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 * Privacy notice

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PRIVACY NOTICE

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Protecting your privacy is very important to Glencore International AG and its
affiliates ("Glencore", "our", "us" or "we").  This Privacy Notice details how
we collect, use and manage personal data about the individual directors,
officers, employees, board members and beneficial owners of our prospective and
existing customers and counterparties, their other associated individuals, about
prospective and existing customers and counterparties who are themselves
individuals and about Glencore’s candidates. When we refer to "you" or "your" in
this Privacy Notice, we are referring to you (as a prospective or actual
customer, candidate or counterparty) and/or your associated individuals.


WHAT PERSONAL DATA DO WE PROCESS

As a prospective or existing customer, candidate or counterparty of Glencore, we
may collect personal data about you, your directors, officers, employees,
beneficial owners, board members and other associated individuals. This includes
names, current and previous addresses, date of birth, telephone number and email
address, job title / role with / shareholding in your organization, information
about your business, and information relevant for money laundering and sanctions
compliance checking purposes.

In some circumstances, we may also collect identification information about you
or your directors, officers, employees, beneficial owners or other associated
individuals in order to verify your or their identity, such as driver’s license
and passport information. We collect this information where it is reasonably
necessary to comply with the law or if it is required to administer aspects of
the relationship between you and us.

For our candidates, we may also collect education and employment information,
such as employment and education history, information provided in CV and cover
letter, professional qualifications, references, background checks, interview
evaluations, as well as identification details (such as document copies, e.g.
passport, work permit) and other similar data.

You may need the consent of your associated individuals if you disclose their
personal data to us. You must provide them with a copy of [or link to] this
Privacy Notice before you give us their personal data.

We may also collect details of the interactions that you have with us, together
with any other information that you choose to give us.


WHY DO WE PROCESS PERSONAL DATA

We may collect your and your associated individuals' personal data for a range
of different purposes as a prospective or existing customer, candidate or
counterparty, including:

 * to support our procurement and onboarding processes, including complying with
   our internal policies (particularly policies designed to prevent money
   laundering and sanctions violations); 
 * to provide our products and services to you, or to provide you with a quote
   or offer for our products and services;
 * to communicate with you about a potential or existing engagement with
   Glencore;
 * to answer your enquiries and provide any information or documents you ask
   for;
 * for administrative, planning, product or service development and delivery
   purposes; and
 * to update our records and keep your contact details up to date.


If you choose not to provide your personal data to us, we may not be able to
engage in a business relationship with you, either partly or at all.


WHAT ARE THE LEGAL BASES FOR OUR PROCESSING OF YOUR PERSONAL DATA

The legal bases on which we process personal data are:

 * The processing is necessary for compliance with a legal obligation; or
 * The processing is necessary in connection with any contract that you (as an
   individual) may enter into with us, or to take steps prior to entering into a
   contract with us; or
 * We have a legitimate interest in carrying out the processing in order to
   further our business interests or for the purposes of compliance with our
   policies, in particular in relation to money laundering and sanctions
   violations (to the extent such legitimate interest is not overridden by your
   interests or fundamental rights and freedoms).


HOW DO WE COLLECT YOUR PERSONAL DATA

We will collect your personal data in a number of ways, including:

 * directly from you (where it is practicable to do so);
 * from third parties including employers, authorised representatives, agents or
   third parties who are authorised to share personal data, and publicly
   available sources of information, such as address validation software and
   telephone directories; and
 * from third parties (some of whom may be our agents) who have identified you
   as someone who may wish to purchase our products or provide services to
   Glencore.


TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA

We may share your personal data with Glencore affiliates and disclose your
personal data to third parties during the course of business, including: 

 * your authorised representatives (agents, consultants, intermediaries);
 * financial institutions (for payment processing or KYC purposes);
 * government and regulatory authorities (where required or authorised by law);
   and
 * our service providers, such as information technology suppliers, contractors,
   debt collection agencies and our professional advisors, such as accountants,
   auditors and lawyers. 


Where appropriate, we ask that these third parties hold, use and disclose your
personal data in accordance with any applicable data protection laws.
 


INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

The disclosures discussed above include transfers of personal data which is
subject to Swiss, UK or European Economic Area data protection laws to countries
outside Switzerland, the UK and the EEA – Glencore is an international group of
companies and we have affiliates and service providers, and relationships with
counterparties and governmental authorities, in many countries. This includes
transfers to countries, which are not regarded by the European Commission (or
the equivalent authorities in other jurisdictions) as ensuring an adequate level
of data protection, but we take appropriate steps to ensure that the transfers
comply with the applicable data protection laws. Note in particular that, where
we transfer personal data subject to Swiss, UK or EEA data protection laws to
our service providers or Glencore affiliates in those other countries, we do so
on the basis of data transfer agreements designed to protect the privacy of your
information, in forms approved for this purpose by the European Commission.


HOW LONG DO WE KEEP YOUR PERSONAL DATA

We will keep your personal data for as long as we need to keep it for legal
compliance or business purposes. Please contact info@glencore.com for more
information about our record retention practices.


HOW YOU CAN ACCESS OR CORRECT YOUR PERSONAL DATA

We take reasonable steps to ensure the Personal Data we collect, use and
disclose about you is correct, complete and relevant for the purposes for which
we collect it. 

You have a right to request access to your personal data and to request for it
to be updated or corrected.  In some circumstances you also have the right to
request that your personal data is deleted, to object to our processing of your
personal data and/or to request that we limit the purposes for which we continue
to process your data.

In some circumstances, we may refuse to give you access to your personal data,
or to comply with your other requests, in accordance with the Swiss Federal Act
on Data Protection and other relevant laws. 

To protect your personal data we will always confirm your identity with you
before giving you access to any information or making any changes. 

You can make a request by contacting Glencore by email at info@glencore.com.  


RESOLVING COMPLAINTS

If you have a complaint about how we have dealt with your personal data, please
contact us using the details below. We will investigate your complaint and
provide you with a formal response, usually within 30 days. If the circumstances
of your complaint are complex and we need additional information or time to
provide you with a formal response, we will contact you to let you know. 

If you are not satisfied with our response, then you may file a report with the
Federal Data Protection and Information Commissioner at
https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/kontakt.html or lodge a
formal complaint with your local data protection authority. 

If you have any comments or questions or would like further information about
the international data transfer agreements that we have in place, please contact
your regular Glencore contact or email us at info@glencore.com.  

Last update: 9 January 2023

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30/05/2024 18:33 GMT
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