The PetrofacGo Privacy Policy

Welcome to the PetrofacGo Privacy Policy (“Privacy Policy”). Petrofac respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you use the PetrofacGo app (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary

1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy gives you information on how Petrofac collects and processes your personal data through your use of the PetrofacGo app. It applies to anyone who uses the PetrofacGo app including Petrofac employees, contractors and other third parties. Please note that the PetrofacGo app is not intended for children, and we do not knowingly collect data relating to children through the PetrofacGo app.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Controller

This Privacy Policy is issued on behalf of Petrofac Services Limited so when we mention Petrofac, "we", "us" or "our" in this Privacy Policy, we are referring to Petrofac Services Limited which is the controller responsible for processing your data in relation to the PetrofacGo app.

Contact details

If you have any questions about this Privacy Policy or privacy practices in relation to the PetrofacGo app, please contact Petrofac via the following email: dataprivacy@petrofac.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under review and may update it from time to time. This version was last updated in May 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed of changes to your personal data.

Third-party links

The PetrofacGo app may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

Petrofac also has a social media presence for the purpose of engaging with you.

If you enable such connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave the PetrofacGo app, or interact with us on social media, we encourage you to read the privacy policy of each website or forum that you visit or use.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where our ability to identify that person has been removed (anonymous data).

Where you are a registered user of the PetrofacGo app, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, Vantage ID number, Worker ID number (where you are a Petrofac employee), crew type, work site.
• Contact Data includes your email address and telephone number provided when you register for the PetrofacGo app.
• Communication Data includes content of any messages/reports that you send to us through the PetrofacGo app, and any responses received through the PetrofacGo app, including both through chat functions and reporting feedback, and any registration of interest that you submit to the PetrofacGo app (e.g. in relation to an advertised vacancy).
• Mobilisation Data includes travel and other information applicable to mobilising you for projects that you are engaged on (e.g. in relation to your mobilisation).
• Reporting Data includes information about you in feedback reports that are submitted to the PetrofacGo app as part of HSE and quality reporting activities.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the PetrofacGo app.
• Profile Data includes your username and password, and clothing size (where you require PPE and other items for mobilisation).
• Usage Data includes information about how you use the PetrofacGo app and what information/communications you have viewed.

Where you are an unregistered guest user of the PetrofacGo app we may collect, use, store and transfer Technical Data relating to you.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not actively 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) when you use the PetrofacGo app. Nor do we actively collect any information about criminal convictions and offences. If you submit such personal data to us when using the PetrofacGo app we will process it in accordance with relevant data protection law. Please contact us if you require further information.

If you fail to provide personal data

Where we need to collect personal data by law, , and you fail to provide that data when requested, we may not be able to provide the PetrofacGo app to you. In this case, we may delay, adjust or deny access to the PetrofacGo app, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Communication Data when using the PetrofacGo app.
• Automated technologies or interactions. As you interact with the PetrofacGo app, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other apps or websites employing our cookies. Please see our cookie policy for further details.
• Third parties. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google (both in and outside the UK) and Bidu in China.
  • Reporting Data that relates to you in reports submitted to the PetrofacGo app by registered users.

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 a contract we are about to enter or have entered with you or your employer.
• 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 obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent where it is required by law. Where we rely on consent, you have the right to withdraw your consent at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data when you use the PetrofacGo app, and which of the legal grounds mentioned above we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Where you are an unregistered guest user of the PetrofacGo app:

Where you are an unregistered guest user of the PetrofacGo app, we will process your personal data for the purposes set out in the table below:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To provide you with access to the PetrofacGo app	(a) Technical	(i) Performance of a contract with you
To administer and protect our business and the PetrofacGo app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Technical (b) Usage	(i) Necessary for our legitimate interests (for running the PetrofacGo app, administering the Petrofac business, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (ii) Necessary to comply with a legal obligation
To use data analytics to improve the PetrofacGo app	(a) Technical (b) Usage	(i) Necessary for our legitimate interests (to keep the PetrofacGo app updated and relevant, to develop our business and to inform our communications strategy)

Where you are a registered user of the PetrofacGo app

Where you are a registered user of the PetrofacGo app, we will process your personal data for the purposes set out in the table below:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To provide you with access to the PetrofacGo app including access to restricted content and services.	(a) Identity (b) Contact (c) Communication (d) Mobilisation (e) Reporting (f) Technical (g) Profile	(i) Performance of a contract with you
To manage our relationship with you and provide the PetrofacGo app services which will include: (a) Notifying you about personnel mobilization, and to communicate with you and provide you with information regarding projects that you are engaged on (b) Registering your interest in vacancies posted on the PetrofacGo app (c) Processing HSE and quality feedback and reporting where feedback and reports are not submitted on an anonymous basis (d) Facilitating PPE requests (e) Notifying you about changes to the PetrofacGo app terms of use, or privacy policy	(a) Identity (b) Contact (c) Communication Data (d) Mobilisation Data	(i) Performance of a contract with you (ii) Necessary for our legitimate interests (to perform a contract with your employer or a Petrofac business partner) (iii) Necessary for our legitimate interests (to ensure health and safety compliance, and quality of Petrofac products and services) (iv) Necessary to comply with a legal obligation
To deliver relevant app content to you	(a) Identity (b) Contact (c) Mobilisation (d) Communication (e) Profile (f) Usage	(i) Performance of a contract with you (ii) Necessary for our legitimate interests (to study how users engage with the PetrofacGo app).
To administer and protect our business and the PetrofacGo app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Technical (b) Usage	(i) Necessary for our legitimate interests (for running the PetrofacGo app, administering the Petrofac business, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (ii) Necessary to comply with a legal obligation
To use data analytics to improve the PetrofacGo app	(a) Technical (b) Usage	(i) Necessary for our legitimate interests (to keep the PetrofacGo app updated and relevant, to develop our business and to inform our communications strategy)

PetrofacGo feedback and reporting

Whether you are a user of the PetrofacGo app or not, your personal data may be submitted to us as part of feedback or reporting in relation to HSE or quality reporting activities. Where we receive personal data through such feedback or reporting, processing such information is necessary for our legitimate interests (to ensure health and safety compliance, and quality of Petrofac products and services), and in some cases pursuant to our legal obligations. If you would like more information about how we process your personal data as part of feedback and reporting carried out through the PetrofacGo app, please contact us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when apps set or access cookies. If you disable or refuse cookies, please note that some parts of the PetrofacGo app may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, but otherwise in compliance with this Privacy Policy, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data processed by the PetrofacGo app with the parties set out below for the purposes set out in the table above.

• Internal Third Parties which are other companies in the Petrofac Group acting as controllers or processors and who are based in and outside of the UK for delivery of projects and group wide services.
• External Third Parties which are service providers acting as processors based in and outside the UK who provide services such as travel, insurance, and IT services.
• Authorities and regulators, such as HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in and outside the UK who require reporting of processing activities in certain circumstances.
• Professional advisers including lawyers, bankers, auditors, and insurers acting as processors or controllers based in and outside the UK who require reporting of processing activities in certain circumstances or who process your personal data for the purpose of delivering their services to us.
• 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 Policy.

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 any third-party service providers who are acting as processor for us 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.

If you require any further information about third parties with whom we may share your personal data, please contact us.

6. International transfers

We share your personal data within the Petrofac Group. This will involve transferring your data outside the UK.

Many of our external third parties are also based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, whether to an external third party or a company in the Petrofac Group, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. 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.

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in relation to which your personal data is relevant.

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, regulatory, tax, accounting, or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of your rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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 a 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.