Privacy policy
for business customers, suppliers, business partners
This notice sets out what personal data we collect, for what purposes and your rights in this respect.
What does this privacy notice cover?
This Privacy Notice provides information regarding the personal data which are processed by SBRS GmbH (SBRS) and its affiliates within the Shell group of companies (‘Shell’) in relation to (i) individuals who work for, or on behalf of, or who are shareholders of our business customers (‘Business Customers’), (ii) suppliers or vendors (‘Suppliers’), (iii) business partners, investors and shareholders (‘Business Partners’).
Individuals who require access to an SBRS site on behalf of a business customer, supplier or business partner will be asked to provide additional information so that they can be identified for health, safety and security purposes and so that SBRS can conduct or manage the business relationship with the relevant business customer, supplier or business partner. For further information, please refer to the Privacy Policy – Employees, contractors, relatives at https://www.sbrs.com/en/privacy-policy-current-or-former-sbrs-employees-contractors-or-dependents/
For individuals who require access to a SBRS site on behalf of a Business Customer, Supplier or Business Partner you will be asked to provide additional information to enable you to be identified for health, safety and security purposes and to manage the relationship between SBRS and the relevant Business Customer, Supplier or Business Partner. For further information please refer to the Privacy Notice – “Current or former SBRS Employees, Contractors and Dependents” at https://www.sbrs.com/en/privacy-policy-for-business-customers-suppliers-business-partners/
For individuals who apply to work for SBRS, or who attend a recruitment event or undertake an assessment please refer to the Privacy Notice – Job Applicant at https://www.sbrs.com/en/privacy-policy-for-applicants/
For persons who have successfully applied for employment or as an intern or for the award of a contract, the privacy policy “Current or former SBRS employees, contractors and dependents” applies at https://www.sbrs.com/en/privacy-policy-current-or-former-sbrs-employees-contractors-or-dependents/
Cookies that are used when you visit our website are explained in our Cookie Policy at https://www.sbrs.com/en/privacy-policy-cookie-policy/.
Bespoke notices and supplementary privacy statements may contain further information about how SBRS is processing your personal data. In those instances, such privacy notices will be communicated to you separately. These privacy notices may vary among the countries in which we operate to reflect local practices and applicable law requirements.
If personal data of children is gathered this requires consent of the parent or guardian.
Special Notice – if you are under 16 years old. Processing children’s personal data
The categories of personal data we collect about you.
What personal data do we process about you? Collection of information
We process personal data from and in relation to individuals who are, or who work for or on behalf of or who are shareholders in our Business Customers, Suppliers, Business Partners in the following categories:
- Private contact information (such as name, postal or e-mail address, date-of-birth and phone number) only if necessary;
- Business contact and other information (such as job title, department, name of organization and your dealings with SBRS or its affiliates on behalf of the relevant Business Customer, Supplier, Business Partner.
Screening
Screening (“verification”)
Data Controller
Who is responsible for any personal data collected?
SBRS GmbH
(Head Office: Hünxer Strasse 149 / 46537 Dinslaken / Deutschland,
Telephone: +49 2064 602 – 100, Telefax: +49 2064 602 – 484,
E-Mail: info@sbrs.com, Internet: www.sbrs.com),
registered with the District Court of Duisburg under No. HRB 19295, will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies.
Purposes for which we process your personal data.
For which purposes do we process your personal data? How will we use your personal data?
We process the personal data covered by this privacy policy for the following purposes:
- Business execution – including providing, researching, developing and improving products or services; concluding and executing agreements with Business Customers, Suppliers and Business Partners; recording and settling services, products and materials to and from SBRS; managing relationships and marketing such as maintaining and promoting contact with existing and prospective customers, account management, customer service, and development, execution and analysis of market surveys and marketing strategies, dealing with any complaints or enquiries, purposes permitted under the Privacy Act and credit reporting legislation, debt-recovery;
- Organization and management of the business – including financial management, asset management, mergers, demergers, acquisitions and divestitures, implementation of controls, management reporting, analysis, internal audits and investigations;
- Health, safety and security – including protection of an individual’s life or health, occupational health and safety, protection of SBRS and staff, authentication of individual status and access rights; or
- Legal and/or regulatory compliance – including compliance with legal or regulatory requirements.
We may also process your personal data for a secondary purpose where it is closely related, such as:
- storing, deleting or anonymizing personal data;
- fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defense of claims; or
- statistical, historical or scientific research.
Communication and marketing
You may receive marketing communications on behalf of the relevant Business Customer, Supplier or Business Partner. On all occasions you will be given the opportunity to use the unsubscribe functionality through the different digital channels we use to interact with you.
We will only process your personal data where we have a lawful basis to do so.
Why do we process your personal data?
The personal data covered by this Privacy Notice are only processed:
- in order to take steps at the request of an individual prior to entering into a contract;
- in order to provide services to the relevant Business Customer.
- where it is necessary to comply with a legal or regulatory obligation to which SBRS or its affiliates are subject to;
- where it is necessary for the purposes of the legitimate interests pursued by SBRS or its affiliates, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual/s respectively data subject/s; or
- (only if legally required) with the explicit consent of the individual.
In those cases where processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.
SBRS is committed to the safeguarding your personal data.
Security of your personal data: how will we hold your personal data?
Who do we share your personal data with?
Who will we share your personal data with?
The personal data covered by this Privacy Notice are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:
- Other companies within the Shell Group;
- Authorized third party agents, service providers, external auditors and/or subcontractors of SBRS or its affiliates; or
- A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which SBRS respectively the affected companies of the Shell Group are subject to or as permitted by applicable local law.
Interacting with SBRS through social media
If you choose to interact with SBRS through social media on a SBRS or Shell administered social media page (such as Xing, LinkedIn, etc.), your personal data (such as your name, your profile picture and the fact that you are interested in SBRS) will be visible to all visitors of your personal webpage depending on your privacy settings on the relevant social media platform, and will also be visible to SBRS. You can delete any information that you share on these sites at any time through your relevant social media platform’s account. SBRS does not track your activity across the different social media sites that you use. Please contact SBRS if you wish to make a request that you are unable to action yourself and which relates to a SBRS social media page – see the section ‘Your rights in relation to your personal data’ below.
Additionally, and to the extent SBRS is jointly responsible with a social media platform of a social media page, SBRS and its affiliates will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on those sites. For more information on how your personal data are processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.
Your personal data may be transferred outside of your country, subject to appropriate safeguards.
Transfers of your personal data to other countries
Where your personal data have been transferred to companies within the Shell group and/or to authorized third parties located outside of your country (including outside of the European Economic Area) we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data.
What are the consequences of not providing your personal data?
Personal data gathered by SBRS and its affiliates for these processes either directly or indirectly are required in order to:
- Fulfil legal requirements and/or which is required for entering into a contract with a counterparty and continuing to contract with that counterparty; or
- Maintain contact with Business Customers, Suppliers and Business Partners.
Failure to provide us with the information required will negatively affect our ability to communicate with you, or our ability to enter into a contract with a counterparty or continue to contract with a counterparty.
SBRS will only hold your personal data for a defined period of time.
How long do we hold your personal data for?
With some exceptions any personal data that are required for the purposes of conclusion and execution of agreements with Business Customers, Suppliers and Business Partners or for considering bids or tenders, will be held during the duration of the contractual relationship and up to 15 years after. For agreements which have a term of more than five years and for the purposes set out above, these agreements will be held for 35 years with effect from the commencement of the agreement.
In all other cases for the purposes set out above, including personal data gathered as part of any unsuccessful bids to SBRS or which relates to the screening against publicly available or government issued sanctions lists and media sources, such personal data are held for no longer than 15 years after it was first gathered. In all cases information may be held for (a) a longer period of time where there is a lawful reason to do so (in which case it will be deleted once no longer required for that purpose) or (b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate business purpose to retain it.
Your rights
and how to exercise them.
Your rights in relation to your personal data
We aim to keep our information as accurate as possible. You can request:
- access to your personal data;
- correction or deletion of the personal data (but only where they are no longer required for a legitimate business purpose);
- that you no longer receive marketing communications on behalf of the relevant Business Customer, Supplier or Business Partner;
- that the processing of your personal data is restricted; and/or
- that you receive personal data that you have provided to SBRS, in a structured, digital form to be transmitted to another party, if this is technically feasible.
To make any of these requests, please contact either info@sbrs.com or Datenschutz@shell.com.
Who can you contact if you have a query, concern or complaint about your personal data?
If you have any issues, queries or complaints regarding the processing of your personal data please contact us at any time at info@sbrs.com or Datenschutz@shell.com. Furthermore, you can choose to contact us using our postal address. The postal address is: SBRS GmbH, Hünxer Strasse 149, 46537 Dinslaken, Deutschland). You may also contact the Shell Group Chief Privacy Officer at Privacy-Office-SI@shell.com or Shell International B.V. The Hague, The Netherlands, Trade Register No. 27155369, Correspondence: PO Box 162, 2501 AN, The Hague, The Netherlands.
If you are not satisfied or do not agree with the processing of your personal data by SBRS, you have the right to lodge a complaint with the Federal German Data Protection Commissioner or with the State Data Protection Commissioner responsible for you (Federal Estate in which you have your residence) or also with the Dutch Data Protection Authority with the address PO Box 93374, 2509 AJ The Hague, The Netherlands or alternatively Prins Clauslaan 60, 2595 AJ The Hague, The Netherlands. Visit the following websites for more information:
Visit the following websites for more information:
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html
or
https://autoriteitpersoonsgegevens.nl/en
.
Cookies and similar technologies
SBRS may use cookies and similar technologies that aim to collect and store information when you visit a SBRS website. This is to enable SBRS to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). We also use cookies to personalize and enhance your experience on our site and improve the delivery of ads to you. You can control and manage your cookies preferences by adjusting your browser settings or using the cookies preference tool on SBRS websites – for more information, please refer to the SBRS Cookie Policy at https://www.sbrs.com/en/privacy-policy-cookie-policy/
