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 you when you visit an office of PavEnergy group of entities (the “premise”).

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 categories of personal data we process.

We process personal data necessary to manage the application process, employment relationships, to provide benefits to certain dependent of employees, and to engage contractors and interns of Pavilion Energy group.

This includes personal home contact information, date of birth, marital status, payroll and wage and benefit information, emergency contacts, work history, qualifications, work performance information, information required to ensure you have the right to work in the country/ies you are engaged in, as well as any other information necessary for managing the application process and the employment relationship, for providing benefits to certain dependents of employees and engaging contractors and interns.

We may also process some special categories of personal data (’sensitive personal data’) such as data relating to an individual’s health, medical records and medical history, bank account information, their racial or ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions and trade union membership. We will only process such personal data where it is necessary for the purposes of complying with employment and social security laws, for the establishment, exercise or defense of claims or where necessary for the purposes of providing occupational medical advice and support, to protect the vital interests of an individual (such as in an emergency), where necessary for reasons of public health or where the individual has provided their explicit consent.

PavEnergy consists of several entities which visitors 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 solely, or jointly with its affiliates, within PavEnergy group of companies to which you provided your personal data (including that of dependents) will be a “Controller” of your personal data.

PavEnergy will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies.

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.

• Pavilion LNG Bunker I Pte. Ltd. registered with the Accounting and Corporate Regulatory Authority (ACRA) of Singapore with number 201837218K and address 12 Marina Boulevard, #37-02 Marina Bay Financial Centre Tower 3, 018982, Singapore.

The personal data that we collect are full name, designation, company, contact information (including any emergency contact information as required) and video footage (CCTV).

All information collected are for access control, health and safety and security purpose.

The basis under which these are collected is your consent at the time of providing the information and, subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.

We will only keep your personal data for as long as is reasonably necessary for the purposes outlined above or to comply with legal requirements under applicable law(s). We will only use your information for the purposes stated above.

The personal data collected by Pavilion Energy group for these processes, whether directly or indirectly, is necessary to:

• Satisfy legal and/or necessary requirements to enter into a contract with a counterparty and continue to enter into contracts with that counterparty; or

• Maintain contact with Commercial Customers, Suppliers and Business Partners.

Failure to provide the requested information will adversely affect our ability to communicate with you or enter into or continue to enter into contracts with a counterparty.

We will only hold your personal data for a defined period.

With some exceptions which are explained in supplementary privacy statements, any personal data that are required for the purposes of conclusion and execution of agreements with Business Customers, Suppliers and Business Partners or for considering bids or tenders, will be held during the duration of the contractual relationship and up to 15 years after. For agreements which have a term of more than five years and for the purposes set out above, these agreements will be held for 35 years with effect from the commencement of the agreement.

In all other cases for the purposes set out above, including personal data gathered as part of any unsuccessful bids or which relates to the screening against publicly available or government issued sanctions lists and media sources, such personal data are held for no longer than 15 years after it was first gathered.

In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate business purpose to retain it.