Welcome to Connector Subsea Solutions (CSS) privacy notice.

CSS respects your privacy and is committed to protecting your personal data.

This privacy notice will inform you how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you.

We are committed to ensuring that your privacy is protected, in accordance with the General Data Protection Regulation (GDPR). Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy policy.

We may change this policy at any time by updating this page. This version was last updated on 22 March 2021. You should check this page occasionally to ensure that you are happy with any changes.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely

Purpose of this Privacy Notice

This privacy notice aims to give you information on how CSS collects and processed your personal data through your use of this website, including any data you might provide when you sign up to our newsletter, register for an event or enquiry form.

This website is not intended for children and we do not knowingly collect data relating to children.

Connector Subsea Solutions (CSS) is the controller and is responsible for your personal data. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact CSS by sending an email to: GDPR@connectorsubsea.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

It is important that the personal data we hold about you is correct and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name and title.
• Contact Data includes email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have to are trying to enter into with you.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • register for an event
  • subscribe to our service or publications;
  • send an enquiry through our website
  • request information to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU;
    • advertising networks such as LinkedIn based inside OR outside the EU; and
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

What we do with the information we gather

Our website incorporates privacy controls which affect how we will process your personal data. Any personally identifiable information we may collect is required to understand your needs and provide you with a better service.

We only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• We need to perform a contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending direct marketing communications to you via email, phone, fax or mail. You have the right to withdraw consent to marketing at any time by emailing us at GDPR@connectorsubsea.com

We do not share your information with other organisations other than as detailed in this policy. If we ever decide to do so, we will let you know, and you will have the option to say no.

We may disclose information about you if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at, GDPR@connectorsubsea.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you.
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);	(c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Profile (b) Usage (c) Marketing and Communications (d) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, to inform our marketing strategy, to optimise customer experience, to ensure customers are kept up-to-date with the latest products and services to improve their business)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, to inform our marketing strategy to optimise customer experience, to ensure customers are kept up-to-date with the latest products and services to improve their business).
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business, to optimise customer experience, to ensure customers are kept up-to-date with the latest products and services to improve their business).

Marketing

We may use the information to improve our products and services and may periodically send promotional emails once we receive your consent about new products or services, special offers or other information, which we think you may find interesting using the email address which you have provided.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

• You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you have provided us with your details when you have registered for an event or made an enquiry to CSS and in each case, you have not opted out of receiving that marketing.

When we receive your express opt-in consent you also consent to us sharing your personal data with the Internal and External Third Parties set out in the Glossary. We will ensure that your personal data is only use by such Third Parties for processing and will not be stored by the Third Party for their use.

You can ask us to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purpose of satisfying any legal accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the protection risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, you can ask us to delete your data (please see below) and in some circumstances, we may anonymise your personal data (so it can be no longer associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Security

We are committed to ensuring as far as is reasonably within our control that your information is secure. In order to minimise the risk of any potential unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. In addition, we limit access to your personal data to those employees, agents, contractors and third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the Internet or through satellite or other communication methods is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is ultimately at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of breach where we are legally required to do so.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our website, you should note that we do not have any control over any other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the website in question.

International Transfers

We share your personal data within the CSS Group. This may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your person data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring the following safeguard is implemented:

• We will only transfer your personal your personal data to countries that have been deemed to provide any adequate level of protection for personal data by the European Commission.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA.

Controlling your personal information

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at GDPR@connectorsubsea.com. If you wish to access or amend any personal data we hold about you, or to request that we delete any information about that that we have obtained through our services you may do so by writing to the address below.

You may decline to share certain personal data with us, in which case we may not be able to provide to you some of the features and functionality of our services.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data (more information can be found in the Glossary):

• Request to access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of the other rights). This a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

General Information of Joint Controllers on The Processing of Personal Data (In Accordance With Article 13 Of The General Data Protection Regulation)

Introduction

Regulation (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter: the General Data Protection Regulation) contains a set of rules to ensure that the processing of personal data is carried out in accordance with human rights and fundamental freedoms, and national laws implementing the General Data Protection Regulation. In accordance with Article 26 of the General Data Protection Regulation, as joint controllers, we inform you about the jointly determined purposes and methods of processing your personal data. With this document of the General Information of the Joint controllers, we also acquaint you with the agreed individual roles and mutual relations of the joint controllers in relation to you as a respondent. As a respondent, regardless of the agreement reached by the joint controllers, you can exercise your rights under the General Data Protection Regulation in relation to each controller individually, as well as against each of them.

I. Data on Joint Controllers

Your data for the purposes of point III. this Information is processed by:

• CONNECTOR SUBSEA SOLUTIONS AS, Kokstadflaten 17, 5257 Kokstad, Kingdom of Norway, Registration number: 984 609 701;

• CONNECTOR SUBSEA d.o.o., Split, Kopilica 5 / A, Republic of Croatia, OIB: 26148476955;

• CONNECTOR SUBSEA SOLUTIONS (UK) Ltd, Airport House Suite 43-45, Purley Way Croydon Surrey CR 0XZ, United Kingdom, Registration Number: 10973101;

• CSS ISOTEK LIMITED, Unit 9 Clayton Wood Bank, West Park Ring Road, Leeds, West Yorkshire, LS16 6QZ, United Kingdom, Registration Number: 07176384;

• CONNECTOR SUBSEA BOSNIA d.o.o., Ulica Inžinjerske brigade br. 6., prvi sprat, lamela 1, 75000 Tuzla, Bosnia and Herzegovina, Registration number: JIB 4210373970009

II. Contact for Data Protection

For information related to the processing of your data, you can contact us by e-mail at GDPR@connectorsubsea.com

III. Purposes, Legal Basis of Processing and Categories of Personal Data

With this information, the joint controllers agree to inform you about the next common purpose of the processing of your personal data, which is employment with any joint controller. Joint controller may process your personal data to assess skills, qualifications and suitability for work, and to verify references, where applicable. Namely, the goal of joint data processing is that each joint controller has access to the CVs of potential candidates from all countries in which they operate, to hire the best candidate or to offer candidates employment options in more countries, on the consent of the respondent as a legal basis under Article 6 (1) (a) of the General Data Protection Regulation. The delivery of the application and / or curriculum vitae is considered an act of consent, provided that such data are processed no later than 60 days from delivery. In case the candidate wants to leave their data in the database for a longer period, they have the option of giving consent for the data to be stored for 2 years. Joint controllers process your personal data, namely: name and surname, address, contact number, e-mail, personal identification number, gender, day, month and year of birth, citizenship, residence, professional education, special exams and courses that are a condition for doing the job, information about previous work experiences, photography, and other information that is listed in the resume and / or application.

IV. Categories of Recipients of Your Personal Data

Your personal data will not be passed on to any third parties, it will only be used by joint controllers. If an external company is hired for the purpose of conducting the evaluation of candidates for a particular job, they may also process your personal data for the purpose of evaluation for employment.

V. Transfer of Personal Data To Third Countries or International Organizations

For the joint controller whose headquarters are outside the European Union, namely CONNECTOR SUBSEA BOSNIA d.o.o personal data are processed by the controller based in the European Union, namely CONNECTOR SUBSEA d.o.o., Croatia, except when citizens of Bosnia and Herzegovina submit personal data to the joint controller CONNECTOR SUBSEA BOSNIA d.o.o., as such delivery is not subject to the GDPR. The transfer is made to the United Kingdom as a third country with an adequate level of protection.

VI. Personal Data Retention Period

The joint controller will process all your personal data as a job candidate from the job application and submitted applications and / or CVs for a maximum of 30 days from the end of the acceptance period for specific vacancies or 60 days from the date of submission of an open application if a vacancy is not advertised. The vacancy is completed by hiring a candidate. If you have given your consent for your data to be kept in our database for a longer period, we keep your data, application, and CV for a maximum of 2 years from the date of granting the consent, or until the withdrawal of the consent.

VII. Rights of Respondents

At any time, you may exercise your rights under Article 13 (2) (b) of the General Data Protection Regulation from the joint controllers and / or from each individual controller, as follows:

1. Right to access data;

2. Right to correction;

3. The right to erase (the “right to be forgotten”);

4. The right to limit processing;

5. The right to data transfer;

6. Right to object

As a respondent, regardless of the agreement reached by the joint controllers, you can exercise your rights under the General Data Protection Regulation in relation to each controller individually, as well as against each of them.

You can exercise your rights regarding the processing of your personal data by sending an email to GDPR@connectorsubsea.com

You may withdraw your consent to the processing of your personal data at any time, without prejudice to the lawfulness of the processing based on the consent before it is withdrawn. Joint controllers do not implement automated decision making, including profiling. You can lodge a complaint with any supervisory authority at any time.

Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal third parties

Other companies in the CSS Group acting as joint controllers or processors and who are based in UK, Norway, Bosnia, Brazil and Croatia and provide IT and system administration services and undertake leadership reporting.

External third parties

• Professional advisers including lawyers, bankers, auditors and insurers based UK, Norway, Brazil and Croatia who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK, Norway, Brazil and Croatia who require reporting of processing activities in certain circumstances.
• Marketing, research or fulfilment agencies where it is necessary to process your data on our behalf to provide you with information or a service.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your cons

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.