Last updated: 9th December 2020
Forsa Energy Gas Holdings 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.
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.
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.
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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.
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.
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 email@example.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.
If you have any questions, comments and requests regarding this policy, please address these to firstname.lastname@example.org