Privacy and Data Protection Policy

Personal Data Privacy and Protection Policy Statement


SUEZ (Asia Pacific) Limited and its related bodies corporate in Asia (“SUEZ Asia Pacific”, “we”, “our”, “us”) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal data. This document is our Privacy and Data Protection Policy (“Privacy Policy”) that informs our customers and other individuals we deal with (“you” or “your”) how we collect and manage your personal data.


We respect your rights to privacy under the applicable personal data protection act, or equivalent, (“PDPA”) which deals with the collection, management and disclosure of your personal data and that is applicable in the jurisdiction of the relevant SUEZ Asia Pacific entity that has collected your personal data.


For the purpose of this Privacy Policy, “Asia” means China, Hong Kong SAR, Macau SAR, Taiwan, Singapore, the Philippines, Malaysia, Thailand, Indonesia, Vietnam, Lao, Cambodia,  South Korea or Japan (“Jurisdictions”); “SUEZ Asia Pacific” means SUEZ Asia Pacific Limited (of Hong Kong SAR) or that SUEZ Asia Pacific group controlled company or sister company incorporated in these Jurisdictions which is collecting and managing your personal data.


In relation to your information collected in Asia, SUEZ Asia Pacific respects your rights to privacy under the PDPA. It is also SUEZ Asia Pacific’s policy to meet regional or international standards of personal data privacy protection and to comply with the requirements of all applicable data protection and privacy laws.

What is your personal data?

When used in this Privacy Policy, the term “personal data” has the meaning given to it in the PDPA. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal data.

What personal data do we collect and hold?

We may collect the following types of personal data:

  • name;
  • mail, email and street addresses;
  • telephone and facsimile numbers;
  • profession, occupation, job title and work history;
  • bank account details;
  • photos and videos;
  • licence plates details;
  • details of the products and services you have purchased from us, or which you have enquired about, together with any additional information necessary to deliver those products and services, respond to your enquiries and generally to complete any commercial transaction between us;
  • details of the products and services that we may purchase, have purchased or enquired about from you, together with any additional information necessary for us to respond to your enquiries and generally to complete any commercial transaction between us;
  • any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise; and
  • information you provide to us through our service centre, customer surveys and/or visits by, or telephone calls from, our representatives from time to time.

Additionally, if you are applying for employment with SUEZ Asia Pacific, we will collect the following: ID/Passport copies, Date of Birth, Nationality, Marital Status, Gender, Educational and employment history and professional qualifications, including testimonials and references, Medical, legal and financial history, Next of Kin, family or emergency contact information, Curricula Vitae.

We may also collect some information that is not personal data because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.

For what purposes do we collect, hold, use and disclose your personal data?

We collect personal data about you for various purposes so that we can perform our business activities and functions, and provide the best possible quality of customer service.

We collect, hold, use and disclose your personal data for purposes including:

  • to provide products and services to you and to send communications requested by you;
  • to answer your enquiries and provide information or advice about existing and new products or services;
  • to provide you with access to protected areas of our website;
  • to assess the performance of the website and to improve the operation of the website;
  • for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of SUEZ Asia Pacific, its related bodies corporate, contractors and/or suppliers;
  • to provide your updated personal data to our related bodies corporate, contractors or suppliers;
  • to update our records and keep your contact details up to date;
  • to process and respond to any complaint made by you;
  • to contact and/or pay you for or in connection with products or services you provide us;
  • to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country);
  • to facilitate data analysis and business planning purposes;
  • to perform or carry out SUEZ Asia Pacific’s obligations arising from any contracts entered into between you and us;
  • to perform all human resources management purposes, relating to such matters as recruitment, appointment, benefits administration, employees’ compensation, termination, performance appraisal, discipline and the like;
  • to apply for employee work visas with the immigration services;
  • to enable SUEZ Asia Pacific’s subcontractors, third-party agents and service providers, to fulfil obligations/services as stipulated in your contract with SUEZ Asia Pacific;
  • to ensure the security of our products, services and digital content, of our activities and of others, for the protection against fraud and the compliance with our terms and conditions and this Privacy Policy. We may also investigate potential breaches;
  • to enable or administer our business, such as for quality control and consolidated reporting;
  • to support corporate transactions or reorganizations in which SUEZ Asia Pacific is involved;
  • for business continuity and disaster recovery;
  • to comply with legal obligations to which we are subject. For example, accounting and tax obligations; and
  • any other lawful purpose otherwise conveyed to you.

We generally explain at the time we collect personal data how we will use or disclose information we collect. We will only use or disclose personal data for a purpose other than that for which it was collected or a related purpose if you have consented to such different use or disclosure, or such use or disclosure is otherwise allowed by the privacy laws.

The specific terms of the personal data collection statement applicable to employees of SUEZ Asia Pacific prevail over the terms of this general privacy policy.

How do we collect your personal data?

We collect your personal data online and offline, directly from you where it is reasonable or practicable to do so, such as, for example, in ways including:

  • through your access and use of our website;
  • during conversations between you and our representatives;
  • when you complete an application, purchase order, agreement or related paperwork;
  • through your participation in our procurement processes;
  • through security cameras at our premises, inboard vehicle and other camera and video systems;
  • if you apply for a position with SUEZ Asia Pacific and/or sign an employment agreement with us;
  • if you enter into any contract with SUEZ Asia Pacific or purchase any products/services from SUEZ Asia Pacific; or
  • if you participate in any exhibition, event or workshop organised by SUEZ Asia Pacific or where SUEZ Asia Pacific is a participant;

We may also collect your personal data from third parties including, for example, from credit reporting agencies, business data providers, professional and/or industry associations, law enforcement agencies and other government entities.

What happens if we can’t collect your personal data?

If you do not provide us with the personal data described above, some or all of the following may happen:

  • we may not be able to provide the requested products or services to you, either to the same standard or at all;
  • we may not be able to provide you with information about products and services that you may want;
  • we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful;
  • we may be unable to contact and/or pay you in respect of products or services you provide to us; or
  • we may not be able to purchase goods and/or services from you.

Consent for the collection and use of your Personal Data

You consent to the collection, use and disclosure of your personal data for the above mentioned purposes and agree to be bound by the obligations it imposes on you, when you accept this Privacy Policy.  You accept this Privacy Policy when you continue to browse on SUEZ Asia Pacific’s website.

In this regard, please note that it is on your part to ensure that all personal data submitted to us is complete, accurate, true and correct at the time of submission.  Failure on your part to do so may result in our inability to provide you with products and services you have requested.

Please note that if you do not consent to any of the above business purposes, SUEZ Asia Pacific may also be unable to meet the purposes for which the information was collected.

To whom may we disclose your information?

We may disclose your personal data to:

  • our employees, related bodies corporate, contractors or suppliers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry suppliers, electronic network administrators, regulators and other government authorities (e.g. the various governmental environment protection and work health and safety agencies) and professional advisors such as accountants, solicitors, business advisors and consultants;
  • labour, tax and other employment related public and private administrations;
  • our clients, in response to their requests for details about the products and/or services we have purchased from you;
  • suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
  • respond to requests from courts, law enforcement agencies, regulatory agencies and other public and governmental authorities which may include such authorities outside your country of residence,
  • the persons or entities mentioned in the terms and conditions of use of our websites, and
  • any organisation for any authorised purpose with your express consent.

We may combine or share any information that we collect from you with information collected by any of our related bodies corporate.

By your submission of your personal data to us, you consent to the onward disclosure of your personal data to the above persons or service providers and the processing of your personal data by these persons or service providers.

Do we disclose your personal data to anyone overseas?

In compliance with the relevant applicable cybersecurity laws, we may disclose personal data to our related bodies corporate and third-party suppliers located overseas, to satisfy the purposes for which the data was collected and your personal data may also be hosted by our IT service providers in overseas servers. We take reasonable steps to ensure that the overseas recipients of your personal data do not breach the privacy obligations relating to your personal data.

How do we protect personal data?

SUEZ Asia Pacific complies with widely recognized key data protection principles (fairness, purpose limitation, data quality, data retention, compliance with individuals’ rights, security) and takes reasonable measures for the security of personal data. We may hold your information in either electronic or hard copy form.  

SUEZ Asia Pacific respects the privacy rights and interests of individuals. SUEZ Asia Pacific observe the following principles when processing personal data:

  • Processing personal data fairly, lawfully and in a transparent manner;
  • Collecting personal data for specified, legitimate purposes and not processing it further in ways incompatible with those purposes;
  • Collecting personal data which is relevant to and not excessive for the purposes for which it is collected and used. We may render information anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses;
  • Maintaining accurate personal data, and where necessary, kept up-to-date. We will take reasonable steps to rectify or delete information that is inaccurate or incomplete;
  • Keeping personal data only as long as it is necessary for the purposes for which it was collected and processed;
  • Processing personal data in accordance with individuals’ legal rights;
  • Taking appropriate technical, physical, and organizational measures to prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to personal data; and
  • When processing sensitive personal data, ensuring appropriate notice and consent or that the processing otherwise complies with applicable law.

SUEZ Asia Pacific is committed to taking commercially reasonable technical, physical, and organizational measures to protect personal data against unauthorized access, unlawful processing, accidental loss or damage, and unauthorized destruction. We offer the use of secure servers to enable you to place orders or to access your account information. We implement access control measures for our internal systems that hold personal data. Authorized users are given access to such systems through the use of a unique identifier and password.

Access to personal data is provided to our staff for the sole purpose of performing their job duties. We sensitize our employees on proper use and handling of personal data. We also require our service providers to maintain compliant security measures. We implement security measures to determine the identity of registered users, so that appropriate rights and restrictions can be enforced for these users. In case of a registered user, we use both log ins and passwords for authentication. You are responsible for maintaining the security of your log-in credentials.

Security incidents and breaches of personal data

SUEZ Asia Pacific complies with mandatory personal data breach notification laws and will also notify you either directly or through our website of any personal data breach which is likely to cause you serious harm.

For how long does SUEZ ASIA PACIFIC retain your personal data?

SUEZ Asia Pacific will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.

Direct marketing materials

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS and email. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list. We do not provide your personal data to other organisations for the purposes of direct marketing.


For personal data that you transmit to us through our website, as our website is linked to the internet and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Therefore, any personal data or other information which you transmit to us online is transmitted at your own risk.

How can you access and correct your personal data?

It is the policy of SUEZ Asia Pacific to comply with any personal data access and correction requests and personal data collection requests in accordance with the PDPA. You may request access to any personal data we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). Generally, we will not charge you a fee to cover our administrative and other reasonable costs in providing the information to you, however, where we anticipate that such costs may be considerable, and where we have your prior consent to charge a pre-agreed fee, we may do so. We will not charge for simply making the request and will not charge for making any corrections to your personal data. There may be instances where we cannot grant you access to the personal data we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal. If you believe that personal data we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal data stating that you disagree with it.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.

Contacting us

If you have any questions about this Privacy Policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact the relevant data privacy officer at:


In most cases, we will ask that you put your request in writing to us. We will investigate your complaint and use reasonable endeavours to respond to you in writing within 30 days of receiving the written complaint. If we fail to respond to your complaint within 30 days of receiving it in writing, or if you are dissatisfied with the response that you receive from us, you have the right, depending on the jurisdiction, to make a complaint to the applicable regulator.

Changes to our Privacy Policy

We operate in a dynamic business environment. Over time, aspects of our business may change as we respond to changing market conditions. This may require our policies to be reviewed and revised. We reserve the right to change this Privacy Policy at any time and to notify you by posting an updated version of the policy on our website. If at any point we decide to use personal data in a manner materially different from that stated at the time it was collected, we will notify users by email or via a prominent notice on our website and, where necessary, we will seek the prior consent of our users.