Doosan Data Protection Policy : Doosan Babcock
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Doosan Data Protection Policy

Doosan Babcock is committed to protecting your privacy. This data protection policy (hereinafter: “Privacy Policy”) governs the processing of your personal data as part of your visit to our website http://www.doosanbabcock.com (hereinafter: “Website”), ), your communication with us via e-mail telephone, and social media (hereinafter: “Social Media Channels”; e.g. Facebook, LinkedIn and Twitter,).

NOTE 1: This Privacy Policy does not apply to the processing of personal data of people who choose to apply via our online job application platform. The processing of personal data via the job application platform is governed by a separate data privacy statement.

NOTE 2: If you want information on how we process personal data via cookies, social plug-ins, pixels and other types of tracking technology, you are kindly referred to our Cookie Policy

1. In general

1.1. Your personal data are processed by Doosan Babcock Ltd, Doosan House, Crawley Business Quarter, Manor Royal, Crawley, West Sussex, RH10 9AD, Registered as 839354 (hereinafter: “Doosan”, “we”, “us”, “our”). You can contact us via e-mail at db.info@doosan.com.

1.2. Any notion starting with a capital shall be defined by explicit reference in this Privacy Policy. Where possible given the context, singular words shall be interpreted as also including the plural and vice versa.

1.3. Where reference is made to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.

1.4. Doosan reserves the right to modify, change or amend the Privacy Policy at our own discretion and from time to time. Such modification, change or amendment shall be communicated via the Website. If you do not accept the modifications, changes or amendments, you are to inform us by sending an e-mail to db.info@doosan.com. If we do not receive such an e-mail from you within three (3) business days after the changes to the Privacy Policy have been announced on our Website, you will be deemed to have accepted unambiguously all such changes.

2. Types of personal data we process

2.1. Whenever you use our Website or Social Media Channels, we collect:

  • Technical information associated with the device you use, such as your IP address, browser type, geographical location and operating system;
  • Information concerning your browsing behaviour, such as how long you visit, what links you click on, what pages you visit and how many times you visit a page.

2.2. When you contact us via e-mail, telephone, or Social Media Channels, we collect:

  • The basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the company you work for, your function;
  • The content of your communication and the technical details of the communication itself, such as with whom you correspond at our end, and the date and time;
  • Any other personal data you choose to provide us with.

3. Purposes for processing

3.1. We process your personal data to provide you in a personalised and efficient way with the information, products and services you request via the Website, e-mail, telephone, and Social Media Channels.

3.2. We process your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of Doosan.

3.3. We process your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.

Your personal data may be transferred upon Doosan’s own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, our Social Media Channels or other communication with us.

3.4. We may process your personal data for the preservation of the legitimate interests of Doosan, use of the Website, Social Media Channels or other communication channels can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website, Social Media Channels or other communication channels, (c) a danger to the Website, Social Media Channels or other communication channels or any of Doosan’s or our subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

4. Legal basis for processing your personal data

4.1. The processing of your personal data for the purposes outlined in clause 3.3 is necessary to allow Doosan to comply with our legal obligations.

4.2. The processing of your personal data for the purposes outlined in clauses 3.1, and 3.4 is necessary for the purpose of the legitimate interests of Doosan, which are:

  • Continuous improvements to Doosan’s Website, Social Media Channels, products and services to ensure that you have the best experience possible;
  • Keeping our Website, Social Media Channels, products and services safe from misuse and illegal activity;
  • Marketing and promotion of our products, services, brands and overall successful commercialisation of our products and services.

5. Recipients

5.1. We do not send your personal data in an identifiable manner to any third party without your explicit permission to do so. You understand, however, that if you use our Social Media Channels, your personal data is also processed by the social media providers.

5.2. We rely on third party processors to provide you the Website as well as to process your personal data on our behalf. These third party processors are only allowed to process your personal data on behalf of Doosan upon explicit written instruction of Doosan. Doosan warrants that all third party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.

5.3. We may share your personal data with other entities within the Doosan group of companies. However, we will ensure that all Doosan group entities will take due care that all processing of your personal data is in line with what is set out in this Privacy Policy.

6. Location and transfer

6.1. We process your personal data first and foremost within the EEA. However, in order to process your personal data for the purposes outlined in clause 3 above, we may also transfer your personal data to other entities within the Doosan group or to third parties who process on our behalf which are located outside the EEA. Each entity outside the EEA that processes your personal data shall be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards will be the consequence of:

  • The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
  • A contractual arrangement between Doosan and that entity. All Doosan entities are parties to a contractual arrangement based on the EC’s Standard Contractual Clauses (controller-to-controller) (Commission Decision C (2004)5721.

6.2. We may transfer anonymised and/or aggregated data to organisations outside of the EEA. Should such transfer take place, Doosan will ensure that there are safeguards in place to ensure the safety and integrity of your data as well as all rights with respect to personal data you might enjoy under applicable mandatory law.

7. Quality assurances

7.1. We do our utmost best to process only those personal data which are necessary to achieve the purposes listed under clause 3.

7.2. Your personal data are only processed for as long as needed to achieve the purposes listed under clause 3 of this Privacy Policy or up until such time where you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer use the whole or part of the Website, Social Media Channels and other communication channels. We will de-identify your personal data when they are no longer necessary for the purposes outlined in clause 3, unless there is:

  • An overriding interest of Doosan, or any other third party in keeping your personal data identifiable;
  • A legal or regulatory obligation or a judicial or administrative order that prevents Doosan from de-identifying them.

7.3. You understand that an essential aspect of our marketing efforts pertains to making our marketing materials more relevant to you. This means that we build a profile of you based on relevant characteristics as outlined in clause 2.

7.4. We will take the appropriate technical and organisational measures to keep your personal data safe from unauthorised access or theft as well as accidental loss, tampering or destruction. Access by personnel of Doosan or our third party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only which can never be guaranteed.

8. Your rights

8.1. You have the right to request access to all personal data processed by us pertaining to you. We reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to Doosan.

8.2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.

8.3. You have the right to withdraw your earlier given consent for processing your personal data, in which case clause 8.4 will apply.

8.4. You have the right to request that personal data pertaining to you be deleted if they are no longer required in light of the purposes outlined in clause 3 or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by Doosan against:

  • Overriding interests of Doosan;
  • Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

Instead of deletion you can also ask that we limit the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes listed under clause 3 but you need them to defend yourself in judicial proceedings.

8.5. You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with this particular circumstance that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.

8.6. You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.

8.7. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to hrss@doosan.com. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your proof of identification e.g. passport, driving license etc. If you use the contact form, we may ask you for your signed confirmation and proof of identity.

We will promptly inform you of having received this request. If the request proves valid, we shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request.

If you have any complaint regarding the processing of your personal data by us, you may always contact our Data Protection Officer (andy.stephenson@doosan.com). If you remain unsatisfied with our response, you are free to file a complaint with the Information Commissioners Office – www.ico.org.uk.

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