Petropavlovsk PLC respects your privacy and is committed to protecting your personal data. This privacy notice is designed to explain how and when we collect and use your personal data, including any data you may provide through this website if you sign up to our email alerts.
1. WHO WE ARE
Petropavlovsk PLC is the controller and is responsible for your personal data (collectively referred to as the “Company”, “we”, “us” or “our” in this privacy notice).
2. HOW IS YOUR PERSONAL DATA COLLECTED?
If you decide to contact us or subscribe to email alerts, then you will be asked to submit limited personal data necessary for us to provide the service or handle your query. This is completely voluntary.
If you ask us to send you email alerts, we rely on your consent in order to do so. You may opt out of receiving the email alerts at any time.
3. THE DATA WE COLLECT ABOUT YOU
We may collect, use and store different kinds of personal data:
• Identity Data includes [first name, last name, username or similar identifier].
• Contact Data includes [postal address, email address and telephone number].
• Technical Data includes internet protocol (IP) address
• Communications Data includes your preferences in receiving email alerts from us.
• Professional Data includes CVs, professional qualifications and references.
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.
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.
• Your consent in relation to sending our email alerts to you. You have the right to withdraw your consent at any time.
• Where we need to protect the vital interests of you and others and public interests.
5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We may process your personal data:
(a) to deliver relevant website content and email alerts; and
(b) to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
6. EMAIL ALERTS
We use a third party provider, Investis, to deliver our email alerts. Investis requests a full name, email address, occupation and country from individuals that subscribe to email alerts. For more information, please see Investis’s privacy notice.
You can ask us or Investis to stop sending you our email alerts at any time by logging into our website and checking or unchecking relevant boxes to adjust your preferences.
7. REGISTER OF SHAREHOLDERS
We use a third party, Link Asset Services, to maintain our shareholders register. Link Asset Services captures name, address and shareholding for individuals who buy our shares. For more information, please see Link Asset Services’ privacy notice.
8. WEB ANALYTICS
To improve our web based services Thoburns, our website services provider, may collect and use overall data about the use of our site from a third party service, Google Analytics. For more information, please see Thoburns’ privacy notice.
9. CHANGE OF PURPOSE
We will only use your personal data for the purposes we collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
10. DISCLOSURES OF YOUR PERSONAL DATA
We will not share, sell or otherwise make your personal data available to third parties.
We may share your personal data with the third parties who are performing services on our behalf, for example:
• Website hosting services;
• Email alerts delivery services; and
• 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.
11. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
12. 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.
13. DATA RETENTION
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.
14. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.
• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request rectification of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data (“right to be forgotten”). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data if: (a) you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent.
To exercise your rights, please submit a written, signed and dated request to the Company Secretary, Petropavlovsk PLC, 11 Grosvenor Place, London SW1X 7HH.
15. 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.
16. DATA PROTECTION OFFICER
We have appointed a data protection officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your Personal Data, please contact Dorcas Murray, Company Secretary and Corporate Counsel, Petropavlovsk PLC, 11 Grosvenor Place, London SW1X 7HH tel: +44 (0) 207 2018 900, email email@example.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for the data protection issues.
17. CHANGES TO THE PRIVACY NOTICE
We keep our privacy notice under regular review. This privacy notice was last updated on 25 May 2018.