Privacy Policy

Introduction

Arte Bunkering Group of Companies values your privacy and is committed to protecting your personal data. This privacy policy outlines how we handle your personal information, your privacy rights, and how the law protects you. We comply with applicable legal and regulatory requirements to ensure the protection of your personal data across all jurisdictions in which we operate.

1. Who We Are

For the purposes of applicable data protection laws, the data controller is the relevant Arte Bunkering Group entity with which you have a relationship. The Arte Bunkering Group is made up of different legal entities incorporated in various jurisdictions, details of which are available upon request. References to "Arte Bunkering", "we", "our", or "us" in this notice refer to the relevant company in the Arte Bunkering Group responsible for processing your data.

2. Data We Collect

We collect personal data from a variety of individuals as part of our business operations, including:

  • Suppliers, clients, counterparties, and other business contacts;

  • Representatives of suppliers, clients, and other business contacts;

  • Employees;

  • Contractors and consultants;

  • Users of our website;

  • Individuals who contact us by any means;

  • Job applicants.

3. How We Collect Your Data

We collect data that you voluntarily provide to us, both online and offline.

This includes when you:

  • Visit our website and fill out web forms;

  • Visit our premises;

  • Communicate with us via phone, video conferencing, email, social networks, third-party apps, or similar technologies.

We may also collect information automatically from your device as you interact with our website using cookies and similar technologies. Additionally, we may gather information from third-party sources, such as related websites we operate and from subcontractors.

 

4. Types of Data We Collect

Arte Bunkering may collect the following types of personal data:

  • Personal identification information (e.g., name, gender, job title, photo ID, email address, home or business address, and other contact details);

  • Business-related information (e.g., business interests, communications, and meeting notes);

  • Financial and payment information;

  • KYC and compliance information (e.g., passport details, proof of address, sanctions screening results, and beneficial ownership information);

  • Technical data (e.g., IP address, browser type, operating system, language, time zone, access times, and referring website addresses).

 

5. How We Use Your Data

We use your personal data for various purposes, including:

  • To operate and manage our website and ensure it is presented effectively on your device;

  • To provide you with information and services that you request;

  • To manage our internal recruitment processes;

  • To fulfil our contractual obligations to you;

  • To communicate with you and respond to your enquiries;

  •  To comply with legal and regulatory obligations, including AML, sanctions screening, and KYC requirements;

  • For business-related purposes, including contract negotiation, payment processing, account management, and conducting investigations.

 

6. Data Transfers

Your personal data may be transferred to and stored in countries outside your own, including countries that may have different data protection standards. We take all legally required steps to ensure your data is protected when transferred across borders.

If you are in the EEA, the United States of America, Singapore, the United Arab Emirates, the United Kingdom, or any other jurisdiction with cross-border transfer requirements, you can request more information about the safeguards we use to protect your data by contacting us at the details in Section 15.

 

7. Legal Basis for Processing

Our processing of your personal data is based on the following legal grounds:

  • Your consent;

  • The performance of a contract with you or others;

  • Our legitimate business interests;

  • Compliance with legal obligations.

Where we rely on legitimate interests, we ensure those interests do not override your rights and freedoms. You may request details of any legitimate interest assessment by contacting us.

 

8. Data Sharing

We may need to share your personal data with the following third parties:

  • Our clients, counterparties, and suppliers, where relevant to the fulfilment of a contract with them;

  • Other Arte Bunkering Group entities, for internal administrative and compliance purposes;

  • Service providers who provide IT and system administration services;

  • Professional advisers including lawyers, bankers, auditors, and insurers;

  • Sanctions screening and AML data providers;

  • Regulators, tax authorities, and other authorities who require reporting of processing activities in certain circumstances;

  • Third parties to whom we may sell, transfer, or merge parts of our business or assets. 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 our third-party service providers 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.

We will not sell or rent your personal data to any third party.

 

9. Social Media Links

Our website may contain links to social media and other third-party sites. These sites have their own privacy policies, and we are not responsible for their practices. Please review their policies before providing any personal data.

 

10. Data Retention

We retain your personal data only as long as necessary for the purposes for which it was collected, 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 respect of our relationship with you.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure; the purposes for which we process your personal data; and the applicable legal, regulatory, tax, accounting, or other requirements.

Data and records are securely destroyed or erased when they are no longer required.

 

11. Your Rights

You have rights under applicable data protection laws regarding your personal data. Subject to the law of your jurisdiction, these include:

  • Right of access: You may request a copy of the personal data we hold about you.

  • Right to rectification: You may request correction of inaccurate or incomplete personal data.

  • Right to erasure: You may ask us to delete your personal data where there is no good reason for us continuing to process it, subject to certain legal exceptions.

  • Right to object: You may object to processing based on legitimate interests or for direct marketing purposes.

  • Right to restriction: You may ask us to suspend the processing of your personal data in certain circumstances.

  • Right to portability: You may request transfer of your personal data to you or a third party in a machine-readable format.

  • Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

  • Rights in relation to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you, except in the limited circumstances permitted by law.

 

12. Security

Arte Bunkering takes reasonable and appropriate measures to protect your personal data from unauthorised access, use, alteration, or disclosure. We limit access to your personal data to those employees, agents, contractors, and other third parties who have a genuine business need to know, 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.

However, no transmission of data over the internet is completely secure, and we cannot guarantee the absolute security of data transmitted to or from our website.

 

13. Cookies

We use cookies and similar technologies to enhance your experience on our website. Cookies help us understand how visitors use our site and support our marketing activities. You can control cookies through your browser settings and other tools.

For more details, please see our Cookie Policy on our website.

 

14. Applicable Law and Jurisdiction

Arte Bunkering operates across multiple jurisdictions and is committed to complying with applicable data protection laws worldwide. Depending on your location, additional rights or obligations may apply to the processing of your personal data under local law, including but not limited to:

  • European Union: the General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR"), which applies to the processing of personal data of individuals in the EEA regardless of where processing takes place, requires a lawful basis for processing and adherence to the core data protection principles;

  • United Kingdom: the UK GDPR as supplemented by the Data Protection Act 2018, which mirrors the GDPR framework for individuals in the UK;

  • United States: a combination of applicable federal sector-specific laws (including HIPAA, GLBA, and COPPA) and state-level comprehensive privacy legislation, including but not limited to the CCPA/CPRA (California), VCDPA (Virginia), CPA (Colorado), CTDPA (Connecticut), and TDPSA (Texas), as well as the laws of other states where such legislation is in effect;

  • Singapore: Personal Data Protection Act 2012 (PDPA), as amended;

  • United Arab Emirates: UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection; DIFC Data Protection Law 2020; ADGM Data Protection Regulations 2021;

  • Other jurisdictions: applicable local data protection laws, including those of Hong Kong, Australia, Canada, and others.

Where local law provides additional rights or imposes additional requirements, those will apply. You are welcome to contact us for further information about the rules applicable to you.

 

15. Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices, legal requirements, or business operations. Any changes will be posted on this page and, where appropriate, notified to you by email. Please review this policy regularly.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

16. Contact Us

If you have any questions or concerns about this privacy policy or our data practices, or to exercise any of your rights, please contact our data protection team:

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