Privacy policy

Introduction

We are committed to ensuring we respect your right to privacy and shall ensure all necessary measures are implemented to protect personal information you entrust to us. This policy describes the practices that the Vivo Energy Group Companies (VE, “we”, “us”, or “our”) follow when handling personal information that we collect or receive on you in conducting our business. It describes how we will treat your personal information provided to us by you through use of our services, products, websites and user applications or collected by us through other means when you engage with us.

Definition of personal information

Personal Information means any information relating to an identified or identifiable natural person (known as the data subject). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location information, an online identifier or by one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of the natural person.

Personal information does not include information that is truly anonymised, i.e. where the data subject is no longer identifiable. Personal information also does not include corporate information that relates to an organisation but not to an individual, such as a corporate name, corporate address or general corporate phone number.

Sensitive Personal Information varies between countries, but often includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health condition or sexual life, genetic or biometric identifiers, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive Personal Information will only be processed under strict conditions.

For whom is this Privacy Policy for

Our employees, contractors or consultants will be required to act consistently with this Privacy Policy on our behalf and will be made aware of the Privacy Policy in our dealings with them. Joint Venture companies not under our control are encouraged to adopt similar practices and standards.

Vivo Energy Contact Information

We are committed to responding to and resolving questions, requests and/or complaints about your personal information and our collection or processing of your personal information. We have an appointed Data Privacy Officer who is responsible for overseeing this Policy and such matters and who you may contact via email to [email protected].

We will investigate and will do our best to resolve any complaints or disputes you bring to our attention within a reasonable timeframe and as guided under applicable data protection law.

Contact details of all Vivo Energy subsidiaries and affiliates (Vivo Energy Group Companies) are available on our website at: https://www.vivoenergy.com/Contact/Country-Contacts

Collection of personal information

Personal information you provide to us.

We collect personal information that you provide to us through our websites and business applications, in connection with business dealings we may have with you, and/or where we are legally obliged to as part of a contractual agreement or legal obligation to ensure compliance with applicable legislation. We may also collect your personal information based on your consent or where you have shown interest on a product or service.

This includes:

Employment engagements and application for employment via our recruitment processes;
Know Your Counterparty (KYC) process when performing due diligence checks on potential partners;
Vendor, Supplier or customer agreements for the provisioning of products and services;
Loyalty programmes;
Use or viewing our websites via your browser’s cookies;
Voluntarily via promotional offers, community events and engagements held at our operational sites

What data do we collect?

The personal information you provide will be specific to the relevant business dealing we have with you. This may include:

basic contact information about you, such as your name, username, company name, title, occupation, gender, work and residential address, phone number, fax number and email address, photographs;
Unique identifiers such as personal identification numbers (including date of birth), passport numbers, tax numbers, company registration numbers, VAT Numbers, location data, IP address; biometric data;
Information on the products or services you have shown interest in and/or purchased from us;
Financial information such as the card numbers, expiration date, banking details, transactional information (payments made and received), tax certificates;
Images and video footage where permitted and collected through CCTV Footage

The information you provide to us through recruitment processes will include:

name, date of birth, gender, age, contact information, identification/passport/social security number, professional, educational and employment history.

The categories of Sensitive Personal Information we may collect in specific circumstances and as permitted under applicable law include:

Biometric information on our employees for user authentication and security access purposes to our physical and digital assets;
Health information on our employees as part of our health and safety programme where necessary to determine the individual’s health status at the start of and during their employment with Vivo Energy. ;
Race or ethnic origin on our employees where legally required under specific jurisdictions to monitor diversity and inclusion;
Information about criminal proceedings or offenses committed or alleged to have committed as part of our Know Your Counterparty (KYC) due diligence process.

Website information you provide to us.

Cookies are small pieces of data that can be stored in users’ hardware for the purposes of obtaining configuration information and analysing users’ viewing habits. They are commonly used to track users’ preferences in relation to the subject matter of the website and make users’ online experience easier and more personalized. Please review our Cookie Policy for further information on our use of cookies.

Our websites and applications we offer as part of our business dealings with you may include various contact request forms in which you will voluntarily submit personal information which will be held in accordance with this Privacy Policy.

Website usage can be anonymous information. However, if it is combined with your personal information in a manner that reasonably allows it to be associated with your identity, or is otherwise considered personal information under applicable law, it will be treated as personal information in accordance with this Privacy Policy.

We also use software to help us better understand how you like us to communicate with you and whether you may be interested in our products and services. For example, based on our records that you recently shown interest in a certain product, our software helps us identify related products and services that may interest you. We may then use this to contact you about these by post, telephone, SMS text messaging or email. If you do not wish to receive this type of communication from us, you can opt out at anytime via our engagement portal .

Information we may receive from our counterparties.

From time to time, we may receive personal information about you from counterparties who suggest that we contact you for business purposes. Such personal information may include basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address.

We may receive such personal information because you have given your consent to the relevant counterparty to share your personal information with businesses like ours. If we use that information to contact you, it will only be to see if you are interested in our products or services, or those of our business partners. We will not use this information for other purposes without your consent.

We may also obtain personal information about you from our counterparties in connection with business transactions you initiate with us, such as through credit verification or other processes related to the transaction.

You have the right to opt out at anytime and upon receipt of our first engagement with you if you do not wish to receive any further communication from us.

Use of personal information

For business use

We use your personal information to facilitate our ongoing and proposed business dealings with you. This includes:

To process your business transactions with us;
To fulfil contractual obligations with you or our counterparties;
To establish and maintain counterparty (including customer accounts so that we may provide our products or services as requested by you or your company;
To register you as a user of these products or services so that you may access them through our websites (includingany web portals, mobile applications), operational sites or otherwise;
To communicate with you about updates, maintenance, outages or other technical matters concerning these products or services;
To provide you with training regarding usage of these products or services;
To notify you about changes to any of the policies and procedures for use of these products or services;
To verify the accuracy of account and technical contact information we have on file for you and your company in relation to these products or services;
To respond to questions or inquiries that you or your company may have about our products or services;
To conduct due diligence checks on companies and their directors to establish the legal status of all potential new business partners to ensure we do business with reputable, honest and qualified business partners and agents;
To comply with relevant laws and regulations relating to the products or services that we provide in any of the jurisdictions in which we operate;
To conduct recruitment and hiring process;
General administration on our counterparties, including employees, suppliers, vendors and customers.

Marketing Purposes

With your consent or as otherwise permitted by applicable law, we may use your personal information for purposes relating to the marketing of our products and services, or those of our business partners where you may have shown interest in. This means we may from time to time:

Send you newsletters, press releases, event announcements and other similar communications regarding the products or services that we offer;
Market or promote our products or services to you or similar products to those which you have already signed up for, including by offering you trial or limited access to certain of our products or services;
Solicit input from you regarding improvement of our products or services;
Inform you of third-party offerings that we think you or your company may be interested in which relate to our products or services;
Send you announcements or requests on behalf of other customers of ours who believe you would benefit from use of our products or services; and
Use your personal information for other purposes that we disclose to you at the time we obtain your consent.

You may at any time opt-out to receiving marketing related communication from us, by updating your marketing preferences in the relevant web portals or websites through which you have registered, or by contacting our offices directly in your country of operation, alternatively you may log a request via our engagement portal:

Data Integrity

You are responsible for the accuracy of all personal information you provide to us.

We will use reasonable efforts to maintain the accuracy and integrity of your personal information, and to update that information as appropriate and when requested by you. We will take reasonable steps to ensure that the personal information we collect from you is relevant to its intended use, and that it is only used in ways that are compatible with the purposes for which it was collected or otherwise authorised by you.

Recruitment

We may use the personal information you provide to us for job applications, using our online website, email or via fax solely for the purposes of processing your job application for the position you have shown interest in and in accordance with this privacy notice and applicable law. This may also include data we collect from third parties such as professional recruiting firms, your references, prior employers, educational history and where applicable psychometric tests in order to identify and evaluate candidates for potential employment. We may conduct vetting for specific job roles, which may include criminal background checks and credit checks, as permitted by local laws in our countries of operation. We may retain a record of your job application and references for a period of time, in order to ensure compliance with legal requirements.

Information Sharing

Internal within Vivo Energy

We transact business internationally. From time to time we may share your personal information within our subsidiaries. Such information will be used by each entity consistently with the purpose for which the information was originally collected or subsequently authorised by you. The information may also be processed for administrative, operational and investigation purposes where necessary and to ensure compliance with applicable law.

The personal information that we collect from you may be transferred to, and stored at, a destination outside of the country where the personal information was collected. It may also be processed by members of staff operating outside of the country where the personal information was collected who work for us or one of our service providers. The country where the personal information was collected is transferred under an intra-group data transfer agreement incorporating the terms of the approved standard data protection clauses to ensure appropriate safeguards are put in place in respect of the transfer.

External outside of Vivo Energy

We may disclose and transfer your personal information in connection with a corporate merger, consolidation, restructuring, the sale of stock or assets, or other corporate change, including, without limitation, during the course of any due diligence process. In all such cases, this Privacy Policy will continue to govern the use and disclosure of such information.

In addition, we will share your personal information with partner companies for the following reasons:

We may from time to time employ service providers to perform services on our behalf, such as hosting our data (including your personal information), websites, products and other applications; sending emails and other communications relating to our products and/or services; fulfilling and processing orders for our products or services; assisting with promotions and conferences relating to our products or services, or those of our business partners; providing analytic services, such as in relation to the tracking of usage of our operational sites or websites; or performing other administrative services they are contracted by us to provide. Prior to allowing these service providers to access your personal information, we will enter into a formal agreement with them to ensure that they handle and process the information in accordance with this Privacy Policy and applicable law and ensuring they have adequate technical and organisational controls in place to safeguard your personal data.
To offer various promotions/competitions through our operational sites, websites or elsewhere that may require registration with your personal information. If you choose to enter or otherwise participate in a promotion/competition, your personal information may be disclosed to third parties in connection with the administration of the promotion/ competition, such as in connection with winner selection, prize fulfilment and as otherwise required by applicable laws. By entering into a promotion / competition, you agree to the official rules that govern that promotion, which may contain specific requirements around you, including allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. These rules will be displayed and communicated to you during the registration process, and you will be asked for your consent to the respective data processing at that time.

We will not share your personal information with third parties outside of Vivo Energy for their marketing purposes without your consent.

From time to time, we also may offer you the option of sharing your personal information with third parties in order to receive information and/or marketing offers from them or other persons. If you consent to the sharing of your personal information for these purposes, it will be subject to the privacy policies and business practices of those third parties.

Legal Protections and Law Enforcement

We may access, use, preserve, transfer and disclose to our counterparties your personal information for the following purposes:

To satisfy any applicable law, regulation, subpoena, or legal or regulatory process, if in our opinion such is required or permitted by law or reasonably requested by a regulatory authority (including any listing authority or stock exchange);
To protect and/or defend this Privacy Policy or other Vivo Energy policies or terms of use applicable, including investigations of potential violations thereof, ensuring the protection of the safety, rights, property or security of Vivo Energy or any of our counterparties;
To detect, prevent or otherwise address fraud, security issues or breaches, or technical issues. This may include allowing third parties, such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, to access and use your personal information in order to identify you. We may take any of these steps without notice to you to the extent permitted by law.

Data Protection

Your Data Protection Rights

As an individual (also referred to as a data subject), you have rights regarding the processing of your personal information under data protection law, including rights to, in certain circumstances:

Withdraw any consent you have given, or are deemed to have given, in relation to our collection or use of your personal information;
Request access to any personal information held about you by us and details of the processing of your personal information by us;
Have inaccurate personal information amended or erased, and to have incomplete personal information completed;
Request the erasure of your personal information;
Object to or restrict the processing of your personal information (including profiling), including where the processing is unlawful or no longer necessary;
Receive your personal information in a format suitable for transmission to another data controller;
Object to or unsubscribe to processing of your personal information for direct marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information.
Prevent processing that is likely to cause unwarranted substantial damage or distress to yourself or anyone else;
Object to any decision about you based solely on automated processing (including any profiling) that produces legal effects or otherwise significantly affects you; and
Complain to the relevant data protection supervisory authority or regulator, if you think that we are not complying with our obligations in relation to our processing of your personal information.

You can make a request to us in relation to these rights at any time by submitting a request via our online portal accessible at https://dsr.vivoenergy.com/ All requests will be dealt with promptly and any information to which you are entitled will be provided within a reasonable timeframe, subject to any exemptions stipulated in applicable data protection laws.

If you feel that any attempts to resolve the matter are inadequate, you may lodge a complaint with an appropriate data protection regulator in your jurisdiction.

Data Security

We take protecting your privacy seriously and recognise we have a duty of care to the individuals whose data we hold. As a result, we will only collect and process data as necessary to support the purposes outlined in this policy and will take all reasonable security measures to protect your personal information in our possession from loss, misuse, and unauthorised access, disclosure, alteration or destruction. We will take additional precautions regarding the security of Sensitive Personal Information.While we strive to secure your personal information, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control.

Data retention

We will keep your personal information for as long as you continue to engage with us. We will not retain personal information for longer than is necessary for the purposes for which it was collected, except where retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims. Our retention periods will vary between our countries of operation and is aligned to applicable laws. Once the time period for retention has expired as permitted, we will securely dispose of your data.

Policy Changes

We reserve the right to update this Privacy Policy at any time, without prior notice to you, to the extent permitted by applicable law. We will notify the changes that we make by posting the revised Privacy Policy on our websites, and such changes will be effective immediately unless otherwise stated. We encourage you to check this Privacy Policy periodically for any changes where you continue to engage with us and have business dealings with us where you will be deemed to have accepted the updated Privacy Policy.

Vivo Energy Privacy Policy last updated on the 7 August 2023.