Privacy Policy

Kumul Petroleum Holdings Limited
Effective Date: October 22, 2025
Last Updated: October 22, 2025

1. Introduction

Kumul Petroleum Holdings Limited (“KPHL”, “we”, “us”, or “our”) is Papua New Guinea’s national petroleum and energy company. We are committed to protecting the privacy and security of personal information provided to us through our website at kumulpetroleum.com and in the course of our business operations.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information in accordance with the Papua New Guinea Privacy Act and other applicable laws and regulations.

2. Information We Collect

2.1 Information You Provide to Us

We may collect personal information that you voluntarily provide when you:

  • Submit inquiries through our contact forms
  • Apply for employment or our Graduate Development Programme
  • Subscribe to our newsletters or updates
  • Register for events such as our annual Energy Summit
  • Apply for scholarships or STEM sponsorship programs
  • Engage with us as a business partner or supplier
  • Participate in stakeholder consultations

This information may include:

  • Full name and contact details (email address, phone number, postal address)
  • Employment history and professional qualifications
  • Educational background and academic transcripts
  • Curriculum vitae and references
  • Government-issued identification documents
  • Company name and business details
  • Any other information you choose to provide

2.2 Information Collected Automatically

When you visit our website, we may automatically collect certain technical information, including:

  • Internet Protocol (IP) address
  • Browser type and version
  • Device type and operating system
  • Pages visited and time spent on pages
  • Referring website addresses
  • Date and time of access
  • Cookie data (see Section 5 below)

2.3 Information from Third Parties

We may receive information about you from:

  • Recruitment agencies and employment references
  • Educational institutions verifying qualifications
  • Government agencies and regulatory bodies
  • Our business partners and joint venture participants
  • Publicly available sources

3. How We Use Your Information

We use the personal information we collect for the following purposes:

3.1 Primary Purposes

  • Processing employment applications and managing recruitment
  • Administering scholarship and sponsorship programs
  • Responding to inquiries and providing information about our services
  • Managing business relationships with partners, suppliers, and stakeholders
  • Organizing and managing events, conferences, and training programs

3.2 Secondary Purposes

  • Improving our website functionality and user experience
  • Sending newsletters and updates about KPHL initiatives (with your consent)
  • Conducting research and analysis to improve our services
  • Complying with legal and regulatory obligations
  • Protecting our rights, property, and safety, and that of others
  • Managing corporate governance and internal operations

4. Legal Basis for Processing

We process your personal information based on:

  • Consent: Where you have given explicit consent for specific purposes
  • Contractual necessity: To fulfill contractual obligations or take steps before entering into a contract
  • Legal obligations: To comply with Papua New Guinea laws and regulations
  • Legitimate interests: To operate our business effectively while respecting your privacy rights
  • Public interest: As Papua New Guinea’s national petroleum and energy company performing functions in the public interest

5. Cookies and Similar Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience. Cookies are small text files stored on your device that help us:

  • Remember your preferences and settings
  • Understand how visitors use our website
  • Improve website performance and functionality
  • Provide relevant content and features

You can control cookie settings through your browser preferences. However, disabling cookies may affect your ability to use certain features of our website.

Types of cookies we use:

  • Essential cookies: Required for basic website functionality
  • Analytics cookies: Help us understand website usage patterns
  • Functional cookies: Remember your preferences and settings

6. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your information with:

6.1 Within KPHL

  • Authorized employees and departments who require access to perform their duties
  • Our wholly-owned subsidiaries and related entities

6.2 External Parties

  • Government agencies: When required by law or to fulfill our statutory obligations
  • Service providers: Third-party vendors who assist with IT services, recruitment, training, event management, and other business operations (under strict confidentiality agreements)
  • Joint venture partners: When necessary for collaborative projects and operations
  • Legal and regulatory authorities: To comply with legal obligations, court orders, or regulatory requirements
  • Professional advisors: Including lawyers, accountants, and auditors
  • Business successors: In the event of a merger, acquisition, or sale of assets

All third parties are required to maintain the confidentiality and security of your personal information and use it only for specified purposes.

7. International Data Transfers

As a national company operating in Papua New Guinea, we primarily process data within the country. However, some of our service providers may be located overseas. When we transfer personal information internationally, we ensure appropriate safeguards are in place to protect your data in accordance with applicable laws.

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Secure servers and encrypted data transmission
  • Access controls and authentication procedures
  • Regular security assessments and updates
  • Staff training on data protection and confidentiality
  • Physical security measures at our facilities

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security.

9. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Retention periods vary depending on the type of information and purpose:

  • Employment applications: Typically retained for 2 years after the recruitment process concludes
  • Scholarship applications: Retained for the duration of the program plus 5 years
  • Business records: Retained in accordance with Papua New Guinea record-keeping requirements
  • Website analytics: Typically retained for 2 years

When personal information is no longer needed, we securely delete or anonymize it.

10. Your Rights

Under Papua New Guinea privacy laws, you have the following rights regarding your personal information:

10.1 Right to Access

You may request access to the personal information we hold about you.

10.2 Right to Correction

You may request correction of inaccurate or incomplete personal information.

10.3 Right to Erasure

You may request deletion of your personal information in certain circumstances.

10.4 Right to Object

You may object to certain types of processing, including direct marketing.

10.5 Right to Withdraw Consent

Where processing is based on consent, you may withdraw consent at any time.

10.6 Right to Lodge a Complaint

You may lodge a complaint with the relevant Papua New Guinea regulatory authority if you believe your privacy rights have been violated.

To exercise any of these rights, please contact us using the details in Section 13 below.

11. Children’s Privacy

Our website and services are not directed at children under the age of 18, except for specific programs such as our STEM scholarship initiative for students. We do not knowingly collect personal information from children without parental or guardian consent. If you believe we have collected information from a child inappropriately, please contact us immediately.

12. Third-Party Websites

Our website may contain links to third-party websites, including social media platforms. We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Kumul Petroleum Holdings Limited
Level 7, Deloitte Tower
Douglas Street
Port Moresby
National Capital District
Papua New Guinea

Email: media@kumulpetroleum.com
Phone: 3232253
Website: https://kumulpetroleum.com

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated policy on our website with a revised “Last Updated” date. We encourage you to review this Privacy Policy periodically.

Material changes will be notified through prominent notices on our website or, where appropriate, directly to you via email.

15. Governing Law

This Privacy Policy is governed by the laws of Papua New Guinea. Any disputes arising from this policy shall be subject to the exclusive jurisdiction of the Papua New Guinea courts.

Acknowledgment

By using our website or providing personal information to KPHL, you acknowledge that you have read, understood, and agree to this Privacy Policy.

For inquiries about our petroleum projects, career opportunities, or corporate information, please visit our website at https://kumulpetroleum.com or contact us using the details provided above.