Current or Former Employees, Contractors or Dependents
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 employees. This information, among other things, enables us to adhere to HR Recruitment Policy and Performance Management Guidelines.
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 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.
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.
In the case of individual contractors, the company within the PavEnergy group that has contracted your services solely, or jointly with its affiliates, within the PavEnergy group of companies and your external contracting/employing company/agency.
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 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.
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.
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.
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.
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.