For the purposes of the data protection legislation the data controller is Pharos International plc with registered office address at 48 Dover Street, London, W1S 4FF and is registered with the UK Information Commissioner’s Office with registration number Z8819425 (“Pharos”).

1. Information we may collect from you

From time to time we may collect the following information from you:

1.1 information that you provide by filling in forms on the Site. This includes information provided at the time of registration on the Site for email updates, recruitment information requests, raising enquiries or requests for further information.  We may also request information if you report a problem with the Site;

1.2 if you contact us, we may keep a record of that correspondence; and

1.3 details of your visits to the Site, including but not limited to traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise, and the resources that you access

2. IP addresses

2.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers.

2.2 An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the internet. When you visit the Site, we may view the IP address of the device you use to connect to the internet.  This forms statistical data about our user’s browsing actions and patters, and does not identify any individual.

2.3 We use this information to determine the general physical location of the device and understand from what geographic regions our Site users are from. We may also use this information to enhance our Site.

3. Cookies

3.1 A cookie is a small text file that can be placed on the hard drive of your computer. A cookie will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie, and a value which is a randomly generated unique number.  This helps us to provide you with a good experience when you browse our Site, allows us to improve the Site and assist in your navigation of the Site. The Site uses cookies to distinguish you from other users of the Site and to assist your use of the Site.

3.2 By using the Site you are consenting to our use of the cookies as set out in this policy.

3.3 You can disable the cookies or set your browser to alert you when cookies are being sent, but if you choose to do so, you may not be able to access some areas of the Site.

3.4 The following cookies are used on the Site:

Persistent or Necessary (2 cookies)

Name	Provider	Purpose	Expiry	Type
ARRAffinity	https://www.pharos.energy	Used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session.	Session	HTTP Cookie
smConsent	https://www.pharos.energy	Stores the user’s cookie consent state for the current domain	1 year	HTTP Cookie

Performance (3 cookies)

Name	Provider	Purpose	Expiry	Type
_ga	https://www.pharos.energy	Registers a unique ID that is used to generate statistical data on how the visitor uses the website.	1 year	HTTP Cookie
_gat	https://www.pharos.energy	Used by Google Analytics to throttle request rate	Session	HTTP Cookie
_gid	https://www.pharos.energy	Registers a unique ID that is used to generate statistical data on how the visitor uses the website.	Session	HTTP Cookie

Your consent to the use of cookies applies to https://www.pharos.energy

You can view and change your cookie settings at any time.

4. Where we store your personal data

4.1 Although our Site is hosted in the UK, the data that we collect from you may be transferred and stored at a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or one of our suppliers. Such staff may be engaged in responding to your queries or complaints or sending you updates which you have subscribed to.  By submitting your personal data, you are agreeing to this transfer, storing and processing.  We will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this policy.

4.2 All information you provide to us is stored on our secure servers. Any personal information will be encrypted where possible.

4.3 As you will be aware, transmission of information via the internet is not completely secure. Although we will use industry-standard methods and processes to protect your personal data, we cannot guarantee the security of it when transmitted to our Site, please note that any transmission is at your own risk. Once we have received your information we will use strict procedures to try to prevent unauthorised access.

4.4 We also collect your personal data if you sign up to receive news from us. These are collected by third party firms on our behalf. We have two separate lists:

• RNS alerts, to send you details when we issue a Regulatory News Service announcement. These records are held by BrighterIR. The BrighterIR privacy statement is available here: https://www.brighterir.com/gdpr-privacy-cookie-policy/
• Pharos Energy company news, these records are held by MailChimp. The MailChimp privacy statement is available here: https://mailchimp.com/legal/privacy/ (see the section relating to Privacy for Contacts).

5. How we use the information

5.1 We use your information:

5.1.1 to ensure content from the Site is presented in the most effective manner for you;

5.1.2 to provide you with information and services that you request from us, or which we consider may interest you – only where you have consented to be contacted for that purpose; and

5.1.3 to notify you of changes to the Site and this policy, or email updates.

5.1.4 If you would like us to remove your information from our news alerts contact lists, you can also do this directly through the BrighterIR site or MailChimp site.

5.2 You can change your mind at any time about how we use your information, please let us know as soon as possible if you wish to change the use of your data in this way.

6. Disclosure of your information

6.1 We may disclose your personal information to any member of the Pharos Group, which means our subsidiaries, our ultimate holding company and its subsidiaries as defined in s.1159 of the UK Companies Act 2006.

6.2 We may disclose your data to third parties who:

6.2.1 assist in the operation and management of our Site;

6.2.2 in the event that we sell or buy any business or its assets, in which case the prospective buyer or seller may receive your data;

6.2.3 if Pharos, or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets; and

6.2.4 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 Website Terms of Use and other agreements; or to protect the rights, property or safety of Pharos or other interested parties. This includes exchanging information with organisations, authorities for the purposes of fraud protection, crime detection or prevention.

6.2.5 We do not collect information with an intention to sell it to unconnected third parties, however if the events in 6.2.3 occur details of our Site users would be part of any sale of the business.

7. Your rights

7.1 We are required to comply with the provisions of the Data Protection Act 1988. This provides amongst other things that the data we hold about you should be processed lawfully and fairly. It should be accurate, relevant and not excessive. The information should be kept up to date, where necessary, and not retained for longer than is necessary. It should be kept securely to prevent unauthorised access by other people.

7.2 From time to time our Site may contain links to and from other third party websites. If you follow a link to these websites please note that they will have their own privacy notices and polices, that we do not accept any responsibility or liability for.

8. Access to information

You have the right to see what is held about you and for any inaccuracies to be corrected. Please contact us if you wish to make a data access request. Any access request may be subject to a fee of £10 to meet our costs in providing you with the details of the information we hold about you.

9. Contact

Questions, comments and requests regarding this policy and our use of your personal data are welcomed, please contact us.

10. Changes to this policy

We reserve the right to amend or vary this policy from time to time by placing an updated policy on the Site.

11. General

11.1 Any use of our Site shall be subject to our Website Terms of Use.

11.2 The Site is operated by Pharos Energy plc, 48 Dover Street, London, W1S 4FF and is registered with the Information Commissioner’s Office with Registration Number Z8819425, and with company registration number 03300821.

11.3 This policy is governed by and shall be construed in accordance with the laws of England and Wales, and any claim brought under this policy shall be subject to the exclusive jurisdiction of the English courts.