Our Privacy Policy aims to give you information on how Sirius Petroleum Plc collects and processes your personal data through the use of our website or any other interaction with Sirius Petroleum Plc. We keep our Privacy Notice under regular review. Please ensure you look at it regularly to be aware of any updates.

Cookies

Please also note our separate Cookies Policy which describes how we use cookies on this website and how to refuse the use of cookies.

Privacy Notice – website

1. PURPOSE

This privacy notice aims to give you information on how Sirius Petroleum Plc (‘Sirius Petroleum”) collects and processes your personal data through the use of our website.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

As the data controller of this website, in association with Q4 Inc, web host of the Sirius Petroleum website, we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained intis privacy notice.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

1.1. DATA CONTROLLER

Sirius Petroleum is made up of different legal entities, details of which can be found in our Annual Report and Accounts. This privacy notice is issued on behalf of Sirius Petroleum plc, which is the data controller and responsible for the website.

Our Compliance Manager is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Compliance Manager using the details set out below.

CONTACT DETAILS
Our full details are:
Company Secretary, Sirius Petroleum plc
Email address: Enquiries@siriuspetroleum.com
Address: Sirius Petroleum Plc, 25 Bury Street, London, SW1Y 6AL

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.2. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated in September 2020. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. We reserve the right to change this Privacy Notice at any time without notice to you so please check back regularly to obtain the latest copy of this Privacy Notice.

This Privacy Notice does not override any applicable national data privacy laws and regulations in countries where the Company operates.

1.3. THIRD-PARTY LINKS

Our 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 our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier.
  • Contact Data includes email address and telephone numbers.
  • Usage Data includes information about how you use our website.

Communications Data includes your preferences in receiving communications and alerts from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.1. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • subscribe to our alert service
  • request marketing or publications to be sent to you or
  • give us some feedback

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below.

Identity and Contact Data from publicly available sources such as Companies House.

4. HOW WE USE YOUR PERSONAL DATA

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

  • Where we need to perform the contract we are about to enter into or have entered into with you
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation

Generally, we do not rely on consent as a legal basis for processing your personal data.

4.1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful purpose depending on the specific reason for which we are using your data. Please contact the Compliance Manager if you need details about the specific legal grounds we are relying on to process your personal data. Details of the lawful bases have been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To send you communications via our alert service (a) Identity (b) Email In pursuit of our legitimate interests including supporting business communications and regulatory announcements, maintaining and managing our communications with you
Administering the contract we have entered into with you (a) Identity
(b) Contact
(c) Financial
Performance of a contract with you
Business management and planning, including accounting and auditing (a) Identity
(b) Contact
(c) Financial
(d) Terms of appointment
Performance of a contract with you
Statutory, regulatory and legal obligations (a) Identity
(b) Contact
(c) Financial
(d) Terms of appointment
To comply with our legal obligations
HSE information for offshore representatives (a) Identity including passport
(b) Contact
To comply with our legal obligations
Conducting general business relationships (a) Identity including passport
(b) Contact
(c) Financial
In pursuit of our legitimate interests including supporting business communications and complying with our regulatory and legal obligations, including assessing and managing risk

4.2. OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting our Compliance Manager.

4.3. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Compliance Manager.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary
  • External Third Parties as set out in the Glossary
  • Specific third parties such as Q4 Inc who host our website

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the EEA. However certain External Third Parties with whom we may share your personal data may transfer your personal data outside of the EEA as a consequence of sharing your personal data within their group of companies. We will not consent to an External Third Party transferring your personal data outside of the EEA (including any onward transfer) unless they undertake to comply with the requirements of the General Data Protection Regulations in relation to such transfers.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

8.1. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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 requirements.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact the Compliance Manager.

9.1. NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

9.2. WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.3. TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within 28 days. Occasionally it may take us longer than 28 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. RIGHT TO LODGE A COMPLAINT

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact the Sirius Compliance Manager in the first instance using the details set out below.

Company Secretary, Sirius Petroleum plc
Email address: Enquiries@siriuspetroleum.com
Address: Sirius Petroleum Plc, 25 Bury Street, London, SW1Y 6AL
Phone number: +44 (0) 20 3967 4500

11. COMPLIANCE MANAGER

We have a Compliance Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Compliance Manager using the details these details:

Company Secretary, Sirius Petroleum plc
Email address: Enquiries@siriuspetroleum.com
Address: Sirius Petroleum Plc, 25 Bury Street, London, SW1Y 6AL