Mitsui Bussan Gas & Power Solutions B.V. (MBGP) (“we”, “us”, “our” or “ourselves”) is committed to protecting your personal data and respecting your privacy. We are registered in the Netherlands (company no. 84300264) and our registered office is Barbara Strozzilaan 201, 1083HN Amsterdam, the Netherlands.
This Privacy Notice set outs the basis by which the personal data we, or one of our subsidiaries, collect or receive is processed. MBGP is the Data Controller responsible for your personal data. We are responsible for ensuring that we use your personal data in compliance with the relevant data protection laws. Accordingly, we have implemented policies, practices and technical measures to protect the personal data under our control. Please take time to read and understand this privacy notice. It should be read in conjunction with our website Cookie Policy.
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their services (for example, where you follow links to third party websites over which we have no control, or you purchase services from those third parties).
In providing our website (“Site”) and any services we offer (“Services”), we may collect and process different types of personal data about you for different processing purposes. Unless specified otherwise, references to our Site include the platforms that we make available to our clients including Report Portal (the “Platform”). The types of personal data we collect depends on who you are and how you use our Site and our Services, and includes the following:
Identity Data | First name; last name. |
Contact Data | Address; email address; telephone number; company. |
Registration Data | First name; last name; company; email address; any KYC information that we may collect; any other personal data that you may provide when you register an account with us. |
Financial Data | Bank account details. |
Transaction Data | Details about payments made between you and us; details of Services provided to you by us. |
Profile Data | Account username; password; job title; company; details of any Services provided to you; contact preferences. |
Behavioural Data | Data relating to your browsing activity or interaction with our emails, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any products you viewed or purchased through the Site. |
Technical Data | IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device. |
Marketing and Communications Data | Marketing preferences; service communication preferences. |
We will collect and process personal data about you that either you provide directly to us, or one of our affiliates, or we collect or generate about you. This includes:
Personal data you provide to us | You may give us your personal data directly, for example, to help us provide the Services, to enable us to fulfil our agreements with you, when you contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us. |
Personal data we collect using cookies and other similar technologies | |
Personal data received from third parties | We may receive personal data about you from third parties. Such third parties may include third parties that provide technical services to us so that we can provide our Site and our Services. |
Publicly available personal data | From time to time, we may collect personal data about you (Identity Data, Contact Data, Profile Data) that is contained in publicly available sources (including media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories). |
We collect and process personal data from the following people:
Site visitors | If you browse our Site or register an account on our Site, we will collect and process your personal data in connection with your interaction with us and our Site. |
Customers | We may collect and process your personal data in connection with the supply of services to you. |
People who contact us with enquiries | If you contact us with an enquiry, submit a complaint, or provide any feedback to us, we will collect and process your personal data in connection with your interaction with us and our Site. |
People who work for our customers and suppliers | If you work for one of our customers or suppliers and have responsibility for placing orders with us, administering your organisation’s account with us or handling our orders or our account with your organisation, we will process your personal data in connection with your organisation’s relationship with us. |
Visitors to our physical locations | If you attend one of our physical offices or other locations, we may process personal data that you volunteer in connection with your visit and any enquiries you make. CCTV footage may also be collected for security purposes. |
Event attendees | If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other document relating to the event. |
Job applicants | If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application. |
We use your personal data for the purposes set out in this section.
Visitors to our Site
If you register and access an account on our Site | You may be required to register an account in order to gain access to certain features and functionality of our Site, in particular our company reports. Account applicants will need to provide all required Registration Data and Profile Data. We will use this data in order to process your registration and provide access to relevant reports. Once your account is registered, we will process your Registration Data and Profile Data to identify you when you log in to your account and access our reports. We will also process certain Technical Data and Marketing and Communications Data so that we can administer your account and contact you about your account. We will also collect and process Behavioural Data and Technical Data when you use certain features and functionality on our Site. This data helps us understand how you use our Site so that we can improve it. Our legal basis for processing It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to the Site and our Services in a secure and effective way and so that we can make improvements to our Site. |
If you browse our Site | When you browse our Site, we collect and process Behavioural Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can improve the structure and navigation of our Site. Our legal basis for processing It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Site in a secure and effective way and so that we can make improvements to our Site. |
Fulfilment of our Services
Fulfilment of our Services | We collect and maintain personal data that you submit to us for the purpose of supplying our Services. These purposes include but are not limited to (i) making necessary regulatory or other communications with customers and/or intermediaries; (ii) general customer and/or intermediary management to ensure Services are provided correctly; and (iii) relationship management purposes. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent. The personal data we process may include your Contact Data, Registration Data, Profile Data, and Financial Data (where applicable). We process this information so that we can fulfil the supply of Services, maintain our user databases and to keep a record of how our Services are being used. If you attend one of our offices, we will process personal data about you which you volunteer in connection with your visit and any enquiries you may have. This will usually include your Contact Data, and any other personal data you volunteer. Some Services we offer are also subject to separate terms and conditions which will also apply. Our legal basis for processing It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Services in an effective, safe and efficient way. |
Customer service and enquiries
If you have a general question or need help with any issue concerning our Site or our Services | There are various ways in which you are able to contact us. In particular, our Site features a “Contact Us ” page, which provides contact details for each of our office locations. From time to time, you may also be able to submit specific enquiries on other areas of our Site. When you make an enquiry, we will collect and process your Identity Data, Contact Data, Profile Data and, if applicable, certain Transaction Data, as well as any other personal data you volunteer that is relevant to your enquiry. If you have a technical issue concerning our Site, we may also collect and process Behavioural Data and Technical Data to help us diagnose the technical issues you are experiencing and to help us resolve them in an efficient way. We use this information to manage and respond to your enquiry. We may also record (including voice recordings of telephone conversations) and use the information referred to above to train our personnel so that they can effectively deal with enquiries. Our legal basis for processing It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services. |
Insight and analysis through Cookies
If we use cookies to help us understand more about you and your use of our Site and our Services | We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Site, our Services, [and any emails that you receive from us]. The data that is collected includes Behavioural Data and Technical Data, and certain Profile Data. Please see our Cookie Policy for further information, including details of our third-party partners. We and our third-party partners use this data to analyse how you use our Site and our Services and the effectiveness of our Site and our Services, including:
[In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.] Our legal basis for processing Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Policy for further details.
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Advertising and marketing activities
If we send you marketing communications by post and/or email | We use your Identity Data, Contact Data and Marketing and Communications Data to send you (or the organisation you represent) marketing communications by post and/or email. Our marketing will include press releases and information about us, our Site, our Services, and any events we may hold. Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you. Where we are sending you personalised marketing, we may also use Profile Data, Transaction Data and Behavioural Data to help us decide what sort of personalised marketing to send you (please see the “Insight and analysis through Cookies ” section above for more details). Our legal basis for processing It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you. It is in our legitimate interest to use your personal data to send our marketing to you by post. However, we will only send marketing communications to you by email where you have consented to receive such content by email, or where we have another lawful right to send marketing to you using email. For example, we may rely on our legitimate interest to send marketing by email to certain business users of our Site and our Services. Unsubscribing from post or email marketing. You can unsubscribe from post or email marketing by sending an email to UNSUBCSRIBE@mbgp.eu
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Recruitment
If we use your personal data in connection with our recruitment activities | We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data and Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment. We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees. The personal data we process may include your Identity Data, Contact Data, Registration Data, details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for. We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit. Our legal basis for processing Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions. We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent. |
Receipt of products and services from our suppliers
If we have engaged you or the organisation you represent to provide us with products or services | If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others. The personal data we collect from you may include your Identity Data and Contact Data and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent. Our legal basis for processing It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our Services to others, in an effective way. |
Security
If we need to use your personal data in connection with the administration of our security measures | We have security measures in place at our premises, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft). We may require visitors to our premises to sign in on arrival and where that is the case we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident). Our legal basis for processing It is in our legitimate interests to process your personal data so that we can keep our premises secure and provide a safe environment for our personnel and visitors to our premises. |
Business administration and legal compliance
If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business | We may use your personal data: (i) to enforce our legal rights; (ii) to protect the rights of third parties; (iii) to make any necessary corporate filings; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
In particular, please note that as a financial institution we have legal and regulatory obligations to carry out due diligence on our customers, vendors, staff and counterparties to comply with our legal obligations such as know your client, anti-money laundering, anti-bribery and counterterrorism financing protocols. We also conduct automated screening of names against politically exposed persons and sanctions lists. This may include people connected to you. As a financial institution we also have a legal obligation to carry out monitoring of activities and communications (e.g. by phone, email and IM). Our legal basis for processing Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us. We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent. |
Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided, or by sending an AGREECONSENT@mbgp.eu email.
If you wish to withdraw your consent at any time, please email us at UNSUBSCRIBE@mbgp.eu .
We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations. We may share your personal data with the following third parties, (including other entities within our group of companies). This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
Auditors, lawyers, accountants and other professional advisers - we share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Please see our “Cookie Policy” on our website www.mbgp.eu for more details on our use of cookies.
The personal data that we collect from you may be transferred to, and processed by, affiliates or service providers outside the UK and the EEA. Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
Where we transfer personal data outside the UK and/or the EEA, we will, where required by applicable law, implement at least one of the safeguards below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.
In respect of personal data that we process in connection with the supply of our Services, we generally retain your personal data for up to seven years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.
Where we process personal data in connection with the registration and use of an account on our Site, we generally retain your personal data for up to seven years from the date that the relevant account is terminated (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability).
Where we process any other personal data, we will retain relevant personal data for up to five years from the date of our last interaction with you (and in compliance with our data protect obligations) or for such period as permitted or required by applicable laws. We may then destroy such files without further notice or liability.
If any personal data is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.
We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who use our Services.
You have a number of legal rights in relationto the personal data that we hold about you. These rights include:
Your questions, comments, requests and concernsshould be addressto our Data Compliance Officer(DCO):
Email: DCO@mbgp.eu
Address: DCO, MBGP, Barbara Strozzilaan 201, 1083HN Amsterdam, the Netherlands
To find out more about your rights or to make a complaint, please contact the Informatie- en Meldpunt Privacy van de Autoriteit Persoonsgegevens (AP) on 088 - 1805 250 or search their website at https://autoriteitpersoonsgegevens.nl/