Privacy

FORSA WEBSITE PRIVACY POLICY

Last updated:   24th January 2019

Introduction

Forsa Energy Limited and its affiliates (hereinafter together “Forsa”, “we”, “our” or “us”) respect your privacy and protecting your personal data is a top priority for us. This policy sets out the basis on which we will process any personal data we collect from you, or that you provide to us, in connection with our business, and/or your use of our website at www.forsaenergy.com (the “Website”). It also tells you about your rights and how privacy law protects you.

If you are located in the EU or the United Kingdom, for the purpose of the European General Data Protection Regulation and the Data Protection Act 2018, Forsa Energy Limited (registered office at 1st Floor, 17 Slingsby Place, London, WC2E 9AB, United Kingdom) is the data controller and responsible for the Website. This privacy policy is issued on behalf of the Forsa group of companies (“Forsa Group”), so when we mention Forsa in this policy, we are referring to the relevant company in the Forsa Group responsible for processing your personal data.

Please read this policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your information.

The types of data we collect about you

We collect, use, store and transfer different kinds of personal data about you when commencing and maintaining business relations, including data which we have received legitimately from publicly accessible sources (e.g. land registers or company registries) and other third parties with which we have long-standing business relationships.

The scope of such personal data includes:

  •  Identity/Contact Data including (i) for individuals, first and last names, address, contact data (e.g. email address, telephone number) date of birth, data from any identity documents submitted, and bank details; and (ii) for corporate suppliers or customers, the name of the legal representative, company, company registration number, VAT number, address, contact person and contact data (e.g. email address, telephone number,) and bank details.
  • Business Relationship Data. Information concerning the nature and details of our business relationship with you, including contract data, customer or supplier history and consultancy documentation; information about financial status (e.g. creditworthiness), other data that we have received from you in the course of our business relationship, and data which we generate from master/contact data.
  • Technical Data. When you visit the Website, we automatically collect information sent to us by your computer, mobile phone or other device. This includes your IP address, browsing actions and patterns, device information (including but not limited to name, identifier and type of operating system) and other technology on the devices you use to access the Website.
  • Usage Data includes information about how you use the Website. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

How we use your information

We only use your personal data when the law allows us to. Most commonly, we will use your information:

  • To comply with (pre)contractual obligations. Your data is processed for procurement purposes as well as for supplier, customer and partner management and analysis. In particular, data is processed when commencing and maintaining business relations with you and executing contracts with you.
  • To protect legitimate interests. It is in our legitimate interests (or those of a third party) to process your information to provide effective services, including but not limited to administration of the Website and ensuring it is safe and secure and/or in the context or legal proceedings.
  • To comply with legal obligations. Your data may require to be processed for the purpose of meeting various legal obligations which Forsa is subject to.
  • With your consent.

Cookies

We use cookies on our Website to collect information about your browsing activities. Cookies are small text files that are stored on your browser or on your device until you delete them. They allow us to recognise your browser when you next visit the Website and count the number of visitors to our Website. By continuing to browse the Website, you are agreeing to our use of cookies.

The Website uses Google Analytics, an internet analysis service from Google. Google Analytics uses cookies which are stored on your computer and which enable your use of the Website to be analysed. This enables us to provide you with a good browsing experience and allows us to improve the way our Website works.

You can modify your browser settings so that it notifies you when cookies are sent to it or disable cookies altogether. The Help function within your browser should tell you how to do this. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers. Google Analytics may be disabled by installing the following add-on: https://tools.google.com/dlpage/gaoptout. If you disable or block cookies, please note that some parts of our Website may become inaccessible or not function properly.

How we share your information

We only share your information with selected recipients for the purposes set out in this policy. Even if we use a service provider in the context of processing your data, we remain responsible for protecting your information. All of our contractors are contractually obliged to handle your data confidentially and process it only within the scope which is required for the purpose of the services being undertaken. The contractors we engage will receive your personal data if required to perform their respective services. These include, for example, IT service providers that we need to operate and protect our Website.

Your data will be shared with companies which are part of the Forsa Group. Other service providers, including professional advisors, banks, invoice management service providers and insurance companies may also receive your data for the purpose of entering into and fulfilling contracts.

In addition, we will share your information with law enforcement agencies, authorities or other organisations where this is legally required and in the context of legal proceedings, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation or request; enforce our terms and conditions and other agreements. External auditors may also receive your information.

Where we store your information

Transfers of your data outside the European Economic Area (EEA) may take place in individual cases. Whenever we transfer your personal data out of the EEA, this will only be on the basis of an adequacy decision with regard to the level of protection for personal data by the European Commission, standard contractual clauses as approved by the European Commission or your express consent.

The security of your information

We will do our best to protect your personal information and have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Unfortunately, however, the transmission of information via the internet or email is not completely secure and we cannot guarantee the security of your information transmitted through the Website or over email; any such transmission is at your own risk.

Third-party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy of every website you visit.

How long we store your information

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We may retain your personal data for a longer period in the event of a complaint or until any legal disputes in which the data is required as evidence have ended.

Your rights

You have certain rights under data protection laws in relation to your personal data, including to request copies of information; or to correct, delete or restrict (suspend) the information. In addition, you can object to the processing of your information in certain circumstances (in particular, where we do not have to process your information to meet a contractual or legal requirement).

Certain of these rights may be limited. For example, if you ask us to delete information which we are required to retain by law or where we have overriding legitimate interests in retaining such information.

If you wish to exercise any of the rights set out above, please contact legal@forsaenergy.com. If you have unresolved concerns, you have the right to make a complaint to the Information Commissioner’s Office, the UK supervisory authority for data protection issues – www.ico.org.uk.

Changes to the privacy policy

We keep our privacy policy under regular review. Any changes made to this policy will be posted on our Website. Please check back from time to time to see any updates or amendments to this policy.

Contact

If you have any questions, comments and requests regarding this policy, please address these to legal@forsaenergy.com .