Personal Data and Cookies Policy

Personal Data and Cookies Charter

Welcome to the Website https://services.totalenergies.ng/ (hereinafter the “Website”)

The Personal Data and Cookies Charter (hereinafter “Charter”) aims to inform you about your rights that you can exercise regarding the processing of your data and describes the measures that we take to protect these data.

TotalEnergies Marketing Nigeria Plc (TEMNPlc) is the “data controller” regarding managing the website and responsible for personal data processing on the website https://services.totalenergies.ng/.

These processing operations are carried out in accordance with the applicable law including the Nigeria Data Protection Act (NDPA), 2023.

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

When visiting the website, you may need to provide us with personal data.

Purpose	Categories of personal data	Legal basis	Retention Period
Respond to your information requests (e.g. press contacts, general information requests)	Identification data (name, first name, e-mail, phone number)	The processing of your data is based on our legitimate interest.	Your data is kept for as long as necessary for processing.
Requests to subscribe to e-mail alerts	Identification data (name, first name, e-mail, phone number)	The processing of your data is based on our legitimate interest.	Your data will be kept for the duration of your subscription to the requested e-mail alerts. You have the right to unsubscribe at any time.
Respond to your requests for information regarding your status as an individual shareholder or potential shareholder, or as an investor in TotalEnergies	Identification data (name, first name, e-mail, phone number)	The information collected is necessary for the implementation of the pre contract with TotalEnergies SE, without which it cannot be executed.	Your data is kept for a maximum period of three (3) years from your last contact with us, or for the duration of our contractual relationship if applicable; and may be kept in an intermediate archive if necessary.
Statistics	Connection data (IPs, Logs), Navigation	You authorize us to process your data. This information is necessary to enable your request to be processed, otherwise it cannot be processed. You can withdraw your consent at any time without jeopardizing any processing operations that have already been completed, by writing to the following address: contact form	Your data is kept for a maximum of 13 months. For more information, please refer to article 5. Cookie management.

2. Recipients of the data

In order to process your personal data according to the Charter, your personal data may be communicated to one or more of the data controller's departments or to TotalEnergies Group subsidiaries and one or more partners, independent distributors or subcontractors: Marketing service providers, software service providers.

3. 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.

As part of the services provided on the site and to respond to your requests, your data, such as your name, first name and e-mail address, may be transferred to TotalEnergies Group entities located outside the European Union.

In order to ensure adequate protection of personal data originating from the European Economic Area that may be transferred to TotalEnergies Group entities located outside the European Economic Area, Binding Corporate Rules (BCR) have been adopted.

For transfers of personal data not covered by BCRs to countries outside the European Economic Area, other measures are put in place to ensure adequate data protection.

If you would like more information on our BCRs please see the next tab. For information on the other measures in place to ensure adequate protection, please write to the contact address indicated at the end of this page.

4. 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.

5. Cookies management

A cookie is a file that allows a website to record information relating to your computer’s navigation on it in order to make your visits to this website smoother.

Cookies are text files that are stored on your computer's browser. They allow access to various information about you. Some of them belong to the publisher of the Website (First party) and some to third parties.

The table below details each cookie used on https://services.totalenergies.ng/.

We enable cookies once you have given your consent, except for technical cookies that are necessary to provide the service you request on the Website.

Categories of cookies and trackers	Name of the cookies and trackers	Objectives of the cookies and trackers	Editor	Retention period of the cookies and trackers
Statistics	atidvisitor, atuserid, atauthority	Analysis of the traffic on the website.	AT Internet	Up to 6 months
Statistics	_cs_s, _cs_id, _cs_c	Analysis of the traffic on the website.	Content Square	Up to 6 months
Advertising	IDE, DSID doubleclick.net	Analysis of the traffic on the website.	doubleclick	Up to 6 months
Technical and functional	__cfduid	Optimisation of website performance	Cloudflare	10 days
Technical and functional	preferred-language	User's language preference	Drupal	1 year
Technical and functional	utag_main	Used by the Tealium tag manager	Tealium	1 year
Technical and functional	CONSENTMGR	GDPR consent choices, used by Drupal	Tealium	180 days
Technical and functional	user-country-slb	Protection of access to the SLB page	Drupal	Session
Advertising	utag_main	Used by Tealium	Tealium	6 months
Advertising	_kuid_	Targeted advertising	Salesforce DMP	6 months
Social networks	_fbp, fr,	Allows the display of advertising products	Facebook	90 days
Social networks	lang, AnalyticsSyncHistory, UserMatchHistory, bcookie, lidc, li_gc, bscookie	Customisation of the user experience on the platform	LinkedIn	Session or up to 6 months
Social networks	personalization_id	Allows the visitor to share content from the website on their Twitter profile	Twitter	6 months

How to withdraw your consent?

On your first connection to the website https://services.totalenergies.ng/, you will be asked to give your consent to the use of non-essentials cookies and/or to make setting. If you subsequently wish to change your choices, you can manage your cookies by going to the section at the bottom of the page of our Website or application or via a reminder button called “cookies”.

To delete cookies already stored, please refer to the procedure provided by your operating system (Windows, OS X, etc.).

6. Your rights / Contact

In accordance with the current regulations, you have the right to access and correct your data and to give post-mortem instructions. Regarding processing based on the performance of a contract or the implementation of pre-contractual measures, you have also the right to delete your data and to data portability and you can request a restriction of processing.

You can exercise these rights and consult us regarding the processing of your personal data via email at [email protected] OR by post at the following address:

TotalEnergies Marketing Nigeria Plc.

c/o Data Protection Officer
TotalEnergies House
4 Churchgate Street

Victoria Island, Lagos State

Nigeria

If you feel, after contacting us, that your rights have not been respected, you can lodge a complaint with the competent supervisory authority, Nigeria Data Protection Commission (NDPC): [email protected]

Summarized version of TotalEnergies' Binding Corporate Rules

1. Introduction

The TotalEnergies Group (or “Total”) promotes a culture and practices regarding the protection of personal data1, 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.

2. 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.

3. 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 Group subsidiaries as well as shareholders (hereafter “data subjects”).

4. Protection principles

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

Lawfulness

Any processing3 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 Group 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 Group

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 transfers4 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 Group 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 Group (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.

5. 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:

An e-mail to: [email protected]

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.

6. Governance

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

A Corporate Data Privacy Lead who monitors and follows compliance actions at the Group 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.

7. 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 Group’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 Group Internal Audit Direction also integrates the control of the personal data protection pattern into its periodic audit plan.

8. Changes to Total’s rules

If necessary, our BCRs may be completed or updated.

9. 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]

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.

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 Group 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 Total’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 Group 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 Total’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 Total’s BCRs. If, in the course of a transfer of Personal Data outside the EEA, the Data importer fails to observe Total’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 Total’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]

(NDPC)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.

2. TotalEnergies’ 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”).

3. 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.