I. What does this Privacy Notice cover
This notice sets out what personal data we collect, for what purposes and your rights in this respect.
This privacy notice provides you with information on the processing of your personal data when using services and/or purchasing products from Sprng Energy Pvt Ltd in relation to customers, suppliers, business partners, stakeholders and/or investors. For all other interactions with companies within the Shell group please refer to www.shell.com/privacy.html.
We are committed to ensuring the privacy and security of your personal information. This privacy notice explains, amongst other things, what personal data we process, for which purposes we process your personal data, for how long we hold your personal data for; how to access and update your personal data and where to go for further information or to lodge a complaint.
If you would like to receive this Privacy Notice in an alternative format (for example, in larger print) or if you have any questions about our processing of your personal information which are not answered by this notice, please contact us at email@example.com or call us on (+91) 020-67490001.
Sprng Energy Pvt Ltd does not sell your information
We will not sell or otherwise provide your personal information to third parties and will only make it available to third parties involved in the performance of the service agreed with you. Our employees and any third parties utilized by us are contractually obligated to protect the privacy and confidentiality of your information.
II. Special Notice - Processing children’s personal data
If personal data of children is gathered this requires consent of the parent or guardian.
We do not collect personal data of individuals under the age of 16. If you are under 16 years old please do not send us your personal data; for example, your name, address and email address. If you wish to contact us in a way which requires you to submit your personal data (such as for education or innovation events), please get your parent or guardian to do so on your behalf.
III. Who is responsible for any personal data collected
Sprng Energy Pvt Ltd, Magarpatta City, Hadapsar, Pune – 411013, India, will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies.
IV. What personal data do we process -
The categories of personal data we process.
We collect personal data about you as a customer and vendor this may include data that you provide to us in using our services, you may provide us with information, including, without limitation:
- Private contact information (such as name, postal or e-mail address and phone number) as well as AADHAR No. (social security number), PAN card number, bank account details only if necessary; or
- Business contact and other information (such as job title, department, name of organization and your dealings with Shell on behalf of yourself or the relevant Business Customer, Supplier and/or Business Partner)
V. What is the basis for processing your personal information
The personal information covered by this Privacy Notice is only processed:
- With your explicit consent
- Customer service and development of our products and services;
- Where it is necessary to carry out and/or conclude transactions, requests, and/or contractual obligations with you
- Where it is necessary to comply with a legal or regulatory obligation which we are subject to
- Where it is necessary for the purpose of legitimate interests pursued by us, except where such interests are overridden by the interests or rights of individuals
- To create an individual profile for you so that we can understand and respect your preferences and improve your experience on our digital platforms –
- for profiling purposes to enable us to personalise and/or tailor any marketing communications that you may consent to receive from us
- Performance of and analysis of market surveys and marketing strategies;
- Where it is necessary for the legitimate interests, such as for marketing and promotional purposes, for providing offers tailored to your preferences, for detecting and investigating fraud, and/or responding to security threats
In those cases where processing is based on consent, and subject to applicable local law which provides otherwise, 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.
VI. For what purposes do we process your personal data
We only process your personal data where we have a lawful basis and purpose to do so.
We process your personal data for the purposes of:
- 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 a Shell company; 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;
- Organisation 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 Shell companies and staff, authentication of individual status and access rights; or
- Legal and/or regulatory compliance - including compliance with legal or regulatory requirements.
or 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
In addition, in order to comply with legal and regulatory obligations, to protect our assets and employees/contractors and specifically to ensure that we can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening (pre-contract and on a periodic basis post-contract) on owners, shareholders and directors of our Business customers, Suppliers and Business Partners. This screening takes place against publicly available or government issued sanctions lists and media sources.
The screening does not involve profiling or automated decision making in relation to the counterparties or potential counterparties.
VII. What are the consequences of not providing your personal data
Personal data gathered by us for these processes either directly or indirectly is required in order to:
- fulfil legal requirements and/or which is required for entering a contract with a counterparty and continuing to contract with that counterparty
- maintain contact with business customers, suppliers and business partners and visitors to our website
Failure to provide us with the information required will negatively affect our ability to communicate with you, or our ability to enter a contract with a counterparty or continuing to contract with a counterparty.
VIII. Who will we share your personal data with
Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:
- any company that is a member of our group of companies, which includes our parent company Royal Dutch Shell Plc, where necessary for internal administrative purposes, corporate strategy, auditing and monitoring, sanctions screening and research and development
- we may also share your personal data with our group companies where they provide products and services to us that help us to provide products and services to you as our customer
- we may also share your data within our group of companies to offer you promotions or to inform you about related products and/or services. This is based on your marketing consent preferences and in all cases any marketing material will be sent to you by us only
- our authorized 3rd party agents, service providers and/or subcontractors on need-to-know basis
- a competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which we are subject to or as permitted by applicable local law.
- on request of a party, we can forward your data to such party if such party has a legitimate interest to obtain your personal data. We and the requesting party will conduct a legitimate interest assessment to determine whether and which information is shared
IX. Transfers of your personal data to other countries
Your personal data may be transferred outside of your country, subject to appropriate safeguards.
Where your personal data is transferred to companies within the Shell group and/or to authorized 3rd party agents service providers and/or subcontractors who may be located in or outside of your location we take organizational, contractual and legal measures to ensure that the personal data is exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard the personal data.
These measures include Binding Corporate Rules for transfers among the Shell Group and European Commission approved transfer mechanisms for transfers to 3rd parties in countries which have not been deemed to provide an adequate level of data protection as well as any additional local legal requirements. You can find a copy of the Shell Binding Corporate Rules at www.shell.com/privacy.html
X. Security of your personal data
We are committed to safeguarding your personal data.
We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use. In particular, we may use encryption for some of our services, we apply authentication and verification processes for access to Shell services and we regularly test, assess and evaluate the effectiveness of our security measures.
XI. How long do we hold your personal data for
We will only hold your personal data for a defined period.
We’ll only store your personal data for as long as is necessary to fulfil the purposes outlined in this notice or for as long as we reasonably consider necessary to establish, exercise or defend our legal rights. Your data will be retained in line with statutory and regulatory requirements.
In all cases information may be held for a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate purpose to retain it.
XII. Your rights in relation to your personal data
Your rights and how to exercise them.
We aim to keep our information as accurate as possible. You can request:
To make a verifiable rights request please email us at privacy-office-SI@shell.com.
- access to your personal data
- correction or deletion of your personal data (but only where it is no longer required for a legitimate business purpose such as completing a retail transaction)
- that you no longer receive marketing communications
- that the processing of your personal data is restricted
- combining of your personal data from different sources to create a personal profile no longer takes place
- that you receive personal data that you have provided to us, in a structured, digital form to be transmitted to another party, if this is technically feasible
The verifiable request must:
- provide sufficient information for us to be able to verify you are the person whose personal information we hold or are an authorized agent of that person and that the authorized agent is authorized to make the request on your behalf; and
- describe your request in enough detail so that we can properly locate the personal information the request or request relate to.
We cannot respond to your request unless we can verify your identity or if you are an authorized agent, your authority to make the request on behalf of the consumer. We will aim to verify your identity based on personal information we already hold about you. If we need to request further information from you in order to verify your identity, we will only use that personal information for the purposes of identifying you or that you have authorized the request.
Note that we may not be able to action a request for deletion if the personal information is required for a lawfully permitted purpose such as completing a transaction for which the personal information was collected or to comply with a legal obligation such as financial reporting. However, the personal information will be deleted once no longer needed for that purpose in line with the time periods set out above
XIII. Who to 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: firstname.lastname@example.org or call us on (+91) 020-67490001.
Since we are part of the Shell Group, you may also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, The Netherlands - Trade Register No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague, alternatively you can also email the Shell Group Chief Privacy Office at privacy-office-SI@shell.com
If you are unsatisfied with the handling of your personal data by us, you have the right to lodge a complaint to the Shell Group regulator which is the Dutch Data Protection Authority located at Bezuidenhoutseweg 30 2594 AV Den Haag , The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.
You also have the right to lodge a complaint to your local data privacy authority/regulator.
XIV. Cookies and similar technologies
Privacy notices are updated over time.
This Privacy Notice may change over time and you are advised to regularly review this Privacy Notice for possible changes. This notice was last updated in September 2022