Updated on 15 February, 2023


The purpose of this privacy policy (hereinafter "the Policy") is to inform visitors and users (hereinafter “the User(s)") of the website www.suez-asia.com (hereinafter the "Website") of the methods of protection of their personal data, pursuant to the applicable laws and regulations in the Asia Pacific region of which SUEZ or its affiliates has business operations in, including and limited to People’s Republic of China, Hong Kong, Macao, Vietnam, the Philippines, Singapore and Indonesia (hereinafter collectively the "Regulations").


The methods of collecting and processing data collected by means of cookies are specified in the “Cookies Policy
”.


The publisher of the Website is SUEZ (Asia Pacific) Limited, a company registered under the laws of Hong Kong SAR, Company No. 151306, whose registered office is located at Room 701, 7/F, Lee Garden Two, 28 Yun Ping Road, Causeway Bay, Hong Kong SAR (hereinafter “the Publisher” or “SUEZ”).


SUEZ may amend the Policy at any time, in particular in order to comply with any regulatory, case law, editorial or technical changes. Before browsing the Website, the User must read the latest version of the Policy.


This Privacy Policy forms an integral part of the General Terms and Conditions of Use of the Website.

Identity of the personal data processor

The processor of Users’ personal data is one of the following entities, depending on the case:

  • SUEZ, a joint stock company (SA) registered on the register of companies of Nanterre, registration No.901 644 989, whose head office is located at Tour CB21, 16 place de l’Iris, 92400 Courbevoie, France.
  • Fondation d’entreprise SUEZ, a private law association without a legal personality, located at 1 rue d'Astorg, 75008 Paris, France.


These entities are hereinafter referred to individually as a “SUEZ Entity” and collectively as the “SUEZ Entities”.


The personal data processor will be the SUEZ Entity referred to below, depending on the purpose of the request indicated in the contact form:

  • Business information: SUEZ SA or the subsidiary of the Group responsible for dealing with Users’ request or answering their question. 
  • Human resources (apart from submission of applications): SUEZ SA.
  • Supplier relations: SUEZ SA or the Group subsidiary named in the contract (or any similar document) that the supplier is party to, or that the supplier is having pre-contractual discussions with.
  • SUEZ Foundation: the SUEZ Foundation.
  • Press: SUEZ SA.
  • Others: SUEZ SA or the subsidiary of the Group responsible for dealing with Users’ request or answering their question. 


All requests to exercise Users’ rights
 must be submitted via the “Data subject’s rights” form provided for that purpose. Please input "SUEZ Asia" in the field of "SUEZ entity if known".

Description of the processing

As part of the operation of the Website, the Publisher may collect and process personal data to enable Users to access the functions and services offered by the Website (hereinafter the "Services").

1) What categories of data are collected?

  • Contact data: refers to the compulsory data that Users enter by filling in the contact form(s), i.e.: title, surname, first name, email address, company name, telephone number, country of residence.
  • Data published voluntarily by Users: refers to the personal data given voluntary to the Publisher by Users when filling in the text boxes provided for that purpose on the contact form(s), i.e. “Subject of your request” and “Message”. The Publisher strongly advises Users to avoid providing any personal data via these text boxes, and in any case to only provide information that is strictly required in order to process the User’s request (hereinafter the "Data Published").

All this data will be referred to collectively hereinafter as the "Data".

2) Why does the Publisher collect Users’ Data?

The Data is collected for the following purposes:

  • To deal with Users’ request for information or question and communicate efficiently with them, in the following fields: individual shareholders, analyst and investor relations, press relations, SUEZ Foundation, human resources (apart from submission of applications), supplier relations, SUEZ Ventures, or to answer any other Users’ questions, whether or not it is related to a current contract.
  • To send commercial communications to the User in relation to the main interests he or she has previously expressed.
  • To manage access to certain Services and their use.


Compulsory fields to be filled in on the contact form are marked by an asterisk. If the compulsory fields are not filled in, SUEZ will be unable to answer your request.

3) What is the legal basis for processing the Users’ Data?

The legal basis of the data processing carried out in connection with the Website’s operation are the following:

  • If the User is a supplier: the contract or the performance of pre-contractual measures taken at the request of the data subject.
  • If the User is an applicant (or potential applicant): the legitimate interest of SUEZ to answer the request of the applicant/potential applicant.
  • If the User is a journalist, consumer or any other person: their consent obtained by means of the checkbox.
  • If the User is a professional prospect wishing to receive information or make requests about the activities and services offered by SUEZ in relation to the specific needs previously expressed, or if the User is already a customer of SUEZ: the legitimate interest of SUEZ.
  • If the User is a prospect (professional or not), the Publisher collects his consent by means of a check box before sending any global information via commercial communications.

4) Recipients of the Data collected

The Data collected by means of the contact form are intended for the internal departments of the Entity that is the personal data processor responsible for answering the Users’ request.

Depending on the case, this may be the “Investor Relations”, “Human Resources” or “Communications” department etc.


The Data can also be transferred/used by third parties under the following conditions:

  • Data transferred to public authorities and/or bodies:
    In accordance with the Regulations in force, the Data may be sent to the competent authorities on request and in particular to public bodies solely to comply with legal obligations, representatives of the law, ministerial officers and organisations responsible for debt collection, and in connection with the pursuit of perpetrators of offences committed online.
  • Data transferred to third parties:
    The Data can be transferred or made accessible to the Publisher’s processors, suppliers and third party service providers (such as the Website hosting service provider and IT and/or technical services suppliers of SUEZ).
  • Social networks
    Users can share pages that concern them on social networks by clicking on the share buttons.
    Collection of data via social networks share buttons is subject to the privacy policies of these third parties. You are asked to read the social networks’ policies to find out how your personal data is used.

Exercise of Users’ rights

In accordance with the regulations, all Users who are natural persons have the right to access, rectify, erase, restrict processing, and to portability of their Data.


Users also have the right to define general and specific instructions for how they wish their rights to be exercised after their death.


For all processing carried out in connection with the Website, and solely in that connection, regardless of which Entity is the personal data processor, Users can exercise their rights


The Publisher states that Users can object to processing of their personal Data, on legitimate grounds.


If processing is based on consent, Users are entitled to withdraw their consent at any time by sending an email to privacy.asia@suez.com.


It is noted that if the Users exercise some of the above rights, the Publisher may be unable to take the action required to achieve the purposes described above, or Users may be unable to use some or all of the Services.


The Publisher is obliged to keep the Data collected from Users up to date. Users are therefore advised to inform the Publisher of any changes to their Data by sending an email to the following address: privacy.asia@suez.com.

Data storage and archiving period

Users’ Data will not be stored for longer than is strictly required for the purposes pursued as specified herein.


In this regard,

  • Data collected in order to respond to requests for information and questions from prospects (professional or otherwise) are kept on an active basis for the calendar year of the User's request, then for a period of 5 years for intermediate archiving.
  • Data collected with a view to sending commercial communications to prospects (professionals) are kept on an active basis for 3 years from the last contact with the User (for example, a request for documentation or a click on a hypertext link contained in an e-mail), unless the User has exercised his right to withdraw consent, his right to oppose or delete (as the case may be), then for a period of 5 years in interim storage.
  • Data collected with a view to contacting the customer service department of the Professional User with an existing contract with SUEZ (customers) is kept for the entire duration of the contractual relationship, unless the User has exercised his right to oppose or exercise his right to erasure. The data is then kept for 3 years on an active basis from the end of the contractual relationship, then for 5 years for intermediate archiving.

At the end of the temporary archiving period, Users’ Data will be permanently erased.


In addition, the Publisher may keep Data permanently on an anonymous basis for producing statistical studies. These studies will not on any account make it possible to identify the Users, and will only concern trends resulting from their aggregated Data.

Security

The Publisher shall take appropriate technical and organisational measures to ensure that the Data is secure and to prevent unauthorised access or disclosure of the Users' Data. However, the Publisher cannot guarantee that all risks of hacking, falsification, unlawful reproduction or misuse of Data have been eliminated.


The Database created when Users send a request via the contact form is strictly confidential. SUEZ undertakes to take all necessary precautions and appropriate organisational and technical measures to safeguard the security, integrity and confidentiality of the Data and, in particular, to prevent it being distorted or damaged or accessed by unauthorised third parties.