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Privacy notice
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