Sprng Energy Privacy Policies

Sprng Energy Privacy Policy

I. What does this Privacy Notice cover

This notice sets out what personal data we collect, for what purposes and your rights in this respect.

This privacy notice provides you with information on the processing of your personal data when using services and/or purchasing products from Sprng Energy Pvt Ltd in relation to customers, suppliers, business partners, stakeholders and/or investors. For all other interactions with companies within the Shell group please refer to www.shell.com/privacy.html.

We are committed to ensuring the privacy and security of your personal information. This privacy notice explains, amongst other things, what personal data we process, for which purposes we process your personal data, for how long we hold your personal data for; how to access and update your personal data and where to go for further information or to lodge a complaint.

If you would like to receive this Privacy Notice in an alternative format (for example, in larger print) or if you have any questions about our processing of your personal information which are not answered by this notice, please contact us at contact@sprngenergy.com or call us on (+91) 020-67490001.

Sprng Energy Pvt Ltd does not sell your information

We will not sell or otherwise provide your personal information to third parties and will only make it available to third parties involved in the performance of the service agreed with you. Our employees and any third parties utilized by us are contractually obligated to protect the privacy and confidentiality of your information.

II. Special Notice - Processing children’s personal data

If personal data of children is gathered this requires consent of the parent or guardian.

We do not collect personal data of individuals under the age of 16. If you are under 16 years old please do not send us your personal data; for example, your name, address and email address. If you wish to contact us in a way which requires you to submit your personal data (such as for education or innovation events), please get your parent or guardian to do so on your behalf.

III. Who is responsible for any personal data collected

Sprng Energy Pvt Ltd, Magarpatta City, Hadapsar, Pune – 411013, India, will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies.

IV. What personal data do we process -

The categories of personal data we process.

We collect personal data about you as a customer and vendor this may include data that you provide to us in using our services, you may provide us with information, including, without limitation:

  • Private contact information (such as name, postal or e-mail address and phone number) as well as AADHAR No. (social security number), PAN card number, bank account details only if necessary; or
  • Business contact and other information (such as job title, department, name of organization and your dealings with Shell on behalf of yourself or the relevant Business Customer, Supplier and/or Business Partner)

V. Why do we process your personal data?

The personal data covered by this Privacy Notice are only processed:

  • in order to take steps at the request of an individual prior to entering into a contract;
  • where it is necessary to comply with a legal or regulatory obligation to which the relevant Shell company/companies is subject to;
  • where it is necessary for the purposes of the legitimate interests pursued by the relevant Shell company/companies, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual/s; or
  • (only if legally required) with the explicit consent of the individual.

In those cases where processing is based on consent, and subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.

VI. For what purposes do we process your personal data

We only process your personal data where we have a lawful basis and purpose to do so.

We process your personal data for the purposes of:

  • Business execution - including providing, researching, developing and improving products or services; concluding and executing agreements with Business Customers, Suppliers and Business Partners; recording and settling services, products and materials to and from a Shell company; managing relationships and marketing such as maintaining and promoting contact with existing and prospective customers, account management, customer service, and development, execution and analysis of market surveys and marketing strategies;
  • Organisation and management of the business - including financial management, asset management, mergers, demergers, acquisitions and divestitures, implementation of controls, management reporting, analysis, internal audits and investigations;
  • Health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of Shell companies and staff, authentication of individual status and access rights; or
  • Legal and/or regulatory compliance - including compliance with legal or regulatory requirements.

or for a secondary purpose where it is closely related, such as:

  • storing, deleting or anonymizing personal data;
  • fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defense of claims; or
  • statistical, historical or scientific research

Screening

In addition, 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 (pre-contract and on a periodic basis post-contract) on owners, shareholders and directors of our Business customers, Suppliers and Business Partners. This screening takes place against publicly available or government issued sanctions lists and media sources.

The screening does not involve profiling or automated decision making in relation to the counterparties or potential counterparties.

Communication and marketing

You may receive offers on behalf of the relevant Business Customer, Supplier or Business Partner. On all occasions you will be given the opportunity to use the unsubscribe functionality through the different digital channels we use to interact with you.

VI. What are the consequences of not providing your personal data

Personal data gathered by us for these processes either directly or indirectly is required in order to:

  • fulfil legal requirements and/or which is required for entering a contract with a counterparty and continuing to contract with that counterparty
  • maintain contact with business customers, suppliers and business partners and visitors to our website

Failure to provide us with the information required will negatively affect our ability to communicate with you, or our ability to enter a contract with a counterparty or continuing to contract with a counterparty.

VII. Who will we share your personal data with

Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:

  • any company that is a member of our group of companies, which includes our parent company Royal Dutch Shell Plc, where necessary for internal administrative purposes, corporate strategy, auditing and monitoring, sanctions screening and research and development
  • 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
  • we may also share your data within our group of companies to offer you promotions or to inform you about related products and/or services. This is based on your marketing consent preferences and in all cases any marketing material will be sent to you by us only
  • our authorized 3rd party agents, service providers and/or subcontractors on need-to-know basis
  • a competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which we are subject to or as permitted by applicable local law.
  • on request of a party, we can forward your data to such party if such party has a legitimate interest to obtain your personal data. We and the requesting party will conduct a legitimate interest assessment to determine whether and which information is shared

VIII. Transfers of your personal data to other countries

Your personal data may be transferred outside of your country, subject to appropriate safeguards.

Where your personal data is transferred to companies within the Shell group and/or to authorized 3rd party agents service providers and/or subcontractors who may be located in or outside of your location we take organizational, contractual and legal measures to ensure that the personal data is exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard the personal data.

These measures include Binding Corporate Rules for transfers among the Shell Group and European Commission approved transfer mechanisms for transfers to 3rd parties in countries which have not been deemed to provide an adequate level of data protection as well as any additional local legal requirements. You can find a copy of the Shell Binding Corporate Rules at www.shell.com/privacy.html

IX. Security of your personal data

We are committed to safeguarding your personal data.

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use. In particular, we may use encryption for some of our services, we apply authentication and verification processes for access to Shell services and we regularly test, assess and evaluate the effectiveness of our security measures.

X. How long do we hold your personal data for

We will only hold your personal data for a defined period.

With some exceptions which are explained in supplementary privacy statements, any personal data that are required for the purposes of conclusion and execution of agreements with Business Customers, Suppliers and Business Partners or for considering bids or tenders, will be held during the duration of the contractual relationship and up to 15 years after. For agreements which have a term of more than five years and for the purposes set out above, these agreements will be held for 35 years with effect from the commencement of the agreement.

In all other cases for the purposes set out above, including personal data gathered as part of any unsuccessful bids to/by Shell or which relates to the screening against publicly available or government issued sanctions lists and media sources, such personal data are held for no longer than 15 years after it was first gathered.

In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate business purpose to retain it.

XI. Your rights in relation to your personal data

Your rights and how to exercise them.

We aim to keep our information as accurate as possible. You can request:

  • access to your personal data
  • correction or deletion of your personal data (but only where it is no longer required for a legitimate business purpose such as completing a retail transaction)
  • that you no longer receive marketing communications
  • that the processing of your personal data is restricted
  • combining of your personal data from different sources to create a personal profile no longer takes place
  • that you receive personal data that you have provided to us, in a structured, digital form to be transmitted to another party, if this is technically feasible

To make a verifiable rights request please email us at privacy-office-SI@shell.com.

The verifiable request must:

  • provide sufficient information for us to be able to verify you are the person whose personal information we hold or are an authorized agent of that person and that the authorized agent is authorized to make the request on your behalf; and
  • describe your request in enough detail so that we can properly locate the personal information the request or request relate to.

We cannot respond to your request unless we can verify your identity or if you are an authorized agent, your authority to make the request on behalf of the consumer. We will aim to verify your identity based on personal information we already hold about you. If we need to request further information from you in order to verify your identity, we will only use that personal information for the purposes of identifying you or that you have authorized the request.

Note that we may not be able to action a request for deletion if the personal information is required for a lawfully permitted purpose such as completing a transaction for which the personal information was collected or to comply with a legal obligation such as financial reporting. However, the personal information will be deleted once no longer needed for that purpose in line with the time periods set out above

XII. Who to contact if you have a query, concern or complaint about your personal data

If you have any issues, queries or complaints regarding the processing of your personal data, please contact us at: contact@sprngenergy.com or call us on (+91) 020-67490001.

Since we are part of the Shell Group, you may also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, The Netherlands - Trade Register No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague, alternatively you can also email the Shell Group Chief Privacy Office at privacy-office-SI@shell.com

If you are unsatisfied with the handling of your personal data by us, you have the right to lodge a complaint to the Shell Group regulator which is the Dutch Data Protection Authority located at Hoge Nieuwstraat 8, 2514 EL, The Hague, The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.

You also have the right to lodge a complaint to your local data privacy authority/regulator.

XIII. Cookies and similar technologies

We use cookies and similar technologies that collect and store information when you visit our website. This is to enable us to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). You can control and manage your cookies preferences by adjusting your browser settings or using the cookies preference tool.

XIV. Changes to this Privacy Policy

Privacy notices are updated over time.

This Privacy Notice may change over time and you are advised to regularly review this Privacy Notice for possible changes. This notice was last updated in May 2024.

Sprng Energy Recruitment Policy

What does this Privacy Policy cover?

This Privacy Policy provides information about personal data which are processed by Sprng Energy Pvt Ltd (‘Sprng Energy’ or ‘we’) which are part of the Shell group of companies (‘Shell’) in relation to individuals who apply to work for, or who attend a recruitment event or undertake an assessment with Sprng Energy Pvt Ltd. This includes prospective employees, interns and contractors.

For individuals who are successful in their application for employment, internship or engagement as a contractor, the Privacy Policy for Sprng Energy Pvt Ltd Employee, Contractor and Dependents’ Personal Data will be provided during onboarding process.

As well as this Privacy Policy, bespoke privacy Policies and supplementary privacy statements may contain further information about how Sprng Energy Pvt Ltd is processing your personal data. In those instances, such privacy Policies will be communicated to you separately.

This Privacy Policy explains what personal data we process about you, why we are processing your personal data and for which purposes, how long we hold your personal data for, how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.

Who is responsible for any personal data collected?

Sprng Energy Pvt Ltd, Magarpatta City, Hadapsar, Pune – 411013, India, will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies.

Special Policy - if you are under 16 years old and wish to apply for SPRNG ENERGY PVT LTD sponsored education or innovation event

Except in those cases where Sprng Energy Pvt Ltd organises educational events specifically designed for children; we do not intentionally collect personal data of individuals under 16 years old. If you are under 16 years old please do not send us your personal data for example, your name, address and email address. If you wish to contact Sprng Energy Pvt Ltd in a way which requires you to submit your personal data (such as for education or innovation events) please get your parent or guardian to do so on your behalf.

What personal data do we process about you? Collection of information

We process personal information relating to individuals who apply to work for, or who attend a recruitment event and/or undertake an assessment (‘Applicants’).

This may include personal contact information, date of birth, gender, whether you have the legal right to work in the country in which you have applied, your application for employment, your qualifications and experience, results of interviews and assessments.

Sensitive personal data

For the purposes of recruitment, special categories of data (‘sensitive personal data’) including personal data regarding health data may be processed only as strictly required and as permitted or required by local law for the purposes of making adjustments to the recruitment process, for assessing eligibility for positions and fitness to work and provision of facilities in the workplace to accommodate health problems or for the establishment, exercise or defense of claims. 

In addition, in order to ensure equal employment opportunities as permitted or required by local law, we may also gather additional sensitive personal data regarding Applicants, including their nationality, racial and/or ethnic origin.

For what purposes do we process your personal data? How will we use your personal data?

We process your personal data for the following purposes:

  • Human Resources, personnel management, business process execution and internal management - including resource planning, and recruitment;
  • Health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of Sprng Energy Pvt Ltd’s assets and staff, authentication of individual status and access rights;
  • Legal and/or regulatory compliance - including compliance with legal or regulatory requirements; or
  • Management reporting and analysis - including statistical analysis and surveys regarding the quality of the recruitment process.

We may also process your personal data for a secondary purpose where it is closely related, such as:

  • storing, deleting or anonymising your personal data;
  • fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defence of claims; or
  • statistical, historical or scientific research.

Automated decision making and profiling

All applicants must answer questions which are necessary to ensure that individuals can lawfully enter into a contract with a Sprng Energy Pvt Ltd if they are successful in their application. In addition, for graduate hires, we utilize an online assessment tool which scores individuals on their suitability for employment, based on automated decision making to ensure objectivity. In those cases, you will be notified of this and you will have the opportunity to have such automated decisions reviewed by or on behalf of a member of the Sprng Energy Pvt Ltd recruitment team. Save for graduate hires or as specifically notified to you in a bespoke privacy notice or a supplementary privacy statement during the recruitment process, no profiling or automated decision making will take place to determine suitability or eligibility for employment or engagement as a contractor.

Why do we process your personal data?

We only process personal data of Applicants:

  • in order to take steps at the request of the Applicant prior to entering into a contract;
  • where it is necessary to comply with a legal obligation to which Sprng Energy Pvt Ltd is subject to ensure compliance with applicable employment, social security laws and regulations;
  • where it is necessary for the legitimate business interests of Sprng Energy Pvt Ltd (such as ensuring compliance with legal obligations other than those related to employment or social security, the protection of Sprng Energy Pvt Ltd assets, reputation and Sprng Energy Pvt Ltd employees and contractors except where such interests are overridden by the interests or fundamental rights and freedoms of the Applicant; or
  • if legally required, with the explicit consent of the Applicant.

In those cases where processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.

Who will we share the personal data with?

Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:

  • Other companies within the Shell group of companies, including to those which may be located outside of India;
  • Authorised third party agents, service providers, external auditors and/or subcontractors of Sprng Energy Pvt Ltd and in particular authorised third parties who carry out reference and background checks on behalf of Sprng Energy Pvt Ltd;
  • A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which Sprng Energy Pvt Ltd is subject to or as permitted by applicable law; or
  • Any person to whom Sprng Energy Pvt Ltd proposes to transfer any of its rights and/or duties.

Interacting with Sprng Energy Pvt Ltd through social media

If you choose to interact with Sprng Energy Pvt Ltd through social media on a Sprng Energy Pvt Ltd administered social media page (‘Sprng Energy Pvt Ltd Social Media Page’) such as LinkedIn, your personal data (such as your name, your profile picture and the fact that you are interested in Sprng Energy Pvt Ltd) will be visible to all visitors of your personal profile depending on your privacy settings on the relevant social media platform, and will also be visible to Sprng Energy Pvt Ltd. You can delete any data that you shared on these sites at any time through your relevant social media platform’s account. Sprng Energy Pvt Ltd does not track your activity across the different social media sites that you use. Please contact Sprng Energy Pvt Ltd if you wish to make a request that you are unable to action yourself and which relates to a Sprng Energy Pvt Ltd Social Media Page - see the section below Your rights in relation to your personal data.

Additionally, and to the extent Sprng Energy Pvt Ltd is jointly responsible with a social media platform of a Sprng Energy Pvt Ltd Social Media Page, Sprng Energy Pvt Ltd will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on Sprng Energy Pvt Ltd Social Media Pages. For more information on how your personal data are processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.

Transfers of your personal data to other countries

Where your personal data has been transferred to companies within the Shell group and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data. These measures include Binding Corporate Rules for transfers among the Shell group of companies which you can access here.

Security of your personal data: how will we hold your personal data?

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.

How long do you hold my personal data for?

We hold personal data of unsuccessful Applicants for at least six (6) months but no longer than three (3) years after the recruitment process or assessment has been completed unless there is a lawful reason to retain it for longer, in which cases it will be deleted once no longer needed for that purpose (for example to defend any claims).

If you are successful in your application, the personal data gathered through the recruitment process will be retained in line with the Privacy Policy - Employee, Contractor and Dependents’ Personal Data which will be provided to you during the onboarding process.

What are the consequences of not providing your data?

Personal data requested and provided by Applicants are required in order to fulfil legal requirements and/or which is required for entering into a contract with you (or in the case of a contractor your employer/service provider). Failure to provide us with the information requested which is limited to that required for these purposes will negatively affect your chances of being selected for any potential employment, engagement or internship.

Your rights in relation to your personal data

We aim to keep our information as accurate as possible. You can request:

  • access to your personal data
  • correction or deletion of your personal data (but only where it is no longer required for a legitimate business purpose such as completing a retail transaction)
  • that you no longer receive marketing communications
  • that the processing of your personal data is restricted
  • combining of your personal data from different sources to create a personal profile no longer takes place
  • that you receive personal data that you have provided to us, in a structured, digital form to be transmitted to another party, if this is technically feasible

To make a verifiable rights request please email us at privacy-office-SI@shell.com.

Who can you contact if you have a query, concern, complaint, about your personal data?

If you have any issues, queries or complaints regarding the processing of your personal data, please contact us at: contact@sprngenergy.com or call us on (+91) 020-67490001.

You may also contact the Shell Group Chief Privacy Officer at Privacy-Office-SI@shell.com or Shell International B.V. The Hague, The Netherlands - Trade Register, No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague.

Without prejudice to any rights, you may have in line with local law you have the right to lodge a complaint with the Dutch Data Protection Authority whose address is Prins Clauslaan 60, 2595 AJ The Hague, The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information

Cookies and similar technologies

Sprng Energy Pvt Ltd may use cookies and similar technologies that aim to collect and store information when you visit an Sprng Energy Pvt Ltd website. This is to enable Sprng Energy Pvt Ltd to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). We also use cookies to personalise and enhance your experience on our site and improve the delivery of ads to you.

Changes to this Privacy Policy

This Privacy Policy may be changed over time. You are advised to regularly review this Privacy Policy for possible changes. This Privacy Policy was last updated in October 2024.