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Personal datas and cookies

Personal Data & Cookies Charter

Welcome to the website https://www.remit.totalenergies.com. By connecting to or browsing the website, you agree that you have read, understood and accepted, without limitation or reservation, the Personal data and cookies charter (the “charter”) and our terms and conditions of use. Please note that other terms and conditions and Personal data and cookies charter apply to other TotalEnergies Company websites, and we recommend that you read them carefully.

The charter aims to inform you of the rights and freedoms that you can exercise in respect of our use of your personal data and describes the measures that we take to protect these data.

TOTALENERGIES S.E. is the “data controller” with responsibility for processing the personal data used to manage the website. These processing operations are carried out in accordance with the applicable law.
 

  1. Purpose of processing, legal basis, the period of storage and types of data collected

When you visit the website, you may need to provide us with a number of items of personal data, such as your first name and surname, in order to use the services available.

This processing of your data is based on our legitimate interest to provide you answer your request or provide you services.

 

Your personal data will not be processed subsequently in a way that is incompatible with the purposes described above or below the collection forms. Your data are kept for no longer than 2 years.

 

  1. Recipients of data

Your personal data may be communicated to one or more of the data controller's departments or to TotalEnergies Company companies and one or more partners, independent distributors or subcontractors.

 

  1. Data Transfers

Any transfer of data to a country outside the European Economic Area shall be carried out in accordance with the applicable regulations and in such a way as to protect your data appropriately. 

For the purposes of the services provided on this website, your data (first name, surname, e-mail address) [MR1] may be transferred to other TotalEnergies Company Companies located outside the European Union.

 

For this reason, the TotalEnergies Company has adopted “Binding Corporate Rules” (BCR) governing intra-Company transfers of personal data originating in the European Economic Area.

For data transfers not covered by the BCR, to countries outside the European Economic Area, other measures to ensure adequate protection are taken.

If you would like more information about our BCRs see below. [MR2] For more information about the other measures taken to ensure adequate protection, please write to the contact address specified below.

 

  1. Data security and confidentiality

The data controller takes appropriate steps to preserve the security and confidentiality of your personal data, including to prevent them from being distorted, damaged or disclosed to unauthorized third parties.

  1. Cookie management

6.1. Principle

A cookie is a file which enables a website to save information relating to your computer’s browsing of the website (page views, number of visits, bounce rate, traffic source, etc.), to make your visits to the website smoother.

You can at any time delete the cookies stored on your computer, object to the storage of new cookies and receive a notification before new cookies are stored by changing your browser settings using the instructions below (“Types of cookies, cookies and statistics, and settings”).

Please note that if you remove a cookie or object to the storage of cookies on your device, you may not be able to use some of the website's services.

 

6.2. Types of cookies, cookies and statistics, and settings.

The cookies that may be stored on your server when you browse the website are cookies which are intended solely to enable or facilitate electronic communication or which are strictly necessary to provide the service you are requesting (language cookies, login cookies, etc.), or statistics cookies or other cookies in accordance with the conditions below.

When cookies require your agreement before they can be saved, we ask you for this agreement via the “find out more” link displayed on the first page of the website that you land on, in which it is made clear that by continuing to browse the website you accept these cookies.

 

6.2.1. Which cookies are stored?[MR3] 

 

  • Cookies issued by the data controller

 

Cookie

Description

Duration

Site (has_js)

Contains information on the navigation session and gives the user access to the website

Deleted at the end of the session

Site (cookie_agreed)

Registers the user’s choice regarding cookies

13 months

Drupal.language

Drupal cookie configuration (language redirection)

7 days

Drupal_language_redirection

Drupal cookie configuration

1 year

Drupal.tableDrag.showWeight

Drupal cookie configuration

1 year

authorized_config

Allows knowledge of what services were rejected/accepted by the user

1 year

getaquote

Registers the user’s choice on the Find My Product webform

1 year

cookie-agreed

Cookie created by “Smile” to retain the user’s choice on cookies within the GDPR scope

1 year 1 day

 

  • Cookies issued by third parties

Cookie

Description

Duration

__unam

Cookie offered by ShareThis to activate content sharing

9 months

_trossion

Allows displaying of offers adapted to the interests of the user on the internet (doubleclick.net)

1 year et 1 month

_troRUID

Allows displaying of offers adapted to the interests of the user on the internet (doubleclick.net)

6 months

_troSYNC

Allows displaying of offers adapted to the interests of the user on the internet (doubleclick.net)

6 months

utag_main

Used by Tealium

1 an

 

  • Statistics cookies

Cookie

Description

Duration

xtant

Cookie used by AT Internet (Analytics) containing a technical value linked to the identified visitors management. Used by XITI.

6 months

xtat

Cookie used by AT Internet (Analytics) containing a textual ID linked to the identified visitor. Used by XITI.

6 months

xtvrn

Cookie used by AT Internet (Analytics) containing a technical value linked to the identified visitors management. Used by XITI.

6 months

atuserid

Cookie used by AT Internet (Analytics) to identify the website visitors in first-party cookie (PS : this cookie is not calling a domain name different from the website). Used by XITI.

1 year 1 day

dtCookie

Cookie used by Dynatrace (Analytics) containing the session ID (performance tracking)

1 minute

dtLatC

Cookie used by Dynatrace (Analytics) containing the session ID (performance tracking)

1 minute

dtPC

Cookie used by Dynatrace (Analytics) to identify the ideal location to measure performance (performance tracking)

1 minute

dtSa

Cookie used by Dynatrace (Analytics) like intermediate stocking to follow the user’s actions  (performance tracking)

1 minute

rxVisitor

Cookie used by Dynatrace (Analytics) to identify the visitor (performance tracking)

1 minute

rxvt

Cookie used by Dynatrace (Analytics) to identify the end of the user’s session (performance tracking)

1 minute

atidvisitor

Cookie used by AT Internet (Analytics) to collect the numsites (unique site IDs) seen by the visitor and to stock the visitor ID. Used by XITI.

6 months

dtCookie

Cookie used by Dynatrace (Analytics) containing the session ID (performance tracking)

1 minute

dtLatC

Cookie used by Dynatrace (Analytics) to measure the server latency (performance tracking )

1 minute

 

Statistics cookies are used to measure the number of visits, the number of pages viewed, users’ activity on the website and how often they return. The used statistics tool, AT Internet generates a cookie with a unique identifier, which is stored for no longer than 13 months. Your IP address is also collected in order to determine the town/city from which you are accessing the website. Your IP address is immediately anonymized after use so that you cannot be identified as a natural person. The statistical data on website visits are collected by the provider AT Internet and subsequently transferred to the data controller in an aggregated and anonymized form in a web interface to which it alone has access. The data collected are not transferred to third parties or used for other purposes. You can block these cookies at any time by opting out as described above by clicking the link http://www.xiti.com/en/optout.aspx     [MR4] 

6.2.2. How do you delete cookies, receive notification of their storage or change your browser settings?

 

  • How do you delete cookies already stored on your computer?
    • On your workstation:
    • On the C:\ drive select the Windows folder;
    • Open the “Temporary Internet Files” folder;
    • Select all files (CTRL A);
    • Choose the “delete” option.

 

  • How do you change browser settings to reject or be informed of the storage of cookies?
  • In the Internet Explorer 5 (Microsoft) browser: Select “Tools”, and then “Internet Options”. Click on the “Security” tab, then “Custom level” and scroll down to the “cookies” section. Next to “Allow cookies that are stored on your computer” select “Ask” to be notified or “Disable” to decline all cookies;
  • In the Internet Explorer 6, 7 or 8 (Microsoft) browser: Select “Tools”, “Internet Options”, “Privacy”, then the level you wish to apply;
  • In the Firefox browser: Click on “Tools” and select “Options”. In the “Privacy and security” tab, untick the box “Accept cookies from websites”;
  • In the Chrome (Google) browser: Click “Customize and control Google Chrome” and select “Settings”. Under “Privacy and security”, click on “Content settings” and enable “Block third-party cookies” ;
  • In the Safari browser: Select “Preferences” then “Privacy” and select one of the following options regarding “Cookies and website data”: “Always block”, “Allow from current website only”, “Allow from websites I visit”.

 

 

  1. Your rights /Contact

In accordance with current regulations, you have the right to access, rectify, delete and object to the use of your personal data.

You can ask for your personal data to be sent to you and you have the right to give instructions for the use of your personal data after your death.  You can also ask for restriction of the data processing, or of data portability.

You can exercise your rights and ask us about the processing of your personal data by contacting:

 

TotalEnergies Raffinage Chimie
2 place Jean Millier
92400 Courbevoie

 

Finally, you can lodge a complaint with the authority responsible for compliance with personal data protection obligations.

 

 

 

SUMMARIZED VERSION

OF TOTALENERGIES’S BINDING CORPORATE RULES

 

  1. Introduction

 

The TotalEnergies Company (or “TotalEnergies”) promotes a culture and practices regarding the protection of personal data[1], in accordance with the applicable laws. To this end, TotalEnergies has implemented Binding Corporate Rules (“BCRs”).

 

This document summarizes the data protection principles that apply under our BCRs and the rights granted by them.

 

  1. Purpose

 

Our BCRs are a set of internal binding rules, which are applicable to all of the TotalEnergies subsidiaries that have adopted them. They have been approved by the European data protection authorities.

 

They allow TotalEnergies subsidiaries to transfer personal data originating from the European economic area (“EEA”)[2] to TotalEnergies subsidiaries located outside of the EEA in compliance with the applicable law.

 

  1. Implementation scope

 

Our BCRs apply to all EEA-originating personal data processed by TotalEnergies subsidiaries including data relating to former and current employees, job applicants, clients and prospective clients, suppliers and sub-contractors and the staff of third companies acting on behalf of the Company subsidiaries as well as shareholders (hereafter “data subjects”).

 

  1. Protection principles

 

The following principles set out in our BCRs must be respected, among which: 

 

  • Lawfulness

 

Any processing[3] operation carried out has a legal basis, provided by the applicable law.

 

Personal data must only be processed for lawful, determined and legitimate purposes. The data must not be further processed in a way which is incompatible with those purposes.

 

  • Relevance

 

Personal data must be accurate and proportionate, in terms of quality and quantity, in relation to the purpose of the processing.

 

  • Transparency

 

Personal data must be obtained lawfully and loyally. Data subjects must be informed about the characteristics of the processing of their personal data and about their rights, unless this proves impossible or would involve disproportionate efforts.

 

  • Security

 

Personal data must be protected by appropriate security measures to limit the risks of unauthorized access, destruction, alteration or loss.

 

To do so, a set of internal norms apply, allowing to ensure the security and the confidentiality of personal data:

  • The usage Charter for the IT and communication resources, that requires to act in accordance with the regulation and with the confidentiality rules;
  • The Information Systems Security policy, that defines the governance mode of the security of information systems;
  • The Information Systems Security Reference System, that enumerates, through 19 detailed themes, the different requirements of the Company in terms of security of information systems;
  • The Information Protection policy, that presents the requirements relative to the protection of confidentiality, integrity and of the availability of the information held and exchanged within the Company.

When calling upon the services of a third party to process personal data, TotalEnergies subsidiary makes sure that the latter offers sufficient guarantees as regards the security and confidentiality of data.

 

  • Retention

 

Personal data must be retained only for a reasonable and not excessive period of time with regard to the purpose of the processing.

 

When the retention period expires, the data is destroyed, anonymized or archived.

 

  • International transfers[4] of personal data

 

TotalEnergies does not transfer personal data originating from a country of the EEA directly to a TotalEnergies subsidiary located in a third country which does not provide an adequate level of protection, unless such subsidiary has formally subscribed to the BCRs or uses another legal instrument recognized by the European Commission.

 

TotalEnergies does not transfer personal data originating from the EEA directly to a company not belonging to the Company located in a country which does not provide an adequate level of data protection (data controller or processor) without a legal basis under applicable law and instruments providing for sufficient safeguards, such as the standard contractual clauses.

 

Similarly, where a data importer further transfers personal data originating from the EEA to a company not belonging to the Company (data controller or processor) located in a country which does not provide an adequate level of data protection, the data importer shall enter into an agreement with this company whereby it commits to observe the principles of BCRs.

 

  1. Data subject rights

 

Under our BCRs, data subjects whose personal data are processed have the following rights:

 

  • Right of access to the data

 

  • Right to rectify, erase and lock data

 

  • Right to object to the processing

 

  • Right to limit the processing

 

[A comprehensive list of the rights granted by the BCRs is detailed in APPENDIX 1 hereafter].

 

Data subjects may exercise these rights by submitting a request using the contact details provided in the legal notice concerning the processing of their data. TotalEnergies subsidiaries undertake to give replies within the legal deadline about queries concerning the processing outside the EEA.

 

Moreover, if data subjects believe that a TotalEnergies subsidiary has failed to observe the BCRs, they have the right to lodge a complaint by sending:

 

 

or

 

  • A letter to TOTALENERGIES – DATA PROTECTION, Tour Coupole, 2 place Jean Millier, Arche Nord Coupole/Regnault, 92078 PARIS LA DEFENSE CEDEX.

 

Data subjects will be informed about the status of their complaint and of any further steps.

 

The internal complaint procedure is described in APPENDIX 2 hereafter.

 

The fact that data subjects may file a complaint with TotalEnergies does not affect their rights to lodge a complaint with the competent EEA data protection authorities or to bring an action before the courts of the EEA country where the TotalEnergies subsidiary responsible for exporting the personal data is established.

 

  1. Governance

 

An internal « personal data Protection network » is in charge of monitoring and controlling the implementation of the BCRs within the Company. It is composed of:

  • A Corporate Data Privacy Lead who monitors and follows compliance actions at the Company level;
  • Branch Data Privacy Leads who lead and coordinate compliance actions at the Branch level;
  • Data Privacy Liaisons who lead and coordinate compliance actions at the affiliate level.

 

  1. Internal control and audit

 

To ensure the proper application of our BCRs, some internal control and audit mechanisms have been implemented.

 

An annual internal control plan is defined by the personal data Protection network to assess the level of compliance of the Company’s processing regarding our BCRs. A reporting is also set up to report regularly on the actions plans that have been drawn up after evaluations.

 

Furthermore, the Company Internal Audit Direction also integrates the control of the personal data protection pattern into its periodic audit plan.

 

  1. Changes to TotalEnergies’s rules

 

If necessary, our BCRs may be completed or updated.

 

  1. More information

 

A copy of the comprehensive version of our BCRs as well as a list of TotalEnergies subsidiaries that adopted them can be obtained by sending an e-mail at: [email protected]

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX 1

THIRD PARTY BENEFICIARY RIGHTS

 

Our BCRs grant rights to Data Subjects to enforce the Rules as third-party beneficiaries.

 

More specifically, they may enforce the following principles according to the terms and conditions set out in our BCRs:

 

  • That any processing operation carried out within the Company must have a legal basis as provided for by Applicable Law;

     

  • That TotalEnergies must collect and process Personal Data for legitimate, specified and explicit purposes and must not further process any Personal Data in a way incompatible with the purpose for which they were collected;

     

  • That TotalEnergies must process Personal Data that are relevant and not excessive in relation to the purposes for which they are collected, and that these Data must be accurate and, where necessary, kept up to date;

     

  • That Data Subjects must be provided with easy and permanent access to the information relating to their rights under these BCRs;

     

  • That Data Subjects whose Personal Data originate from the EEA must have a right of access, of rectification and of objection to the processing of their Personal Data in accordance with Applicable Law;

     

  • That Data Subjects whose Personal Data originate from the EEA must not be subject to a decision that produces legal effects concerning them or significantly affects them and that is based solely on automated processing of Personal Data intended to evaluate certain personal aspects relating to them, unless that decision:

     

    • Is taken in the course of the entering into or performance of a contract, provided the request for the entering into or the performance of the contract, lodged by the Data Subject, has been satisfied or that there are suitable measures to safeguard his/her legitimate interests, such as arrangements allowing him/her to express his/her point of view; or

       

    • Is authorized by Applicable Law, which also lays down measures to safeguard the Data Subject’s legitimate interests;

       

  • That TotalEnergies must implement appropriate measures to guarantee the security and confidentiality of the Personal Data, having regard to the state of art and the cost of their implementation;

     

  • That TotalEnergies must conclude a written processing agreement with any service provider used to process Personal Data, specifying that the service provider shall act only under TotalEnergies’s instructions and shall implement appropriate security and confidentiality measures;

     

  • That TotalEnergies must not transfer Personal Data from a Member State of the EEA or originating from the EEA to a company not belonging to the Company and located in a Third Country which does not provide an adequate level of data protection (either an External Data Controller or Processor) without a legal basis under Applicable Law and instruments providing for sufficient safeguards;

     

  • That a TotalEnergies Subsidiary must immediately inform the Data exporter if this TotalEnergies Subsidiary deems that the legislation applicable in its jurisdiction is likely to prevent it from fulfilling its obligations pursuant to TotalEnergies’s BCRs, and have a detrimental effect on the guarantees offered by these BCRs, unless where prohibited by a law enforcement authority, in particular as a result of a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation;

 

  • That any Data Subject may lodge a complaint with TotalEnergies through the internal complaint mechanism in accordance with the terms set out in the Chapter « Complaint handling »;

     

  • That any TotalEnergies Subsidiaries that have subscribed to the BCRs must cooperate with the competent supervisory authorities, follow their recommendations regarding the international Transfers of Data in the event of a complaint or of a particular request from such authorities and accept to be audited by the supervisory authority of their country of establishment;

     

  • That any Data Subject may lodge a complaint with the National Supervisory Authorities or bring an action before the court of the EEA Member State where the Data exporter is established in order to enforce the above principles, and, where appropriate, to receive compensation for the damage suffered as a result of a breach of TotalEnergies’s BCRs. If, in the course of a transfer of Personal Data outside the EEA, the Data importer fails to observe TotalEnergies’s BCRs, the Data exporter will defend any claim, establish that the Data importer has not violated the BCRs, and pay compensation to the Data Subject for the damage suffered as a result of that violation.

 

 

APPENDIX 2

INTERNAL COMPLAINT HANDLING PROCEDURE

 

If a Data Subject believes that a TotalEnergies Subsidiary has not complied with TotalEnergies’s BCRs, he/she may file a complaint in accordance with the complaint procedure set forth in the relevant privacy policy or contract or pursuant to the procedure described below.

 

  1. How to make a complaint

     

    Data Subjects may file a complaint by sending:

     

  • An e-mail to: [email protected]

     

    or

     

  • A letter to TOTALENERGIES – DATA PROTECTION, Tour Coupole, 2 place Jean Millier, Arche Nord Coupole/Regnault, 92078 PARIS LA DEFENSE CEDEX.

     

    The complaint should clearly provide as much detail as possible about the issue raised, including:

     

  • The country and the TotalEnergies Subsidiary concerned, the Data Subject’s understanding of the violation of the BCRs, the redress requested;

     

  • The Data Subject’s full name and contact details as well as a copy of his/her identity card or any other identifying document;

     

  • Any previous correspondence on this specific issue.

     

  1. TotalEnergies’s response

     

    Within three months of TotalEnergies receiving a complaint, the appropriate Branch Data Privacy Lead (“BDPL”) shall inform the Data Subject in writing of the admissibility of the complaint; and if the latter is admissible, of the corrective actions that TotalEnergies has taken or will take in response. The appropriate BDPL shall ensure that, if necessary, appropriate corrective actions are taken to achieve compliance with the BCRs.

     

    The appropriate BDPL shall send a copy of the complaint and any written reply to the Corporate Data Privacy Lead (“CDPL”).

     

  2. Recourse process

     

    If the Data Subject is not satisfied with the response from the appropriate BDPL (e.g., the complaint has been rejected), he/she may refer to the CDPL by sending an e-mail or letter as indicated above. The CDPL will review the complaint and reach a decision within three months of the data the request was received. Following this period, the CDPL will inform the Data Subject whether the initial response has been upheld or communicate a new response.

     

    The fact that Data Subjects may file a complaint with TotalEnergies does not affect their right to lodge a complaint with the competent National Supervisory Authority or bring an action before the court of the EEA Member State where the Data exporter is established.

     

     

     

 

 

[1] Personal data means any information enabling the direct or indirect identification of a natural person.

[2] EEA means Member States of the European Union plus Iceland, Liechtenstein and Norway.

[3] Processing means any operation which is performed upon personal data, whether or not by automatic means (e.g: collection, recording, storage, destruction…).

[4] Transfer means all virtual and physical exchanges of EEA-originating personal data from one country to another.