NJORD traders is a "controller" in relation to its use of your personal data. This is a legal term which means that we make decisions about how and why we use your personal data and, because of this, we are responsible for making sure it is used in accordance with applicable data protection laws (in certain jurisdictions, we may not be called a “controller” under the applicable laws, but the legal essence is the same. For example, in the People’s Republic of China (PRC), the concept of “data processor” is equivalent to “controller”). The controller in respect of personal data processed in connection with the www.LyondellBasell.com website (the “Website”) is NJORD traders For the purposes of the other processing activities set out in this Privacy Statement, the controller will be the relevant NJORD traders entity providing you and/or your organization with products/services (or, in the case of suppliers/vendors, the NJORD traders entity receiving products/services from you) or any website or digital platform or sending you marketing communications. Click here for a list of the NJORD traders operating entities and their contact details.

In this Privacy Statement, when we talk about “personal data” or “personal information”, we mean any information that relates to an identifiable natural person – in this case, you.

The term “process” means any activity relating to personal data, including, by way of example, collection, storage, use, consultation and transmission.

You should read this Privacy Statement so you know what personal data we collect about you, what we do with it and how you can exercise your rights in connection with it. You should also read any other privacy notices that we give you that might apply to our use of your personal data in specific circumstances from time to time.

Personal Data We Collect 

What types of personal data do we collect and where do we get it from?

The personal data we process about you broadly falls into five main categories: (i) Contact Information; (ii) Background and Identity Information; (iii) Customer / Supplier Information; (iv) Marketing Preferences; and (v) Website Information / Browsing and Device Usage Information. Just because these categories are noted below, that does not necessarily mean that we will collect all such personal data about you. What we collect will depend on how you engage with us, and thus the purpose which we have your personal data for.

We collect your personal data from various sources. The table below sets out the different types of personal data that we collect and the sources we collect it from.

Please note that your personal data is a prerequisite for our engagement with you, therefore, if you do not provide us with your Contact Information we may not be able to provide you with any information you request, and if you do not provide us with your Contact Information, Background and Identity / Regulatory Information or certain Customer / Supplier Information, we may not be able to provide goods or services to you, or work with you as one of our suppliers (as applicable).

Data Protection and Privacy Rights

What are your privacy rights and how can you exercise them?

You may access the personal data about you that we store. You may also review or make certain corrections to the personal data we store about you. You may also request the deletion of personal data about you or object to its processing. In limited circumstances, you may have data portability rights in relation to certain personal data we hold about you. These rights are not unlimited and the exercise of these rights, and the limits upon them, are briefly set out in the table below.

Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we need to rely on – in which case, we will let you know. Your withdrawal of your consent won’t impact any of our processing up to that point.

Where our processing of your personal data is necessary for our legitimate interests, you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.

Legal Basis

What do we do with your personal data, and why?

We use your personal data for a number of different purposes in connection with your use of the Website, the provision of services or goods from us to you, or from you to us, your communication or other engagement with us and the management and administration of our business. We must always have a “lawful basis” (i.e. a reason prescribed by law) for processing your personal data. The personal data purposes table below sets out the purposes for which we process the different categories of your personal data and the corresponding lawful basis for that processing. The purposes applicable to you will vary according to the relevant NJORD traders controller of your personal data (as explained in the introductory paragraph above) as well as the applicable local laws. For some processing activities, we consider that more than one lawful basis may be relevant – depending on the circumstances.

Please note that where our processing of your personal data is either:

• necessary for us to comply with a legal obligation; or
• necessary for us to take steps, at your request, to potentially enter into a contract with you, or to perform it, and you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our contract or engagement with you.

If you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our contract or engagement with you, except for the circumstance where there are other parts of our contract or engagement with you that do not require such personal data and those parts of our contract or engagement with you can nevertheless still be entered into or performed.

Communicating with you

We will use your personal data to communicate with you:

• in relation to any purchases you make with us;
• to administer our relationship with you;
• to respond to any questions or complaints that you may have; and
• to invite you to take part in market research or request feedback on our products and services.

From time to time and with your opt-in consent (if required), we will provide you with information about our products, services, promotions and/or offers which may be of interest to you. Such communications will be sent either by email, text, post or telephone.

If you do not wish to receive such communications, you can refuse to give your consent (where your consent is required) or opt-out at any time by either following the instructions within the communication or by contacting us.

Security

How do we keep your personal data secure?

We will put in place appropriate security measures to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.

However please note that, in relation to any personal data you submit to us online, we cannot guarantee the security of data sent to us in this way. Transmission of data over the internet is at your own risk. You are responsible for keeping any passwords you use to access NJORD traders platforms safe. 

Retention

How long do we keep your personal data?

We will only retain your personal data for a limited period of time, and for no longer than is necessary for the purposes for which we are processing it. This will depend on a number of factors, including:

• any laws or regulations that we are required to follow;
• whether we are in a legal or other type of dispute with each other or any third party;
• the type of information that we hold about you; and
• whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.
• the period of time during which any claims or proceedings can be brought against us or a member of the group to defend against any such claims. 

Sharing and Transferring Personal Data

Who do we share your personal data with, and why?

Sometimes we share your personal data with third parties where permitted by law, including the following:

Inside NJORD traders group:

We are part of the NJORD traders , which includes a number of companies and operations globally. Therefore, we will need to share your personal data with other companies in the NJORD traders for our general business management purposes and, in some cases, to meet our customer needs where providing services across branches/locations and/or for authorizations/approvals with relevant decision makers, reporting and where systems and services are provided on a shared basis. You can find out more about the group and companies in the group here: lyb.com

Access rights between members of the NJORD traders group are limited and granted only on a need to know basis, depending on job functions and roles.

Where any NJORD traders group companies process your personal data on our behalf (as our processor), we will make sure that they will process your personal data within the scope of your consent to us, or based on other lawful basis under the applicable laws and have appropriate security standards in place to make sure your personal data is protected.

Outside NJORD traders group:

From time to time we may ask third parties to carry out certain business functions for us, such as the administration of our Website and IT support. These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those functions. Before we disclose your personal data to these third parties, we will impose a contractual obligation on them to ensure that they process your personal data within the scope of your consent to us, or based on other lawful basis under the applicable laws and have appropriate security standards in place to protect your personal data. Examples of these third party service providers include our outsourced IT systems software and maintenance, back up, and server hosting providers. 

In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right for the purposes set out above, where the relevant disclosure is in relation to:

• • services provided to you or us by a third party acting independently to NJORD traders but which has a relationship with NJORD traders, for example certain payment fraud checking services;
  • the purchase or sale of our business (or part of it) in connection with a share or asset sale, for which we may disclose or transfer your personal data to the prospective seller or buyer and their advisors; and
  • the disclosure of your personal data in order to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers or others. 

We have set out below a list of the categories of recipients with whom we are likely to share your personal data:

• • IT support, website and data hosting providers and administrators;
  • payment processors in relation to purchases you make with us;
  • consultants and professional advisors including legal advisors and accountants;
  • courts, court-appointed persons/entities, receivers and liquidators;
  • business partners and joint ventures;
  • insurers; and
  • governmental departments, statutory and regulatory bodies (including tax authorities).

Where is your personal data transferred to?

Since NJORD traders operates globally, we will sometimes need to transfer your personal data to recipients (either internally or externally, as set out above) in jurisdictions other than your own. Some of these jurisdictions may not provide the same level of protection to your personal data as provided in your jurisdiction.

If you are based in Europe and we transfer your personal data outside the European Economic Area, we will only make that transfer if:

• that country ensures an adequate level of protection for your personal data;
• the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments which amount to appropriate safeguards for your personal data;
• we have put in place appropriate safeguards to protect your personal data, such as a contract with the person or entity receiving your personal data which incorporates specific provisions as directed by the European Commission;
• the transfer is permitted by applicable laws; or
• you explicitly consent to the transfer.

If you are based in the PRC, please note that we will not provide your personal data in the PRC to any government authorities outside the PRC unless we have obtained the Chinese government’s approval. Where the data recipient outside the PRC is not a government authority, we will only make that transfer if:

• a proper data cross-border transfer agreement has been entered between us and the third-party, and where applicable, we will use standard contract clauses mandated by the PRC government;
• we have passed the PRC government-led personal data cross-border transfer security assessment, or
• we have completed personal data protection certification conducted by an accredited institution. 

Cookies

In some cases, we may use cookies and other tracking technologies described herein to collect personal information, or to collect information that becomes personal information if we combine it with other information.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information. 

Cookies set by the website owner or service provider (in this case, NJORD traders) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website or service you are using (such as advertising, interactive content and analytics). The third parties that set these third-party cookies can recognize your computer both when it visits the website or service in question and also when it visits certain other websites or services. 

We may also use other technologies similar to cookies, such as web beacons. These are tiny graphic files that contain a unique identifier that enable us to recognise when someone has visited the Website or opened an email we have sent them. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their function.

Why do we use cookies and other tracking technologies?

We use first party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as “strictly necessary” or “essential” cookies. Other cookies enable us and the third parties we work with to track and target the interests of visitors to the Website, and we refer to these as “performance” or “functional” cookies. Lastly, third parties serve cookies through our Website for advertising, analytics, and other purposes.  

For more detailed information on which cookies we use, click here.

Cookies are very important to help us make online services easier to use, to monitor the use of the Website and to help us improve services to you. Specifically, we may use certain cookies for security purposes, to tell us whether you have visited the Website before, to remember your language preferences, and to personalise your experience on the Website. Cookies also allow us to collect technical and navigational information, such as computer and connection information, browser type and version, operating system and platform details and the time of accessing the website. Cookies may enhance your online experience by saving your preferences while you are visiting a website.

Can you manage your cookies?

Yes, you have the ability to manage your cookie preferences.The information in this Cookie statement is provided to you in an open and transparent way, so that you can see how cookies are used to enrich your visitor experience and make an informed choice to allow their usage. However, if you wish to control and remove cookies, this can be done by clicking on the “Manage Cookie Preference” button below or via settings in your web browser. Most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which allows you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. However, please be aware that restricting cookies may impact the functionality of a website. Many of the interactive functions offered by websites are dependent on cookies and disabling or blocking cookies can prevent these services from working or reduce their usefulness.

Updates to this Privacy Statement

We may update this Privacy Statement from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. In the event of a material change which effects the processing of your personal data, we will contact you. We also encourage you to check this Privacy Statement on a regular basis.

If you have any questions about this Privacy Statement, please contact privacy@njordtraders.com.