1. Scope

This Privacy Policy informs you of how TOTSA TotalEnergies Trading SA, route de l’Aéroport 10, P.O. Box 276, 1215 Geneva, Switzerland (“TOTSA”), as data controller, may collect and process your data when you visit the https://trading.totalenergies.com website (the “Website”).

TOTSA takes the protection of your personal data seriously, meaning that TOTSA processes your personal data with due care and in accordance with applicable data protection laws.

2. Consent

By accepting this Privacy Policy, you explicitly agree to the processing of your personal data for the purposes mentioned hereinafter and be legally bound by and explicitly consent to this Privacy Policy, as it may be amended from time to time.

Wherever processing of your personal data by TOTSA is based on your consent, you have the right to withdraw your consent at any time by contacting TOTSA at the contact details below. Withdrawal of your consent does not affect the lawfulness of processing of your personal data based on consent before your withdrawal. Should you withdraw your consent to the processing of your personal data, please note that such withdrawal may prevent TOTSA from providing you with all or part of the access to the Website.

3. Personal data collected and method of collection

TOTSA may collect data that your browser sends whenever you visit the Website. This data may include information such as your computer’s Internet Protocol address, browser type, browser version, the pages of the Website that you visit, the time and date of your visit, the time spent on those pages and other statistics.

TOTSA uses cookies and similar technologies to collect such information. A cookie is a special packet of data designed to help a website operator determine in particular whether a particular user has visited the website previously and what that user’s preferences are. Your browser’s help resources tell you more about managing cookies. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, you may refuse a cookie and still navigate the Website; however, other functionalities or portions of the Website may be impaired. After termination of the visit to the Website, you can always delete the cookie from your system if you wish.

4. Purpose of the processing

If you visit the Website, the use of cookies and similar technologies will help TOTSA improve and optimize the functionality, stability and security of the Website, and provide you with a good experience when you browse the Website.

Your personal data might also be used and disclosed to protect the security and integrity of the Website and for TOTSA to comply with legal and regulatory obligations, including court orders and exercise and/or defense of legal rights, reporting to and/or being audited by regulatory bodies, record keeping obligations.

5. Legal basis

When you visit the Website, processing of your personal data by TOTSA is based on your consent that you give to TOTSA when you accept the disclaimer notice displayed before you can access the Website.

In certain cases, the processing of your personal data might be based on the legitimate interests of TOTSA (e.g. to protect the security and integrity of the Website) or those of any third party recipients that receive your personal data or a legal obligation to which TOTSA is subject.

6. Storage duration

TOTSA will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected or provided, keeping in mind the following factors:

  • the activity for which it is being processed;
  • any legal, regulatory or contractual requirements; and/or
  • the time in which any litigation or investigations might arise.

7. Your rights

You are entitled to submit TOTSA a request in order to:

  • have access to your personal data and obtain information in relation to its processing;
  • request the completion or correction of any personal data that is incomplete or inaccurate;
  • restrict or object to the processing of your personal data;
  • erase your personal data;
  • receive, or request TOTSA to transmit to another designated person or entity, your personal data in a structured, commonly used and machine-readable format; and
  • wherever processing of your personal data by TOTSA is based on your consent, withdraw your consent to the processing of your personal data.

The exercise of some of your rights (e.g. objection to the processing, withdrawal of any previously given consent, etc.) may in some cases prevent TOTSA from providing you with all or part of the access to the Website.

Please note that the above rights can be limited – for example, when TOTSA needs your personal data to comply with the law or assert or defend against legal claims or has other compelling legitimate grounds for the processing that override your interests, rights and freedoms. TOTSA may therefore be able to continue processing your personal data even after you have chosen to withdraw your consent or objected to the processing of your personal data to the extent required or otherwise permitted by law.

To exercise any of the abovementioned rights, please contact TOTSA at the contact details below.

If requests are manifestly unfounded or excessive, in particular because of their repetitive character, TOTSA reserves the right to either charge a reasonable fee taking into account the request or refuse to act on the request.

TOTSA may request the provision of additional information to confirm your identity if it has reasonable doubts concerning the identity of the person making the request.

8. Security

While TOTSA strives to maintain reasonable and appropriate technical and organizational security measures to ensure an adequate level of protection for your personal data, please remember that no method of transmission over the Internet, or method of electronic storage is 100% secure and TOTSA therefore cannot guarantee its absolute security.

If, despite the security measures, a security breach would occur that is likely to result in a risk for your personal data, TOTSA will inform you, as well as relevant authorities when required by applicable data protection laws, about the security breach as soon as reasonably possible.

9. Service providers

TOTSA may employ third party companies and individuals to perform Website-related services or to assist TOTSA in analysing how the Website is used.

These third parties may have access to your personal data only to perform these tasks on behalf of TOTSA and are obligated not to disclose or use it for any other purpose. TOTSA concluded written agreements with all its contractual partners that may have access to your personal data imposing data protection obligations that are no less protective than its commitments described in this Privacy Policy and in accordance with applicable legal requirements.

10. International transfer

TOTSA is a Swiss company. If you are located outside Switzerland, please note that your personal data will be transferred to and processed in Switzerland. Swiss data protection laws may differ from those of your jurisdiction.

Should TOTSA need to transfer your personal data to a country that is not regarded as ensuring an adequate level of protection for personal information by the European Commission and/or the Swiss Federal Data Protection and Information Commissioner, TOTSA will put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your personal data is adequately protected.

11. Amendments to the Privacy Policy

TOTSA reserves the right, at its sole discretion, to amend this Privacy Policy at any time and without prior notification. The amended Privacy Policy shall be effective immediately upon posting of the amended Privacy Policy on the Website. TOTSA will require your consent to the amended Privacy Policy through the disclaimer notice displayed before you can access the Website. Please note that TOTSA may not be able to provide you with all or part of the access to the Website as long as you have not accepted the amended Privacy Policy.

12. Contact

For any question in relation to this Privacy Policy, you can contact TOTSA at [personaldata[at]totsa.com].

TOTSA is the data controller’s representative in the European Union and can be contacted at [personal-data[at]totsa.com].

TOTSA is committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that TOTSA has not been able to assist with your complaint or concern, this Privacy Policy is without prejudice of your right to make a complaint to the competent data protection authority.