Your data will generally be stored on systems located in the United Arab Emirates and Singapore. We will comply with all applicable legal requirements, including the legal requirements of the place where the data is collected and the place where the data is transferred to, where your personal data has to be transferred to a country other than your own for the purposes set out in this Data Protection Notice. This will include ensuring that following any transfer, your personal data is given the same level of protection which we are required to provide in your country or adopting appropriate safeguards to protect your personal data, such as for example by entering into standard contractual clauses that have been approved by a competent regulator.
It should be noted that the collection, storage, use, processing, transfer (including offshore transfer), disclosure or erasure of personal data by the Borouge Group's holding companies, the Abu Dhabi National Oil Company and Borealis AG, will be covered by the policies of these respective entities and these entities operate independently of the Borouge Group. Kindly refer to section 7 of this Data Protection Notice for further details on this.
3. What is personal data
In this Data Protection Notice, “personal data” means any information which can be used to identify you or any other individual, directly or indirectly, or which otherwise describes your behaviour or that of any individual, including but not limited to the data set out in section 4 below.
In some countries, certain types of personal data may be classified as "sensitive personal data" (including but not limited to personal data revealing or concerning (directly or indirectly) your (or any other individual's) racial or ethnic origin, political opinions, religious or philosophical beliefs, where applicable trade-union membership and health and sex life). Borouge generally does not collect sensitive personal data, unless permitted by applicable law, or where required by a competent regulatory authority.
Where we need to collect unique information from you, such as passport or identification numbers where you seek employment with us, your separate express consent to process this data may be obtained, and we will comply with any applicable legal requirements in relation to processing such personal data.
4.Types of personal data collected
Borouge may collect personal data about you either directly from you, from your authorised representatives (i.e. persons who you have authorised and persons who have been validly identified as being you or your authorised representative), from third parties, or publicly available sources.
Subject always to applicable legal requirements, personal data which we may collect includes but is not limited to:
(a) Personal information such as your name, passport or identification numbers, date of birth, marital status or gender;
(b) Contact information such as postal addresses, email addresses, telephone, mobile phone and fax numbers;
(c) Employment information such as employment history and references, resumes, organisation name, organisation type, industry sector, job function and responsibilities, designation, business telephone and fax numbers, business email addresses;
(d) Education information and academic qualifications such as schools attended, courses of study, the period of study and academic results;
(e) Financial information such as bank account details;
(f) Records from discussions or correspondences, including details obtained through customer satisfaction or other surveys;
(g) Details of your transactions with Borouge for the provision of any products;
(h) Information derived from cookies (small text files which uniquely identify your browser) where you visit any website or use any application created by or on behalf of Borouge; and
(i) IInformation you provide to Borouge in relation to the provision of any products from Borouge to you or in relation to your employment with Borouge.
5.Collection of personal data
We may collect personal data from you in the following ways:
(a) when you submit an application form or registration form, or other forms (for example, relating to any of our products);
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you transact with us for our products;
(c) when you interact with our employees, agents, representatives or officers, for example, via telephone calls, letters, face-to-face meetings, social media platforms and emails;
(d) when you use our electronic services, or interact with us via any of our websites or use services on any of our websites;
(e) when you request that we contact you or request that you be included in an email or other mailing list;
(f) when you respond to our promotions, initiatives or to any request for additional personal data;
(g) when your images are captured by us via CCTV cameras (retained for 30 days) while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises or events sponsored by us at other locations;
(h) when you are contacted by, and respond to, our marketing representatives and customer service officers;
(i) when we receive references from business partners, sales contacts and/or other third parties, for example, where you have been referred by them;
(j) when you fill up surveys administered by our third-party surveying service providers;
(k) when we seek information from third parties about you in connection with the products you have applied for; and/or
(l) when you submit your personal data to us for any other reason, to the extent that it is permissible by applicable laws.
When you browse our websites, or use our applications and/or digital services, we may collect and store certain information automatically. Please see the section below on cookies for additional detail.
If you provide us with any personal data relating to a third party (e.g. information relating to your spouse, children, parents (dependent on jurisdiction, for example under UAE Federal Law is categorised as sensitive personal data), and/or employees), you represent and warrant to us that you have obtained the prior consent for the respective purposes set out above, and for us to use such data for the purposes and in the manner set out in this Data Protection Notice.
We generally do not collect personal data from children and minors and will take reasonable measures to remove such personal data from our systems. If you believe that a child or minor has provided us with personal data, please contact us in accordance with section 12 below.
You should ensure that all personal data submitted to us is complete, accurate, true, current and correct. Please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided in section 12 below.
6.Purposes for the collection, use and disclosure of personal data
We may collect, store use, process, transfer (including offshore transfer) disclose and erase your personal data for the following purposes:
(a) verifying and authenticating your identity for the purpose of providing you with our products, or where you provide products and/or services to us;
(b) responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
(c) managing the administrative and business operations of Borouge and complying with internal policies and procedures;
(d) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the entities of the Borouge Group of companies;
(e) matching any personal data held which relates to you for any of the purposes listed herein;
((f) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical or other purposes;
(g) preventing, detecting and investigating crime and analysing and managing commercial risks;
(h) managing the safety and security of our premises (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(i) archival of documents and records in both electronic and physical form for record-keeping purposes for no longer that is required by any applicable law;
(j) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
(k) conducting investigations relating to disputes, billing or fraud;
(l) complying with any applicable local or foreign statute, rule, law, regulation, judgment, decree, directive, code of practice, guideline, administrative requirement, sanctions regime, court order, or contractual agreement to which any Borouge entity is a party;
(m) any other purposes which are permitted under applicable law and for which your consent is not expressly required on the basis that, where recognised under the applicable law, we have a legitimate interest and such interests are not otherwise overridden by your fundamental rights or compelling legitimate interests under any applicable law; and/or ;
(n)any other purposes for which you have provided information;
(o) sharing of personal data with other entities as set forth in this Data Protection Notice.
In addition, we may collect, store, use, process, transfer (including offshore transfer), disclose and erase your personal data for the following purposes depending on the nature of our relationship:
(a) User / Visitor on Website
If you browse, use or visit our websites, applications and/or any digital services,
(i) to aggregate anonymised statistical data and gather feedback to enable us to continually improve our website and your user experience;
(ii) to administer our website, including for troubleshooting;and/or
(iii) to the extent permitted by any applicable laws, to personalise and tailor your experience on our website.
(b) Customer / Consumer
If you are an employee, business partner, sole proprietor, director, nominee director or guarantor, agent, distributor or representative of an organisation that is a customer (including prospective customer) or otherwise has a corporate relationship with Borouge:
(i) to assess and process any requests, applications or orders made by you for any products;
(ii) to facilitate the continuation or termination of your business relationship with any of the entities of the Borouge Group;
(iii) creating and maintaining the profile or account in our system database for internal records and reference;
(iv) to provide you with customer service and support;
(v) to facilitate and carry our due diligence checks;
(vi) to facilitate marketing and promotional activities; and/or
(vii) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, or customer due diligence).
(c) Vendor / Service Provider
If you are an agent, employee, officer or owner of an external service provider or vendor outsourced or prospected by Borouge:
(i) to manage project tenders or the supply of goods;
(ii) to process and pay vendor invoices; and/or
(iii) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks).
(d) Candidate for employment
If you submit an application to us as a candidate for employment:
(i) to respond to, and process, your application for employment with a Borouge Group company;
(ii) to conduct the interview process;
(iii) to process your application which includes pre-recruitment checks involving your qualifications and facilitate the interview process;
(iv) to provide or obtain employee references and for background screening;
(v) for evaluative purposes such as assessing your suitability for the position applied for;
(vi) to process staff referrals under our internal referral scheme; and/or
Where permitted by any applicable law, we may also collect, store, use, process, transfer (including offshore transfer), disclose and erase your personal data for the following additional purposes:
(a) subject to your consent, for providing or marketing our products, including but not limited to any special events and promotions organised by Borouge; and/or
(b) subject to your consent, for conducting market research, analytics and surveys to enable Borouge to understand and determine customer preferences and demographics for us to offer you our products as well as marketing programmes.
In relation to particular products or in your interactions with Borouge, we may specifically notify you of additional purposes for which we collect, store, use, process, transfer (including offshore transfer), disclose or erase your personal data. If so, we will collect, use and disclose your personal data for these additional purposes as well, unless we have specifically notified you otherwise.
7. Disclosure of personal data
We may share your personal data with other companies in the Borouge Group.
Depending on the products you require, we may also need to share your personal data with other companies, including our holding companies, the Abu Dhabi National Oil Company and Borealis AG, and their respective subsidiaries. Any transfer or sharing of your personal data with our holding companies and affiliates, and/or related processing, will be carried out proportionally in accordance with the purposes stated in section 6. In this regard, please be assured that when our holding companies are located in countries where laws governing the processing of personal data do not provide an adequate level or protection for your personal data, we shall implement adequate safeguards to protect your personal data, for example, by signing standard contractual clauses approved by a competent regulator.
Your personal data may also be disclosed for the purposes listed in section 6 to the following third parties:
(a) agents, contractors or third-party service providers who provide services to the Borouge Group;
(b) banks, financial institutions, credit card companies and their respective service providers;
(c) any business partner, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving a Borouge Group company;
(d) our professional advisers such as our auditors and lawyers; and/or
(e) any judicial, administrative or regulatory body, any government or public or government agency, instrumentality or authority, any domestic or foreign tax, revenue, fiscal or monetary authority or agency, securities or futures exchange, self-regulatory organization, trade repositories, central counterparties, court, central bank or law enforcement body or any agents thereof.
