and, where required, to enable us to establish, exercise and defend legal rights and claims or for other legitimate business reasons. In general, this will mean that your Personal Data will be deleted after seven years from the cessation of a business relationship with us unless we are required to perform an alternative treatment.
You should know that you have a number of legal rights concerning how we use your personal data, these include the right to:
- access and request a copy of the personal data we hold about you;
- request rectification of inaccurate data which we hold about you;
- object to our processing of your personal data;
- request the erasure and/or deletion of data which we hold about you;
- obtain a restriction on how we process your data;
- make a complaint to the relevant Personal Data protection authority.
For more information about your rights, or to exercise your rights, please contact our Data Protection Officer. Please note that in responding to such requests, and to ensure we maintain yours and other individuals’ information securely, we may require you to validate your identity.
This notice may be updated from time to time. Such updates may reflect the types of personal data we collect, the purposes we use it for, and the ways in which it is shared. If you would like to confirm the latest version of this Privacy notice please contact our Data Protection Officer.
Full contact addresses and company registrations:
- Pavilion Energy Pte. Ltd. registered with the Accounting and Corporate Regulatory Authority (ACRA) of Singapore with number 201210107Z and address 12 Marina Boulevard, #37-02 Marina Bay Financial Centre Tower 3, 018982, Singapore.
- Pavilion Energy Singapore Pte. Ltd. registered with the Accounting and Corporate Regulatory Authority (ACRA) of Singapore with number 201211671M and address 12 Marina Boulevard, #37-02 Marina Bay Financial Centre Tower 3, 018982, Singapore.
- Pavilion Energy Spain S.A.U. registered with the Commercial Registry of Madrid, under Volume 39,345, Sheet 10, Section 8, Page M-698,632, having Número de Identificación Fiscal (“NIF”) A88410493 and address Torre de Cristal, Paseo de la Castellana 259C, Planta 21 Sur, 28046 Madrid, Spain.
- Pavilion Energy Trading and Supply Pte. Ltd. registered with the Accounting and Corporate Regulatory Authority (ACRA) of Singapore with number 201837333R and address 12 Marina Boulevard, #37-02 Marina Bay Financial Centre Tower 3, 018982, Singapore.