Important Legal Notice
Trafigura recognises the importance of data protection. We understand and value your rights to autonomy and control over how, when and why your personal data is used. Given this remains an evolving area, we are firmly committed to ensuring compliance with applicable regulatory and legal requirements, as is reflected in this Notice.
For the purposes of applicable data protection and privacy laws, the data controller is Trafigura Limited (company number 02737924) of 14 St. George Street, London W1S 1FE, United Kingdom.
This Notice explains what personal data we collect, how we may use and manage it and the rights you have in relation to your personal data. Before you provide us with any personal data or browse our Websites (as defined below), you should read through this Notice in full and make sure that you are comfortable with our privacy practices.
If the relevant Trafigura entity you are dealing with in relation to this Notice is operating in South Africa, the term “personal data” includes information relating to an identifiable, existing juristic person (for example a company or similar legal entity) and any references to “you” shall be interpreted accordingly.
1. Whose personal data do we collect?
Trafigura collects personal data from a range of persons in the context of its business activities, including:
- our suppliers, customers and other business contacts;
- representatives of suppliers, customers and other business contacts;
- Contractors and consultants;
- users of our Websites;
- individuals who contact us by any means; and
- job applicants.
2. How we collect your personal data
We obtain personal data which you knowingly and voluntarily disclose to us, both online and offline, notably when you:
- visit our Websites and / or complete one of our web forms;
- visit our premises; and
- communicate with us via any means, including but not limited to telephone, video conferencing, email and through the use of social networking websites, third party apps or similar technologies.
Other types of information may be collected automatically from your device as you interact with our Websites. We collect this personal data by using cookies and other similar technologies.
We may also collect information from third party sources, e.g. relating to your use of other websites which we operate and from related third parties e.g. sub-contractors.
3. Information Trafigura may collect from you
Trafigura may collect a range of personal data from you in a business context, including but not limited to your name, gender, job title, photographic identification, email address, home address and other contact details, details of your business and other interests, communications with you (including notes from meetings) and financial and payment information.
When you use our sites https://www.trafigura.com, https://www.trafigurainsights.blog, https://www.commoditiesdemytified.info and https://www.lpg4sdg7.org ("Website(s)"), we collect certain standard information that is sent by your browser to the Websites, e.g. your IP address, browser type, operating system, language, time zone setting, access times and any referring website addresses.
We may collect and process information that you provide by filling in forms on the Websites, including without limitation information provided as part of a job application or other employment related enquiry.
If you contact us, we may keep a record of that correspondence.
Trafigura may also ask you to complete surveys that we use for research purposes, although you are under no obligation to respond to them.
We may also record details of your visits to the Websites, including any resources that you access.
Trafigura may record and retain certain telephone conversations and video conferences where we are required to do so to comply with our regulatory obligations.
4. Transfers of personal data
The data that we collect from you may be transferred to, and stored in, a country other than your own and that such country may provide a lower level of data protection requirements than your own country.
Whenever we transfer personal data across borders, we will take legally required steps to ensure that adequate safeguards are in place to protect your personal data and to make sure that it is treated in accordance with this Notice.
If you are located in the EEA, Switzerland, South Africa or the UK, you can request more information on the safeguards which we have put in place to protect your personal data and privacy rights in these circumstances, using the contact form available on our Websites (https://www.trafigura.com/dpo/).
5. Uses made of the information
We use personal data held about you in the following ways:
- To administer the Websites and to ensure that content from the Websites is presented in the most effective manner for you and for your computer, including carrying out analytics in relation to the use of the Websites, and to notify you about changes to our Website.
- To provide you with information that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To play video content via third party sites.
- To manage our internal recruitment processes.
- To carry out our obligations arising from any contracts entered into between you and us.
- To review and post entries or comments that you submit to our blog https://www.trafigurainsights.blog.
- To communicate with you and third party contacts.
- To comply with our legal and regulatory obligations, which may include the disclosure of certain information and/or recordings of telephone conversations and video conferences to regulatory authorities.
- For other business-related purposes, including negotiating contracts, concluding and performing contracts, administering payments, managing accounts and records, supporting corporate social responsibility activities, legal, regulatory and internal investigations and debt administration.
- All employment related activities.
When you apply for a job via our Websites or otherwise, we will collect additional more specific personal data about you, e.g. your qualifications, career history, third party references and interview notes. We may also ask you for other information, e.g. your interests and the types of jobs you are interested in. There will be circumstances where we collect and process special category personal data as part of the recruitment process. For example, with your consent, we may collect information about your race, ethnicity, health and whether you have a disability, for the purposes of conducting equal opportunities monitoring. Any personal data you provide to Trafigura in relation to a job vacancy will be processed in accordance with our Recruitment Privacy Notice.
7. The legal basis for Trafigura processing your personal data
In accordance with the purposes for which we collect and use your personal data, as set out above, the legal basis for Trafigura processing your personal data will typically be one of the following:
- your consent;
- the performance of a contract that we have in place with you or other persons;
- Trafigura's legitimate business interests; or
- compliance with our legal obligations.
Our legitimate business interests may include: (i) keeping our Websites up to date and relevant and ensuring that they are performing as intended; (ii) to develop our products / services and grow our business; (iii) to provide IT services and network security; (iv) to provide customers with information about our business; (v) to manage and improve our recruitment practices; and (vi) to inform our strategy in relation to corporate social responsibility.
8. Disclosure of your Information
Trafigura may share your personal data with people within the organisation who have a "need to know" that data for business or legal reasons, e.g. in order to carry out an administrative function such as processing an invoice, or to direct a query that you have submitted to the relevant department within Trafigura.
Because Trafigura operates globally, we may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, each as defined in section 1159 of the Companies Act 2006. These entities are required to maintain the confidentiality of your data and are restricted from using it for any purpose other than the purposes set out in this Notice.
We may also disclose your personal data to third parties:
- In the event that we sell, merge or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Trafigura or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be transferred.
- In the event that we are required to do so to comply with our regulatory obligations, to regulatory authorities.
We may decide to allow our Website users to share comments, postings, testimonials, or other information. If you choose to submit such information to us, the information that you submit may be available generally to the public. Information that you provide in these areas may be read, collected, and used by others who access it.
Finally, we may share non-personal data with other third parties that are not described above. When we do so we may aggregate or de-identify the information so that a third party would not be likely to link data to you, your computer, or your device. Aggregation means that we combine the non-personal data of numerous people together so that the data does not relate to any one person. De-identify means that we attempt to remove or change certain pieces of information that might be used to link data to a particular person.
9. Social Media
Our Websites (including our blog https://www.trafigurainsights.blog) may contain links to Facebook or other social media sites, to video streaming sites such as Vimeo, or to recruitment platforms such as LinkedIn. When you interact with these links, your browser will establish a direct link with the third party site's servers. The third party site will then receive information about your browser and activity, and may link it to your user account for that site, if you have one. For more information about how Facebook. Vimeo and other social media and streaming sites use data, please see their own policies.
10. Records retention
Your personal data is not kept for longer than is necessary for the purposes for which it is collected. This means that data and records are destroyed or erased from our systems when no longer required. The amount of time that records are kept for varies depending upon the type of personal data they contain.
11. Your Rights – Marketing and Third Party Websites
Where you have consented to us doing so, we may send you email marketing communications.
You have the right to ask us not to process your personal data for marketing purposes. Where required by law, we will inform you (before or at the time of collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your data. You can exercise your right to 'opt-out' from receiving marketing communications at any time by clicking on the "unsubscribe" link provided at the bottom of each commercial email and updating your preferences.
The Websites may, from time to time, contain links to and from the websites of our partner networks and affiliates, or of other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12. Your Rights - Access, Rectification and Deletion
Applicable data privacy laws give rights to persons in respect of personal data that organisations hold about them. If you wish to:
- request access to or a machine-readable copy of the personal data that we hold about you;
- request that we rectify or delete your personal data;
- object to the processing of your Personal data; or
- withdraw consent at any time where we are relying on consent to process your personal data (this will not affect the lawfulness of any processing we conducted prior to your withdrawal).
Please submit your request here.
Trafigura takes reasonable technical and organisational security measures to protect personal data from accidental or unlawful destruction, accidental loss and unauthorised access, destruction, misuse, modification or disclosure. We aim to protect your personal data but unfortunately the transmission of information over the internet is not completely secure. We cannot guarantee the security of your personal data and any transmission of your data to Trafigura is at your own risk.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
14. Cookies and other tools
We may use information about your visits to the Websites by using a "cookie" or similar technologies for storing information, e.g. local shared objects and web beacons ("cookies").
A cookie is a small text file which is transferred to and stored on your computer, portable device or mobile. Cookies can be unique to your web browser and contain text and information e.g. unique identifier, site name, digits and numbers.
Cookies are used to differentiate one user from another, to pass information from page to page during their visit to the Websites and to collect data about a given browser, along with the information requested and sent by the browser's operator. They enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences, and so allow us to customise the Websites according to your individual interests.
- To recognise you when you return to the Websites.
15. What cookies do we use?
16. How can you change your cookie preferences?
You may at any time refuse to accept or block cookies by activating the setting on your internet browser which allows you to refuse the setting of cookies. You may also be able to change the setting on your internet browser so that only particular types of cookies will be accepted. For further information please visit https://www.allaboutcookies.org.
Additionally, you may change your cookie preferences by amending your selection on the cookie declaration.
Please note, if you change your settings in either of these ways, you may be unable to access certain parts of the Websites.
17. Changes to Our Privacy Notice
We reserve the right to modify or amend this Notice at any time. Any changes we may make to this Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. It is your responsibility to review this Notice every time you submit information to us.
Questions can be sent here.
If you are not satisfied with the handling of your concern or complaint by Trafigura, you can escalate this to your national Data Protection Authority. However, we kindly ask that you raise any such matters with Trafigura in the first instance, in order that we may have the opportunity to resolve them, without involving a Data Protection Authority.
Last Updated: 1 November 2022