• 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; and
• your rights in relation to our processing of your personal data, and how you can exercise these rights.

We only process personal data of Applicants:

• in order to take steps at the request of the Applicant prior to entering into a contract;

• where it is necessary to comply with a legal obligation to which PavEnergy is subject to ensure compliance with applicable employment, social security laws and regulations;

• where it is necessary for the legitimate business interests of PavEnergy (such as ensuring compliance with legal obligations other than those related to employment or social security), the protection of PavEnergy’s assets, reputation and PavEnergy’s employees and contractors except where such interests are overridden by the interests or fundamental rights and freedoms of the Applicant; or

• if legally required, with the explicit consent of the Applicant.

In those cases where processing is based on consent, 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 process your personal data for the following purposes:

• Human Resources, personnel management, business process execution and internal management - including resource planning, and recruitment;

• Health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of PavEnergy ’s assets and staff, authentication of individual status and access rights;

• Legal and/or regulatory compliance - including compliance with legal or regulatory requirements; or

• Management reporting and analysis - including statistical analysis and surveys regarding the quality of the recruitment process.

We may also process your personal data for a secondary purpose where it is closely related, such as:

• storing, deleting or anonymising your personal data;

• fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defence of claims; or

• statistical, historical or scientific research.

Pre-screening of Applicants

We carry out screening of all Applicants who we intend to make an offer of employment, engagement or internship (as the case may be) and prior to any offer being confirmed for the purposes of:

• verifying the information that an Applicant provides during the screening/interview process. This will include verifying information with current/previous employers and educational institutions. No steps will be taken in this respect until the Applicant confirms the verification can take place;

• screening Applicants against publicly available or government issued sanctions lists and media sources. This is to ensure Shell is able to comply with legal and regulatory obligations, to protect assets and employees/contractors of PavEnergy and also Shell, and specifically to ensure that Shell can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements.

Any personal data collected through the screening will not involve profiling or automated decision-making regarding suitability for continued employment, internship or engagement as a contractor.

Automated decision making and profiling

All applicants must answer questions which are necessary to ensure that individuals can lawfully enter into a contract with a PavEnergy if they are successful in their application. In addition, for graduate hires, we utilize an online assessment tool which scores individuals on their suitability for employment, based on automated decision making to ensure objectivity. In those cases, you will be notified of this and you will have the opportunity to have such automated decisions reviewed by or on behalf of a member of the PavEnergy recruitment team. Save for graduate hires or as specifically notified to you in a bespoke privacy notice or a supplementary privacy statement during the recruitment process, no profiling or automated decision making will take place to determine suitability or eligibility for employment or engagement as a contractor.

This Privacy Policy provides information about personal data which are processed by Pavilion Energy group (‘PavEnergy’ or ‘we’) which are part of the Shell group of companies (‘Shell’) in relation to individuals who apply to work for, or who attend a recruitment event or undertake an assessment with PavEnergy. This includes prospective employees, interns and contractors.

For individuals who are successful in their application for employment, internship or engagement as a contractor, the Privacy Policy for PavEnergy Employee, Contractor and Dependents’ Personal Data will apply.

As well as this Privacy Policy, bespoke privacy Policies and supplementary privacy statements may contain further information about how PavEnergy is processing your personal data. In those instances, such privacy Policies will be communicated to you separately.

This Privacy Policy explains what personal data we process about you, why we are processing your personal data and for which purposes, how long we hold your personal data for, how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.

Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:

• Other companies within the Shell group of companies, including to those which may be located outside of your location;

• Authorised third party agents, service providers, external auditors and/or subcontractors of Pavilion Energy group;

• A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation Pavilion Energy group is subject to or as permitted by applicable law; and

• Any person to whom Pavilion Energy group proposes to transfer any of its rights and/or duties.

This Privacy Policy may be amended from time to time. We advise you to regularly re-read this Privacy Policy to check for changes. This Privacy Policy was last updated in March 2025.

We use cookies and similar technologies that collect and store information when you visit our website. This is to enable us to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). You can control and manage your cookies preferences by adjusting your browser settings or using the cookies preference tool.

If you have any problems, questions, or complaints about the processing of your personal data, please contact us at dataprotectionoffice@pavilionenergy.com, 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.

As we are part of the Shell group, you can also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, Netherlands - Commercial Register No. 27155369 Correspondence: P.O. Box 162, 2501 AN, The Hague, alternatively, you can also send an email to the Shell Group Privacy Office in privacy-office-SI@shell.com

If you are not satisfied with the processing of your personal data by us, you have the right to lodge a complaint with the Shell group regulator, which is the Dutch Data Protection Authority located at Hoge Nieuwstraat 8, 2514 EL The Hague, The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information or your own data protection authority Personal Data Protection Commission at Personal Data Protection Commission Singapore | PDPC for more information or www.aepd.es (Spain).

Our goal is to keep our information as accurate as possible. You can request:

• access to your personal data;

• correction or deletion of personal data (but only when it is no longer necessary for a legitimate business purpose);

• that you stop receiving marketing communications on behalf of the Business Customer, Supplier or Business Partner;

• that the processing of your personal data is restricted; and/or

• the receipt of the personal data you have provided to PavEnergy, in a structured and digital manner, in order to transmit this data to a third party, if this is technically feasible.

To make these requests, please contact us at the e-mail privacy-office-SI@shell.com.

Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:

• Other companies within the Shell group of companies, including to those which may be located outside of Singapore and Spain;

• Authorised third party agents, service providers, external auditors and/or subcontractors of PavEnergy and in particular authorised third parties who carry out reference and background checks on behalf of PavEnergy;

• A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which PavEnergy is subject to or as permitted by applicable law; or

• Any person to whom PavEnergy proposes to transfer any of its rights and/or duties.

Interacting with PavEnergy through social media

If you choose to interact with PavEnergy through social media on a PavEnergy administered social media page (‘PavEnergy Social Media Page’) such as LinkedIn, your personal data (such as your name, your profile picture and the fact that you are interested in PavEnergy ) will be visible to all visitors of your personal profile depending on your privacy settings on the relevant social media platform, and will also be visible to PavEnergy. You can delete any data that you shared on these sites at any time through your relevant social media platform’s account. PavEnergy does not track your activity across the different social media sites that you use. Please contact PavEnergy if you wish to make a request that you are unable to action yourself and which relates to a PavEnergy social media Page- see the section below - Your rights in relation to your personal data.

Additionally, and to the extent PavEnergy is jointly responsible with a social media platform of a PavEnergy social media Page, PavEnergy will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on PavEnergy Social Media Pages. For more information on how your personal data are processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.

Transfers of your personal data to other countries

Where your personal data has been transferred to companies within the Shell group and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data. These measures include Binding Corporate Rules for transfers among the Shell group of companies which you can access here.

Security of your personal data: how will we hold your personal data

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.

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 party agents, service providers, external auditors and/or subcontractors of PavEnergy, 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.

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.

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.

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

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.

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 reasons.

We process personal data covered by this Privacy Notice for the following purposes:

• Personnel management, business process execution, internal management, management reporting, organisational analysis and development - including budgetary, financial and organisational planning, administration, tax payment, compensation, performance management;
• Health, safety, insurance and security - including protection of PavEnergy Staff’s life or health and authentication of PavEnergy staff status and access rights.
• For building and office access.
• To upload photos taken at company events or seminars on PavEnergy’s social media page or main website.

We may also process your personal data for a secondary purpose where it is closely related, such as:

• Storing, deleting or anonymising your personal data;
• Fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defence of claims; or

The basis under which we collect the above data 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.

Your personal data may be transferred outside of your country, subject to appropriate safeguards.

Where your personal data is transferred to companies within the Shell group and/or to authorized 3rd party agents service providers and/or subcontractors who may be located in or outside of your location we take organizational, contractual and legal measures to ensure that the personal data is exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard the personal data.

These measures include Binding Corporate Rules for transfers among the Shell group and European Commission approved transfer mechanisms for transfers to 3rd parties in countries which have not been deemed to provide an adequate level of data protection as well as any additional local legal requirements. You can find a copy of the Shell Binding Corporate Rules at shell-binding-corporate-rules.pdf

We aim to keep our information as accurate as possible. You can request:

• access to your personal data;

• correction or deletion of your personal data (but only where it is no longer required for a legitimate business purpose such as completing a retail transaction);

• that you no longer receive marketing communications;

• that the processing of your personal data is restricted;

• combining of your personal data from different sources to create a personal profile no longer takes place;

• that you receive personal data that you have provided to us, in a structured, digital form to be transmitted to another party, if this is technically feasible.

To make a verifiable rights request please email us at privacy-office-SI@shell.com.

Tratamos los datos personales a los que se refiere esta Política de Privacidad para los siguientes fines:

• Ejecución comercial: investigación, desarrollo y mejora de productos o servicios; celebración y ejecución de contratos con Clientes Comerciales, Proveedores y Socios Comerciales; registro y reubicación de servicios, productos y materiales hacia o desde PavEnergy; gestión de relaciones y actividades de marketing, como mantener y promover el contacto con clientes actuales y potenciales, gestión de cuentas, servicio al cliente, así como desarrollar, ejecutar y analizar estrategias de investigación de mercado y marketing;

• Organización y gestión del negocio: gestión financiera, gestión de activos, fusiones, escisiones, adquisiciones y desinversiones, implementación de controles, emisión de informes de gestión, análisis, auditorías internas e investigaciones;

• Salud, seguridad y protección: protección de la vida o la salud de una persona, salud y seguridad ocupacional, protección de las empresas y empleados de PavEnergy, autenticación del estado individual y derechos de acceso; o

• Cumplimiento legal y/o regulatorio: cumplimiento de requisitos legales o reglamentarios.O para una finalidad secundaria, con la que estén directamente relacionados, como por ejemplo:

• Almacenamiento, eliminación o confidencialidad de datos personales;

• Auditorías, investigaciones, prevención de fraudes, resolución de disputas, asuntos de seguros, litigios y defensa de reclamaciones; o

• Investigación estadística, histórica o científica.

Verificación

Además, con el fin de cumplir con las obligaciones legales y reglamentarias, para proteger los activos y los empleados/contratistas del grupo Shell y, específicamente, para garantizar que el grupo Shell, que incluye

PavEnergy, pueda cumplir con las leyes de control comercial, contra el lavado de dinero y/o el soborno y la corrupción y otros requisitos reglamentarios, llevamos a cabo una evaluación (previa al contrato y periódica después del contrato) de los propietarios, accionistas y consejeros de nuestros Clientes Comerciales, Proveedores y Socios Comerciales. Este control se lleva a cabo teniendo en cuenta listas de sanciones disponibles públicamente o emitidas por el Gobierno, así como fuentes de los medios de comunicación.

El cribado no implica la elaboración de perfiles ni la toma automatizada de decisiones en relación con las contrapartes o posibles contrapartes.

Comunicación y marketing

Es posible que reciba ofertas en nombre de Clientes Comerciales, Proveedores o Socios Comerciales. Siempre puede utilizar la función de cancelación de suscripción a través de los diversos canales digitales que utilizamos para interactuar con usted.

We will not sell or otherwise provide your personal information to third parties and will only make it available to third parties involved in the performance of the service agreed with you. Our employees and any third parties utilized by us are contractually obligated to protect the privacy and confidentiality of your information.

This Privacy Notice may change over time and this notice was last updated in March 2025.

If you have any problems, questions or complaints about the processing of your personal data, please contact us electronically at the following email address: dataprotectionoffice@pavilionenergy.com, 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.

If you have any problems, questions or complaints regarding the processing of your personal data you can contact also Shell Chief Privacy Office under email address: Privacy-Office-SI@shell.com.

You can also contact the Shell Group Data Protection Officer by correspondence to Shell International B.V. The Hague, Netherlands - Commercial Register No. 27155369, P.O. Box 162, 2501 AN, The Hague.

If you are dissatisfied with the processing of your personal data by Shell, you have the right to lodge a complaint with your own data protection authority at PDPC in Singapore Personal Data Protection Commission Singapore | PDPC or www.aepd.es (Spain) or to the Dutch Data Protection Authority at Hoge Nieuwstraat 8, 2514 EL The Hague /The Hague NETHERLAND. Visit autoriteitpersoonsgegevens.nl/en for more information.

Our goal is to keep your information as accurate as possible. You can request:

• access to your personal data;

• correction or deletion of your personal data (but only when it is no longer necessary for a legitimate business purpose);

• that the processing of your personal data is restricted; and/or

• the receipt of the personal data you have provided to Shell in a structured and digital manner in order to transmit this data to a third party, if this is technically feasible.

Please contact your Shell Chief Privacy Office in case you want to send any subject access request under privacy-office-SI@shell.com.

All information, including personal data, is managed in accordance with the Pavilion Energy group group's standards for Information and Records Management, and will be securely deleted once it is no longer necessary for legitimate business purpose or for legal/regulatory purposes.

• Some exceptions necessary to comply with local legal requirements are:

• information contained within employee files will be retained for a maximum of 10 years after the termination of employment;

• information regarding retirement benefits will be retained for a maximum of 99 years from the beginning of the employment relationship;

• any personal data collected as part of the evaluation process from publicly available or government-issued sanctions lists and media sources will be retained for a maximum of 15 years after it was first obtained;

• names, dates, times and access points of all individuals entering Pavilion Energy group facilities will be retained for 3 years from each access;

• in the event that an individual has been terminated or has their contract terminated due to serious misconduct, including violation of Shell’s Life-Saving Rules or Shell's Code of Conduct, such information will be retained for a maximum of 30 years after termination.

In all cases, the information may be retained for (a) a longer period of time when there is a legal or regulatory reason to do so (in which case it will be deleted after it has served its legal or regulatory purpose) or (b) a shorter period when you disapprove of the processing of your personal data and there is no longer a legitimate business purpose to retain it.

We have implemented technologies and policies to protect your privacy from unauthorized access and misuse, and we will update these measures as new technologies become available where appropriate.

We process personal data necessary to manage the employment relationship, to engage contractors and interns and to provide benefits to certain dependents of PavEnergy employees. This includes data such as full name, photograph, residential address, Date of Birth, mobile number, citizenship/nationality, marital status, emergency contact information, dependent's particulars, identification card and passport details, qualifications, bank account details, background checks (credit history, past employment, etc), and declarations of any relationship to an existing employee. 

Sensitive Personal Data

We also process some special categories of personal data (’sensitive personal data’) such as data relating to an individual’s health, their racial or ethnic origin, religious beliefs, sexual orientation 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.

Pavilion Energy group, 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.

HR emails to contact: hr@pavilionenergy.com, will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies.

Except in those cases where PavEnergy organises educational events specifically designed for children; we do not intentionally collect personal data of individuals under 13 years old. If you are under 13 years old, please do not send us your personal data for example, your name, address and email address. If you wish to contact PavEnergy in a way which requires you to submit your personal data (such as for education or innovation events) please get your parent or guardian to do so on your behalf.

PavEnergy may use cookies and similar technologies that aim to collect and store information when you visit an PavEnergy website. This is to enable PavEnergy to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). We also use cookies to personalise and enhance your experience on our site and improve the delivery of ads to you. You can control and manage your cookies preferences by adjusting your browser settings or using the PavEnergy cookies preference tool on PavEnergy  websites - for more information, please refer to the PavEnergy Cookie Policy

If you have any issues, queries or complaints regarding the processing of your personal data, please contact us at dataprotectionoffice@pavilionenergy.com, 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.

Since we are part of the Shell group, you may also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, The Netherlands – Trade Register No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague, alternatively you can also email the Shell Group Chief Privacy Office at privacy-office-SI@shell.com.

If you are unsatisfied with the handling of your personal data by us, you have the right to lodge a complaint to the Shell group regulator which is the Dutch Data Protection Authority located at Hoge Nieuwstraat 8, 2514 EL The Hague, The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.

You also have the right to lodge a complaint to your local data privacy authority/regulator here www.pdpc.gov.sg (Singapore) or www.aepd.es (Spain).

Personal data requested and provided by Applicants are required in order to fulfil legal requirements and/or which is required for entering into a contract with you (or in the case of a contractor your employer/service provider). Failure to provide us with the information requested which is limited to that required for these purposes will negatively affect your chances of being selected for any potential employment, engagement or internship.

We hold personal data of unsuccessful Applicants for at least six (6) months but no longer than three (3) years after the recruitment process or assessment has been completed unless there is a lawful reason to retain it for longer, in which cases it will be deleted once no longer needed for that purpose (for example to defend any claims).

If you are successful in your application, the personal data gathered through the recruitment process will be retained in line with the Privacy Policy - Employee, Contractor and Dependents’ Personal Data which will be provided to you during the onboarding process.

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.

We process the personal data addressed in this Privacy Notice for the following purposes:

• Human Resources, personnel management, business process execution, internal management, management reports, organizational analysis and development - budgetary, financial and organizational planning, administration, compensation, performance management.

• Health, safety and security – protection of the life or health of employees, occupational health and safety, protection of Shell assets, authentication of employees’ status and access rights; or

• Legal and/or regulatory compliance - compliance with legal or regulatory requirements.

We may also process your personal data for a secondary purpose, in which they are directly related, such as:

• storage, deletion or confidentiality of your personal data;

• audits, investigations, fraud prevention, dispute resolution, insurance issues, litigation and claims defense; or

• statistical, historical or scientific research.

Monitoring

All activities using Shell IT equipment and/or connected to Pavilion Energy group's IT network may be monitored for legitimate business purposes.

Data from access and security systems are used to:

• health, safety and security effects, specifically to prevent fraud and protect Pavilion Energy group assets, Pavilion Energy group employees, as well as visitors to Pavilion Energy group facilities;

• comply with legal and regulatory requirements, specifically when it is mandatory, by virtue of local law, to provide information to governmental/regulatory authorities;

• monitor (in aggregate) the number of individuals entering and working at a Pavilion Energy group facility for human resource and real estate planning purposes; and

• only in cases of contractors (not employees of Pavilion Energy group), monitor dates and times of entry and exit in a Shell facility for the purposes of management and financial control.

In cases where the processing is based on consent, which may establish otherwise, you will 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.

Screening

In order to comply with legal and regulatory obligations, to protect the Shell’s group's assets and employees/contractors and specifically to ensure that the Shell group, which includes Pavilion Energy group, can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening on all employees and contractors on a periodic basis. This screening takes place against publicly available or government issued sanctions lists and is compared with information held about you by Shell (for example from the Conflict of Interest register - see here for more information).

Any personal data collected through the screening will not involve profiling or automated decision-making regarding suitability for continued employment, internship or engagement as a contractor.

• 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 or, in the case of whistle blowing, any personal data provided by you relating to any other person
• 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.

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.

When using this website or any other services or platforms provided, we collect your personal data when you provide it to us voluntarily, through completion of forms, emails, enquiries and requests, or when you provide it as part of your electronic use of our website, services or platforms and emails. The personal data we collect from you may include:

• Your name, identification number or passport number, job title, email address and contact number if you provide it to us;
• The name(s) and contact details of the individual(s) making the whistleblowing report, of potential witnesses or individuals otherwise involved in the allegation, and/or of the person against whom any allegations are made; 
• questions, queries or feedback you leave, including your email address if you contact us via our webforms or email;
• your email address and subscription preferences when you sign up for our email alerts;
• your Internet Protocol (IP) address, and details of which version of web browser you used;
• information on how you use the site, using cookies and page tagging techniques.

Should you choose not to provide such information, it may not be possible for us to respond to your request or enquiry.

For Whistleblowing Reports specifically, unless prohibited by local law, individuals are encouraged to provide their name and personal contact details so that any submissions through the whistleblowing reporting channel can be investigated fully. Where you provide your name and personal contact details, your identity will be strictly confidential and will not be disclosed to the person or people to whom the report relates unless you provide your consent. The only exceptions are where we are legally required to disclose your identity; where we are legally permitted to disclose your identity to protect or defend our rights or those of our employees, customers, suppliers or business partners, or,  where we have determined that the allegations were malicious and were made in bad faith.

All information collected may be used by PavEnergy individually or collectively, and may be combined with other information for the following purposes:

• Responding to your enquiries, feedback or requests submitted via our forms, telephone calls, faxes or emails
• Sending you newsletters or other communications which you may have agreed to receive;
• Communicating to you any benefit, feature and other information about products and services you have with us;
• Managing an account which you created with us;
• Managing our risks and operations; and
• Meeting regulatory and legal requirements.

For personal data submitted specifically through the whistleblowing channel, personal data is processed for the following purposes:

• To administer the whistleblowing report and assess and follow-up on submissions;
• To investigate alleged violations; and
• To take any necessary follow up action upon the completion of an investigation

The basis under which we collect the above data 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.

Should your information be required to fulfil a different purpose than what you have initially consented to, we will seek your consent on its new use before we proceed.

If you have agreed to receive marketing communications, you may always opt out later. You can do this by clicking the link in the email, or by contacting the address given in the communication. If you choose to unsubscribe from a service, we may keep a ‘suppression list’ containing your details so we know you have unsubscribed.

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.

The Pavilion Energy website contains links to other third-party websites. These websites operate independently from our Sites, and we do not control and are not responsible for the content, security or privacy practices employed by other websites. You should review the privacy statements of those websites to determine how they protect and use personal data.

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 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.

This Privacy Policy provides information on the processing of your personal data when providing and/or contracting services of the Pavilion Energy group, (‘PavEnergy’ or ‘we’) in relation to customers, suppliers, business partners, interested parties and/or investors, as well as websites visitors. For all other interactions with Shell group companies, please refer to www.shell.com/privacy.html.

We are committed to ensuring the privacy and security of your personal information. This Privacy Policy explains, among other things, what personal data we process, for what purposes we process your personal data, how long we keep your personal data, how to access and update your personal data and where to seek more information or file a complaint.

If you would like to receive this Privacy Notice in an alternative format (e.g. in larger print) or if you have any questions about the processing of your personal information that are not addressed by this policy, please contact us at: dataprotectionoffice@pavilionenergy.com.

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 job applicants. This information, among other things, enables us to adhere to HR Recruitment Policy.

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").

This notice sets out what personal data we collect, for what purposes and your rights in this respect.

Every individual within Pavilion Energy group and within the Shell group of companies is responsible for protecting personal data about each other as well as that of our customers, business partners and suppliers.

This Privacy Notice provides information about personal data processed by Pavilion Energy group in relation to individuals who are or were employees, interns or individual contractors as well as dependents listed as emergency contacts of Pavilion Energy group employees.

As well as this Privacy Notice, bespoke privacy notices and supplementary privacy statements may contain further information about how we process your personal data in relation to specific HR Shell processes (such as Open Resourcing, One Health IT and International Mobility programs). In those instances, such privacy notices will be communicated to you separately. These privacy notices may vary among the countries in which we operate to reflect local practices and applicable law requirements.

This Privacy Notice explains what personal data are processed about you, why we are processing your personal data and for which purposes, how long we hold your personal data for, how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.

For individuals applying to work or attending a recruitment event or undergoing an assessment, please refer to Pavilion Energy’s Recruitment Privacy Notice.

PavEnergy consists of several entities which job applicants or employees 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.

We process your personal data:

• in order to comply with local laws and regulations;

• for legitimate business interests (e.g. performance management in order to ensure the qualification and competence of our personnel or for health, safety and security purposes, so that only authorized personnel have access to certain locations or assets, litigation and defense of claims); or

• when there is your explicit consent.

As a general principle, Pavilion Energy and Shell do not request or rely on the consent of Pavilion’s employees for the processing of personal data. However, there are particular circumstances in which consent is required, such as in cases that are mandatory under applicable local law.

The personal data requested from Pavilion Energy group represents the minimum necessary in order to comply with legal and/or contractual requirements and to provide opportunities to participate in programs or provide a benefit. Failure to provide the requested information may adversely affect your chances of remaining in employment, internship or being hired as a provider, participating in a program or receiving a benefit.

In cases where processing is based on consent, 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. However, the withdrawal of consent may have an impact on your chances of remaining employed or hired as a provider or participating in a program or receiving a benefit.

When your personal data is transmitted to companies that are part of the Shell group and/or authorized third parties located outside your country, we take organizational, contractual and legal measures to ensure that it is processed exclusively for the purposes mentioned above, and that adequate levels of protection have been implemented to preserve it. Among these measures are the Binding Corporate Rules for transmissions between the Shell group and, for Shell companies in the European Union, transfer mechanisms approved by the European Commission for transmissions to third parties, as well as any other local legal requirements. You can find a copy of Shell's Binding Corporate Rules at shell-binding-corporate-rules.pdf by contacting us at privacy-office-SI@shell.com.

The personal data addressed in this Privacy Policy are processed only:

• to take action, at the request of an individual, prior to the conclusion of a contract;

• when necessary to comply with a legal or regulatory obligation to which PavEnergy's company(ies) are subject;

• where necessary for the purposes of the legitimate interests of PavEnergy's company(ies), except where the interests or freedom and fundamental rights of the individual(s) prevail over such interests; or

• (only when required by law) with the explicit consent of the individual.

In cases where the processing is based on consent and is subject to applicable local law, which may provide otherwise, you will 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.

Security of your personal data

We implement technologies and policies to protect your privacy from unauthorized access and misuse. We may use encryption, in particular, for some of our services and apply an authentication and verification process for access to Pavilion Energy group services, and we will regularly test and evaluate the effectiveness of our security measures.

We process the personal data addressed in this Privacy Policy for the following purposes:

• Commercial execution - research, development and improvement of products or services; conclusion and execution of contracts with Commercial Customers, Suppliers and Business Partners; registration and relocation of services, products and materials to or from PavEnergy; relationship management and marketing activities, such as maintaining and promoting contact with current and potential customers, account management, customer service, as well as developing, executing and analysing market research and marketing strategies;

• Organization and management of the business - financial management, asset management, mergers, spin-offs, acquisitions and divestitures, implementation of controls, issuance of management reports, analysis, internal audits and investigations;

• Health, safety and security – protection of an individual's life or health, occupational health and safety, protection of PavEnergy companies and employees, authentication of individual status and access rights; or

• Legal and/or regulatory compliance - compliance with legal or regulatory requirements.

or for a secondary purpose, in which they are directly related, such as:

• Storage, deletion or confidentiality of personal data;

• Audits, investigations, fraud prevention, dispute resolution, insurance issues, litigation and defense of claims; or

• Statistical, historical or scientific research.

Screening

In addition, in order to comply with legal and regulatory obligations, to protect the Shell group’s assets and employees/contractors and specifically to ensure that the Shell group, which includes PavEnergy, can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening (pre-contract and on a periodic basis post-contract) on owners, shareholders and directors of our Business Customers, Suppliers and Business Partners. This screening takes place against publicly available, or government issued sanctions lists and media sources.

The screening does not involve profiling or automated decision making in relation to the counterparties or potential counterparties.

Communication and marketing

You may receive offers on behalf of Business Customers, Suppliers or Business Partners. You can always use the unsubscribe functionality through the various digital channels we use to interact with you.

We process personal data from or in relations to individuals who work for or on behalf of or who are shareholders of our Business Customers, Suppliers, Business Partners and website users in the following categories:

•  Private contact information (such as name, mailing or email address, and telephone number) only if necessary; or

•  Business or other contact information (such as professional position, department, name of the organization and its business with PavEnergy done on behalf of you or the Business Customer, Supplier, Business Partner).

Except in the case of educational events organized by Shell or PavEnergy that are developed specifically for children, we do not knowingly collect personal data from individuals under the age of 13. If you are under 13 years of age (or another age indicated in the local legal requirements stated on the Shell website of your locality), do not send us your personal data, such as name, address and e-mail address. If you wish to contact PavEnergy or Shell in a manner that requires us to submit your personal data (such as for education or innovation events), please ask your parent or guardian to do so on your behalf.

We hold personal data of unsuccessful Applicants for no longer than 3 years after your last application was made. We retain such personal data in case a similar job becomes vacant for which you will be a suitable candidate. Even if such job opportunity did not arise, we retain your personal data for this period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way.

If you are successful in your application, the personal data gathered through the recruitment process will be retained in line with our Privacy Notice for employees, contractors or dependents which you will be provided access to upon commencement of employment, engagement or internship.

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 assist us in complying with legal and regulatory obligations.

For the purposes of recruitment, special categories of data (‘sensitive personal data’) including personal data regarding health data may be processed only as strictly required and as permitted or required by local law for the purposes of making adjustments to the recruitment process, for assessing eligibility for positions and fitness to work and provision of facilities in the workplace to accommodate health problems or for the establishment, exercise or defense of claims.

In addition, in order to ensure equal employment opportunities as permitted or required by local law, we may also gather additional sensitive personal data regarding Applicants, including their nationality, racial and/or ethnic origin.

We process personal information relating to individuals who apply to work for, or who attend a recruitment event and/or undertake an assessment (‘Applicants’).

This may include personal contact information, date of birth, gender, whether you have the legal right to work in the country in which you have applied, your application for employment, your qualifications and experience, results of interviews and assessments.

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.

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").

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 liquified 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.  

PavEnergy recognises the importance of protecting the privacy of all information provided by users (“User”) of our website (“https://www.pavilionenergy.com/”), or subscribers (“Subscriber”) to our marketing materials, recipients of our e-mail newsletters and all other customers and potential customers of our products and services, including those or other persons who may be making a “whistleblowing” report to us. This Privacy Policy applies to your use of our website including digital publications, social media and e-newsletters, any services of products you subscribe to, or any submission of a whistleblowing report.  

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").

When using this website, we collect your personal data when you provide it to us voluntarily, through completion of forms, emails, enquiries and requests, or when you provide it as part of your electronic use of our website and emails. The personal data we collect from you may include:

• Your name, job title, email address and contact number if you provide it to us;
• questions, queries or feedback you leave, including your email address if you contact us via our webforms or email;
• your email address and subscription preferences when you sign up for our email alerts.
• how you use our emails - for example whether you open them, and which links you click on;
• your Internet Protocol (IP) address, and details of which version of web browser you used;
• information on how you use the site, using cookies and page tagging techniques

Should you choose not to provide such information, it may not be possible for us to respond to your request or enquiry.

All information collected may be used by Pavilion Energy individually or collectively, and may be combined with other information for the following purposes:

• Responding to your enquiries, feedback or requests submitted via our forms, telephone calls, faxes or emails; 
• Sending you newsletters or other communications which you may have agreed to receive;
• Communicating to you any benefit, feature and other information about products and services you have with us;
• Managing an account which you created with us;
• Managing our risks and operations; and
• Meeting regulatory and legal requirements.

Should your information be required to fulfil a different purpose than what you have initially consented to, we will seek your consent on its new use before we proceed. 

You should know that if you have agreed to receive marketing communications, you may always opt out at a later date. You can do this by clicking the link in the email, or by contacting the address given in the communication. If you choose to unsubscribe from a service, we may keep a ‘suppression list’ containing your details so we know you have unsubscribed.

Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:

• any company that is a member of our group of companies, which includes our parent company Shell, where necessary for internal administrative purposes, corporate strategy, auditing and monitoring, sanctions screening and research and development

• we may also share your personal data with our group companies where they provide products and services to us that help us to provide products and services to you as our customer.

• we may also share your data within our group of companies to offer you promotions or to inform you about related products and/or services. This is based on your marketing consent preferences and in all cases any marketing material will be sent to you by us only.

• our authorized 3rd party agents, service providers and/or subcontractors on need-to-know basis.

• a competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which we are subject to or as permitted by applicable local law.

• on request of a party, we can forward your data to such party if such party has a legitimate interest to obtain your personal data. We and the requesting party will conduct a legitimate interest assessment to determine whether and which information is shared.

Interaction with Pavilion Energy group through social networks

If you choose to interact with PavEnergy through a social network operated by PavEnergy ("PavEnergy Social Network"), such as LinkedIn, your personal data (your name, your profile picture and the fact that you have an interest in PavEnergy), depending on the privacy settings set on the social media platform, will be visible to everyone who visits your personal page and also to PavEnergy. PavEnergy does not monitor your activity on the different social networks you use. If you send a message to PavEnergy via a social network's messaging service, that message will be retained for a maximum of one month after it is received.

In addition, and to the extent that PavEnergy is responsible in conjunction with the social media platform, PavEnergy will have access, through the social network, to a set of data with statistics and insights that help you understand the types of actions you take on the PavEnergy Social Networks. For more information on how your personal data is processed on social networks, including any targeted advertising you may receive, please refer to your privacy settings, accessible in your social network account.

Transmission of your personal data to other countries

When your personal data is transmitted to companies that are part of the Shell group and/or authorized third parties located outside your country, we take organizational, contractual and legal measures to ensure that it is processed exclusively for the purposes mentioned above, and that adequate levels of protection have been implemented to preserve it. Among these measures are the Binding Corporate Rules for transmissions between the Shell group and, for Shell companies in the European Union, transfer mechanisms approved by the European Commission for transmissions to third parties, as well as any other local legal requirements. You can find a copy of Shell's Binding Corporate Rules at shell-binding-corporate-rules.pdf by contacting us at privacy-office-SI@shell.com.

The legal basis for processing personal data in relation to site security is our legitimate interests, and the legitimate interests of our users, in ensuring the security and integrity of our website.

The legal basis for processing the data you have chosen to provide to us, including processing anonymised analytical data, is your consent.
 

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 retain your personal data for as long as:

• it is needed for the purposes set out here;
• the law requires us to;

Where you have provided us with your personal information for marketing or newsletter purposes, we will keep your personal data until you unsubscribe. If you subsequently enter a business relationship with us, we will advise you at the point of entering such relationship.

Pavilion Energy has appointed Data Protection Officers to safeguard and manage our use of personal data. They may be contacted electronically at the following email address: dpo@pavilionenergy.com, 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.

Should you wish to report a complaint or if you feel that Pavilion Energy has not addressed your concern in a satisfactory manner, you may contact the relevant Data Protection Authority.

• Singapore: Personal Data Protection Commission of Singapore: https://www.pdpc.gov.sg
• Spain: Spanish Data Protection Agency, Agencia Española de Protección de Datos: https://sedeagpd.gob.es