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Privacy and Cookies Policy

This Privacy and Cookies Policy describes how Rowan Companies, Inc. ("Rowan") collects, uses, shares, and otherwise processes individually identifiable data about visitors to this Site (defined below) as well as contact persons for our customers, job applicants, suppliers and other third parties ("Personal Data"). This Privacy and Cookies Policy applies to Personal Data that we collect through this website and our other online properties (each, a "Site"), as well as through conferences, direct calls and other offline means.  Note that information regarding Personal Data collection via the employee portal will be available upon request through HRNow.

Summary of Key Points

Collection As a business to business ("B2B") organization, we collect name, contact details, and other Personal Data related to our commercial relationships. Click here to learn more.
Use We use Personal Data to perform transactions and respond to inquiries, to manage accounts and maintain business operations, to provide relevant marketing, and to fulfil other business and compliance purposes. Click here to learn more.
Sharing

We share Personal Data as necessary to perform transactions and respond to requests, and to fulfil other business and compliance purposes. Click here to learn more.
Marketing choices You have control on how we use Personal Data for marketing. Click here to learn more.
Cookies We use cookies on our Sites, and provide choices on use of cookies, including third party targeting and advertising. Click here to learn more.
Data subject rights You have certain rights to request access, rectification, deletion, or other actions regarding your Personal Data where required by applicable law. Click here to learn more.
Data security We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration, or unintentional destruction of Personal Data. Click here to learn more.
Cross-border data transfers We provide appropriate protections for cross-border transfers where specified by law. Click here to learn more.
Other issues We provide other information in this Privacy and Cookies Policy about: (i) the legal basis for our collection and processing of Personal Data, (ii) the consequences for not providing Personal Data, (iii) automated decision-making, (iv) DNT signals (defined below), (v) data retention, (vi) links to third party websites, and (vii) changes to this Privacy and Cookies Policy. Click here to learn more.
Contact us Please contact us as detailed below with any questions. Click here to learn more.

Collection of Personal Data
We collect the following categories of Personal Data:

Personal Contact Information: Name, contact details, date of birth, nationality, gender, and emergency contact details. Employment Related Information: Company, job responsibilities, and work contact details.
Account Information: Transaction history, orders and other customer requests, and performance data. Financial Details: Information for payments (e.g., credit card information, bank account information, personal identity card information).
Contract Data: Limited data about individual contacts with suppliers and their service rates. Applicant Data: Data provided by job applicants or others on our Sites or offline means in connection with employment opportunities.
Device Data: Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Sites (Usage Data).

Use of Personal Data
We use the following categories of Personal Data for the following purposes:

Purpose of Use Categories of Personal Data
Business administration, including processing corporate customers' requests, testing, providing services, and supplier onboarding, assigning, managing, and administering projects Personal Contact Information, Account information, Financial Details, Employment Related Information, Contract Data
Safety and accountability, in particular for safety on the rig Personal Contact Information, Account information, Financial Details, Employment Related Information
Marketing and communication activities Personal Contact Information, Account information, Financial Details, Employment Related Information
Internal reporting functions Personal Contact Information, Account information, Financial Details, Employment Related Information
Quality management and customer service activities Personal Contact Information, Account information, Financial Details, Employment Related Information
Recruiting and employee onboarding Applicant Data
Addressing regulatory and compliance obligations and internal reporting functions Personal Contact Information, Employment Related Information, Contract Data

Sharing of Personal Data
We share Personal Data with the following categories of recipients:

  • Affiliates: We share Personal Data within the Rowan group of affiliated companies as necessary for the purposes identified above. The list of affiliates within the Rowan group is provided here: http://www.rowan.com/contact-us/default.aspx.
  • Suppliers and service providers: We share Personal Data with suppliers and service providers to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above. We require such parties by contract to provide reasonable security for Personal Data and to use and process such Personal Data on our behalf only.
  • Auditors, advisors, and financial institutions: We share Personal Data with auditors for the performance of audit functions, with advisors for the provision of legal and other advice, and with financial institutions in connection with payment and other transactions.
  • Emergency responders: We share Personal Data with emergency responders to assist with safety and accountability, in particular for activities on the rig.
  • Corporate purchasers: We may share Personal Data with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of the company.
  • Mandatory disclosures and legal claims: We share Personal Data in order to comply with any subpoena, court order or other legal process, or other governmental request. We also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.

If you have questions about the parties with which we share Personal Data, please contact us as specified below.

Marketing Choices
You have control regarding our use of Personal Data for direct marketing. If you no longer wish to remain on a mailing list to which you previously subscribed, or receive any other marketing communication, you can choose to not receive such communications at any time. Please follow the unsubscribe link in the relevant communication or contact us as per below.

Cookies
We use and allow certain third parties to use cookies, web beacons, and similar tracking technologies (collectively, "cookies") on our Sites.

What are cookies?
Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a websites. More information about cookies and how they work is available at www.allaboutcookies.org.

How do we use cookies?
We use cookies to provide the Sites and services, gather information about your usage patterns when you navigate this Site in order to enhance your personalized experience, and to understand usage patt

Cookies on our Sites are generally divided into the following categories:

  • Strictly Necessary Cookies: These are required for the operation of our Sites. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies that are erased when you close your browser.
  • Analytical/Performance Cookies: These allow us to recognize and count the number of users of our Sites and understand how such users navigate through our Sites. This helps to improve how our Sites works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser. We use Google Analytics, and you can see below for how to control the use of cookies by Google Analytics.
  • Functional Cookies: These improve the functional performance of our Sites and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Sites and asked to remain logged into it. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Sites. You can delete these cookies via your browser settings.

What are your options if you do not want cookies on your computer?
You can review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site.

For questions about the use of cookies for Google analytics and to exercise choice regarding such cookies, please visit https://tools.google.com/dlpage/gaoptout.

Data Subject Rights
Where required by applicable law, you have the right to obtain confirmation of the existence of certain Personal Data relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal), by contacting us as detailed below. In particular, you have the right to object to our use of Personal Data for direct marketing and in certain other situations at any time. Contact us below for more details. Please note that we need to retain certain Personal Data as required or permitted by applicable law.

Data Security
We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration, or unintentional destruction. However, no security measure can guarantee against compromise. You also have an important role in protecting Personal Data. You should not share your username and password with anyone, and you should not re-use passwords across more than one Site. If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.

Cross-Border Data Transfers
We transfer Personal Data to various jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers. With respect to transfers originating from the European Economic Area ("EEA"), we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required by applicable law. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.

Other Issues

(i) What is the legal basis of processing?
Some jurisdictions require an explanation of the legal basis for the collection and processing of Personal Data. We have several different legal grounds on which we collect and process Personal Data, including: (a) as necessary to perform a transaction (such as when we respond to your requests); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping to substantiate tax liability); (c) consent (where you have provided consent as appropriate under applicable law); and (d) necessary for legitimate interests (such as when we act to maintain our business generally). With respect to legitimate interests, given that we are a B2B company, we typically collect and process limited Personal Data about customer contacts and other individuals acting in their business capacities, as part of our overall effort to reduce the privacy impact on individuals.

(ii) What are the consequences of not providing Personal Data?
You are not required to provide all Personal Data identified in this Privacy and Cookies Policy to use our Sites or to interact with us offline, but certain functionality will not be available if you do not provide Personal Data. If you do not provide Personal Data, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.  

(iii) Do we engage in automated decision-making without human intervention?
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

(iv) Does the Sites honor do-not-track ("DNT") signals sent via browsers?
Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to DNT signals at this time.

(v) How long do we retain Personal Data?
We typically retain Personal Data related to marketing activities for as long as you accept marketing communications from us, and we will securely delete such data in accordance with applicable law upon request. For Personal Data that we collect and process for other purposes, we typically retain such Personal Data for no longer than for the period necessary to fulfill the purposes outlined in this Privacy and Cookies Policy and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations.

(vi) Are third party websites governed by this Privacy and Cookies Policy?
The Site contains links and references to other websites administered by unaffiliated third parties. This Privacy and Cookies Policy does not apply to such third party Sites. When you click a link to visit a third party website, you will be subject to that website’s privacy practices. We encourage you to familiarize yourself with the privacy and security practices of the linked third party website before providing any Personal Data on those websites.

(vii) How will we handle any changes to this Privacy and Cookies Policy?
We may update this Privacy and Cookies Policy from time to time as our services and privacy practices change, or as required by law. The effective date of our Privacy and Cookies Policy is posted below, and we encourage you to visit our Sites periodically to stay informed about our privacy practices. We will post the updated version of the Privacy and Cookies Policy on our Sites, and ask for your consent to the changes if legally required.

Contact Us
If you have questions or comments regarding this Privacy and Cookies Policy or our privacy practices, please contact us at legaldept@rowancompanies.com. You may also have a right to lodge a complaint with a supervisory authority.

Effective Date: October 29, 2018