What does this privacy notice cover?
This privacy notice provides information regarding the processing of your personal data when using services and/or purchasing products from or on behalf of a company or companies within the Shell group of companies (“Shell” or “we”) whether as:
- a retail customer;
- a member of a Shell loyalty programme (like Shell Bonus Card or “Shell Loyalty Programme”);
- a visitor to a Shell website (“Website” or “Shell Website”); and/or
- a user of the Shell Application or other Shell applications (“Shell Apps”).
If you choose to do so, a personal profile will be created for you to use and navigate across these Shell services (‘Single Sign On’). As well as this notice, supplementary notices may contain further information to reflect local practices and applicable legal requirements and contains further contact details regarding the processing of personal data by Shell.
This privacy notice explains what personal data is processed, for which purposes, how long we hold the personal data for, how to access and update your personal data, the options you have regarding your personal data and where to go for further information.
Special Notice – if you are under 18 years old.
Processing minors personal data. Shell does not intentionally collect personal data of those under 18 years’ old. If you are under 18 years’ old please do not send us your personal data (for example, your name, address and email address). If you are under 18 years’ old and you wish to ask a question or use the Shell Website and/or a Shell App in anyway which requires you to submit your personal data please get your parent or guardian to do so on your behalf.
What personal data do we process? Collection of information
We collect information, including personal data about you, as a Shell customer, user of Shell Apps and/or visitor to a Shell website. This information may be either:
- Information that you provide to us– when creating a Shell account profile, we will ask for your name, e-mail address and gender (so that we can address you properly but you do not have to provide us with this information), your contact preferences and information necessary for answering any security questions. If you decide to become a member of a Shell loyalty program, a user of Shell Apps, Shell Drive services or our mobile payments, we may ask you to provide further personal data necessary for the performance of such services and/or authentication such as type of vehicle, driver pattern, date of birth (if collected), communications preferences and mobile number.
- Information that we obtain through your use of Shell services - we will also collect information about how and where you use or purchase Shell services and products. Such information may include electronic device information, IP addresses, log information, browser type and preferences, location information, online identifiers to enable ‘cookies’ and similar technologies. Your purchase history includes data regarding (i) specific products you buy, (ii) the total amount of your purchases per transaction, (iii) the time and place of the purchases you make and (iv) the payment method you use, including payment methods embedded in the App (such as mobile payment option).
- If you are a member of Shell Loyalty Programme and/or Shell Drive - we will collect information about your participation in these programmes - this includes data regarding (i) the type and description of the award you have chosen, (ii) the awards you have chosen, (iii) the amount of points you have redeemed, (iv) the frequency and time of redemption of your points and (v) delivery method used to deliver your award (if any).If you are a user of Shell Drive we will collect your recorded journeys, including your vehicle co-ordinates, speed and acceleration, comparing this against other users (if you have consented to the collection of such information, including your location).
Why do we process your personal data?
The personal data covered by this privacy notice is only processed:
- with your explicit consent; or
- where it is necessary to conclude a transaction with you (such as payment information); or
- where it is necessary for Shell to comply with a legal obligation.
Where the 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. Where you choose not to provide us with information set out above for the purposes of using a Shell App or participating in the Shell Loyalty Programme the only consequence is that it will affect your ability to fully interact with the Shell App and/or to participate in the Shell Loyalty Programme.
For what purposes do we process your personal data?
We process your personal data for the purposes of:
- maintaining and promoting contact and relationship with you;
- account management including account verification (that is, ensuring that only you or someone you have authorized can access your account and information);
- customer service and development;
- performance of and analysis of market surveys and marketing strategies;
- promotions and contests offered to Shell customers, including offering you digital rewards to recognise you as a valued customer;
- detecting or preventing fraud if you use a mobile payment function to purchase Shell products (if available in your market);
(or for a secondary purpose where it is closely related, for example such as storing or deleting it).
Communication and marketing – my choices
If you have consented to receive such communications from Shell, you may receive offers that are tailored towards your preferences based on your use of Shell services, your purchase history, your participation in promotions, surveys, the Shell Driver’s Club loyalty program and your use of Shell websites, Apps and other digital channels as well as other data that you have provided to Shell.
As a member of our Shell Loyalty Programme, in order to participate in benefits from the Shell Loyalty Programme that are tailored towards your personal preferences we analyze your participation in the Shell Loyalty Programme, use of Shell services, your purchase history, your participation in promotions, surveys and your use of Website, Apps and other digital channels as well as any other data that you have provided to Shell.
We may send you service updates and notifications without your advance consent only where you are an existing user Shell Apps or other services and such updates and/or notifications are necessary for the proper functioning of the Shell Apps or other services that you use.
You may receive pertinent offers and communications by different channels and you may update your subscription preferences via your Single Sign On account settings anytime or use the unsubscribe functionality for the different digital channels.
Transaction security and preventing, detecting and investigating fraud
When you use a mobile payment App to purchase Shell products (if available in your market), you may be asked to provide additional personal details to complete the transaction. We may use the personal data you provide to prevent, detect and investigate fraud and to enforce the terms and conditions of the mobile payment App.
We may share some information with the service providers involved in mobile payments (such as WeChat Pay, Alipay, PayPal, etc), including but not limited to your IP address, device ID or unique identifier, loyalty card number for the purposes detailed above as well as for the purposes of collecting points, device type, geo-location information, connection information (for e.g. wi-fi) and mobile network information.
We may process the information that you have provided to Shell as well as the information that we obtain through your use of Shell products and services to offer you digital awards and rewards to recognise you as our valued customer. Such electronic badges may be assigned to users of Shell Apps as with regard to their use of the Shell Apps, purchasing history, expressed interests in Shell products and services and use of Shell Drive.
You can choose to opt-out from such communication by opting-out from the Badges functionality through the settings in the Shell Apps.
We aim to keep our information as accurate as possible. You can access your personal data, request correction or deletion of the personal data (but only where it is no longer required for a legitimate business purpose such as completing a retail transaction) and request that the processing of the personal data is restricted. Please go to your Shell account profile to make such update or please communicate with us as per the contact details in your country specific privacy notice.
You have the right to receive personal data that concerns you and which you have provided to Shell, in a structured, digital form and transmit such data to another party, if this is technically feasible. Please contact us at (852) 24354789 or email@example.com in this respect.
If you have any issues, queries or complaints regarding the processing of your personal data, please contact us at (852)24354789 or firstname.lastname@example.org for further information or for submitting such requests. 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 at privacy-office-SI@shell.com.
You may also have the right to lodge a complaint with The Office of the Privacy Commissioner for Personal Data, whose address is Unit 1303 on 13/F of Sunlight Tower. Please visit https://www.pcpd.org.hk/ for more information. If you remain unsatisfied by the handling of your complaint and the processing of your personal data by Shell, you may also lodge a complaint to the Dutch Data Protection Authority whose visiting address is Prins Clauslaan 60, 2595 AJ The Hague, Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.
Cookies and similar technologies
Security of your personal information
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 process for access to Shell services and we regularly test, assess and evaluate the effectiveness of our security measures.
Who will you share my personal data with?
Your personal data is 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;
- With your consent, authorized third party companies in co-operation with Shell that may supply products and/or services to users of Shell Apps and Shell Loyalty Programme
- Authorized service providers involved in mobile payments (such as WeChat Pay, Alipay, PayPal, Apple Wallet or Android Pay)
- Authorised agents, licensees, service providers and/or subcontractors of Shell;
- A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Shell company/companies is subject to or as permitted by applicable local law;
- Any person to whom Shell proposes to transfer any of its rights and/or duties
Where the personal data has been transferred to companies within the Shell Group and/or to authorized third parties located outside of your country (including outside of the European Economic Area) we take organizational, contractual and legal measures to ensure that your personal data is exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include Binding Corporate Rules for transfers among the Shell Group and European Commission approved transfer mechanisms for transfers to third 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 request a copy of these by contacting HK-DPO@shell.com for the local Data Privacy Officer for Hong Kong, www.shell.com or by calling the Shell Hong Kong customer hotline (852)24354789 or at such number as updated by Shell from time to time.
If you communicate with us through social media
- without undue delay upon you requesting that your Shell account profile is deleted or request to discontinue your participation in the Shell Loyalty Programme; OR
- within 3 years for all subscribed services after our last interaction with you;.
In relation to financial transactions (including that made through a Shell App), your personal data will be held for 10 years from the transaction.
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 purpose to retain it.
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