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").

• 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.

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 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: 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.

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).

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.