LUKOIL Lubricants Europe Privacy Statement
This Privacy Statement was published May 16th 2018.
In LUKOIL Lubricants Europe we are committed to protect and respect your privacy in compliance with EU-General Data Protection Regulation (GDPR) 2016/679, dated April 27th 2016. This privacy statement explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. This Privacy Statement applies to the use of our products and to our sales, marketing and customer contract fulfilment activities. It also applies to individuals seeking a job in LUKOIL Lubricants Europe.
Who are we?
LUKOIL Lubricants Europe GmbH is the European lubricants division of PJSC LUKOIL. PJSC LUKOIL is the first private owned Russian company which is fully listed on the London Stock Exchange. The main business is production, trading, export of lubricants as well as import of other
oil products and chemicals.
Today LUKOIL LUBRICANTS is one of the leaders in the development and production of lubricants made for the most demanding conditions. The wide range of products meet the most advanced operating requirements and specifications of foreign vehicle and equipment manufacturers. LUKOIL is the largest private oil company worldwide by production and got over 150 new approvals from leading OEM manufacturers.
The European market is supplied with finished lubricants from LUKOIL Lubricants Europe´s three owned blending plants in Europe. They are located in Hamina, Finland, in Vienna, Austria and in Ploiești, Romania.
The three blending plants distribute lubricants to North, Central and Western Europe through LUKOIL Branch Offices and an extensive dealer network.
Our company’s headquarter is located in Austria/Vienna, and our subsidiaries are based in Sweden, Finland, Germany, Italy, Slovakia, Hungry and Czech Republic. The headquarter’s registered office address is Uferstrasse 8, Vienna 1220.
For more information LUKOIL Lubricants Europe Data Protection coordinator can be contacted by Email: LLE.Privacy@eu.lukoil.com
When do we collect personal data about you?
When you are using our products.
When you interact with us in person, through correspondence, by phone, by social media, or through our website.
When we collect personal information from other legitimate sources, such as third-party data aggregators, LUKOIL Lubricants Europe marketing partners, public sources or social networks. We only use this data if you have given your consent to them to share your personal data with others.
We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and LUKOIL Lubricants Europe.
Why do we collect and use personal data?
We collect and use personal data mainly to perform direct sales, direct marketing and customer service. We also collect data about suppliers, partners and persons seeking a job or working in our company.
We may use your information for the following purposes:
Send you marketing communications which you have requested. These may include information about our products and services, events, activities, and promotions of our associated partners’ products and services. This communication is subscription based and requires your consent.
Send you information about the products and services that you have purchased from us.
Perform direct sales activities in cases where legitimate and mutual interest is established.
Provide you content and venue details on a webinar or event you signed up for.
Reply to a ‘Contact me’ or other web forms you have completed on one of our LUKOIL Lubricants Europe websites (e.g. to download a whitepaper).
Follow up on incoming requests (customer support, emails, chats, or phone calls).
Provide you with access and services related to a Free Trial of LUKOIL Lubricants Europe products.
Provide access to our Customer Service Center or the LUKOIL Lubricants Europe Community website.
Perform contractual obligations such as order confirmation, license details, invoice, reminders, and similar. The contract may be with LUKOIL Lubricants Europe directly or with a LUKOIL Lubricants Europe partner, dealer network or Branch Offices.
Notify you about any disruptions to our services.
Contact you to conduct surveys about your opinion on our products and services.
Process a job application.
Our legal basis for collecting personal data
Collecting personal data based on consents
The collection of personal data based on consent from the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual.
Individual consents will always be stored and documented in our systems.
Collecting personal data based on contracts
We may use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.
Collecting personal data based on legitimate interest
We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between LUKOIL Lubricants Europe and the individual person has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.
What type of personal data is collected?
We may collect name, phone number, title and email address, in addition to your company’s name and contact information. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our websites we may collect IP-address and actions taken on the site.
If you upload photos or videos, add posts or comments, etc. on our Community website, the information can be read by anyone with access to the Community site and used for purposes over which LUKOIL Lubricants Europe or you have no control. Therefore, LUKOIL Lubricants Europe is not responsible for any information you submit to the Community website. If you apply for a job at LUKOIL Lubricants Europe, we collect the data you provide during the application process. LUKOIL Lubricants Europe does not collect or process any special categories of personal data, such as public unique identifiers or sensitive personal data.
How long do we keep your personal data?
We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes. This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.
What are your rights related to your personal data?
You have the following rights with respect to your personal data:
The right to request a copy of your personal data that LUKOIL Lubricants Europe holds about you.
The right to request that LUKOIL Lubricants Europe corrects your personal data if inaccurate or out of date.
If you are a customer or partner and you have registered a profile on our Community website, you may update your user profile by logging into Community and selecting “Edit Profile”.
If you are a customer and using LUKOIL Lubricants Europe CRM Online, you may update your user profile in LUKOIL Lubricants Europe by logging into LUKOIL Lubricants Europe and choose the option “Show my contact info” to edit your
details.The right to request that your personal data is deleted when it is no longer necessary for LUKOIL Lubricants Europe to retain such data.
The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications:
If you want to withdraw your consent to e-marketing, please make use of the link to manage your subscriptions included in our communication. Please note that you may still receive system messages and administrative communications from
LUKOIL Lubricants Europe, such as order confirmations, system messages and notifications about your account activities.The right to request that LUKOIL Lubricants Europe provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
Any query about your Privacy Rights should be sent to LLE.Privacy@eu.lukoil.com
The use of cookies
We use cookies and web beacons (‘Website Navigational Information’) to collect information as you navigate the company’s websites. Website Navigational Information includes standard information from your web browser, such as browser type and browser language; your Internet Protocol (“IP”) address; and the actions you take on the company’s websites, such as the web pages viewed and the links clicked.
This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.
By law, we may store cookies on your device if they are strictly necessary for the operation of this site. For all other cookie types we need your Consent. Consent must be given through a clear affirmative action, such as clicking an opt-in box or choosing settings or preferences on a settings menu. Simply visiting a site doesn’t count as consent. Please also view our cookie policy.
Do we share your data with anyone?
We do not share, sell, rent, or trade your information with any third parties without your consent, except from what is described below:
Third-party Service Providers working on our behalf:
We may pass your information on to our distributors, agents, sub-contractors and other associated organizations with the purpose of them providing services to us and to you on our behalf. In this case we ensure that they respect your privacy in compliance with EU-General Data Protection Regulation (GDPR).
If required by law:
We will disclose your personal information if required by law or if we, as a company, reasonably believe that disclosure is necessary to protect our company’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.
Use of sub-contractors (processors and sub-processors)
We may use sub-contractors to process personal data on our behalf, we are responsible for making sure they commit themselves to adhere to this Privacy Policy and applicable data protection legislation by signing a Data Processing Agreement.
Any process of Personal Data outside the EU/EEA area by us must be in accordance with the EU Privacy Shield Framework, EU Standard Contractual Clauses for transfer to third countries, or another specifically stated lawful basis for the transfer of personal data to a third country.
Changes to this Privacy Statement
LUKOIL Lubricants Europe reserves the right to amend this Privacy Statement at any time. The applicable version will always be found on our websites. We encourage you to check this Privacy Statement occasionally to ensure that you are happy and agree with any changes.
If we make changes that significantly alter our privacy practices, we will notify you by email or post a notice on our websites prior to the change taking effect.
Your right to complain with a supervisory authority
If you are unhappy with the way in which your personal data has been processed, you may, in the first instance contact us and send your complaint to: LLE.Privacy@eu.lukoil.com
If you remain dissatisfied, then you have the right to apply directly to your national supervisory authority for a decision. The supervisory authority in Austria can be contacted at:
www.dsb.gv.at
dsb@dsb.gv.at
The use of cookies
We use cookies and web beacons (‘Website Navigational Information’) to collect information as you navigate the company’s websites. Website Navigational Information includes standard information from your web browser, such as browser type and browser language; your Internet Protocol (“IP”) address; and the actions you take on the company’s websites, such as the web pages viewed and the links clicked.
This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.
By law, we may store cookies on your device if they are strictly necessary for the operation of this site. For all other cookie types we need your Consent. Consent must be given through a clear affirmative action, such as clicking an opt-in box or choosing settings or preferences on a settings menu. Simply visiting a site doesn’t count as consent.
This page uses different cookie types. Some cookies are placed by third parties that appear on our pages. In case of any questions or if you need further information kindly contact:
LLE.Privacy@eu.lukoil.com
Facebook Plug-In
This website uses social plug-ins of the social network facebook.com, which is operated by Facebook Inc., 1601 South California Avenue, Palo Alto, CA 94304, USA. After the plug-in is activated, a direct connection is established between your browser and the Facebook server. When this happens, Facebook is informed that you, with your IP address, have visited our site. If you click on the Facebook "Like" button while you are logged in to your Facebook account, you can link the content of our pages to your Facebook profile. This lets Facebook associate visiting our pages with your user account.
Please note that we as the provider of the pages are not notified of the content of the data transmitted or of the use thereof by Facebook. For more information on this, please see the Facebook data protection/privacy statement at www.facebook.com/about/privacy. If you do not wish Facebook to be able to associate visiting our pages with your Facebook user account, please log out of your Facebook user account.
YouTube Plug-In (Videos)
Our Website uses plug-ins from the video portal YouTube, which is operated by YouTube (represented by Google Inc.), LLC, Cherry Ave., USA. If you call up the Internet pages from our Website and the pages have such plug-ins, a connection is made to YouTube servers. If you are logged into YouTube as a member, YouTube matches your information with your personal user accounts. You can only prevent this by logging out before using the plug-in. We would like to point out that as a provider of the pages, we have no knowledge of the content of the transmitted data or its use by YouTube. For more information, please see the privacy policy of Google at: www.google.com/policies/privacy/
Google Analytics
This website uses Google Analytics, a web analysis service from Google Inc. ("Google") Google Analytics used so-called "cookies", text data which is stored on your computer which enables an analysis to be made of your use of the website. Information generated by the cookie about your use of this website (including your IP address) is sent to a Google server in the USA and stored there. Google will use this information to assess your use of the website, to compile reports about website activities for the website operator, and to offer further services related to Internet usage.
Google may if necessary forward this information to third parties, in so far as this is legally prescribed and provided that these third parties process data on Google's behalf. Google will in no case use your IP address in connection with other Google data. You can prevent the installation of cookies through a relevant setting on your browser software; we should advise you however that in this case you may not be able to use all the functions of this website fully. By using this website, you consent to the processing of the data collected by Google in the manner previously outlined for the purpose previously stated.
For more information, please see the Terms of Service of Google Analytics at www.google.com/analytics/terms/us.html.
Twitter:
Our page incorporates functions of the service Twitter. These functions are offered by Twitter, Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA. When you use Twitter and the "Re-Tweet" function, the websites you visit are linked to your Twitter account and disclosed to other users. In the process, data are transmitted to Twitter, as well. Please note that we, as the provider of the pages, are not notified of the content of the data transmitted or of the use thereof by Twitter. For more information concerning this topic, please see the Twitter data protection/privacy statement at www.twitter.com/privacy. You can change your privacy settings on Twitter by accessing your account settings at www.twitter.com/account/settings.
LinkedIn:
This website uses social plug-ins of the social network linkedIn.com, which is operated by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. After the plug-in is activated, a direct connection is established between your browser and the LinkedIn server. When this happens, LinkedIn is informed that you, with your IP address, have visited our site. If you click on the “LinkedIn” button while you are logged in to your LinkedIn account, you can link the content of our pages to your LinkedIn profile. This lets LinkedIn associate visiting our pages with your user account. Please note that we as the provider of the pages are not notified of the content of the data transmitted or of the use thereof by LinkedIn. For more information on this, please see the LinkedIn privacy policy at www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv .If you do not wish LinkedIn to be able to associate visiting our pages with your LinkedIn user account, please log out of your LinkedIn user account.
