sonnen Australia Pty Limited
In the course of carrying on its activities sonnen Australia Pty Limited will collect, store, use and disclose personal information. We are committed to the protection of your personal information and to compliance with Australian privacy law.
Personal information is information or an opinion about an identified or reasonably identifiable individual, whether or not the information or opinion is true and whether or not the information is recorded in a material form.
Types of personal information we collect and hold
We collect and hold personal information about individuals for the provision of our products and services and purposes connected to those products and services.
Consistent with the provision of our products and services, the types of personal information we may collect and hold include individuals’ name, address, telephone number, email address and financial information.
How we collect and hold personal information
We may collect personal information directly from you in the course of providing our products and services, from our website and/or directly from you.
We may collect and hold personal information disclosed to us by third parties when they engage us to provide products and services, or other third parties, such as your local distributor or credit reporting bodies. We will only do so where those third parties have the right to disclose to us that personal information.
Personal information is held securely, is subject to various security protections and is held only for as long as the information remains relevant to the purpose for which it was collected. Our internal policies and procedures strictly govern the way we hold our clients’ personal information.
Purposes for which we hold, use and disclose information
We will not use or disclose personal information for any secondary purpose, unless that secondary purpose is related to the primary purpose for which we have collected that information, and you would reasonably expect the disclosure in the circumstances, or unless you consent to that use or disclosure.
The purposes for which we hold, use and disclose information include:
(a) conducting our business, for example completing our transactions with you. This may include disclosing your personal information to a third party supplier who assists us in supplying services to you;
(b) to communicate information about our products and services or the products and services of our clients;
(c) for our internal administrative, research, planning, performance measuring, marketing and product development;
(d) confirming your identity and carrying out credit checks;
(e) complying with our legal and regulatory obligations;
(f) when required by a third party to provide services to you (e.g. if your local distribution company requires information);
(g) when we need to communicate with one of our community or commercial partners to tell them which customers have chosen to support them;
(h) to collect any money you may owe us (including by using a third party to collect such money);
(i) to transfer your information to a new supplier; and
(j) to share your information with third party government entities who require the personal data for the purposes of administering or analysing subsidy or funding schemes which have been utilised by you to obtain our products.
Your personal data is exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:
Your personal data may also be shared with a company that is a member of our group of companies, which includes our ultimate parent company Royal Dutch Shell Plc.
We may also share your personal data with our group companies where they provide products and services to us that help us to provide products and services to you as our customer.
Authorized third party agents, service providers and/or subcontractors of sonnen.
A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which sonnen or the relevant sonnen company/companies is/are subject to or as permitted by applicable local law.
In order to comply with legal and regulatory obligations, to protect our assets and employees/contractors and specifically to ensure that we can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening on existing customers and business partners and potential customers and business partner pre-contract and on a periodic basis post-contract (minimum at least quarterly).
The screening takes place against publicly available or government issued sanctions lists. The screening is conducted in Europe. We compare your first and last name with the names published on these publicly available sanctions lists. In case of an initial match sonnen will assess if the match is accurate based on the information sonnen may hold on you (such as your address) or sonnen may use other public sources such as information held by the credit check agencies. sonnen may also contact the individual directly to obtain further information. If sonnen cannot rule out the match, we may rely on the services of our external consultants (KPMG EU) to further assess and evaluate.
Once it has been verified that we have a match the Shell company RDS plc. (Royal Dutch Plc.) has a legal reporting obligation to the US Securities and Exchange Commission (SEC). Shell Midstream Partners LP (MLP) is required to file quarterly and annual reports to SEC. If legally required sonnen has to alert the local regulatory authority.
Legal basis for the processing is Art. 6 subpar. 1, lit. c) and f) GDPR (EU General Data Protection Regulation).
The screening does not result in any automated decision making in relation to our customer, business partner or potential customer or business partner.“
Access and correction
We will take all reasonable steps to ensure any personal data we collect, use or disclose is up to date and accurate. If you believe personal information we hold about you is not up to date or accurate, you may ask us to correct it.
You may ask us to provide you with details of the personal information we hold about you, and copies of that information. We will respond to your request and attempt to provide you with the data within 30 days of receipt of your request.
If we provide you with copies of the information you have requested, we may charge you a reasonable fee to cover the administrative costs of providing you with that information.
Please direct all request for access and correction to:
We may, in the course of providing products and services, disclose personal information to overseas entities.
Those overseas entities are likely to be located in the following countries: Germany, Italy, UK, USA, and Japan.
You agree that where personal information is disclosed to the countries above, the Privacy Act 1988 (Cth) will not apply to that information.
Changes to this policy
If you consider a breach of the Privacy Act 1988 (Cth) has occurred, you may direct your query to our data protection officer, Deutsche Shell Holding GmbH, Michael Seus, Suhrenkamp 71-77, 22335 Hamburg, Germany, email@example.com and we will attempt to resolve your complaint.
If you do not consider our response satisfactory, you may contact the Australian Privacy Commissioner at its website www.oaic.gov.au or by telephone on 1300 363 992.