LITASCO SA
LITASCO SA

Privacy Notice

February 5, 2025

 

LITASCO SA and its trading and shipping subsidiaries (collectively, "LITASCO", the "LITASCO Group", "we", "our" or the "Company") are committed to protecting your personal data and ensuring compliance with applicable data protection laws. We process any personal data we collect from you or that you provide to us solely for legitimate purposes and in accordance with legal requirements.

 

This Privacy Notice may be updated periodically. We encourage you to review it regularly. The effective date of the latest version is indicated at the beginning of this document.

 

General information

 

Who is the Data Controller?

 

LITASCO SA, headquartered in Geneva, Switzerland, registered at rue Kazem-Radjavi 3, 1202 Geneva, Switzerland, serves as the primary data controller for the LITASCO Group.

 

What do we mean by personal data?

 

Personal data refers to any information that identifies or can be used to identify an individual, either directly or indirectly. This includes:

 

     

  • Basic identifiers like name, address, and date of birth

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  • Contact details such as phone numbers and email addresses

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  • Online identifiers like IP addresses and cookies

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  • Financial information like bank account numbers

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  • Photograph, Biometric data such as fingerprints or facial recognition data

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  • Location data

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  • Personal characteristics including age, gender, and physical attributes

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  • Identifiers such as physical, physiological, genetic, mental, economic, cultural, or social identity

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  • Professional or educational information

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Whose personal data we collect?

 

We may collect personal data from individuals such as:

 

     

  • (prospective) suppliers, customers, consultants, service providers and other counterparties, their employees and representatives

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  • Visitors to physical locations

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  • Website users

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  • Job applicants

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  • Authorities (when there is interaction with public authorities that may involve personal data)

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  • Employees and certain family members

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What information we may collect from you?

 

     

  1. In the course of our business and social activities, LITASCO SA may collect the following categories of personal data:

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    • Basic Information: Name, gender, job title, and photographic identification

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    • Contact Details: Email address, home address, phone number, and other relevant contact information

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    • Professional Information: Details of your business role, professional interests, and affiliations

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    • Communication Records: Correspondence and communications (e.g., emails, letters, instant messages exchanged with us through third-party platforms and applications) and notes from meetings or other interactions with us

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    • Financial Data: Payment information, including bank account details and other financial records

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  1. When you use LITASCO Group's websites, we may collect the following types of personal data:

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    • Technical data: IP address, browser type, operating system, language, and time zone setting

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    • Usage information: Access times and referring website addresses

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  1. Additional personal data collection by us may include:

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    • Form submissions: personal data provided through website or paper forms, including but not limited for job applications

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    • Survey responses: data provided through optional participation in research surveys

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    • IT activity: details of your visits and resource access to LITASCO Group's websites and applications, as well as details of employees’ use of our IT tools and systems

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    • Conversations: conversations may be recorded and processed for regulatory compliance and other lawful purposes, provided always in accordance with the law

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How we collect your personal data?

 

The LITASCO Group collects personal data that you provide to us voluntarily through various channels, both digital and physical. We gather this information when you:

 

     

  1. Interact with Our Online Platforms:

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    • Browse our websites

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    • Complete forms on our web pages

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    1. Visit Our Physical Locations:

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      • Enter our offices or facilities

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      • Attend in-person meetings or events

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      1. Engage in Communication with us via:

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        • Phone calls

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        • Video conferencing sessions

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        • Email exchanges

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        • Social media interactions

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        • Third-party messaging applications and platforms

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        • Other similar communication technologies

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        In addition to the information you provide, the LITASCO Group may also automatically collect data as you interact with our websites with your device, through the use of cookies and similar technologies

         

        We may obtain data from external sources from third parties, such as subcontractors.

         

        Why LITASCO processes your personal data?

         

        LITASCO processes personal data for several key purposes, including but not limited to:

             

          • Business Operations: To handle commercial inquiries, manage business activities, and conduct due diligence on counterparties.

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          • Recruitment: To manage job applications, evaluate candidates, and facilitate the hiring process.

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          • Enhancing Your Online Experience: To optimize website performance and personalize content, ensuring a more tailored user experience.

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          • Security: To safeguard user data

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          • Regulatory and Legal: To ensure compliance with regulatory and other legal requirements, including but not limited to trade controls, sanction laws, anti-money laundering (AML) laws, anti-corruption and antitrust and competition laws. To conduct necessary investigations and cooperate with regulators and other authorities.

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          • Customer Service: To respond to inquiries and provide support, particularly regarding data-related issues.

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        On what legal basis does LITASCO Group process personal data?

         

        LITASCO processes personal data in compliance with applicable data protection laws. The legal bases for processing personal data include:

         

           

        1. Legitimate Interest

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          • We process personal data based on our legitimate business interests, provided that such processing does not disproportionately affect your fundamental rights and freedoms.

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          • This includes activities such as recruitment, due diligence, fraud prevention, IT security measures, and responding to commercial inquiries.

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        1. Legal Obligation

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          • We process personal data when required to comply with legal or regulatory obligations.

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          • This may include compliance with financial reporting requirements, tax laws, anti-money laundering (AML) regulations, sanctions laws, and trade control measures.

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        1. Consent

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          • In certain cases, we process personal data based on your explicit consent.

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          • You have the right to withdraw your consent at any time, which will not affect the lawfulness of processing carried out before the withdrawal.

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        1. Contractual Necessity

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          • We process personal data when necessary to enter into or perform a contract with you.

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          • This includes managing business relationships, providing agreed-upon services, or fulfilling contractual obligations.

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        The disclosure of personal data to third parties

         

        Is personal data disclosed to third parties?

         

        In general, we only disclose your personal data within the LITASCO Group or to third parties insofar as we have a legitimate interest in doing so or you have provided your consent. All third parties to whom we might be transferring data are compliant with our data privacy policy and are assuring the processing, storage and disposal of your data in line with relevant regulations.

         

        Furthermore, your data may be disclosed to third parties insofar as we may be obliged to do so pursuant to legal provisions or an enforceable administrative or court order.

         

        Are third parties used for processing data?

         

        We use third party service providers for data processing. Service providers are generally involved as so-called ‘processors’, who may only process the personal data in accordance with our instructions. These may include IT service providers, cloud storage providers, and HR platforms. For example, your email address may be passed along to a service provider in order for it to send you a newsletter you requested.

         

        Is personal data sent to recipients in a third country (outside Switzerland, the EU or the EEA)?

         

        We also provide personal data to third parties, respectively processors that are not based in the EU/EEA or Switzerland. In this case, we ensure prior to disclosure either that the recipient provides an adequate level of data protection (e.g., on the basis of an adequacy decision for the relevant country, the application of standard contractual clauses of the European Union) or that our users have provided their consent.

         

        We can provide you with an overview of the third country recipients along with a copy of the terms specifically agreed to in order to ensure an adequate level of data protection. Please use the details provided in the data-related enquiries form or contact us at privacy@litasco.com to do so.

         

        General note: In the event of acquisition of LITASCO Group entity by third party corporation, data held by LITASCO Group entity may be transferred to the acquiring company in line with relevant legislations.

         

         

        Duration of storage and retention periods

         

        For how long does LITASCO Group retain personal data?

         

        All personal data is retained, stored and destroyed in line with legislative and regulatory guidelines. We store your personal data for as long as necessary to fulfill the purposes for which it was collected, based on legitimate interests and legal obligations. In most cases, data is retained for a maximum period of ten years. As soon as the data collected is no longer required or relevant for the purpose for which it was obtained, we dispose of it following strict industry standards.

         

        With regards to the recruitment process, we hold personal data of applicants for no longer than one year following the completion of the recruitment process.

         

        Personal data collected for due diligence purposes is retained for the duration of the contractual business relationship and up to ten years after its termination, in accordance with legal and regulatory requirements.

         

        In certain cases, we may be legally required to retain personal data beyond standard retention periods. This applies, for example, to ongoing or threatened litigation, regulatory investigations, or compliance with financial and tax regulations.

         

         

        Rights of users (data subjects)

         

        What are your rights as a data subject?

         

             

          • Right of access: You have the right to request confirmation from the controller regarding whether your personal data is being processed, as well as access to such data and information about its processing, including any transfers to third countries

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          • Right to rectification: You have the right to request the controller to correct any incorrect or incomplete personal data relating to you

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          • Right to erasure ("Right to be Forgotten"): You have the right to request the prompt deletion of your personal data if it is no longer necessary for the purposes for which it was collected. You may also request erasure if you withdraw consent, object to processing (where no overriding legitimate interest exists), or if your data is being unlawfully processed. This right also applies where the controller is legally required to delete your data or if it was collected in relation to online services.

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          • Right to restriction of processing: You have the right to request that the controller restricts the processing of your personal data under certain circumstances, such as when you contest its accuracy or object to processing, pending verification

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          • Right to withdraw consent: You have the right to withdraw your consent to the processing of your personal data at any time, where processing is based on your express consent. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn

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          • Right to object: You have the right to object at any time to the processing of your personal data if it is based on the legitimate interest of the controller or a third party. If your data is processed for direct marketing purposes, you have the absolute right to object to such processing.

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          • Right to lodge a complaint with the supervisory authority: If you wish to lodge a complaint, you may contact the data protection authority in your country of residence. Swiss residents may contact the Federal Data Protection and Information Commissioner (FDPIC), while EU residents can approach their national supervisory authority

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        How can you exercise your rights?

         

        In order to exercise your rights or file a complaint, please use the Data-related enquiries form available on our website or contact privacy@litasco.com.

         

        Data protection contact

         

        Please do not hesitate to contact us via our Data-related enquiries form available on our website, or by contacting our LITASCO Group Data Protection Responsible via email to privacy@litasco.com for any information or with any suggestions regarding data protection.

         

         

         

         

         

         

         

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        Technical details

         

        Log files

         

        Each time you use the internet certain data is automatically transferred from your browser and stored by us in so-called log files:

         

        • Information about the browser type and the version used;

        • The user's operating system;

        • The user's internet service provider;

        • The user's IP address;

        • The date and time of access;

        • Websites from which the user's system accesses our website;

        • Websites that are retrieved by the user's system through our website;

        • Name of the downloaded file;

        • Volume of data transferred;

        • A report as to whether the download was successful.

         

        The log files are stored by us in order to investigate defects and for security reasons. They are stored for up to 20 days, after which they will be deleted. Log files that must be retained for longer periods for evidence purposes are excluded from deletion until the applicable incident has been reviewed and may in particular cases be passed along to investigating authorities.

         

        In addition, log files are used by our web analysis tools in order to provide statistical data. You can find more information on the "web analysis tools" section of this document.

         

        Cookies

         

        Cookies are small text files that are sent whenever a webpage is visited and are stored in the user's browser. If the corresponding webpage is visited again, the user's browser will send back the content of the cookie, thereby enabling the user to be recognised.

         

        What cookies do we use and for what purpose?

         

        We use cookies in order to make our website more user-friendly as well as to measure and analyse the usage of our website. Some elements of our website require identification of the browser accessing the site which is retained after switching to a different page. We also use cookies on our website that enable analysis of user browsing habits.

         

        For how long are cookies stored in the browser?

         

        Some cookies are automatically deleted at the end of the browser session (so-called session cookies), others are stored in the user's browser for a specified period of time or indefinitely, the latter only being deleted upon user action in browser settings (so-called temporary or permanent cookies).

         

        Blocking or cancelling cookies?

         

        • By using the link provided below, you can see whether cookies from various providers have been activated and object to the collection or analysis of your data using their cookies: www.youronlinechoices.com;

         

        • It is possible to object to various cookies in a blanket fashion, including in particular those of US providers, by clicking on the following link: optout.networkadvertising.org;

         

        • Comprehensive information concerning cookies may be found on the following user portal: http://www.allaboutcookies.org.

         

        Absolutely essential cookies

         

        Some cookies are essential in order for us to be able to securely provide our online services. This category includes, for example, cookies:

         

        • that are used in order to identify or authenticate our users;

        • that temporarily store certain information entered by users (e.g., content of an online form);

        • that save particular user preferences (e.g., search or language settings).

         

        Web analysis tools

         

        To make our website more user-friendly and to conduct market research we need statistical information which is collected by the web analysis tools.

         

        The usage profiles generated by the tools using analysis cookies, or from an analysis of the log files, are not cross-referenced with personal data. The tools either do not use the IP addresses of users at all or abbreviate them immediately after collection. The providers of web analysis tools only process data as processors in accordance with our instructions and not for their own purposes.

         

        For each web analysis tool, you can find information regarding the corresponding provider, as well as how to object to the collection and processing of data through the tool. Please note in relation to tools that work with opt-out cookies that the opt-out function is device- or browser-specific and generally only applies for the specific end device or browser used. In addition, you can also prevent usage profiles being generated overall by deactivating cookies in general.

         

        • Google Analytics: Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). We use Google Analytics along with the additional IP address anonymization function offered by Google: This means that IP addresses will generally already by anonymised by Google within the EU, and only in exceptional cases not until they reach the USA, and that in any case they will only be stored in abbreviated form. You can object to the collection and analysis of your data through this tool by downloading and installing the browser plugin available at the following link:

        tools.google.com/dlpage/gaoptout?hl=de;

         

        • Yandex Metrica: Yandex Metrica is provided by Yandex N.V., Ulitsa Lva Tolstogo 16, Moscow, Russia 119021. You can object to the collection and analysis of your data through this tool by downloading and saving the opt-out cookie available at the following link: https://yandex.com/support/metrica/general/opt-out.html.

         

        Technical information regarding browser settings

         

        By using the privacy settings of your browser, you can prevent third parties from being able to monitor your browsing habits. In order to do so you need to activate the private mode. In addition, it is also useful to deactivate or restrict cookies in your browser settings. You can completely prevent the loading of plugins by using add-ons (script blockers) for your browser.

         

        Further details can be found in your applicable browser instructions:

         

        • Internet Explorer: Instructions under https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11-win-7;

        • Mozilla Firefox: Instructions under https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;

        • Google Chrome: Instructions under https://support.google.com/chrome/answer/95647;

        • Safari: Instructions under http://help.apple.com/safari/mac/8.0/#/sfri11471 .

         

        Online contact forms

         

        The individuals and companies are invited to use our online contact forms for submitting requests and documents linked to, for example, job application, tenders or commercial related demands.

         

        Upon finalization of your request, the data submitted will be transferred to our IT platform and processed by LITASCO Group or LUKOIL Group entities or third party service provider insofar as we have a legitimate interest in doing so or you have provided your consent. This data will only be processed for the intended business purpose and will be deleted when storage is no longer necessary, unless stated otherwise by regulatory or legal authorities.

         

        If you have any questions regarding the processing of your personal data, please use the data-related contact form available on our website or contact us directly at privacy@litasco.com.

         

        Third-party links

         

        Our website may contain links to external websites, not controlled by LITASCO Group or LUKOIL Group (e.g.: social media). Note that this privacy notice does not apply to those external websites. We advise you to carefully read the privacy notices of those sites in case you wish to know how your data is processed when you are visiting external web pages.