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Privacy Statement

Who we are

This is the privacy statement of Shelf Drilling, Ltd, and its wholly-owned subsidiary entities, whether direct or indirect (collectively, “Shelf Drilling” or “we” or “us”). In this privacy statement references to our website refers to https://www.shelfdrilling.com/.

Shelf Drilling is located at One JLT, Floor 12, Jumeirah Lakes Towers, P.O. Box 212201, Dubai, United Arab Emirates. The addresses of our other offices are set out at: https://www.shelfdrilling.com/contact-us/.

What personal information we collect and use

We will collect personal information about you:
• when we provide information or services to you or our customers/vendors; and/or
• if you are one of our investors or sign up to receive investor information from us. We may collect information about you from the following sources:
• directly from you;
• indirectly from people who provide it to us (for example, your employer or adviser, or third-party service providers that we use to help operate our business);
• publicly available resources; or
• the internet and social networking sites, such as LinkedIn.

We may collect, use and store different types of personal information about you, including your:
• name, gender, age, date of birth, nationality and national identification number;
• contact information, such as address, email address, and mobile phone number;
• employment information (e.g., the name of your employer and your job title);
• educational background (e.g., colleges or universities attended and degrees earned);
• financial information including your bank details;
• information about how you use our website, products and services;
• CCTV images and other information we collect when you are on our premises; and
• details of how you like to interact with us, and other similar information relevant to our relationship.

We do not intend to collect any ‘sensitive’ or ‘special categories’ of personal data about you in respect of your religious beliefs, political affiliations or health information. We will only collect and use these types of information where:
• you have given us your explicit consent to process that data;
• we are required by law to process that data in order to ensure we meet our ‘anti-money laundering’ obligations (or other legal obligations imposed on us); or
• the processing is necessary for the establishment, exercise or defence of legal claims.

If you choose not to provide, or object to us processing, the information we need, we may not be able to deal with you to provide some or all of our services or information to you.

How we use your personal information

In general terms, we may collect and use your personal information to:
• deliver our services and meet our legal responsibilities to both you or customers/vendors for whom you may work;
• verify your identity where this is required;
• contact you by post, email or telephone;
• provide you with any information you may request;
• understand your needs and how they may be met;
• for our business operations and those of the Shelf Drilling group. This may cover, for example, customer/vendor account management, processing financial transactions, obtaining professional advice, corporate activity or restructuring of the business and managing reporting, performance and services within the Shelf Drilling group;
• protect our rights and defend any claims made against us; and
• prevent and detect crime, fraud and corruption.

We may also use your personal information for marketing purposes with your consent or where applicable data protection laws and regulations otherwise allow.

We do not process personal information by automated means.

We have provided some examples of our use of your personal information below.

The legal basis for processing your personal information

We rely on one or more of the following lawful grounds for processing your personal information:
• consent – where you have agreed to us processing your information for a specific reason (e.g., you have consented to receive marketing materials from us);
• contractual performance – the processing is necessary to perform the agreement we have with our customer/vendor or to take steps to enter into an agreement with our customer/vendor;
• legal requirements – the processing is necessary for compliance with a legal obligation to which we are subject. This would include global anti-corruption and sanction laws or providing information to a public body or law enforcement agency where this does not contravene applicable data protection laws or regulations;
• legitimate interests – the processing is necessary for our legitimate interests such as:
– to provide our services or information to you or customers/vendors for whom you may work or are connected;
– to prevent and detect theft, fraud and other criminal activity;
– to protect our business interests;
– to manage our business (including business planning and promotion)
– to investigate complaints; and
– where permitted under applicable data protection laws to do so, to keep you informed, through electronic communications or otherwise, about relevant services and provide you with information about us, unless you have indicated that you do not wish us to do so.

Sharing your personal information

In connection with our processing of your personal information, we may share your personal information with the following third parties:
• your employer or any organisation for whom you work or are connected;
• our regulators;
• other third parties as necessary to comply with the law;
• other Shelf Drilling group companies;
• our hosting service providers and other service providers
• our professional advisers (including legal counsel, tax advisers, and auditors); and/or
• potential or actual purchasers of the business (or a part thereof), or other third parties in the context of a possible sale or restructuring of the business.

Transferring your personal information outside the EEA

We process personal information in countries around the world where have operations. If you are within the European Economic Area (EEA), we may transfer your personal information to countries outside the EEA for the purposes of carrying out our obligations under our contract with our customers/vendors, to operate our business, and/or to comply with legal obligations. Some of the countries outside the EEA in which we operate, are not covered by an adequacy decision by the European Commission which means that such countries are not deemed to provide an adequate level of protection for your personal information. However, in such cases, we will take appropriate measures to safeguard your personal information in a way that complies with relevant data protection laws. These measures may include approved standard data protection clauses, binding corporate rules, and/or the EU-US Privacy Shield Framework.

How long we keep your personal information

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

In general terms, we will retain personal information about you for the duration of our relationship with you and afterwards for any period required by applicable law or until the time period in which legal claims could be brought has expired. In a global organisation such as ours, the rules that apply to determine how long it is appropriate to hold records for particular matters can be complex and varied. If you wish to know how long we may hold your particular personal information then please e-mail privacy@shelfdrilling.com.

Your rights

We are committed to complying with all applicable data protection laws that apply to our processing of your personal information. This privacy statement applies on a worldwide basis across our operations, unless it conflicts with the laws in any particular jurisdiction, in which case we will process personal information in accordance with those laws to the extent they apply. While this privacy statement is designed, in part, to satisfy the requirements of the EU General Data Protection Regulation (GDPR) and to apply standards which are generally consistent with it, this privacy statement does not create GDPR rights for individuals whose personal information is being processed outside the scope of the application of GDPR.

Under applicable data protection laws and regulations, you may have various rights in relation to your personal information. In particular, where GDPR applies, you have a right to:

• Access to your information – you have the right to request a copy of the personal information about you that we hold.
• Correcting your information – you have the right to ask us to correct your personal information if you believe it is not accurate, complete or up-to-date.
• Deletion of your information – you have the right to ask us to delete your personal information if:
– you consider that we no longer require the information for the purposes for which it was obtained;
– we are using that information with your consent and you have withdrawn your consent – see Withdrawing consent to using your information below;
– you have validly objected to our use of your personal information – see Objecting to how we may use your information below; or
– our use of your personal information is contrary to law or our other legal obligations.
• Objecting to how we may process your information – you have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest or on legitimate interest grounds then, if you ask us to, we will stop using that personal information unless there are overriding legitimate interest grounds to continue.
• Restricting how we may process your information – you have the right to ask us to restrict our processing of your personal information, including if:
– you contest the accuracy of the information (for a period of time that enables us to check it);
– there is no longer a legal basis for us to process your information, but you don’t want the data deleted; or
– you have objected (as above) and are awaiting confirmation as to whether we have overriding legitimate grounds for processing.
• Withdrawing consent for processing your information – you may withdraw your consent for the processing of your personal information at any time in which case we will stop processing your personal information for the purpose(s) for which consent was given.

Contact information, further advice and complaints

If you have any questions about this privacy statement, wish to make a complaint about how we are using your personal information or wish to exercise any of your rights you can contact us by sending an email to privacy@shelfdrilling.com.

Where GDPR applies to the processing of your personal information, you also have a right to complain to the EU data protection supervisory authority in your jurisdiction.

Changes to this privacy statement

We keep this privacy statement under regular review and will place any updates on our website. Paper copies of the privacy statement can be obtained by using the printer icon or by e-mailing us at privacy@shelfdrilling.com with your address.

This privacy statement was last updated on 14 November, 2018.

Legal Information

Shelf Drilling, Ltd, a company incorporated in the Cayman Islands (registration number 271054) and having its registered office at Centralis (Cayman) Limited, One Capital Place, 3rd Floor, George Town, Grand Cayman, Cayman Islands.

14 November 2018