Valid from 26.03.2024
1. General
LITASCO SA is taking data privacy matters seriously and would like to assure you that we are processing your data for its intended use only and that keeping your data safe is one of our top priorities.
LITASCO SA reserves the right to amend this Privacy Notice from time to time. You should therefore read this Privacy Notice regularly. The date of the then-current version (valid from) may be found at the beginning of this Privacy Notice.
The data controller is LITASCO SA, registered at: rue Kazem-Radjavi 3, 1202 Geneva, Switzerland on behalf of itself and its subsidiaries (together LITASCO Group).
What is personal data?
Personal data encompasses any information relating to an identified or identifiable natural person (e.g., name, address, telephone number, date of birth, email address, family information).
In general, you can use our website without providing any personal data. The use of certain website features may require sharing of personal data for us to be able to provide you with an adequate and personalized service. These features include, for instance, signing up for a newsletter, submitting your CV for a career opportunity or lodging a commercial enquiry.
Personal data cannot be, therefore, processed as a matter of course, but rather only under certain circumstances and for specific purposes. You do not have to provide us with this data in case you do not wish to do so.
Note that we are collecting IT personal data from log files and cookies, which are detailed in the relevant sections, further down in this Privacy Notice.
Due Diligence Requirements (for the onboarding and monitoring of new or existing counterparties)
To comply with legal and regulatory requirements, to ensure that LITASCO Group complies with trade-control and sanctions rules, anti-money laundering and/or anti-bribery and anti-corruption laws and other requirements, LITASCO Group entities run due diligence on candidates for employment, potential counterparties, its shareholders and owners, ultimate beneficial owners, directors, employees. LITASCO Group carry out screening on a preliminary (before entering business relationship) and on a regular (during business relationship) basis. The data provided for the purposes of due diligence is being processed through automatic screening data basis from reputable service providers or governmental official channels (e.g. sanctions screening webpages of state authorities).
The screening (onboarding) does not involve profiling mapping or automated decision making in relation to potential candidates for employment or counterparties.
When is personal data processed in connection with LITASCO SA's website?
In order to provide our online services, LITASCO SA or authorized third parties process personal data in connection with:
Website: Personal data is processed through log files, cookies and analysis tools of social media and other providers;
Online contact forms: Personal data is processed via contact forms and transferred to the relevant entity or service.
When is personal data processed in connection with LITASCO Group Due Diligence Requirements?
Name, surname, career details, source of wealth, other data which might be required to undertake due diligence analysis to fulfil legal and regulatory requirements, including establishing the identity of ultimate beneficial owner of (potential) counterparty;
The personal data is being shared with LITASCO Group either on a voluntary or being sourced from official public sources and licensed reputable database (e.g. sanctions screening webpages of state authorities). We hereby presume that whoever is the person sharing person data information of the data subject for Due Diligence Requirements has obtained consent of the data subject.
For what purposes is personal data processed?
- Optimizing the website (e.g.: market research and internet audience measurement);
- Personalizing the website for users;
- Recruitment;
- Commercial enquiries;
- Other business-related activities;
- Ensuring data security for the users of our website;
- Respond to data-related enquiries;
- Business execution, organization and management;
- Compliance with legal and regulatory requirements (e.g. trade control and sanctions, anti-money laundering, anti-bribery and anti-corruption laws).
On what legal basis does LITASCO SA process personal data?
We process your personal data on the basis of our legitimate interest, which is directly linked to a business activity. This includes, for example, processing for purposes of recruitment, due diligence or commercial enquiries.
To the extent personal data is processed based on a legal obligation, this serves as the legal basis for processing. This may be the case for example relating to the disclosure of personal data to third parties or storage or retention periods.
Your consent to the processing of personal data serves as the legal basis. The processing based on a personal consent still gives you the right to withdraw it at any time.
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 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.
Is personal data disclosed to third parties?
In general, we only disclose your personal data to LITASCO Group or LUKOIL Group or 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 of the users of our website in accordance with our instructions. 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, self-certification by the recipient for the EU-U.S. Privacy Shield, 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 SA by third party Corporation, data held by LITASCO SA may be transferred to the acquiring company in line with relevant legislations.
For how long does LITASCO SA 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 we have a legitimate interest in doing so, to provide you with our customized website and related services, for a maximum period of 10 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 gathered for the purpose of due diligence is stored during the duration of the contractual business relationship and no longer than 10 years after.
Note that we might be required to retain data for longer periods in order to comply with legal obligations, for example in cases related to court litigations.
What are your rights as a data subject?
- Right of access: Users have the right to request confirmation from the controller as to which personal data concerning them is being processed and whether these data are being transmitted to a third country;
Right to rectification: Users have the right to request the controller to correct any incorrect or incomplete personal data relating to them;
Right to erasure: Users have the right to request the controller to erase promptly any personal data relating to them if these data are no longer necessary for the purposes for which they were collected or processed. The same applies if the data subject withdraws consent or objects to the processing in absence of an overriding legitimate interest of the controller or if these data are being unlawfully processed. The data subject may additionally execute this right in case where the controller is subject to a legal obligation to delete these personal data or when the personal data have been collected in the context of information society services;
Right to restriction of processing: Users have the right to request the controller to restrict processing;
Right to withdraw consent: Users have the right at any time to withdraw their consent to the processing of any personal data relating to them for any specific purpose or purposes if that processing is based on their express consent. The withdrawal of consent will not affect the lawfulness for the processing on the basis of that consent carried out prior to the withdrawal of consent;
Right to object: Users have the right at any time to object to the processing of any personal data relating to them if the processing occurs on the basis of the legitimate interest of the controller or of a third party. Where personal data are processed for direct marketing purposes, users have an absolute right to object to such processing at any time;
Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with a data protection authority. In order to do so, you may contact the data protection authority competent for your place of residence.
How can you exercise your rights?
In order to exercise your rights, please use the Data-related enquiries form available on our website or contact privacy@litasco.com.
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.