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1. Introduction

Borouge respects your privacy and takes its data protection responsibilities seriously. We recognise the importance of the personal data which has been entrusted to us, and are committed to managing, protecting and processing your personal data in accordance with applicable law. 

This document (“Data Privacy Notice”) applies to all personal data collected by Borouge. The purpose of the Data Privacy Notice is to inform you of how Borouge manages personal data which is subject to personal data protection principles under the applicable law in your jurisdiction. Please read this Data Privacy Notice to understand what information we collect, the purposes as to why we collect it, and your rights with regard to such information. 

By interacting with us, submitting information to us, or signing up for any products offered by us, you acknowledge and agree that you have fully read and understood this policy, and are consenting to the collection, use, processing and disclosure of your personal data as described in this Data Privacy Notice. Depending on your country, we may alternatively collect personal data where such information is necessary for our legitimate interests.

Without prejudice to any of the foregoing, if you provide the personal data of any other third party to us, you warrant and agree that such third party has fully read and understood this Data Privacy Notice, and has consented to you disclosing his/her personal data to us for the collection, use and disclosure by us as described in this Data Privacy Notice.

This Data Privacy Notice supplements but does not supersede nor replace any other consents you may have previously provided to Borouge in respect of your personal data, and your consents herein are additional to any rights which Borouge may have at law to collect, use or disclose your personal data. 

Borouge may from time to time update this Data Privacy Notice to ensure that it is consistent with future developments in our company, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Data Privacy Notice as updated from time to time on our website or otherwise made available to you. Please check back regularly for updated information on the handling of your personal data.

2. Who we are
Borouge is a group of companies based in the United Arab Emirates and Singapore, with multiple offices across the globe. In this Data Privacy Notice, when we refer to “Borouge”, this means all of our affiliates, subsidiaries, related entities, and any of our branches and offices, including without limitation Abu Dhabi Polymers Co Ltd (Borouge) LLC, Borouge Pte. Ltd., Borouge Sales and Marketing (Shanghai) Co. Ltd., Borouge (India) Private Limited, and Borouge Egypt LLC. 

The specific Borouge company responsible for your personal data may vary depending on the jurisdiction in which you are located. Generally, the controlling entity will be:

For personal data collected from individuals located in the United Arab Emirates,

Abu Dhabi Polymers Co Ltd (Borouge) L.L.C
Borouge Tower, Shaikh Khalifa Energy Complex
Corniche Road, PO Box 6951
Abu Dhabi, United Arab Emirates

For personal data collected in China, 

Borouge Sales and Marketing (Shanghai) Co. Ltd.
23rd Floor, Building 1, Sandhill Plaza 
2290 Zu Chong Zhi Road, 
Zhang Jiang Hi-Tech Park, 
Pudong New District, Shanghai 201203, 
China

For personal data collected in India, 

Borouge (India) Pvt Ltd
1501/02, ‘B’ Wing, Lotus Corporate Park, 
Near Jay Coach Signal Western Express Highway, 
Goregaon (East), Mumbai 400063, 
India

For personal data collected in Egypt, 

Borouge Egypt LLC
Galleria40, 2nd Floor, North Tower 
6th Of October, Giza
Egypt

For personal data collected in all other jurisdictions, 

Borouge Pte. Ltd.
1 George Street #18-01
Singapore 049145
Singapore

Your data will generally be stored in your country, and on systems in the United Arab Emirates and Singapore. We will comply with all legal requirements where your personal data has to be transferred to a country other than your own. This will include ensuring that following any transfer, your personal data is given the same level of protection which we are required to provide in your country. 

It should be noted that the collection, use or disclosure of personal data by Borouge's holding companies, the Abu Dhabi National Oil Company and Borealis AG, are operated independently of Borouge and will be covered by the policies of these respective entities. 

3. What is personal data
In this Data Privacy Notice, “personal data” is any information which can be used to identify you or any other individual. Examples of the types of personal data we collect are set out below. 

In some countries, certain types of personal data may be classified as "sensitive personal data". Borouge generally does not collect sensitive personal data, unless otherwise permitted by law, or where required by a local authority. However, where such information is required such as where we collect passport or identification numbers where you seek employment with us, your separate express consent will be obtained, and we will comply with any legal requirements in relation to such personal data.  

4. Types of personal data collected
Borouge may collect personal data about you either directly from you, from your authorised  representatives (i.e. persons who you have authorised and persons who have been validly identified as being you or your authorised representative), from third parties, or from publicly available sources.

Subject always to applicable legal requirements, personal data which we may collect include but are not limited to: 

(a) Personal information such as your name, passport or identification numbers, date of birth, marital status or gender;
(b) Contact information such as postal addresses, email addresses, telephone, mobile phone and fax numbers;
(c) Employment information such as employment history and references, resumes, organisation name, organisation type, industry sector, job function and responsibilities, designation, business telephone and fax numbers, business email addresses;
(d) Education information and academic qualifications such as schools attended, courses of study, period of study and academic results;
(e) Financial information such as credit / debit card details (if required); 
(f) Records from discussions or correspondences, including details obtained through customer satisfaction or other surveys;
(g) Details of your transactions with Borouge for the provision of any products;
(h) Information derived from cookies (small text files which uniquely identify your browser) where you visit any website or use any application created by or on  behalf of Borouge; and
(i) Information you provide to Borouge in relation to the provision of any products from Borouge to you.

5. Collection of personal data
Generally, we collect personal data from you in the following ways:

(a) when you submit an application form or registration form, or other forms relating to any of our products;
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you transact with us for our products;
(c) when you interact with our employees, agents, representatives or officers, for example, via telephone calls, letters, face-to-face meetings, social media platforms and emails;
(d) when you use our electronic services, or interact with us via any of our websites or use services on any of our websites;
(e) when you request that we contact you or request that you be included in an email or other mailing list;
(f) when you respond to our promotions, initiatives or to any request for additional personal data;
(g) when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
(h) when you are contacted by, and respond to, our marketing representatives and customer service officers;
(i) when we receive references from business partners, sales contacts and/or other third parties, for example, where you have been referred by them;
(j) when you fill up surveys administered by our third party surveying service providers;
(k) when we seek information from third parties about you in connection with the products you have applied for; and/or
(l) when you submit your personal data to us for any other reason.

When you browse our websites, or use our applications and/or digital services, we may collect and store certain information automatically. Please see the section below on cookies for additional detail. 

If you provide us with any personal data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent and warrant to us that you have obtained the consent of the third party to provide us with their personal data for the respective purposes.

We generally do not collect personal data from children and minors and will take reasonable measures to remove such personal data from our systems. If you believe that a child or minor has provided us with personal data, please contact us in accordance with section 11 below.

You should ensure that all personal data submitted to us is complete, accurate, true and correct. Please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided at section 11 below.

6. Purposes for the collection, use and disclosure of personal data
Generally, Borouge collects, uses and discloses your personal data for the following purposes:

(a) verifying and authenticating your identity for the purpose of providing you with our products, or where you provide products and/or services to us;
(b) responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
(c) managing the administrative and business operations of Borouge and complying with internal policies and procedures;
(d) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the entities in Borouge;
(e) matching any personal data held which relates to you for any of the purposes listed herein;
(f) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical or other purposes;
(g) preventing, detecting and investigating crime and analysing and managing commercial risks;
(h) managing the safety and security of our premises (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(i) archival of documents and records in both electronic and physical form for record-keeping purposes;
(j) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
(k) conducting investigations relating to disputes, billing or fraud;
(l) complying with any applicable local or foreign statute, rule, law, regulation, judgment, decree, directive, code of practice, guideline, administrative requirement, sanctions regime, court order, or contractual agreement to which any Borouge entity is party;
(m) any other purposes which are permitted under applicable law and for which your consent is not expressly such as where it is within our legitimate interests and such interests are not otherwise overridden by your fundamental rights under an applicable law; 
(n) any other purposes for which you have provided information; and/or
(o) any other incidental business purposes related to or in connection with the above.

In addition, Borouge collects, uses and discloses your personal data for the following purposes depending on the nature of our relationship: 

(a) User / Visitor on Website
If you browse, use or visit our websites, applications and/or any digital services, 
(i) aggregate anonymized statistical data and gather feedback to enable us to continually improve our website and your user experience;
(ii) administer our website, including for troubleshooting; 
(iii) personalizing and tailoring your experience on our website; and/or  
(iv) any other purpose relating to any of the above.

(b) Customer / Consumer 
If you are an employee, business partner, sole proprietor, director, nominee director or guarantor, agent, distributor or representative of an organisation that is a customer (including prospective customer) or otherwise has a corporate relationship with Borouge:

(i) assessing and processing any requests, applications or orders made by you for any products;
(ii) facilitating the continuation or termination of the corporate relationship with Borouge;
(iii) creating and maintaining the profile or account in our system database for internal records and reference; 
(iv) providing customer service and support; 
(v) facilitating and carrying our due diligence checks; 
(vi) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, or customer due diligence; and/or 
(vii) any other purpose relating to any of the above.

(c) Vendor / Service Provider
If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by Borouge: 

(i) managing project tenders or the supply of goods; 
(ii) processing and payment of vendor invoices; 
(iii) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and/or
(iv) any other purpose relating to any of the above.

(d) Candidate for employment
If you submit an application to us as a candidate for employment:

(i) responding to, and processing, your application for employment with a Borouge  company;
(ii) conducting interviews; 
(iii) processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews; 
(iv) providing or obtaining employee references and for background screening; 
(v) evaluative purposes such as assessing your suitability for the position applied for; 
(vi) processing staff referrals; and/or
(vii) any other purposes relating to any of the above.


Where permitted by applicable law, Borouge may also collect, use and disclose your personal data for the following additional purposes:

(a) providing or marketing our products, including but not limited to any special events and promotions organised by Borouge;
(b) conducting market research, analytics and surveys to enable Borouge to understand and determine customer preferences and demographics for us to offer you our products as well as marketing programmes; and/or
(c) any other purpose relating to any of the above.

In relation to particular products or in your interactions with Borouge, we may also have specifically notified you of other purposes for which we collect, use or disclose your personal data. If so, we will collect, use and disclose your personal data for these additional purposes as well, unless we have specifically notified you otherwise.

7. Disclosure of personal data
We may share your data with other companies in Borouge, including Abu Dhabi Polymers Co Ltd in the United Arab Emirates and Borouge Pte. Ltd. in Singapore. 

Depending on the products you require, we may also need to share your personal data with other companies, including our holding companies, the Abu Dhabi National Oil Company and Borealis AG, and their respective subsidiaries. 

Your personal data may also be disclosed for the purposes listed above to the following third parties:
(a) agents, contractors or third-party service providers who provide services to Borouge;
(b) banks, financial institutions, credit card companies and their respective service providers;
(c) any business partner, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving a Borouge company;
(d) our professional advisers such as our auditors and lawyers; 
(e) any judicial, administrative or regulatory body, any government or public or government agency, instrumentality or authority, any domestic or foreign tax, revenue, fiscal or monetary authority or agency, securities or futures exchange, self-regulatory organization, trade repositories, central counterparties, court, central bank or law enforcement body or any agents thereof; and/or
(f) any other party to whom we are authorised to disclose your personal data to.

Where any of your personal data is required to be disclosed to a third party, we will take all reasonable steps to ensure that your personal data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under any applicable law. Some third-party processors may be located in countries where data privacy may not be on an equivalent level. You explicitly consent to a data transfer to processors or other entities in these countries. 

Where we share your personal data with these entities in other jurisdictions, we will take steps to ensure that your data is provided with an equivalent or comparable level of protection, for example, through contractual data transfer agreements.

8. Our use of cookies
When you browse our websites, or use our applications and/or digital services, we may use cookies to distinguish you from other users of our websites, applications and digital services. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our websites applications and digital services.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. 

Before cookies are placed on your computer or device, you will be shown a pop-up message requesting your consent to let us place, set and use those cookies. By continuing to browse our website, or use our applications and/or digital services, you are agreeing to our use of cookies.

We may use any of the following cookies or all of them:

Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, or use services provided by Borouge.

Performance cookies: These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Information used for such purposes is generally stored as anonymized information from which individuals cannot be identified.

Functionality cookies: These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Borouge does not market its products to individual consumers. As such, we do not use cookies for marketing purposes. We do not use cookies which track or monitor your behaviour for targeted advertising, or for the offering of any products. 

You may refuse placement and/or block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our website. 

Cookies are destroyed once they are no longer necessary for their purpose.

Our websites, applications and/or digital services may contain links to other websites some of which may also use cookies. This Data Privacy Notice does not cover non-Borouge websites which will be subject to their own privacy and cookie policies. We do not have access to or control over cookies or other features used by such websites. Please contact them directly for more information about their privacy practices.

9. Protection of personal data
Security of your personal data is important to us. Borouge will take reasonable efforts to protect personal data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. 

Measures that we have put in place to protect your personal data include:
Technical and physical access controls;
Data protection and cybersecurity awareness and training;
Data protection and cybersecurity breach procedures and other forms of emergency planning;
Penetration testing of our systems;
Back-up arrangements for systems and data;
Audit controls; and
Secure disposal

However, we cannot completely guarantee the security of any personal data we may have collected from or about you, or that for example no harmful code will enter our websites, applications, and digital services (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites, applications, and digital services.

While we strive to protect your personal data, we cannot ensure the security of the information you transmit to us via the Internet, when you browse our websites, or use our applications and/or digital services, and the method of electronic storage. We urge you to take every precaution to protect your personal data when you are on the Internet, when you browse our websites, or use our applications and/or digital services. 

Where we have given you (or where you have chosen) a username and password which enables you to access certain parts of our websites, applications or digital services, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (a) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (b) retention is no longer necessary for any other legal or business purposes.

10. Retention Limitation
When personal data is no longer required for the purpose for which it was collected and/or any other legally permissible purpose, we will either securely delete or destroy the personal data, or anonymise it such that it cannot be used to identify you or any other individual. 

The specific period of retention for personal data may be affected by the legal requirements of your country. We will comply with document retention periods which may be set by your country's authorities and/or the contractual limitation periods under the laws of your country. While this would typically mean that we will delete, destroy or anonymise data within 6 years from the time it is no longer required, unless your country requires us to do so at a sooner date, local practice may vary and longer periods of retention may be permitted or required under the laws of some jurisdictions. We may also delete or destroy data where you are entitled to require us to do so, or where directed by a lawful authority in your country. 


11. Your rights and how to exercise them
You shall have the following rights in respect of your personal data:

Withdrawal of Consent
Where you have provided personal data to us and wish to withdraw your consent for our collection, use, disclosure, storage or processing of such data, you may contact our data protection officer to notify us of such withdrawal.
 
Kindly note that if you withdraw your consent to any or all use of your personal data, depending on the nature of your request, Borouge may not be in a position to administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Borouge, and your being in breach of your contractual obligations or undertakings. Borouge’s legal rights and remedies in such event are expressly reserved.

Access and Amendment
You have the right to request access and/or amend any personal data that we hold about you, subject to the requirements of applicable law. If you would like to request for a copy of your personal data being held by us (such right being subject to applicable exemptions), or to update and/or amend personal data which you have previously provided to us, please write to our data protection officer at the contact details provided under section 11 below.

We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time. Borouge generally does not charge a fee for requests to access or amend your personal data. 

Depending on the jurisdiction in which you are located, you may also have other rights, such as:

Right to Data Portability: Right to request for the transfer of the personal data in machine readable formats to other data controllers;

Right to Object: Right to object to the collection, usage and disclosure of the personal data;

Right to Erasure: Right to request for erasure or deletion of all personal data held by us; and/or

Right to Restrict of Processing: Right to request for suspension of use of your personal data.

You should contact our Data Protection Officer if you wish to inquire about the rights you may have in relation to your personal data and/or if you wish to exercise any rights in relation to your personal data.

12. Contact us
To contact us in order to exercise any of your rights in relation to your data, to enquire on any aspect of this Data Privacy Notice or your personal data, or provide us with any feedback, please contact our Data Protection Officer by sending an email to dataprivacyofficer@borouge.com.

We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. All communications should include, at least, the following details:

Your full name and contact information; and
Brief description of your query or feedback.

We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time

13. Right to Seek Further Redress
We take all requests and feedback seriously and will endeavour to address such requests and feedback to your satisfaction. If you believe we have fallen short of our duties in relation to your personal data, you are entitled to lodge a complaint with your local supervisory authority. Depending on your country's laws, you may also be entitled to take legal action against us. 


Last updated: 3 June 2020



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