Website Privacy Notice

PRIVACY NOTICE FOR WEBSITE USERS (“WEBSITE PRIVACY NOTICE”)
 
We respect the privacy of everyone who visits this website (“Site”). As such, we would like to inform you on the personal data we collect from you through your use of this Site and how we use such personal data.
 

Special Notice for Minors under 14 years old
 
We do not intentionally collect personal data of those under 14 years old and do not aim to market our services to those under 14 years old. If you are under 14 years old, please do not send us your personal data. If you are under 14 years old and wish to ask us a question or use our Site in a manner that requires you to submit your personal data, please get your parent or guardian to do so on your behalf.
 

What does this Privacy Notice apply to?
 
This Website Privacy Notice sets out the policy of the Swire Pacific Offshore Group (“SPO Group”) in relation to the personal data we collect through your use of our website (“Site”). In this policy, the SPO Group means Swire Pacific Offshore Operations Pte Ltd (“SPO”) and all its affiliates as set out in our Site.
 
This Website Privacy Notice applies to the majority of the websites operated by the SPO Group, however there may be occasions where there is a need to have a slightly different privacy policy to account for local differences in privacy regulations. When you access another website belonging to our Affiliate, please check the privacy policy of each such website which you visit and do not assume that this privacy policy applies to all websites within the SPO Group.
 
This Website Privacy Notice explains what personal data we collect from you, for which purposes we collect and use such personal data, how long we retain the personal data, how to access and update your personal data and how to contact us for further information.
 

Who controls your personal information?
 
Unless otherwise specified at the relevant part of the Site, your personal data is ultimately controlled by Swire Pacific Offshore Operations Pte Ltd , a company registered in Singapore with its business address at 300 Beach Road, #15-01 The Concourse, Singapore 199555.
 

What information do we collect from you and for what purposes do we use such information:

What personal data do we collect? Legal basis and purpose for processing the data?
  • Personal information which you provide to us through our recruitment page or which you otherwise provide to us through our website when submitting any enquiry or feedback through our Site. Such personal information includes your name, address, telephone number, email and work experience.
  • Information collected automatically in relation to your use of the Site through the use of cookies and other technologies, such as:
    • the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
    • full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time),
    • products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team
  • We will use cookies in accordance with our Cookie Policy, which you should read before carrying on.
Our legal basis for processing your personal data could be any of or a combination of the following:
  • To take steps at your request prior to entering into a contract with you, such as to consider and evaluate your application for a position with us, where you have submitted personal information for the purposes of a job application.
  • (only if legally required) with your explicit consent, for example to provide you with a service you have requested or reply to an enquiry or feedback you have submitted through our Site. In cases where we process your personal data based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of our processing of your data prior to your withdrawal of consent.
  • where necessary for the purposes of the legitimate interests pursued by the relevant company within the SPO Group, where we have considered these are not overridden by your rights. 
  • where necessary for us to comply with our legal obligations or to enforce or defend our legal rights.
The purposes for which we process your personal data include the above and in relation to our legitimate interests, include the following:
  • marketing and development of the business – to promote our products and services, perform and analyse market surveys and marketing strategies, maintain and promote customer service and development
  • managing and improving our Site – to improve our Site and ensure that content from our Site is presented in the most effective manner for you and your computer, to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to to keep our Site safe and secure.
 

Who do we share your information with?

As we are a global business that operates in many countries, we may share your personal data in the following circumstances: 
  1. with other companies within the SPO Group; 
  1. with our authorised third party service providers who process personal data on our behalf; 
  1. where we have your explicit consent to do so for the particular purposes you have consented to; 
  1. where we are authorised or required by law, or exempted by any applicable legislation, to do so; 
  1. in order to enforce or defend our legal rights.
 
By using our website and providing your personal information to us through our Site, you agree to us using the personal information we collect from you and your use of our Site in accordance with the terms of this Privacy Policy and applicable data protection laws and regulations.
 

Transfers of personal data
 
Where the personal data has been transferred to companies within the SPO Group and/or to authorised parties located outside of your country (including outside of the European Union) we take corporate, contractual and legal measures to ensure that your personal data is processed strictly on a need to know basis for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include European Commission approved transfer mechanisms for transfers to third parties in countries which have not been deemed to provide an adequate level of data protection. You can request a copy of these measures by contacting dataprotectionofficer@swire.com.sg.
 

Safeguarding your personal data
 
As we value the privacy of your personal data, we have implemented technology and policies to protect your personal data from unauthorised access, modification and improper use. 
We will treat all personal information you provide us through the Site confidentially and securely in compliance with this privacy notice.
 

Your privacy rights and who to contact
 
You have the right in certain circumstances to: 
  1. request for information on the data we hold about you; 
  1. correct or update your personal information which you have provided to us; 
  1. delete your personal data or withdraw consent you previously provided to us to use the personal data we hold about you (where it is no longer required for a legitimate business purpose), but note that deletion of such data or withdrawal of such consent may result in us not being able to provide you the service you requested or respond to the enquiry / feedback you have submitted or process the job application you submitted or not being able to provide you with the most effective experience on our website. 

Please contact our Data Protection Officer at dataprotectionofficer@swire.com.sg if you have any questions, comments or concerns about how we handle your personal data. To assist us in dealing with your request, please provide your full name and details. Please allow us reasonable time to respond to your request and effect any change.
 
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority (see http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm) for further assistance.
 

How long do we retain your personal data?
 
For personal data submitted for job applications through our website, please refer to our privacy notice for job applicants on our retention policy for such information.
 
For all other personal information submitted through our website by you, we will delete such personal data without undue delay once there is no longer a legitimate purpose to retain it, or where you object to or withdraw your consent for the processing of your personal data.
 
Please note that in all cases, we may retain the personal data for a longer period of time where there is a legal or regulatory reason to do so.
 

Changes to this Website Privacy Notice
 
This Website Privacy Notice may be changed over time. You are advised to regularly review the Website Privacy Notice for any changes made. This Website Privacy Notice was last updated in May 2018.
 

Recruitment Privacy Notice

PRIVACY NOTICE FOR JOB APPLICANTS (“RECRUIMENT PRIVACY NOTICE”)
 
 
What does this Recruitment Privacy Notice apply to?
 
This Recruitment Privacy Notice sets out the policy of the Swire Pacific Offshore Group (“SPO Group”) in relation to the personal data we collect from individuals who apply for any employment, job or internship with the SPO Group. In this policy, the SPO Group means Swire Pacific Offshore Operations Pte Ltd (“SPO”) and all its affiliates as set out in our website.
 
As well as this Recruitment Privacy Notice, local privacy notices may vary among the countries in which the SPO Group operates to reflect local practices and legal requirements and is subject at all times to applicable law.
 
If in the course of or prior to your job application with us, you visit our website to learn more about us, please also refer to our Privacy Notice for our Website Users to learn more about the information we collect through your use of our website.
 
This Recruitment Privacy Notice explains what personal data we collect from you, for which purposes we collect and use such personal data, how long we retain the personal data, how to access and update your personal data and how to contact us for further information.
 

Who is responsible for your personal information?
 
Unless otherwise informed to you or set out in the job portal on our Site, Swire Pacific Offshore Operations Pte Ltd, a company registered in Singapore with its business address at 300 Beach Road, #15-01 The Concourse, Singapore 199555, is responsible for processing your personal data on behalf of itself or the relevant company within the SPO Group to which you are applying for a job. 
 

What information do we collect from you and for what purposes do we use such information:

What personal data do we collect? Legal basis and purpose for processing the data?
Personal information such as:
  • Your name, address and contact details
  • date of birth, marital status, place of residence
Prior work experience information such as:
 
  • CV, employment history, reference information and/or information received from background checks (where applicable). Such information may be provided to us by third parties e.g. recruiters.
  • Professional qualifications and certificates.
  • Education history and transcripts.
  • Information from interviews.
 
Special categories of data (“sensitive personal data”) such as:
  • Health data – while we do not generally collect your health data for recruitment purposes, where required or permitted by local law to assess your fitness to work, we will process your health data strictly for such purpose only.
 
  • Information regarding nationality, racial or ethnic origin – such information may be processed in order to ensure equal employment opportunities and fair employment practices as permitted or required by local law.
Sensitive personal data are processed only as strictly required and as permitted or required by local law.   
Our legal basis for processing your personal data could be any of or a combination of the following:
  • To take steps at your request prior to entering into a contract with you.
  • where necessary for the purposes of the legitimate interests pursued by the relevant company within the SPO Group, where we have considered these are not overridden by your rights.  Such legitimate interests include the following:
    • To verify your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job.
    • To comply with the SPO Group’s own internal policies such as equal opportunity, modern slavery and human trafficking policy
  • where necessary for us to comply with our legal obligations or to enforce or defend our legal rights. Our legal obligations include compliance with equal employment opportunities, fair employment practices, minimum legal working age, local content requirements under applicable law.
  • (only if legally required) in accordance with the purposes for which you have granted your explicit consent. In cases where we process your personal data based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of our processing of your data prior to your withdrawal of consent.
Information collected automatically when you apply for a job through our website through the use of cookies and other technologies Please refer to our Website Privacy Notice and our Cookie Policy for more information on the personal data we collect from you through your use of our website and our use of cookies on our website, and how we use such personal data.
 

Who do we share your information with?

Your personal data is processed only for the purposes above and may be shared with third parties in the following circumstances: 
  1. with other companies within the SPO Group; 
  1. with our authorised third party service providers who process personal data on our behalf, including to carry out reference and background checks on our behalf; 
  1. referees indicated in your application or during your interview for the purposes of carrying our reference checks; 
  1. where we have your explicit consent to do so for the particular purposes you have consented to; 
  1. where we are authorised or required by law, or exempted by any applicable legislation, to do so; 
  1. in order to enforce or defend our legal rights.
 
Transfers of personal data
 
Where your personal data has been transferred to companies within the SPO Group and/or to authorised parties located outside of your country (including outside of the European Union) we take corporate, contractual and legal measures to ensure that your personal data is processed strictly on a need to know basis for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include European Commission approved transfer mechanisms for transfers to third parties in countries which have not been deemed to provide an adequate level of data protection. You can request a copy of these measures by contacting dataprotectionofficer@swire.com.sg.
 

Safeguarding your personal data
 
As we value the privacy of your personal data, we have implemented technology and policies to protect your personal data from unauthorised access, modification and improper use. 
We will treat all personal information you provide us through the Site confidentially and securely in compliance with this privacy notice.
 

Your privacy rights and who to contact
 
You have the right in certain circumstances to: 
  1. request for information on the data we hold about you; 
  1. correct or update your personal information which you have provided to us; 
  1. delete your personal data or withdraw consent you previously provided to us to collect / use the personal data we hold about you (where it is no longer required for a legitimate business purpose), but note that failure to provide us with the information required for us to evaluate your job application will affect our ability to evaluate your suitability for employment with us. This may negatively affect your chances of being selected for any potential employment, engagement or internship with us. 

Please contact our Data Protection Officer at dataprotectionofficer@swire.com.sg if you wish to access, correct or delete your personal data, or have any questions, comments or concerns about how we handle your personal data. To assist us in dealing with your request, please provide your full name and details. Please allow us reasonable time to respond to your request and effect any change.
 
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority (see http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm) for further assistance.
 

How long do we retain your personal data?
 
Where you have been unsuccessful for the job application, we will delete your personal data without undue delay unless you consent to us retaining your information for future job opportunities within the SPO Group for such longer period as informed to and agreed by you. 
 
Please note that in all cases, we may retain the personal data for: 
  1. a longer period where there is a legal or regulatory reason to do so; or 
  1. a shorter period where the individual objects to the processing of their personal data and we no longer have a legitimate purpose to retain the personal data. 

If you are successful in your application, the information collected during your application and recruitment process will become part of your employment record and will be used and retained in accordance with our Employee Privacy Notice, a copy of which will be provided to you upon commencement of employment, engagement or internship.
 

Changes to this Recruitment Privacy Notice
 
This Recruitment Privacy Notice may be changed over time. You are advised to regularly review the Recruitment Privacy Notice for any changes made. This Recruitment Privacy Notice was last updated in May 2018.
 


B2B Privacy Notice

PRIVACY NOTICE FOR OUR BUSINESS SUPPLIERS, CUSTOMERS, AGENTS, CONSULTANTS, ADVISORS, PARTNERS AND INVESTORS (“B2B PRIVACY NOTICE”)
 
 
What does this B2B Privacy Notice apply to?
 
This B2B Privacy Notice sets out the policy of the Swire Pacific Offshore Group (“SPO Group”) in relation to the personal data we collect from individuals who work for or on behalf of or who are shareholders of our business suppliers, customers, agents, consultants, advisors, partners and investors, including users of our Orbis vendor portal. In this policy, the SPO Group means Swire Pacific Offshore Operations Pte Ltd (“SPO”) and all its affiliates as set out in our website.
 
As well as this B2B Privacy Notice, local privacy notices may vary among the countries in which the SPO Group operates to reflect local practices and legal requirements and is subject at all times to applicable law.
 
If in the course of or prior to your business dealings with us, you visit our website to learn more about us, please also refer to our Privacy Notice for our Website Users to learn more about the information we collect through your use of our website.
 
This B2B Privacy Notice explains what personal data we collect from you, for which purposes we collect and use such personal data, how long we retain the personal data, how to access and update your personal data and how to contact us for further information.
 

Who controls your personal information?
 
Unless otherwise specified in our business contract with you, your personal data is ultimately controlled by Swire Pacific Offshore Operations Pte Ltd, a company registered in Singapore with its business address at 300 Beach Road, #15-01 The Concourse, Singapore 199555, and/or one or more of the companies within the SPO Group, depending on your location. 
 

What information do we collect from you and for what purposes do we use such information:

What personal data do we collect? Legal basis and purpose for processing the data?
Business contact and other information such as
  • your name, designation, department, name of organization and your contact details,
  •  your dealings with us on behalf of yourself or our relevant business customer, supplier, partner, agent or investor.
Such information may be provided directly by you to us or by a third party such as your employer or your business partner, customer or supplier whom we work closely with, or through our  Orbis vendor portal.
Our legal basis for processing your personal data could be any of or a combination of the following:
  • To take steps at your request prior to entering into a contract such as conducting credit checks and fulfilling our onboarding requirements.
  • To perform our business contract with you or where applicable, our business customer, supplier, partner, agent or investor whom you act on behalf of or represent.
  • where necessary for the purposes of the legitimate interests pursued by the relevant company within the SPO Group, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual(s). 
  • where necessary for us to comply with our legal obligations or to enforce or defend our legal rights.
  • (only if legally required) in accordance with the purposes for which you have granted your explicit consent. In cases where we process your personal data based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of our processing of your data prior to your withdrawal of consent.
The purposes for which we process your personal data include the above and in relation to our legitimate interests, include the following:
  • Conducting and developing the business such as researching, developing and improving our products or services, managing our business relationships including account management, business development and marketing in relation to our existing and prospective business suppliers, customers, partners, agents or investors.
  • Organisation and governance of business such as financial management, asset management, mergers, acquisitions or divestitures, implementation of controls, management reporting, analysis, internal audits and investigations
  • Health, safety and security such as protecting an individual’s life or death, occupational health and safety, protection of SPO Group assets and staff, authentication of individual status and access rights
Information required to screen individuals such as directors, officers, sole traders, shareholders and key stakeholders of our current and potential counterparties. This screening takes place against publicly available or government issued sanctions lists and media sources     To comply with legal and regulatory obligations including but not limited to trade control, sanctions and/or bribery and corruption laws and other regulatory requirements. The screening does not result in any automated decision making in relation to our current counterparties or potential counterparties.
Information collected when you visit our website or Orbis vendor portal Please refer to our Website Privacy Notice for more information on the personal data we collect from you through your use of our website or Orbis vendor portal and how we use such personal data.
Information collected through the use of cookies when you visit our website or Orbis vendor portal    Please refer to our Cookie Policy for more information on the personal data we collect through the use of cookies.
 

Who do we share your information with?

As we are a global business that operates in many countries, we may share your personal data in the following circumstances: 
  1. with other companies within the SPO Group; 
  1. with our authorised third party service providers who process personal data on our behalf; 
  1. in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective buyer or seller of such business or assets subject to the terms of this privacy policy; 
  1. where we have your explicit consent to do so for the particular purposes you have consented to; 
  1. where we are authorised or required by law, or exempted by any applicable legislation, to do so; 
  1. in order to enforce or defend our legal rights.
 
Transfers of personal data
 
Where your personal data has been transferred to companies within the SPO Group and/or to authorised parties located outside of your country (including outside of the European Union) we take corporate, contractual and legal measures to ensure that your personal data is processed strictly on a need to know basis for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include European Commission approved transfer mechanisms for transfers to third parties in countries which have not been deemed to provide an adequate level of data protection. You can request a copy of these measures by contacting dataprotectionofficer@swire.com.sg.
 

Safeguarding your personal data
 
As we value the privacy of your personal data, we have implemented technology and policies to protect your personal data from unauthorised access, modification and improper use. 
We will treat all personal information you provide us through the Site confidentially and securely in compliance with this privacy notice.
 

Your privacy rights and who to contact
 
You have the right in certain circumstances to: 
  1. request for information on the data we hold about you; 
  1. correct or update your personal information which you have provided to us; 
  1. erase your personal data or withdraw consent you previously provided to us to use the personal data we hold about you (where it is no longer required for a legitimate business purpose), but note that erasures of such data or withdrawal of such consent may result in us not being able to provide you with the service or information you requested or to take steps to enter into or perform the contract. 

Please contact our Data Protection Officer at dataprotectionofficer@swire.com.sg if you wish to access, correct or delete your personal data, or have any questions, comments or concerns about how we handle your personal data. To assist us in dealing with your request, please provide your full name and details. Please allow us reasonable time to respond to your request and effect any change.
 
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority (see http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm) for further assistance.
 

How long do we retain your personal data?
 
Any personal data you have provided us in order for us to take steps at your request prior to entering into a contract, or which we require to perform a contract with you, including for the purposes of considering any bids or tenders with you, will be held throughout the bid / contract period and up to 7 years after such period.
 
Please note that in all cases, we may retain the personal data for: 
  1. a longer period where there is a legal or regulatory reason to do so; or 
  1. a shorter period where the individual objects to the processing of their personal data and we no longer have a legitimate purpose to retain the personal data.
 
Changes to this B2B Privacy Notice
 
This B2B Privacy Notice may be changed over time. You are advised to regularly review the B2B Privacy Notice for any changes made. This B2B Privacy Notice was last updated in May 2018.