Notice for RUBiS Energy Bermuda

Rubis Energy Bermuda Ltd. ("RUBiS") values your privacy and is committed to protecting your personal data. This Privacy Notice outlines how we handle your data in compliance with Bermuda's Personal Information Protection Act (PIPA).

1. Who Does This Privacy Notice Apply To?

This notice applies to:

• Customers and prospective customers of RUBiS
• Visitors to RUBiS websites or those contacting RUBiS

2. Information About RUBiS

Rubis Energy Bermuda Ltd. is located at:

• Main Office and Depot: Ferry Reach, St. George's

For privacy concerns, contact our Privacy Officer:

• Andrew Griffith
• Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
• Phone: +1 441 299 7034

3. What Personal Data Do We Collect and How?

We collect personal data through our website, forms, in-person interactions, and telephone conversations. This includes:

Basic Information:

• Contact details (names, email addresses, phone numbers, mailing addresses)
• Transaction information (purchase history, service preferences, payment details)
• Digital information (IP addresses, browser types, website interactions)

Sensitive Personal Information:

• We do not collect sensitive personal information such as health data, religious beliefs, or racial origin unless required by law or with your explicit consent.

Children's Data:

• We do not knowingly collect data from children under 14 without parental consent
• If we learn we have collected such data, we will take steps to delete it promptly

4. How and Why We Use Your Data

We process your data under the following legal bases:

Contractual Necessity:

• Providing and delivering petroleum products and services
• Processing payments and maintaining accounts

Legitimate Interests:

• Improving our products and services
• Analyzing website performance and user experience
• Preventing fraud and ensuring security

Legal Obligations:

• Complying with regulatory requirements
• Maintaining required business records

Consent:

• Sending marketing communications (which you can opt out of at any time)
• Using non-essential cookies on our website

5. International Data Transfers

Some of your personal data may be transferred to and stored in countries outside Bermuda for the purposes described above. When we do this, we ensure appropriate safeguards are in place, including:

• Data transfer agreements incorporating standard data protection clauses
• Verification that recipients have adequate data protection measures in place

6. Sharing Data With Third Parties

We share personal data with:

• Financial institutions for payment processing
• Logistics providers for product delivery
• IT service providers for system maintenance and security

All third parties are bound by contracts requiring them to:

• Use your data solely for authorized purposes
• Implement appropriate security measures
• Delete or return data when our agreement ends

7. Individual Rights and Timeframes

Under PIPA, you have several rights which we will respond to within 45 days:

• Access: Obtain a copy of your personal data
• Correction: Request corrections to inaccurate data
• Erasure: Request deletion of your data when no longer needed
• Objection: Object to processing, including marketing
• Restriction: Limit data processing in certain circumstances

To exercise these rights, contact our Privacy Officer. If you're unsatisfied with our response, you can complain to the Bermuda Privacy Commissioner at This email address is being protected from spambots. You need JavaScript enabled to view it. or +1 441 543 7748.

8. Retention Periods

We retain personal data based on these criteria:

• Active customer records: Throughout the business relationship plus 2 years
• Financial records: 7 years (legal requirement)
• Marketing data: Until you opt out or 2 years of inactivity

9. Security Practices

We protect your data through:

• Encryption of digital records
• Access controls and authentication
• Regular security assessments
• Staff training on data protection
• Secure physical storage

10. Automated Decision-Making

We do not make automated decisions (including profiling) that have legal or similar significant effects on you.

11. Cookies and Online Privacy

Our website uses:

• Essential cookies: Required for website operation
• Analytics cookies: To understand user behavior (with consent)
• Marketing cookies: For targeted advertising (with consent)

Manage cookie preferences through our cookie banner or browser settings.

12. Data Breach Management

If a breach occurs that risks your rights, we will:

• Notify affected individuals within 72 hours where feasible
• Inform the Privacy Commissioner
• Provide recommendations to protect your interests

13. Changes to This Notice

We review this notice regularly and will post updates on our website. Material changes will be notified to customers directly where possible.

Last Updated: December 2024

For questions about this notice or to exercise your privacy rights, please contact our Privacy Officer using the details in Section 2.