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Privacy Notice and Cookie Policy

This Privacy Notice covers the following:

  • Who we are
  • What information do we collect?
  • Applying to work with us
  • How do we use your information?
  • Who may use your information?
  • Third party links and services
  • How do we protect your information?
  • Where is your information processed?
  • Marketing communications
  • How long do we keep your information?
  • Your rights
  • How do you contact us?
  • How often is this notice updated?
  • Cookies
  • Privacy notice supplement for Brazil

1.1 This Privacy Notice applies to all of the personal data we collect about you, including information collected on our websites (including mobile access or apps) where this notice is linked to; all of which are referred to as the “Site” in this notice, and information collected at events, on our vessels or premises or via telephone with one of our people.

1.2 Your privacy matters to us, so please do take the time to get to know our practices and, if you have any questions, contact us using our contact details below. This Privacy Notice was last updated on 5 July 2018 and applies from that date.

1.3 We may occasionally amend this Privacy Notice. Any new notice will automatically be effective when it is published on the Site. You should therefore return here regularly to view our most up to date Privacy Notice. You should also print a copy for your records.

1.4 We do not knowingly collect or process data from anyone under the age of sixteen (16) years old.

 

2. Who we are

2.1 BW Offshore is a global organisation. By the use of “we” in this Privacy Notice we are referring to the BW Offshore Group whose members are outlined in full in our Annual Report. You can view the Annual Report at www.bwoffshore.com/ir/reports-and-presentations

2.2 We refer to BW Offshore together with its group companies as “BW Offshore”, “we”, “us” or “our” in this Privacy Notice.

 

3. What information do we collect?

3.1 Most of the information we collect is information provided directly by you, which is set out on the web page on which we collect it (for example in our Investor Relations subscription form) at events, on our vessels or premises or by our people by phone. This may include:

  • contact information – information such as name, email address, physical mailing address, device identifier and telephone number;
  • personal information – such as your birthday, gender; hat and shoe size and photograph;
  • professional information – such as your employment background, job description and related information;
  • Social media – such as your LinkedIn, Facebook, twitter or Google account details; and
  • responses to surveys – information you provide in responding to a survey on the Site, via an app or email, on the telephone or otherwise.

3.2 We may also collect and process other information obtained through the Site or the device you are using, including:

  • information through the FPSO University – information for registration for the FPSO University such as your contact information, password and email preferences. If you are a registered user, we collect information about your access to the reserved area of the Site such as information on the date and time of access and with your consent, information on your interests and preferences in relation to our products and services. We also collect information relating to your study; including course number, list of courses you have ordered and information on their status;
  • location information (including GPS signals sent by a mobile device, location information gathered from social media networks or sensor or IP address data from your device);
  • information from cookies, web beacons or from the internet, including your IP address, browser type, operating system, domain name, access times, which pages you visit within our Site and referring website addresses. See section 15. if you ask us to connect with other sites (for example if you ask us to connect with your Facebook account) we may get information that way too; and
  • we may record telephone calls.

 

4. Applying to work with us

4.1 If you use the Site to apply to work with us, we will use the information you supply to process your application and to monitor recruitment statistics. Please do not send us any sensitive personal data with your application unless we specifically ask you for it. As a global business we may transfer your details outside of your home country and to other companies in our group. We will ask you to sign up to additional confidentiality and privacy terms if you apply for a job with us. Once a person has taken up employment with us, we will compile a file relating to their employment. At that stage we will give more details about how we hold employee data and we will expect the employee to sign up to additional confidentiality and privacy terms as part of their employment.

4.2 If you apply to work with us through a third party, such as a recruitment consultant, please also check their privacy notice before proceeding. We do not encourage unsolicited approaches either directly or from third parties – please do not send personal data to us unless the data subject has read and agrees to this Privacy Notice.

4.3 We may retain details of candidates who may be of interest to us, either now or in the future, for up to one year and if we chose to do so, we will notify you. If you would not like us to do that please let us know. Additionally, if your circumstances change – for example you no longer wish to be considered by us for employment – please let us know that too.

 

5. How do we use your information?

5.1 We use information collected about you as outlined in this Privacy Notice.

5.2 Our primary purpose in collecting your personal data is to deal with any request you make and to provide you with services which we believe will optimize your use of the Site. We may use your personal data for the following purposes:

  • to register on the FPSO University and use the services offered to registered users;
  • to provide information, services or support and to manage your requests;
  • to identify you, and to contact you from time to time with product or service updates;
  • to send other messages that are useful to the services we provide;
  • to manage our relationship with you and to carry out any related administration;
  • to provide personalised, targeted, or location-based content, services, and advertising from us and third parties;
  • to promote our services, or the services of our suppliers or partners, including by email and via social media platforms (subject to the relevant marketing permissions)*;
  • to compare information for accuracy, and verify it with third parties*;
  • to detect, investigate and prevent activity we think may be potentially illegal, unlawful or harmful and to enforce our Privacy Notice and/or other legal terms found on the Site or any other purpose referenced herein or therein*; and
  • to carry out surveys, research, including market research, statistical research on site traffic, sales and other commercial information to assist us in improving the services we provide to you and tailor the Site*.

5.3 We process your personal data where we have your consent to do so, which you may withdraw at any time, or otherwise where this is necessary for:

  • the performance of our contract with you for the provision of our services or to take preliminary steps at your request;
  • us to fulfil our legal obligations; or,
  • the purposes of the legitimate interests pursued by us or by a third party.

5.4 A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests are those indicated with a “*” above, and we consider that we have implemented sufficient checks and protections to ensure that your rights and interests are not unreasonably intruded on.

*However, you can object to processing on any of these bases at any time and, if you do so, we will stop processing the personal data unless we can show compelling legitimate grounds which override your rights and interests, or we need the data to establish, exercise or defend legal claims – see “Your rights” below.

 

6. Who may use your information?

6.1 We may disclose your personal data to enforce our policies, to comply with our legal obligations or in the interests of security, public interest or law enforcement in any country where we have entities or affiliates. For example, we may respond to a request by a law enforcement agency or regulatory or governmental authority. We may also disclose data in connection with actual or proposed litigation, or to protect our property, security, people and other rights or interests.

6.2 We share your information with third parties who help deliver our products and services to you. Examples include hosting our web servers, analysing data, providing marketing assistance, and providing customer service. These companies will have access to your personal information as necessary to perform their functions, but they may not use that data for any other purpose.

6.3 We may also share your personal data:

  • with companies in our group (see paragraph 2.1 of this Privacy Notice for more details); or,
  • with any third party you have asked us to share your personal data with – such as Linkedin or any other social media site if you have asked us to connect with your account.

6.4 Those parties include:

  • Applica Training Systems AS of Dronningens, Gate 12, 4610, 4610 Kristiansand, Norway (www.applica.no) who help maintain the FPSO University.
  • Globe Newswire, a division of West Corporation of 11808 Miracle Hills Dr., Omaha, Nebraska, NE 68154, USA (www.west.com) who help provide our investor relations newswire.
  • Telecomputing Norway AS of Drengsrudbekken 12, 1371 Asker, Norway (www.telecomputing.no) who are our IT hosting partner.
  • Visma Unique A, of Karenslyst Alle 56, 0277 Oslo, Norway who provide our recruitment software, EasyCruit (www.easycruit.com)

6.5 You may have accessed our Site through a hyperlink from a third party website. If so, you consent to your personal details and purchase information, including behavioural patterns, being shared with that third party in accordance with our contractual relationship with them.

6.6 If BW Offshore is sold, or some of its assets transferred to a third party, your personal information, as a valuable asset, may also be transferred to the acquirer, even if they are not in the same line of business as us. Our data could be sold separately from the rest of the business, in whole or in a number of parts. Potential purchasers and their advisors may have limited access to data as part of the sale process. However, use of your personal information will remain subject to this Privacy Notice. Likewise, your personal information may be passed on to a successor in interest in the unlikely event of a liquidation, bankruptcy or administration.

 

7. Third party links and services

7.1 The Site may contain links to third parties’ websites. We are not responsible for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those links or websites before either agreeing to their terms or using those websites.

7.2 If you have asked us to share data with third party sites (such as social media sites), their servers may not be secure.

7.3 Note that, despite the measures taken by us and the third parties we engage, the internet is not secure. As a result others may nevertheless unlawfully intercept or access private transmissions or data.

 

8. How do we protect your information?

8.1 We take what we consider to be appropriate technical and organisational measures designed to reduce the risk of unauthorised or unlawful processing of your personal data and accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by the Site reduce our vulnerability to security problems to a level appropriate to the type of data involved. However, it remains your responsibility:

  • where you are a registered user with FPSO University or any other password protected area of our Site:
  • to log off or exit from the Site when not using it;
  • to ensure no-one else uses the Site while your device is logged on to the Site (including by logging on to your device through a mobile, Wi-Fi or shared access connection you are using);
  • to keep your password or other access information secret. Your password and log in details are personal to you and should not be given to anyone else or used to provide shared access for example over a network. You should use a password which is unique to your use of the Site – do not use the same password as you use for another site or email account; and,
  • to maintain good internet security. For example, if your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. You should keep all of your account details secure. If you think that any of your accounts has been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. You should also tell us as soon as you can so that we can try to help you keep your account secure and if necessary warn anyone else who could be affected.

 

9. Where is your information processed?

9.1 BW Offshore is a global organisation. As a result we might transfer your personal information to places outside of your home country, for example to companies in our group that are based outside the EEA such as the USA, Bermuda and Singapore for the purposes outlined in this Privacy Notice. If you are in the European Economic Area (EEA) this means that your data may be transferred from the EEA to another country and stored there, where we (or our suppliers) might process it.

9.2 If we transfer your personal data outside your country we will try to take steps to ensure that your privacy rights continue to be protected in compliance with applicable data protection law and this Privacy Notice.

 

10. Marketing communications

10.1 If you have given permission, we may contact you by mail, telephone, SMS, text/picture/video message, social media and email about products and services that may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time. See further 'Your rights', below.

 

11. How long do we keep your information?

11.1 We will retain your personal data only as long as is necessary for the purposes set out in this Privacy Notice, or as is required by applicable law, and then we will delete it.

 

12. Your rights

12.1 In some countries you may have the right to gain access, correct, update, restrict, delete, be forgotten, or object to the processing of, or request data portability of the personal data collected about you subject to some exceptions and conditions. You can find out more about these rights in the EU by reading the General Data Protection Regulation, available at https://www.eugdpr.org/the-regulation.html

12.2 If you wish to inquire about any of those rights or would like to submit a request then please send us your request by any of the following ways:

  • contact us through dataprotection.officer@bwoffshore.com or write a letter to us and post it to:

Data Protection Officer - BW Offshore, P.O Box 33. Skøyen, 0212 Oslo, Norway.

12.3 We may charge a small fee depending on your request where that is permitted by law. We will take all reasonable steps to delete your personal data from our system(s) on receiving a valid request, unless restricted by law. We may keep a copy for as long as is necessary in our opinion, in compliance with applicable laws and regulations. We will respond to any of your above-mentioned requests within one month but we reserve the right to verify your identity before dealing with your request.

12.4 You may also have the right to lodge a complaint with a data protection regulator, which you may lodge with the The Norwegian Data Protection Authority (Datatilsynet) as the EU lead supervisory authority for BW Offshore. The Norwegian Data Protection Authority (Datatilsynet  contact details are as follows:

Postal address:

Datatilsynet
Postboks 458 Sentrum
0105 Oslo

Org.nr 974 761 467

 

13. How do you contact us?

13.1 If you have any questions about this Privacy Notice, the practices of this Site, or your dealings with this Site, we encourage you to contact us at dataprotection.officer@bwoffshore.com

 

14. How often is this notice updated?

14.1 We regularly review this privacy notice. We will ensure that the most up to date version is published here. This privacy notice was last updated on 04 March 2021.

 

15. Cookies

15.1 What are cookies?

Cookies are small text files that are downloaded and stored on your communication equipment (PC, tablet, smartphone, etc.) when you visit our website.

Cookies make it possible to identify you as a visitor to a website, track your activity and use the services offered on the website.

The website makes use of three types of cookies:

  • Session cookies, i.e., cookies that are temporarily stored in the web browser’s memory during the time you visit the website. They can i.a. be used to identify which language you have chosen. Session cookies are deleted when you close your browser.
  • Persistent cookies, i.e., cookies that are stored on your device for a long period of time. They are i.a. used for functions that indicate what is new since you as a visitor last visited the website. How long the cookie remains on your device depends on the lifespan of the specific cookie and your browser’s settings.

15.2 How we use cookies

We may use information obtained by use of cookies for the following purposes:

  • to carry out surveys, research, including market research, statistical research on site traffic, sales and other commercial information to assist us in improving the services we provide to you and tailor the Site.
  • to improve the website’s functions, make the website easier to use, enhance your experience on the website, and to better customise the website to your interests and needs

15.3 What information do our cookies collect?

When you use our website, the following information is collected:

  • IP address
  • Browser type
  • Operating system
  • Which pages the registered IP address visits, as well as the duration of the visits
  • Access times
  • The link that referred you to our website

15.4 You can consent to or refuse the use of cookies

It is voluntary to use cookies and you give your consent through the cookie banner (pop-up).

15.5 Google Analytics

 We use the Google Analytics tool and cookies to gather statistics on site usage. There are more details in Google’s own privacy notice. The information collected via Google Analytics is restricted in accordance with Google Analytics’ user terms which are available at Google's terms page, and Google’s integrity policy, which is available at Google's privacy page.

Google may aggregate data they collect from their various services including Google Analytics, Google Translate, Google Maps and YouTube. You acknowledge and accept that we have no control over Google’s data collection. You should look at Google’s privacy notice for details of their data collection practices.

You can withdraw your consent by disabling the cookie function in your web browser.

For more information, visit Google's page on Google Analytics Cookie Usage on Websites and Google's privacy page.

 

16. Privacy Notice Supplement for Brazil

This notice supplements BW Offshore’s Privacy Notice with respect to specific rights granted under the Brazilian General Data Protection Law (Law No 13,709/2018 or “LGPD”) to data subjects and provides information regarding how they can exercise their rights under the LGPD. This supplement is only relevant to you if your data is under the scope of the LGPD. Information required to be disclosed regarding the collection of data subjects’ personal information that is not set forth in this LGPD supplement is otherwise set forth above in the Privacy Notice.

16.1 What information do we collect?

We have collected some or all of the categories of personal information from individuals within the last twelve (12) months form the sources as described in “3. What information do we collect?” above and shared these categories of personal information with certain third-party service providers such as fund administrators, our advisors (e.g., auditors, legal counsel, tax and financial advisors). We may also share such information with law enforcement agencies, regulatory or tax authorities and other government or public agencies or authorities.

16.2 How do we use your information?

We may collect or share the personal information we collect about you for one or more of the business or commercial purposes mentioned in the “5. How do we use your information?section of this Privacy Notice.

16.3 Your Rights:

Data subjects have various rights under the LGPD in relation to the personal information we hold.  These include:

  • the right to confirm the existence of the processing and to request access to personal information and obtain a copy of the information held by BW Offshore;
  • the right to correct its personal information that BW Offshore holds where it is incomplete, outdated or inaccurate;
  • the right to have its personal information anonymized, blocked or erased where such information is unnecessary, excessive, or processed non-compliant with the provisions of the LGPD;
  • the right to have its personal information erased when processed based on individual’s consent, except in the situations established in the LGPD;
  • the right to require certain of its personal information to be transferred to a third party (right to data portability);
  • the right to have information regarding public and private legal entities with which BW Offshore has carried out shared use of data;
  • the right to withdraw consent, at any time;
  • the right to have information on the possibility of not providing consent and on the effects of consent denial;
  • the right to request the review of decisions exclusively based in automated processing, which might affect his/her interests; and
  • the right to lodge a complaint with the relevant data protection authority in its jurisdiction.

If you wish to exercise any of these rights, you should contact the DPO (Encarregado) at dataprotection.officer@bwoffshore.com.