Privacy Policy

SA Energy Limited Privacy Policy last updated in June 2022.

INTRODUCTION

This policy describes the information privacy practices that SA Energy Limited (SA Energy, “we”, “us”, or “our”, if not explicitly referring to the company) follow when handling personal information that we collect or receive in conducting our business, including through our services, products, websites, employee(s) and user application(s).

This privacy policy demonstrates our commitment to protect the privacy of individuals with respect to personal information and is designed to assist you in understanding our policies and practices in relation to the collection, use, retention, transfer and access of personal information.

Definition of personal information

Personal Information means any information relating to an identified or identifiable natural person (known as the data subject). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location information, an online identifier or by one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of the natural person. Personal information does not include information that is truly anonymised, i.e. where the data subject is no longer identifiable. Personal information also does not include corporate information that relates to an organisation but not to an individual, such as a corporate name, corporate address or general corporate phone number.

Who is this Privacy Policy for?

Our employees, contractors or consultants who are our agents or working on our behalf or in our name, through outsourcing of services, products, processes or any business activity, will be required to act consistently with this Privacy Policy on our behalf. Independent contractors or consultants will be made aware of the Privacy Policy as it applies to our staff, potential and/or existing customers and counterparties in their dealings with them. Joint Venture companies not under our control are encouraged by SA Energy to adopt similar privacy practices and standards in accordance with various in-country data protection law(s).

SA Energy Limited Data Privacy Contact Information

We are committed to responding to and resolving questions, requests and/or complaints about your personal information and our collection or processing of your personal information. If you believe that we are not complying with the terms of this Privacy Policy or other legal requirements, you should first contact us at the address below, or you may direct your concerns via email to info@saenergypetroleumgh.com. We will investigate and will do our best to resolve any complaints or disputes you bring to our attention regarding the use and disclosure of your personal information.

The data controller of your personal information is SA Energy Limited, 1st Floor, PwC Tower, Rangoon Lane Cantonments – Accra.

COLLECTION OF PERSONAL INFORMATION

Personal information you provide to us

We collect personal information that you provide to us through our websites, and in connection with business dealings we may have with you, and/or where we are legally obliged to as part of a contractual agreement. This includes information that you may provide to us in employment contracts, applications for employment, service agreements, KYC processes, any loyalty or payment card applications as well as competition entries and events.

The personal information you provide includes basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address. It may also include information on the products or services you have shown interest in and/or purchased from us. If you use a payment card (debit and/or credit card) to purchase a product or service from us, we also may collect information necessary to process the card transaction, such as the card type, number, expiration date and any other information required to process your request.

We may collect information you provide to us through recruitment processes such as name, date of birth, gender, age, contact information, identification / passport / social security number, professional and educational history. We may also collect and retain background check information as permitted by applicable law and our KYC policy.

Website information you provide to us.

For your information, Cookies are small pieces of data that can be stored in users’ hardware for the purposes of obtaining configuration information and analysing users’ viewing habits. They are commonly used to track users’ preferences in relation to the subject matter of the website and make users’ online experience easier and more personalised. Please review our website Cookies Policy for further information on our use of cookies.

Our website consists of various contact request forms in which you will willingly submit your contact details, such as name, surname, and email address, company, country location. This information is considered as personal information and will be treated as personal information in accordance with this Privacy Policy.

This website usage can be anonymous information. However, if it is combined with your personal information in a manner that reasonably allows it to be associated with your identity, or is otherwise considered personal information under applicable law, it will be treated as personal information in accordance with this Privacy Policy.

Information we may receive from our counterparties

We may receive personal information about you from our counterparties who may recommend or suggest that we contact you for business purposes. This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address. It may also include information on the products or services you have shown interest in or may be interested in purchasing from us, as well as information on other companies or individuals with whom you do business with. We may also obtain personal information about you from our counterparties in connection with business transactions you initiate with us, such as through credit verification or other processes related to the transaction.

We do not knowingly collect or use any personal information from children younger than the age of sixteen (16), or from children, who do not have the necessary ability to foresee the consequence of their personal information being processed without obtaining the appropriate consent, as required by applicable law.

USE OF PERSONAL INFORMATION

For business use

We use your personal information to facilitate our ongoing and proposed business dealings with you. This includes:

• To process business transactions with us;
• To establish and maintain counterparty (includes customer(s)) accounts so that we may provide products or services of ours requested by you or your company;
• To register you as a user of these products or services so that you may access them through our websites (includes any web portals), operational site(s) or otherwise;
• To communicate with you about updates, maintenance, outages or other technical matters concerning these products or services;
• To provide you with training regarding usage of these products or services;
• To notify you about changes to any of the policies and procedures for use of these products or services;
• To verify the accuracy of account and technical contact information we have on file for you and your company in relation to these products or services; and
• To respond to questions or inquiries that you or your company may have about our products or services.

We may use your personal information as required for us to comply with relevant laws and regulations relating to the products or services that we provide in any of the jurisdictions in which we or our affiliated operating units operate.

Marketing Purposes

With your consent or as otherwise permitted by applicable law, we may use your personal information for purposes relating to the marketing of our products and services, or those of our business partners where you may have shown interest in. This means we may from time to time:

• Send you newsletters, press releases, event announcements and other similar communications regarding the products or services that we offer;
• Market or promote our products or services to you, including by offering you trial or limited access to certain of our products or services;
• Solicit input from you regarding improvement of our products or services;
• Inform you of third-party offerings that we think you or your company may be interested in which relate to our products or services;
• Send you announcements or requests on behalf of other customers of ours who believe you would benefit from use of our products or services; and
• Use your personal information for other purposes that we disclose to you at the time we obtain your consent.

If you no longer wish to receive this type of communication from us, you may opt-out at any time by contacting our offices directly in your country of operation, alternatively you may email us at info@saenergypetroleumgh.com.

Automated decision making/profiling

We use software to help us better understand how you like us to communicate with you and whether you may be interested in our products and services. For example, based on our records that you recently showed interest in a certain product, our software helps us identify related products and services that may interest you. We may then use this to contact you about these by post, telephone, SMS text messaging or email. If you no longer wish to receive this type of communication from us, you can contact us at info@saenergypetroleumgh.com.

Referrals

From time to time, we may receive personal information about you from counterparties who recommend or suggest that we contact you for business purposes. We may receive such personal information because you have consented to the relevant counterparty that they might share your personal information with businesses for these purposes. If we use that information to contact you, it will only be to see if you are interested in our products or services, or those of our business partners. We will not use this information for other purposes without your consent. In addition, if you inform us that you are not interested in these products or services, we will stop using the information to contact you.

Data Integrity

You are responsible for the accuracy of all personal information that you provide to us. We will use reasonable efforts to maintain the accuracy and integrity of your personal information, and to update that information as appropriate. We will take reasonable steps to ensure that the personal information we collect from you is relevant to its intended use, and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorised by you.

Recruitment

We may use your personal information you provide to us through job applications, using our online website, email or via fax solely for the purposes of processing your job application for the position you have shown interest in, in accordance with this privacy notice and applicable law. This may also include data we collect from third parties such as professional recruiting firms, your references, prior employers and educational history in order to identify and evaluate candidates for potential employment. We may conduct vetting for specific job roles, which may include criminal background checks and credit checks, as permitted by local laws. We may retain a record of your job application and references for a period of time, in order to ensure compliance with legal requirements. If you do not wish for us to retain a copy of your job application, you may opt-out at any time by emailing, info@saenergypetroleumgh.com.

INFORMATION SHARING

Internal within SA Energy Limited

SA Energy is a company that transacts business internationally. From time to time we may share your personal information within SA Energy and its subsidiaries. Such information may be used by each entity for internal business, operational and investigation purposes, as well as for purposes consistent with the purpose for which the information was originally collected or subsequently authorised by you.

The personal information that we collect from you may be transferred to, and stored at, a destination outside of the country where the personal information was collected. It may also be processed by members of staff operating outside of the country where the personal information was collected who work for us or one of our service providers.

External…outside of SA Energy Limited

We may disclose and transfer your personal information in connection with a corporate merger, consolidation, restructuring, the sale of stock or assets, or other corporate change, including, without limitation, during the course of any due diligence process. In all such cases, this Privacy Policy will continue to govern the use and disclosure of such information.

We will not share your personal information with third parties outside of SA Energy for their marketing purposes without your consent. However, we may share such information with our counterparties as described for the purposes disclosed to you at the time you provided the information, or as subsequently authorised by you or as permitted by applicable laws. From time to time, we also may offer you the option of sharing your personal information with third parties in order to receive information and/or marketing offers from them or other persons. If you consent to the sharing of your personal information for these purposes, it will be subject to the privacy policies and business practices of those third parties. If you later decide that you no longer want us to share personal information with such third parties, please contact us at info@saenergypetroleumgh.com.

We may offer various promotions / competitions through our operational sites, websites or elsewhere that may require registration with your personal information. If you choose to enter or otherwise participate in a promotion / competition, your personal information may be disclosed to third parties in connection with administration of the promotion / competition, such as in connection with winner selection, prize fulfilment and as otherwise required by law. By entering into a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. These rules will be displayed to you during the registration process, and you will be asked for your consent to the respective data processing at that time.

We may from time to time employ service providers to perform services on our behalf, such as hosting our data (including your personal information), websites, products and other applications; sending emails and other communications relating to our products and/or services; fulfilling and processing orders for our products or services; assisting with promotions and conferences relating to our products or services, or those of our business partners; providing analytic services, such as in relation to the tracking of usage of our operational sites or websites; or performing other administrative services for us. Prior to allowing these service providers to access your personal information, we will enter into a formal agreement with them to ensure that they handle and process the information in accordance with this Privacy Policy and applicable law and ensure they have adequate technical and organisational controls in place to safeguard your personal data.

Legal Protections and Law Enforcement

We may access, use, preserve, transfer and disclose to our counterparties your personal information for the following purposes:

• To satisfy any applicable law, regulation, subpoena, or legal or regulatory process, if in our opinion such is required or permitted by law or reasonably requested by a regulatory authority (including any listing authority or stock exchange);
• To protect and/or defend this Privacy Policy or other SA Energy policies or terms of use applicable, including investigations of potential violations thereof, ensuring the protection of the safety, rights, property or security of SA Energy or any of our counterparties;
• To detect, prevent or otherwise address fraud, security issues or breaches, or technical issues. This may include allowing third parties, such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, to access and use your personal information in order to identify you. We may take any of these steps without notice to you to the extent permitted by law.

Your additional rights

As a data subject, you have rights regarding the processing of your personal information, including rights to, in certain circumstances:

• Withdraw any consent you have given, or are deemed to have given, in relation to our collection or use of your personal information;
• Request access to any personal information held about you by us and details of the processing of your personal information by us;
• Have inaccurate personal information amended or erased, and to have incomplete personal information completed;
• Request the erasure of your personal information;
• Object to or restrict the processing of your personal information (including profiling), including where the processing is unlawful or no longer necessary;
• Receive your personal information in a format suitable for transmission to another data controller;
• Object to processing of your personal information for direct marketing. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information. You can also exercise the right at any time by contacting us at info@saenergypetroleumgh.com.
• Prevent processing that is likely to cause unwarranted substantial damage or distress to yourself or anyone else;
• Object to any decision about you based solely on automated processing (including any profiling) that produces legal effects or otherwise significantly affects you; and
• Complain to the relevant data protection supervisory authority, if you think that we are not complying with our obligations in relation to our processing of your personal information.

You can make a request to us in relation to these rights at any time by contacting us via email at info@saenergypetroleumgh.com. All requests will be dealt with promptly and any information to which you are entitled will be provided within a reasonable timeframe, subject to the exemptions stipulated in applicable data privacy laws.

DATA PROTECTION

Data Security

We will take appropriate security measures to protect your personal information in our possession from loss, misuse, and unauthorised access, disclosure, alteration or destruction. We will make reasonable efforts to keep your personal information reliable for its intended use, accurate, up to date and complete. As necessary, we will take additional precautions regarding the security of particularly sensitive information, such as payment card information and categories of data deemed as sensitive under Ghana’s data protection laws. While we strive to secure your personal information, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control.

Data retention

We will not retain personal information for longer than is necessary for the purposes for which it was collected, except where retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

Enforcement

We will conduct periodic internal compliance audits and assessments of our relevant privacy practices to verify adherence to this Privacy Policy. We encourage you to raise any questions or concerns that you may have about the way we process your personal information by contacting us at info@saenergypetroleumgh.com.

POLICY CHANGES

We reserve the right to update this Privacy Policy at any time, without prior notice to you, to the extent permitted by applicable law. We will notify the changes that we make to this Privacy Policy by posting the revised Privacy Policy on our websites, and such changes will be effective immediately unless otherwise stated.