Privacy

1. Privacy Notice

1.1 All personal data in our possession is collected, processed and protected in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1.2 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?

1.3 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. However, this Privacy Notice does not apply to our employees, whose personal data is subject to different privacy notices which are provided to such individuals in the context of their employment or working relationship with us.

1.4 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.

1.5 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.

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

2. Who we are

2.1 Yinson Group is a global organisation. By the use of “we” in this Privacy Notice we are referring to Yinson Production AS, located in Norway and acting on behalf of other Yinson entities in the European Economic Area (EEA) and United Kingdom.

2.2 We, Yinson Production AS, by the CEO, are the controller for the processing of personal data described 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, 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 job related information;
• Information from 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:

• 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;
• 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

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.

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 applied to work with us and did not get the position, we will only retain your personal information on the basis of your consent.  If your circumstances change – for example you no longer wish to be considered by us for employment – please let us know.
 

5. How do we use your information and on what legal basis do we do so?

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 process your personal data, listed in section 3, on the following legal bases, for the following specified purposes:

• to provide information, services or support and to manage your requests. For this purpose we may process all the categories of personal data listed in section 3. Most of this processing will be necessary for performance of our contract with you, and based on GDPR Article 6(1)(b). In some contexts the processing won't be necessary for the performance of a contract, and then we will base the processing on our GDPR Article 6(1)(f) (legitimate interest) or collect your consent in accordance with GDPR Article 6(1)(a);
• to manage our relationship with you and to carry out any related administration. For this purpose we may process all the categories of personal data listed in section 3. Most of this processing will be necessary for performance of our contract with you, and based on GDPR Article 6(1)(b). In some contexts the processing won't be necessary for the performance of a contract, and then we will base the processing on Article 6(1)(f) (legitimate interest) or collect your consent in accordance with GDPR Article 6(1)(a);
• to provide personalised, targeted, or location-based content, services, and advertising from us and third parties. For this purpose we may process all the categories of personal data listed in section 3. Most of this processing will be based on our legitimate interest – GDPR Article 6(1)(f). In some contexts our legitimate interest may not serve as a legal basis for processing, and in these situations we will base the processing on your consent – GDPR Article 6(1)(a);
• to promote our products or services, or the services of our suppliers or partners, including by email and via social media platforms (subject to the relevant marketing permissions). For this purpose we may process all the categories of personal data listed in section 3. Most of this processing will be based on our legitimate interest – GDPR Article 6(1)(f). In some contexts our legitimate interest may not serve as a legal basis for processing, and in these situations we will base the processing on your consent – GDPR Article 6(1)(a);
• 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. For this purpose we may process all the categories of personal data listed in section 3. The processing will be based on our legitimate interest – GDPR Article 6(1)(f);
• 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. For this purpose we may process all the categories of personal data listed in section 3. Most of this processing will be based on our legitimate interest – GDPR Article 6(1)(f). In some contexts our legitimate interest may not serve as a legal basis for processing, and in these situations we will base the processing on your consent – GDPR Article 6(1)(a).

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. Sharing of information with third parties who process personal data on our behalf, will be subject to data processing agreements. 

6.3 We may also share your personal data:

• with companies in our group; 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 If Yinson 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 we have implemented will reduce our vulnerability to security problems to a level appropriate to the type of data involved.

9. Where is your information processed?

9.1 Yinson 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 Malaysia, India, Nigeria, Brazil and Ghana, or countries within the EEA such as the Netherlands, 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. If the personal data is transferred from the EEA to a third country which is not a member of the EEA, we will provide appropriate safeguards in line with chapter V of the GDPR.

9.2 If we transfer your personal data outside your country, we will 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 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 The GDPR provides you a number of rights, including 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 We will do our utmost to make sure that your personal data is correct and up to date. If you notice that your personal data is not correct, or you want to delete data, we encourage you to contact us.

12.3 We may however not be able to delete data which is necessary for us to fulfil our contract with a client, comply with legal obligations or where we have a legitimate interest to keep personal data. 

12. 4 Where the processing of the personal data is based on consent or a contract and the processing is carried out by automated means, you may have the right of so called data portability. This means that you shall have the right to receive the data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance.

12.5 Furthermore, you will have the right to oppose or restrict the processing of your personal data, herein processing related to profiling and automated decisions. This means that you may require that your personal data is not analysed to reveal your behaviour, preferences, capabilities or needs. However, this does not apply if the processing of your data is necessary to fulfil a contract which you are a party to or if you have consented to the processing.

12.6 If personal data is being processed on the basis of your consent, you may also have the right to withdraw your consent.

12.7 If you are of the opinion that we do not comply with the prevailing data protection legislation or other relevant legislation, you may send a complaint to [email protected] You also have the right to file a complaint to the Norwegian Data Protection Authority. However, we encourage that you contact us first, so that we may come to a mutual understanding.

12.8 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.

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 [email protected]

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 July 2022.15. Your Rights to Access and Correct Your Personal Data

You may request to; (a) access your personal data; (b) correct or update your personal data; or (c) withdraw your consent or limit the processing of your personal data by submitting your written request to:

Yinson Production AS

Olav Vs gate 5, 0161 Oslo, Norway

Email :  [email protected]

We will make all reasonable and practicable efforts to comply with your request, so long as it is consistent with applicable law. An administrative charge may be imposed for any request under paragraphs (a), (b) and (c) above.

If you limit the processing or withdraw your consent to any or all use of your personal data, we may not be in a position to continue to administer any contractual relationship in place, which in turn may result in us being unable to provide you with any of our services/products and/or the termination of any arrangements/agreements with us.

PERSONAL DATA PROTECTION NOTICE

All personal data (“Personal Data”) in our possession is collected, processed and protected in accordance with the Data Protection Act, 2012 (Act 843) (the "DPA"). 

The purpose of this document (“Policy”) is to explain how Yinson Production West Africa Limited (“YPWAL”) handles and is responsible for Personal Data which is subject to the DPA, any regulations enacted there under, and any guidelines that may be issued from time to time by the Data Protection Commission. Where we do so, we are responsible as a ‘data controller’ of that Personal Data for the purposes of the law.

We will take reasonable care to protect your Personal Data from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. We collect, use and are responsible for certain Personal Data about you.

We will review and update our policies, procedures and processes from time to time.

If you wish to opt-out of this Privacy Statement, amend or remove any of your Personal Data in our possession, please read the below for the required procedure.
 

1. PERSONAL INFORMATION AND OTHER DATA COLLECTED

Personal Data as defined in the DPA means data about an individual who can be identified:

• from the data; or
• from the data or other information in the possession of, or likely to come into the possession of, the data controller.

A Data Controller is defined by the DPA as a person who, either alone, jointly with other persons or in common with other persons or as a statutory duty, determines the purposes for, and the manner in, which Personal Data is processed or is to be processed.

Commonly collected Personal Data of our customers and employees include, amongst other things, names, addresses, telephone (landline and mobile) numbers, e-mail addresses, nationalities, profession, education and medical history, dates of birth, tax identification numbers (TINs), driver's licence numbers and credit card information.
 

Collection of Personal Data

We may collect Personal Data from you, your authorised representatives or from publicly available sources including, but not limited to, credit reporting agencies, government department or agencies, public registries, websites and publications. In addition to Personal Data provided to us, certain information related to you that is not considered Personal Data under the DPA may also be collected. We collect this information to improve our website and other online services. Such non-personal data may include information such as your IP address, the internet browser you use, details of your interaction with our website and other types of non-personal data.
 

Processing & Data Protection Principles

We ensure at all times that the Personal Data we obtain is processed in a lawful and reasonable manner and same is processed without infringing your privacy rights guaranteed under the DPA. 

Our processing of Personal Data is effected in accordance with the following principles: accountability, lawfulness of processing, specification of purpose, compatibility of further processing with purpose of collection, quality of information, openness, data security safeguards and data subject participation.

We assure you that we shall only process your data if the purpose for processing is necessary, relevant and not excessive. We shall take all the necessary steps to ensure that you are aware of the purpose for which we are processing your personal information.
 

Use of cookies

Cookies are small files which require user permission in order to be installed on a device's hard drive. Cookies will only start to perform their functions after such permission is granted. By collecting and analysing data on the user's browsing patterns, cookies allow web applications to respond to the user as an individual by tailoring a web application's operations to the user's specific needs and preferences. The purpose of cookies is therefore to enhance your future visits to our website.

Permission for cookies is granted by default in most web browsers. You can, however, choose to disable this function in your browser's settings. This may prevent you from taking full advantage of our website.

You have a variety of tools to control the data collected by cookies, web beacons and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

We may use traffic log cookies to identify which pages are being used. This use is designed to assist us in gathering data on web page traffic. The gathered data is used only for statistical purposes and is removed from our database shortly afterwards.

Overall, the data collected by the cookies is used for the purpose of improving your browsing experience on our website. Cookies do not grant us access to your computer or any information about you outside of your browsing activity on our website.

By accessing our website, you agree that we can place cookies on your device.

Please note that YPWAL is not responsible for the privacy practices or the use of cookies on websites that you have accessed this website from and to other websites that you may access from this website.
 

2. YOUR CONSENT

We assure you that we shall not process your Personal Data without your prior consent unless the purpose for which the Personal Data is processed is:

i. necessary for the purpose of a contract to which you are a party;
ii. authorised or required by law;
iii. to protect a legitimate interest of yours;
iv. necessary for the proper performance of a statutory duty; or
v. necessary to pursue a legitimate interest of ours.

Where we rely on your consent to process your Personal Data, you can withdraw your consent at any time by giving reasonable notice. Upon notice of withdrawal being given, we will inform you of the likely consequences of such withdrawal of consent. In such event, we will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the Personal Data unless it is required or authorised under applicable law.
 

3. USE OF YOUR PERSONAL DATA

We collect Personal Data from our existing and prospective clients and employees for various reasons. Without limitation, these purposes include:

• to communicate with you;
• to verify your identity;
• to process your employment applications;
• to process payments;
• to process, record, execute, monitor, and/or archive your requests and transactions;
• to manage our administrative and business operations;
• to comply with all applicable legal and regulatory requirements;
• to establish, exercise, or defend any legal or equitable claim; and
• Any other purpose necessary, ancillary or consequential to the above specified purposes.

We may, for the above purposes, contact you via mail, electronic mail, telephone, SMS, facsimile or other forms of communication through mobile applications.
 

4. DISCLOSURE OF YOUR PERSONAL DATA

We shall only disclose information you provide to us after we have sought and obtained your consent to the disclosure of same, or where the initial disclosure was made for the purposes of it being made available to the public under the provisions of the DPA, or in circumstances permitted by the DPA.

We may disclose your Personal Data to third parties under circumstances permitted under the DPA. Third parties may include the following:

(a) any persons directed by or consented to by you;

(b) any person for the purposes of compliance with legal and regulatory requirements of the Republic of Ghana;

(c) our subsidiaries, partners, related companies and/or affiliates;

(d) our data processors, that is, a third party who we engaged to process Personal Data on our behalf including, but not limited to, archival storage, data entry service providers, website service providers, computer backup services, disaster recovery services, bank and financial institutions; and

 (f) our professional advisers including, but not limited to, legal advisers, tax advisers, financial advisers, auditors and insurance brokers/insurers.

We will normally process your Personal Data within Ghana. Notwithstanding this, the nature of our business may require that your Personal Data may be disclosed to non- Ghanaian entities by means of a data transfer agreement between us and these entities or in any other manner permitted under the DPA.

We may also use some third-party suppliers to help us provide our services to you. These third parties may have access to or merely host your Personal Data, but will always do so under our instructions and subject to a contractual relationship.
 

5. ACCURACY OF PERSONAL DATA

We will make a reasonable effort to ensure that Personal Data collected by us, or on our behalf, is accurate and complete. You have the right to request that we correct your data because it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully or that it is incompatible with the legitimate purposes for which we obtained the said data.
 

6. AGE POLICY

We do not seek to obtain nor do we wish to receive personally identifiable information directly from minors. If a minor provides us with personally identifiable information, we encourage a parent or guardian of that child to contact us to have this information removed from our records and to unsubscribe the minor from future communication with us.
 

7. SECURITY

We will take the necessary steps to secure the integrity of Personal Data in our possession or control through the adoption of appropriate, reasonable, technical and organisational measures. While the transference of electronic data over the internet has inherent risks, we will use reasonable precautions to ensure your Personal Data is not subject to unnecessary risks. Some of the means through which such protection is rendered include:

• physical security around the premises of our offices where your Personal Data may be stored;
• ensuring that access to your Personal Data is only available to the staff who require it to perform their duties; and
• installing and maintaining industry standard technology to protect our networks and data storage systems from third party interference.

Where there are reasonable grounds to believe that your Personal Data has been accessed or acquired by an unauthorised person, we shall notify you of the unauthorised access or acquisition.
 

8. RETENTION, ERASURE AND DESTRUCTION

We will retain your Personal Data for as long as necessary in order to fulfil the purpose for which it was collected, or as required by the relevant laws. At the end of the retention period, your data will either be destroyed, deleted completely or anonymised, for example by aggregation with other data so that it cannot be reconstructed in an intelligible form. Further to the above, you can request that we destroy or delete a record of Personal Data about you that we no longer have your consent to retain.
 

9. ACCESS TO PERSONAL DATA

Upon request, we will provide you with access to your Personal Data or other appropriate information on your Personal Data in accordance with the requirements of the DPA. You must provide proof of identity in order to make the request, and an administrative charge may be imposed for the request.

You can request that we give a description of your data held by us and data about the identity of a third party or a category of a third party who has or has had access to the said data.

The request will be acceded to if made in compliance with the requirements of the DPA.
 

10. DATA PROTECTION OFFICER

• If you want to access the Personal Data we hold on you;
• If you want to request that we amend or correct your Personal Data;
• If you want to withdraw consent to use or disclose your Personal Data; or
• If you have comments or queries about our Privacy Notice or other related issues

please contact our Data Protection Officer ("DPO") at:

Data Protection Officer
Yinson Production West Africa Ltd
6 Senchi Street, Imperial Square
Airport Residential Area, Accra
Ghana

11. RIGHTS TO AMEND THIS PRIVACY STATEMENT

We reserve the right to amend this Privacy Statement at any time. If material changes are made to this Privacy Statement, they will be posted on this page and date stamped. We encourage you to review this page periodically in order for you to stay notified of any changes.

Your continued use of this website constitutes your consent to any such changes, to the extent such consent is not otherwise provided.

PERSONAL DATA PROTECTION NOTICE

This privacy notice (“Notice”) is issued by Yinson Holdings Berhad and its related and subsidiary companies (collectively “Yinson”, “we”, “us”, “our”) for the purpose of informing you how we process your personal data when you communicate and interact with us (including via our website) and/or when you provide your personal data by filling up and submitting to us forms or documents.

By doing so, you consent to the collecting, recording, holding, storing, use, transfer and processing of your personal data by us in accordance with the terms and condition (as amended by us from time to time) of this Notice.
 

Personal Data We May Collect from You

Generally, personal data means any information that personally identifies you (or from which you may be identified). The type of personal data which may be processed by us may include but not limited to your name, address, designation, email address, fax number, contact details, recording of your images or photographs during any of our corporate events or third party events, recruitment information (such as employment history, education, resume or CVs when you apply job with us and work permit details), citizenship/national origin information, bank account information, and background check reports and other personal data provided by you or third parties on any subsequent occasion. 

It is obligatory that you supply us the details marked with an asterisk (*) in our forms (collectively, “compulsory personal data”).  If you fail to supply us with any of the compulsory personal data, we may refuse to process your personal data for any of the purposes stated below. This may result in us being unable to provide you with the services and/or products requested for and/or the termination of any arrangements/agreements with us.
 

How We Collect Your Personal Data

We may collect personal data from you, your authorized representatives, third parties or from publicly available sources including but not limited to credit reporting agencies, government department or agencies, public registries, websites and publications.
 

How We Use Your Personal Data

You agree that we may use your personal data as permitted by law and for the following purposes:

(a) to verify your identity;

(b) to communicate with you;

(c) to respond to your inquiries;

(d) to transact with you and/or provide services to you;

(e) to send you materials such as brochures, newsletter, articles, write-ups and marketing information;

(f)  to comply with legal and/or regulatory requirements;

(g) to assist in the prevention, detection or investigation of crime or possible criminal activities or for the administration of justice;

(h) for our day-to-day operations and administrative purposes;

(I)  for security and internal audit purposes including monitoring emails, mailboxes and correspondences;

(j)  in our publications and materials;

(k) for such other purposes directly related to the foregoing or as may be directed or consented to by you; and

(l) for any other relevant purposes that are related to the purpose you submit your personal data to us (collectively “Purposes”).
 

To Whom We May Disclose Your Personal Data

We may disclose your personal data to third parties under certain circumstances. Third parties may be as follows:

(a) any persons directed by or consented to by you;

(b) any person for the purposes of compliance with legal and regulatory requirements of Malaysia;

(c) our subsidiaries, related companies and/or affiliates;

(d) our data processors i.e. third party who we engaged to process personal data on our behalf including but not limited to archival storage, data entry service providers, website service provider, computer backup services, disaster recovery services, bank and financial institutions;

(e) third party service providers for the purposes of performing reference checks, background screening, bankruptcy searches, credit etc.; and

(f) our professional advisers including but not limited to legal advisers, tax advisers, financial advisers, auditors and insurance brokers/insurers.

We may be required to transfer your personal data outside of Malaysia for the Purposes and to such third parties stated in this Notice, and you hereby consent to such transfer. Further, the transfer of your personal data outside Malaysia would also be required if you are travelling or based outside Malaysia.
 

Your Rights to Access and Correct Your Personal Data

You may request to; (a) access your personal data; (b) correct or update your personal data; or (c) withdraw your consent or limit the processing of your personal data by submitting your written request to:
 

PDPA Compliance Officer

Yinson Holdings Berhad
Level 16, Menara South Point,
Mid Valley City, Medan Syed Putra Selatan,
59200 Kuala Lumpur

We will make all reasonable and practicable efforts to comply with your request, so long as it is consistent with applicable law. An administrative charge may be imposed for any request under paragraphs (a), (b) and (c) above.

If you limit the processing or withdraw your consent to any or all use of your personal data, we may not be in a position to continue to administer any contractual relationship in place, which in turn may result in us being unable to provide you with any of our services/products and/or the termination of any arrangements/agreements with us.
 

Disclaimer

The accuracy and completeness of your personal data depends on the information you provide. We assume that the information you have provided is accurate, up to date and complete unless you inform us otherwise. Where you provide any third-party information to us, it is our assumption that such information is accurate, up to date and complete and that you have obtained the necessary consent to disclose the same.
 

Conflict

In the event that there is any conflict between the English and national language version of this Notice, the English language version shall prevail.
 

NOTIS PERLINDUNGAN DATA PERIBADI

Notis privasi (“Notis”) ini dikeluarkan oleh Yinson Holdings Berhad dan syarikat-syarikat berkaitan dan anak-anak syarikat (“Yinson”, “kami”) untuk memaklumkan kepada anda bagaimana kami memproses data peribadi anda apabila anda berkomunikasi dan berinteraksi dengan kami (termasuk melalui laman web kami) dan/atau apabila anda membekalkan data peribadi anda kepada kami dengan cara mengisi dan menyerahkan borang-borang atau dokumen-dokumen kepada kami.

Dengan demikian, anda telah memberikan persetujuan untuk kami mengumpul, merekod, memegang, menyimpan, menggunakan, memindah dan memproses data peribadi anda berdasarkan terma-terma dan syarat (sebagaimana yang dipinda oleh kami dari semasa ke semasa) di bawah Notis ini.
 

Data Peribadi Anda yang Kami Mungkin Kumpul

Secara amnya, data peribadi bermaksud apa-apa maklumat yang mengenal pasti anda atau yang melaluinya identiti anda dapat disimpulkan. Jenis-jenis data peribadi yang mungkin akan kami proses adalah termasuk tetapi tidak terhad kepada nama, alamat, jawatan yang disandang, alamat emel, nombor faks, butir-butir untuk dihubungi, rakaman imej atau gambar anda ketika menghadiri mana-mana acara korporat kami ataupun acara pihak ketiga, maklumat pengambilan pekerja (seperti sejarah pekerjaan pendidikan, resume atau kurikulum vitae anda apabila memohon pekerjaan dan butiran permit kerja), maklumat kewarganegaraan/kebangsaan asal, maklumat akaun bank, butiran cukai, pemeriksaan latar belakang dan data peribadi lain yang dibekalkan oleh anda atau pihak-pihak ketiga dalam apa-apa keadaan seterusnya.

Ia adalah wajib untuk anda memberikan segala maklumat yang diperlukan bagi yang bertanda asterik (*) di dalam boring-borang kami (secara kumpulan, “maklumat peribadi wajib”). Sekiranya anda gagal untuk memberikan kepada kami segala maklumat peribadi wajib, kami boleh enggan untuk memproses maklumat peribadi anda untuk segala tujuan dinyatakan di bawah. Ini boleh menyebabkan kami tidak dapat memberikan perkhidmatan dan/atau produk yang diminta dan/atau penamatan apa-apa susunan/perjanjian dengan kami.
                                                        

Bagaimana Kami Mengumpul Data Peribadi Anda

Kami mungkin mengumpulkan data peribadi sama ada daripada anda, daripada wakil yang anda beri kuasa, daripada pihak-pihak ketiga atau daripada sumber-sumber boleh didapati secara umum yang mungkin termasuk (tetapi tidak terhad kepada) agensi-agensi pelaporan kredit, agensi-agensi atau jabatan kerajaan, pendaftaran awam, laman – laman web dan syarikat penerbitan.

Bagaimana Kami Menggunakan Data Peribadi Anda

Anda bersetuju bahawa kami boleh menggunakan data peribadi anda bagi tujuan-tujuan yang dibenarkan oleh undang-undang dan tujuan-tujuan berikut;

(a) untuk pengesahan identiti anda;

(b) untuk berkomunikasi dengan anda;

(c) untuk menjawab pertanyaan-pertanyaan anda;

(d) untuk menjalankan transaksi dengan anda dan/atau untuk menyediakan perkhidmatan untuk anda;

(e) untuk menghantar bahan-bahan seperti risalah, surat berita, artikel, bahan penulisan dan maklumat pemasaran kepada anda;

(f) untuk memenuhi kehendak undang-undang dan/atau pengawalseliaan;

(g) untuk membantu pencegahan atau penyiasatan jenayah atau kemungkinan aktiviti-aktiviti jenayah atau bagi pentadbiran keadilan;

(h) bagi tujuan operasi harian dan pentadbiran kami

(i) bagi tujuan audit dalaman dan keselamatan termasuk pemantauan emel, peti-peti surat dan surat-menyurat;

(j) dalam publikasi dan bahan-bahan kami;

(k) bagi tujuan-tujuan lain sebagaimana yang diarahkan terdahulu atau yang telah diberikan persetujuan oleh anda; dan

(l) bagi segala tujuan lain yang relevan yang berkaitan tujuan data peribadi anda diserahkan kepada kami. (Secara kolektifnya dirujuk sebagai “tujuan-tujuan”)
 

Dengan Siapa Kami Berkongsi Data Peribadi Anda

Kami boleh berkongsi data peribadi anda dengan pihak-pihak ketiga di bawah keadaan-keadaan tertentu. Pihak-pihak ketiga boleh merujuk kepada:

(a) mana-mana orang yang diarahkan oleh atau yang telah diberikan persetujuan oleh anda;

(b) mana-mana orang bagi tujuan pematuhan keperluan undang-undang dan pengawalseliaan;

(c) syarikat-syarikat anak, berkaitan dan/atau berafiliasi kami;

(d) pemproses data iaitu pihak ketiga yang akan diguna khidmat bagi memproses data peribadi bagi pihak kami termasuk tetapi tidak terhad kepada storan arkib, pemberi khidmat kemasukan data, perkhidmatan-perkhidmatan sokongan computer, perkhidmatan-perkhidmatan pemulihan bencana, bank-bank dan institusi-institusi kewangan dan sebagainya;

(e) pemberi khidmat pihak ketiga bagi tujuan permeriksaan rujukan, latar belakang, kebankrapan, kredit dan sebagainya; dan

(f) penasihat-penasihat professional kami, termasuk tetapi tidak terhad kepada penasihat-penasihat undang-undang, penasihat-penasihat cukai, penasihat-penasihat kewangan, juruaudit-juruaudit, broker-broker insurans.

Kami mungkin akan memindahkan data peribadi anda ke luar Malaysia bagi tujuan-tujuan dan kepada pihak ketiga yang dinyatakan didalam Notis ini dan anda telah memberikan persetujuan anda untuk memindahkan data peribadi anda. Selanjutnya, pemindahan data peribadi anda ke luar Malaysia akan diperlukan sekiranya anda melancong atau berada di luar Malaysia.
 

Hak Anda untuk Mengakses dan Membetulkan Data Peribadi

Jika anda ingin (a) akses data peribadi anda; (b) memperbetulkan atau mengemaskini data peribadi anda; atau (c) menarikbalik persetujuan anda atau mengehadkan perosesan  data peribadi anda, sila hantar permintaan anda kepada :

Pegawai Pematuhan PDPA

Yinson Holdings Berhad
Level 16, Menara South Point,

Mid Valley City, Medan Syed Putra Selatan,
59200 Kuala Lumpur

Caj pentadbiran mungkin akan dikenakan bagi permintaan di bawah perenggan (a), (b) dan (c) di atas. Kami berhak untuk menolak permintaan anda jika dibenarkan di bawah undang-undang.

Jika anda hadkan prosesan atau menarikbalik persetujuan anda untuk segala kegunaan maklumat peribadi anda, kami mungkin tidak dapat meneruskan segala hubungan kontrak, dan akan menyebabkan kami tidak dapat memberikan ada apa-apa servis/produk dan/atau penamatan apa-apa susunan/perjanjian dengan kami.

Penafian

Ketepatan dan kelengkapan data peribadi anda bergantung pada maklumat yang anda berikan. Kami menganggap bahawa maklumat yang anda berikan adalah tepat, terkini dan lengkap melainkan jika anda memaklumkan sebaliknya kepada kami. Kami menganggap bahawa maklumat pihak ketiga yang anda berikan kepada kami termasuk tetapi tidak terhad kepada maklumat bekas majikan atau maklumat keluarga adalah tepat, terkini dan lengkap dan anda telah mendapatkan persetujuan yang sewajarnya untuk menzahirkan maklumat tersebut.

Percanggahan

Jika terdapat percanggahan antara versi Bahasa Inggeris dan Bahasa Kebangsaan Notis ini, versi Bahasa Inggeris akan diguna pakai.

YINSON OPERATIONS & PRODUCTIONS WEST AFRICA LIMITED

DATA PRIVACY POLICY

Yinson Operations & Production West Africa Limited (‘’YOPWAL’’) takes its responsibilities with regard to the management of personal data very seriously and we do not take lightly the trust you have reposed in us, in providing us with your personal information. All personal data (“Personal Data”) we collect will be collected, processed and protected in accordance with the Nigeria Data Protection Regulation 2019 (the ‘Regulation’) issued by the National Information Technology Development Agency (the ‘NITDA’) in January 2019. The NDPR Implementation Framework issued by NITDA in November 2020 states that Consent of the Data Subject means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes. This Policy describes how YOPWAL processes your personal data, but it may not address all possible data processing scenarios. This Privacy Policy is a guide to help you understand:

1. The Information We Collect
2. How We Collect and Use Your Data
3. Consent and Access Rights
4. Personal Data Protection Principles
5. User Responsibility
6. Data Security
7. Link to Third Party Sites
8. Third Party Access
9. Violation of Privacy
10. Data Retention
11. How to Contact Us

1. The Information We Collect

   The type of personal data which we may process may include but not limited to your name, address, designation, email address, fax number, contact details, recording of your images or photographs during any of our corporate events or third party events, recruitment information (such as employment history, education, resume or CVs when you apply job with us and work permit details), citizenship/national origin information, bank account information, and background check reports and other personal data provided by you or third parties’ relevant information which constitute Personal Data.

2. How We Collect and Use Your Data
   1. YOPWAL may collect personal data from you, your authorized representatives, third parties or from publicly available sources including but not limited to credit reporting agencies, government department or agencies, public registries, social media, websites and publications.
   2. When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. When you access our services, our servers automatically record information that your browser sends whenever you visit a website.
   3. We use the above-mentioned personal data for the following purposes: to verify your identity, to communicate with you, to respond to your inquiries, to transact with you and/or provide services to you, to send you materials such as brochures, newsletter, articles, write-ups and marketing information, to comply with legal and/or regulatory requirements, to assist in the prevention, detection or investigation of crime or possible criminal activities or for the administration of justice, for our day-to-day operations and administrative purposes, for security and internal audit purposes including monitoring emails, mailboxes and correspondences,  in our publications and materials, for such other purposes as may be directed or consented to by you; and for any other relevant purposes that are related to the purpose you submit your personal data to us (collectively “Purposes”).
       
3. Consent and Access Rights
   1. We require your consent for the processing of your data.  We shall obtain your consent for individual matters, where any document deals with different matters.
   2. We can process your personal data in the absence of consent where :
      1. processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
      2. processing is necessary for compliance with a legal obligation to which you are subject;
      3. processing is necessary in order to protect your vital interests or that of another natural person; and
      4. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official public mandate vested in us.
   3. If we intend to use your data for a purpose which is different from the purpose for which your data was obtained, we will seek your consent prior to the use of your data for that other purpose.
   4. In the event of any arrangement whereby YOPWAL sells or transfers all, or a portion of, its business or assets (including in the event of a reorganization, dissolution or liquidation) to third parties, you hereby consent that your personal data held with YOPWAL can be transferred or assigned to third parties who may become the controllers and/or processors of your personal data that was held by YOPWAL prior to such arrangement. We shall at all times ensure that you are notified when your personal data is intended to be transferred to third parties in the circumstances outlined in this clause.
   5. No Consent shall be sought, given or accepted in any circumstance that may engender direct or indirect propagation of atrocities, hate, child rights violation, criminal acts and anti-social conducts.
   6. You may withdraw your consent at any time and may request access to your personal information in our possession. We can, however, deny you access to the information where we determine that your request is unreasonable.
   7. You reserve the right to request the modification or amendment of your personal data in our possession.
   8. In all cases of access or modification/amendment of personal information, we shall request sufficient identification to enable us to confirm that you are the owner of the data sought to be accessed or modified/ammended.
       
4. Personal Data Protection Principles

   When we process your personal data, we are guided by the following principles, which require personal data to be :

   • processed lawfully, fairly, in a transparent manner and with respect for the dignity of the human person.
   • collected only for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes.
   • adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.
   • accurate and where necessary kept up to date.
   • removed or not kept in a form which permits identification of data subject for longer than is necessary for the purposes for which the personal data is processed.
   • processed in a manner that ensures its security, using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage.
      
5. User Responsibility

   You are required to familiarise yourself with this policy and to ensure that the information you provide to us is complete, accurate and up to date.

6. Data Security
   1. YOPWAL implements and maintains appropriate safeguards to protect personal data, taking into account in particular the risks to you, presented by unauthorised or unlawful processing or accidental loss, destruction of, or damage to their personal data.
   2. Safeguarding will include the use of encryption and pseudonymisation where appropriate. It also includes protecting the confidentiality (i.e. that only those who need to know and are authorised to use personal data have access to it), integrity and availability of the personal data. we regularly evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal data.
   3. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures, we cannot guarantee absolute security. YOPWAL, therefore, accepts no liability for any damage or loss, however caused, in connection with transmission over the Internet or electronic storage.
       
7. Links to third party sites

   The YOPWAL website may contain links to other websites owned and operated by third parties.  These links are provided for your information and convenience only and are not an endorsement by YOPWAL of the content of such linked websites or third parties. The information that we collect from you will become available to these websites if you click the link to the websites. These linked websites are neither under our control nor our responsibility.  We, therefore, make no warranties or representations, express or implied about the safety of such linked websites, the third parties they are owned and operated by and the suitability or quality of information contained on them.  This Privacy Policy does not apply to these websites, thus, if you decide to access these linked third-party websites and/or make use of the information contained on them, you do so entirely at your own risk. YOPWAL accepts no liability for any damage or loss, however caused, in connection with accessing, the use of or reliance on any information, material, products or services contained on or accessed through any such linked website. We advise that you contact those websites directly for information on their privacy policy, security, data collection and distribution policies.

    
8. Third Party Access
   1. YOPWAL only shares personal information with other companies, entities or individuals in the following limited circumstances:
      1. We have your consent.
      2. We provide such information to other professional advisers or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
      3. We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable terms of service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of YOPWAL , its users or the public as required or permitted by law.
   2. YOPWAL is at all times, responsible for the security and appropriate use of that data as long as it remains with YOPWAL.
       
9. Violation of Privacy
   1. We have put in place procedures to deal with any suspected personal data breach and will notify you of any personal data breach and let you know the steps we have taken to remedy the breach and the security measures we have applied to render your personal data unintelligible.
   2. All suspected breach of personal data will be remedied with 1 (one) month from the date of the report of the breach.
   3. If you know or suspect that a personal data breach has occurred, you should immediately contact the YOPWAL team at [email protected]
   4. YOPWAL will not be responsible for any personal data breach which occurs as a result of :
      1. an event which is beyond the control of YOPWAL;
      2. an act or threats of terrorism;
      3. an act of God (such as, but not limited to fires, explosions, earthquakes, drought, tidal waves and floods) which compromises our data protection measures;
      4. war, hostilities (whether war be declared or not), invasion, act of foreign enemies, mobilisation, requisition, or embargo;
      5. rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises our data protection measures;
      6. the transfer of your personal data to a third party on your instructions; and
      7. the use of your personal data by a third party designated by you.
          
10. Data Retention

    We will retain your Personal Data only for the period within which it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws. We will cease to retain your personal data and remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected and are no longer necessary for legal or business purposes.

11. How to Contact Us
    For any enquiries you have in relation to this Privacy Policy, please feel free to contact our Data Protection Officer at [email protected]

All personal information in our possession is valued and is collected, used, disclosed and protected in accordance with the Singapore Personal Data Protection Act 2012 ("PDPA"). The purpose of this document (“Policy Notice”) is to explain how Yinson Global Corporation (S) Pte. Ltd., Yinson Production Offshore Pte. Ltd., Yinson Production Financial Services Pte Ltd., Yinson Green Technologies Pte. Ltd., Yinson Renewables Pte. Ltd., Yinson International Pte. Ltd., Yinson Production Capital Pte Ltd., Farosson Pte. Ltd., Floating Operations and Production Pte Ltd handles Personal Data which is subject to the PDPA, any regulations enacted thereunder, and any guidelines that may be issued from time to time by the Personal Data Protection Commission. We will take reasonable care to protect your Personal Data from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. We will review and update our policies, procedures and processes from time to time.

If you wish to opt-out of this Privacy Notice, amend or remove any of your personal data in our possession, please read the below for the required procedure.

1. PERSONAL INFORMATION AND OTHER DATA COLLECTED

Personal data as defined in the PDPA refers to data about an individual who can be identified from either that particular data, or from that data and other information which we have or likely have access to. Commonly collected personal data of our customers include, amongst other things, names, addresses, telephone (landline and mobile) numbers, e-mail addresses, NRIC/FIN numbers, nationalities, profession, education and medical history, dates of birth, driver's licence numbers and credit card information.

Collection of personal data

We may collect personal data from you, your authorized representatives, third parties or from publicly available sources including but not limited to credit reporting agencies, government department or agencies, public registries, websites and publications. Where you provide us with any personal data of third parties, you confirm that you have obtained all necessary consents to do so and that we may collect, use and disclose such personal data for the purposes as set out below.

In addition to personal data provided to us, certain information related to you that is not considered personal data under the PDPA may also be collected. We collect this information to improve our website and other online services. Such non-personal data may include information such as your IP address, the internet browser you use, details of your interaction with our website and other types of non-personal data.

Use of cookies

Cookies are small files which require user permission in order to be installed on a device's hard drive. Cookies will only start to perform their functions after such permission is granted. By collecting and analysing data on the user's browsing patterns, cookies allow web applications to respond to the user as an individual by tailoring a web application's operations to the user's specific needs and preferences.

Permission for cookies is granted by default in most web browsers. You can however choose to disable this function in your browser's settings. This may prevent you from taking full advantage of our website.

We may use traffic log cookies to identify which pages are being used. This use is designed to assist us in gathering data on web page traffic. The gathered data is used only for statistical purposes and is removed from our database shortly after.

Overall, the data collected by the cookies is used for the purpose of improving your browsing experience on our website. Cookies do not grant us access to your computer or any information about you outside of your browsing activity on our website.

By accessing our website, you agree that we can place cookies on your device.

We are not responsible for the privacy practices or the use of cookies on websites that you have accessed this website from and to other websites that you may access from this website.

2. USE OF YOUR PERSONAL DATA

We collect personal data from our existing and prospective clients and employees for various reasons. Without limitation, these purposes include:-

• to communicate with you;
• to verify your identity;
• to process your employment applications;
• to processing payments;
• to process, record, execute, monitor, and/or archive your requests and transactions;
• to managing our administrative and business operations;
• to comply with all applicable legal and regulatory requirements;
• to establish, exercise, or defend any legal or equitable claim; and
• Any other purpose necessary, ancillary or consequential to the above specified purposes.

We may, for the above purposes, contact you via mail, electronic mail, telephone, SMS, facsimile or other forms of communication through mobile applications.

3. DISCLOSURE OF YOUR PERSONAL DATA

We may disclose your personal data to third parties under circumstances permitted under the PDPA. Third parties may be as follows:

(a) any persons directed by or consented to by you;

(b) any person for the purposes of compliance with legal and regulatory requirements of Singapore;

(c) our subsidiaries, partners, related companies and/or affiliates;

(d) our data processors i.e. third party who we engaged to process personal data on our behalf including but not limited to archival storage, data entry service providers, website service provider, computer backup services, disaster recovery services, bank and financial institutions;

(e) third party service providers and agents, i.e. for the purposes of performing reference checks, background screening, bankruptcy searches, travel and accommodation bookings etc; and

(f) our professional advisers including but not limited to legal advisers, tax advisers, financial advisers, auditors and insurance brokers/insurers.

Such parties may either be in Singapore or abroad. We have taken steps to ensure that appropriate level of protection necessary to maintain the security and integrity of your personal data are in place and that any transferred data is processed only in accordance with the PDPA and any other applicable law.

4. WITHDRAWAL OF CONSENT

Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws

5. ACCURACY OF PERSONAL DATA

We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete. For this reason, you are required to update your personal data by informing us of any changes as promptly as you can.

6. AGE POLICY

We do not seek to obtain nor do we wish to receive personally identifiable information directly from minors. If a minor provides us with personally identifiable information, we encourage a parent or guardian of that child to contact us to have this information removed from our records and to unsubscribe the minor from future communication with us.

7. SECURITY

We will protect your personal data using industry standard precautions. While the transference of electronic data over the internet has inherent risks, we will use reasonable precautions to ensure your personal data is not subject to unnecessary risks. Some of the means through which such protection is rendered include:

• physical security around the premises of our offices where your personal data may be stored;
• access to your personal data is only available to the staff who require it to perform their duties; and
• installing and maintaining industry standard technology to protect our networks and data storage systems from third party interference.

However, you will appreciate that it is not for us to perfectly secure your personal data from cyber-attacks, such as spyware or viruses and you will not hold us liable for any unauthorized disclosure of your personal data arising from such risks.

8. RETENTION

We will retain your Personal Data for as long as necessary in order to fulfil the purpose for which it was collected, or as required by the relevant laws.

9. ACCESS AND CORRECTION OF PERSONAL DATA

Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA. An administrative charge may be imposed for any access requests.

Upon request, we will update, correct an error or omission in the individual’s personal data or withdraw consent to the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.

We will make all reasonable and practicable efforts to comply with your request, so long as it is consistent with the requirements of the PDPA.

10. DATA PROTECTION OFFICER

• If you want to access the personal data we hold on you;
• If you want to request that we amend or correct your personal data;
• If you want to withdraw consent to use or disclose your personal data; or
• If you have comments or queries about our Privacy Notice or other related issues;

Please contact our Data Protection Officer ("DPO") at:

Data Protection Officer

Yinson Production Offshore Pte Ltd

3 Church Street

#18-01 Samsung Hub

Singapore 049483

Email:    [email protected]

11. RIGHTS TO AMEND THIS PRIVACY NOTICE

We reserve the right to amend this Privacy Notice at any time. If material changes are made to this Privacy Notice, they will be posted on this page and date stamped. We encourage you to review this page periodically in order for you to stay notified of any changes.

Your continued use of this website constitutes your consent to any such changes, to the extent such consent is not otherwise provided.