Privacy Notice - Customers

What is the purpose of this document?

We place great value on honesty and integrity. We are committed to protecting, safeguarding, and respecting your privacy.

This privacy notice references “we”, “us” and “our” which means Essar Oil UK Limited (trading as “EET Fuels”) and its group of subsidiary companies (referred to as the “group” below).

This privacy notice describes how we collect and use personal information about you during and after dealing with us in your business capacity as a current or potential supplier, customer, business partner or investor.

We are a data "controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

We may update this notice at any time

Who does it apply to?

This privacy notice applies to individuals who work for, or on behalf of, or who are shareholders of our current, prospective or former business counterparties such as customers, suppliers, business partners, including within non-Essar operated joint ventures, as well as investors and shareholders.

Data protection principles

We will comply with data protection law, which says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely in a manner to ensure appropriate security of the personal data including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage
We as the controller shall be responsible for and be able to demonstrate compliance with the Data protection Principles.

The kind of information we hold about you

We may collect and process the following data about you:

Private contact information (such as name, postal or e-mail address, and phone number) only if necessary; or
Business contact and other information (such as job title, department, name of organisation and your dealings with Essar on behalf of yourself or your organisation).
Photo Identity document: Any Form of Photo identity document
Verification data: such as utility bills.

Information we receive from other sources:

We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

The Purposes for which we process your personal data

We process personal data covered by this Privacy Notice for the following purposes:

Screening

In addition, in order to comply with legal and regulatory obligations, to protect Essar’s assets and employees/contractors and specifically to ensure that Essar can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening (pre-contract and on a periodic basis post-contract) on owners, shareholders and directors of our business counterparties. This screening takes place against publicly available, or government issued sanctions lists and media sources.

The screening does not involve profiling or automated decision-making in relation to the business counterparties or potential counterparties.

Business execution - including providing, researching, developing and improving products or services; concluding and executing agreements with Business Customers, Suppliers and Business Partners; recording and settling services, products and materials to and from an Group company; managing relationships and marketing such as maintaining and promoting contact with existing and prospective customers, account management, customer service, and development, execution and analysis of market surveys and marketing strategies;
Organisation and management of the business - including financial management, asset management, mergers, demergers, acquisitions and divestitures, implementation of controls, management reporting, analysis, internal audits and investigations.
Health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of Essar companies and staff, authentication of individual status and access rights; or
Legal and/or regulatory compliance - including compliance with legal or regulatory requirements.

or for a secondary purpose where it is closely related, such as:

storing, deleting or anonymising personal data;
fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defence of claims; or
statistical, historical or scientific research.

Why do we process your personal data?

The personal data covered by this Privacy Notice are only processed:

in order to take steps at the request of an individual prior to entering into a contract.
where it is necessary to comply with a legal or regulatory obligation to which the relevant Essar company/companies is subject to;
where it is necessary for the purposes of the legitimate interests pursued by the relevant Essar company/companies, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual/s; or
(only if legally required) with the explicit consent of the individual.

In those cases where processing is based on consent, and subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.

Who will we share the personal data with?

The personal data covered by this Privacy Notice are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:

Other companies within the Essar group of companies.
Authorized third party agents, service providers, external auditors and/or subcontractors of Essar; or
A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Essar company/companies is subject to or as permitted by applicable local law.

Any person to whom Essar proposes to transfer any of its rights and/or duties.

Transfers of your personal data to other countries

Where your personal data is been transferred to companies within the Essar Group and/or to third parties located outside of your country (including outside of the European Economic Area and the UK) we take organisational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data.

Data Security

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Additionally, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

With some exceptions which are explained in supplementary privacy statements, any personal data that is required for the purposes of our dealings with business counterparties will be held during the duration of those dealings and/or the contractual relationship, or if submitted for another reason (e.g. in connection with a tender) for as long as the purpose is still relevant to us and in any event will be held in accordance with legal and regulatory requirements.

In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate business purpose to retain it.

Your rights in relation to your personal data

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO in writing.

Please contact DPO@eetfuels.com

Data Protection Officer (DPO)

We have appointed a DPO to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You can do this by email via DPO@eetfuels.com or in writing to Essar Oil (UK) Limited, 5^th Floor, The Administration Building, Stanlow Manufacturing Complex, Ellesmere Port, Cheshire, CH65 4HB United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) with respect to data protection issues.

Contact details

Information Commissioner's Office

Wycliffe House Water Lane

Wilmslow Cheshire United Kingdom

SK9 5AF Website: www.ico.org.uk Phone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

Changes to this Privacy Notice

This Privacy Notice was last updated in July 2024We reserve the right to update this privacy notice at any time, We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact the DPO by sending an email to DPO@eetfuels.com.