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PRIVACY NOTICE – B2B CUSTOMERS AND LEADS

We hereby inform you on our current practices applicable to the processing of your personal data (the “Personal Data”) collected by the relevant company within the Petronas Lubricants group of companies (“Petronas”, “we”, or “us”) in the carrying out of the commercial and business relationship with us.

Data controller

Depending upon your location, a company of the Petronas Lubricants group of companies will be acting as controller of your Personal Data. If you are our customer, the relevant company of the Petronas Lubricants group of companies is indicated in the privacy notice made available to you. If you are not our customer, you may find the relevant company of the Petronas Lubricants group of companies acting as controller on the basis of your location and country selection.

Data protection officer and contact details

For Petronas Lubricants group of companies located in the European Union:

Data protection officer (“DPO”): Giulia Filattiera

E-mail: [email protected]

Source of Personal Data

Petronas collects and processes your Personal Data that originate from the following sources: (i) directly from you; and/or (ii) from the company you work for.

Categories of Personal Data

The term Personal Data refers to the Personal Data provided to Petronas prior to enter into a commercial relationship and then in the carrying out of the business relationship with us. Such Personal Data include:

Company’s data

Petronas collects company’s data such as corporate name, tax code, number of employees, and contact details.

Biographical data relating to the legal representatives and/or other persons in the organization

Petronas collects biographical data such as name, surname, contact details, job position, years of employment and powers of attorney of relevant persons in the customer’s organization.

Economic data

With respect to our customers, Petronas collects economic data in connection with the commercial agreement such as bank details, information on sales targets and related bonus payments, opinions on the products, and other information shared with us in the course of the business relationship.

Purposes of the processing and legal basis

Your Personal Data will be collected and processed for the following purposes:

1. to facilitate the performance of your commercial agreement and any related activities in connection therewith. The legal basis for processing is the performance of a contract;
2. for administrative purposes connected with the performance of the commercial agreement or the fulfilment of legal requirements (g., accounting or tax requirements) or for complying with any requests from competent authorities. The legal basis for processing is the compliance with a legal obligation to which Petronas is subject
3. to share the Personal Data with other PETRONAS Group’s companies for internal administrative and accounting purposes. The legal basis for processing is the legitimate interest of Petronas as part of a group of undertakings in transmitting personal data within the group for internal administrative purposes, including the processing of customers’ personal data;
4. in the event you complete a purchase order or require a service from us, we may use your e-mail address to inform you about offers and promotions on similar products and/or services. The legal basis is the legitimate interest of Petronas to carry out soft marketing activities to its existing customers as per Article 13 par. 2 of the Directive 2002/58/EC. Opt-out: you can opt-out at any time, free of charge, by using the unsubscribe link in the e-mails you receive;
5. to deliver via post brochures, posters, customer testimonials, and/or product samples and to contact you from time to time with information about current or new products, commercial opportunities and services or events sponsored by PETRONAS Group that may be of interest to you, without using automated calling and communication systems or similar means (g., one-to-one call between our and your commercial departments, site visits). The legal basis is the legitimate interest of Petronas to carry traditional marketing activities vis-à-vis customers and leads. Opt-out: you can opt-out at any time, free of charge, by using the following link: [LINK]; and
6. in the event you complete a purchase order or require a service from us, we may use the e-mail address of the representative that is the contact point in the commercial relationship with us, to reach out to you in order to survey your satisfaction in connection with the purchased products and/or the services. The legal basis is the legitimate interest of Petronas in gauging quality of its products or services as perceived by its existing customers with a view to enhancing performances.

In case you give your consent, your Personal Data will be collected and processed also:

1. to contact you from time to time for marketing purposes – by using automated calling and communication systems or similar means (fax, SMS, social messaging apps) as per Article 13 par. 1 of the Directive 2002/58/EC – with information about current or new products, commercial opportunities and services or events sponsored by PETRONAS Group that may be of interest to you, as well as to carry out market researches, and also to allow you to participate to prize contests and rewards programmes. The legal basis for processing is your consent and any refusal to provide the consent will have no effects other than our inability to inform you of any initiatives that may be of interest to you; and
2. to communicate your Personal Data to selected commercial partners that will contact you from time to time (g., by means of commercial newsletters or otherwise) with information about their products and services. Our selected commercial partners are companies and organizations in the lubricants industry (e.g., lubricant distributors). The legal basis for processing is your consent and any refusal to provide the consent will have no effects other than the inability of being contacted by our selected commercial partners.

In case you wish to get in touch with us by completing the relevant online forms in our website (e.g., ‘contact us’ forms), your Personal Data will be collected and processed also:

1. to get in touch with you, provide you with any information requested and attend any queries submitted in your message (g., general information, technical support, etc.). The legal basis for processing is your consent.

The following table summarizes the Personal Data processed by Petronas in the carrying out of the business relationship and the respective purposes of and legal bases for processing.

Possible consequences for failure to provide Personal Data

The processing of your Personal Data is necessary for Petronas to establish a business relationship and to execute and perform the commercial agreement, as well as to comply with its legal obligations. The refusal to provide your Personal Data may prevent Petronas from establishing a business relationship and to execute and perform the commercial agreement, as well as to comply with its legal obligations.

Data Recipients

Your Personal Data are processed by Petronas personnel and, if necessary or functional to fulfilling the purposes indicated above, your Personal Data may be processed by third parties that may also be specifically appointed by us as data processors.

The categories of recipients to whom your Personal Data may be disclosed are the following:

1. IT providers;
2. consultants and professionals in case of potential disputes or if deemed necessary to maintain security, prevent or investigate frauds and abuse;
3. public entities and authorities, exclusively for the purpose of fulfilling legal and regulatory obligation;
4. other PETRONAS Group companies;
5. marketing and travel agencies in connection with the organisation of the events and/or promotional activities;
6. transport/logistic services providers; and
7. any other third party with respect to potential acquisition and/or sale of any of Petronas business or assets or other business combination.

Under certain circumstances, your Personal Data may be transferred to PETRONAS Group companies or to third parties that may also be specifically appointed by us as data processors, also outside the EEA. In such case, we ensure that appropriate safeguards are being in place, including standard data protection clauses adopted by the EU Commission, in order to guarantee an adequate level of protection, or that derogations for specific situations apply. You may request to obtain evidence of the safeguards implemented by contacting us at [email protected].

Data Retention

Your Personal Data will be retained for no longer than it is necessary to fulfil the purpose of its collection (e.g., the performance of the commercial agreement). On the basis of the Personal Data concerned, the following retention periods apply:

• your Personal Data collected by Petronas for the purpose of carrying out the business relationship will be retained for no longer than 10 years after the termination of the business relationship;
• your Personal Data collected by Petronas for the purpose of carrying out promotional/marketing activities will be retained for no longer than 2 years.

We may retain your Personal Data for a further period in the event it is deemed necessary to comply with our legal obligations, to meet regulatory requirements, to resolve potential or actual disputes, to maintain security, prevent or investigate frauds and abuses.

Automated decision

We will not make any decision based solely on automated processing of your Personal Data which produces legal effects concerning you or significantly affects you.

Security measures

We limit the access to your Personal Data to our employees, who we reasonably believe need to have access to the same in connection with your commercial relationship and/or to carry out legitimate purposes of processing. We have reasonable security measures in place to support protection against the loss, misuse, alteration of the information under our control and we ensure that our systems adhere to appropriate market security standards.

Rights of the data subject

You have the right to obtain from us confirmation as to whether or not your Personal Data are being processed by us, and, where that is the case, you have the right to request us access to and rectification or erasure of the same or restriction of processing, and to object to the processing, as well as the right to data portability, at any time. With respect to the right of data portability, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format and to request the transmission of those data to another data controller.

In respect of the processing of Personal Data based on your consent, you have the right to withdraw your consent at any time. You have also the right to (i) partially withdraw your consent by limiting the means of communication we may use to contact you (e.g., phone calls, or e-mails, etc.) and/or the marketing activities we may carry out (newsletters, or market researches, etc), and (ii) opt-out from traditional marketing activities.

In respect of the processing of Personal Data based on our legitimate interest, you have the right to opt-out.

In case you wish to access or correct your Personal Data, intend to exercise any of your rights, or should you have any questions about this Privacy Notice, you may contact us at [email protected].

Supervisory Authority

In the event of a breach of applicable data protection laws you have also the right to file a complaint with the competent data protection authority, in particular in the EU Member State of your habitual residence, place of work, or of an alleged infringement of applicable data protection laws.

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Petronas Lubricants group of companies list