Safe Harbor Privacy Policy

Privacy Policy under U.S.- EU Safe Harbor

Total Petrochemicals & Refining USA, Inc. (“TPRI”) recognizes the importance of individual privacy and adheres to the U.S.- EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding Personal Information.

Notice: Prospective Employees may be required to provide certain Personal Information including legal name (first name/last name), prior legal names/aliases, name of town/city of residence, country(ies) of citizenship and/or permanent residency, and country of birth (“Personal Information”). TPRI may use this information to perform security and background checks, except where prohibited by law, including for review prior to admittance to TPRI premises, facilities, or other controlled physical or electronic environments. This information is necessary in order for TPRI to comply with U.S. laws, regulations and programs.

Choice: Except as permitted by this statement, TPRI does not disclose, give, sell or transfer Personal Information received from prospective employees to third parties, unless required by law.

Onward Transfers: TPRI may share Personal Information provided by prospective employees with third party service providers and other agents who act on our behalf to assist in the screening process. Where Personal Information is shared with a third party service provider, TPRI will provide the information pursuant to a written contract, will choose a third party that provides sufficient safeguards with respect to technical and organizational security measures governing the relevant processing and will ensure that the third party acts on TPRI’s behalf and under its instructions. TPRI’s service providers and agents do not have the right to use the Personal Information for their own purpose or to share same with third parties unless instructed by TPRI. In addition, these entities are required to use and maintain Personal Information in a manner consistent with this Statement. TPRI may also provide, share, or transfer Personal Information with its affiliates and subsidiaries located in the U.S., or abroad, where data protection laws may not provide an equivalent level of protection to the laws in the prospective employee’s home jurisdiction.

TPRI may also provide, share or transfer Personal Information in connection with the sale, assignment or transfer of all or portions of TPRI or its assets. Transfers between TPRI and its affiliates and subsidiaries, are subject to the provisions in this Statement regarding notice and choice and TPRI will take steps to ensure its affiliates and subsidiaries provide sufficient guarantees with respect to technical and organizational security measures governing the Personal Information.

TPRI may also disclose Personal Information or other data if required to do so by law, including without limitation, by search warrant, subpoena or court order.

Access: Prospective employees have the right to access, modify, correct or delete Personal Information provided to TPRI and TPRI will endeavor to comply with such request within a reasonable amount of time. However, unless prohibited by applicable law in the prospective employee’s country of residence, TPRI may withhold information that would be protected under U.S. or other applicable law by the attorney-client or attorney work product privileges and remove some information from a prospective employee’s file before providing access if necessary, in TPRI’s judgment, to protect the privacy of another individual. TPRI will maintain Personal Information for as long as it is required to do so by applicable law(s).

Security: TPRI takes reasonable steps to protect Personal Information provided to us including limiting access to such information. TPRI has put into place appropriate physical and operational safeguards to help secure Personal Information; however, TPRI cannot guarantee the security of Personal Information.

Questions: Inquiries should be directed to Manager, Human Resources Services, Total Petrochemicals & Refining USA, Inc., 1201 Louisiana, Suite 1800, Houston, TX 77002. If a question or inquiry is not satisfactory addressed, you may contact TPRI’s Assistant General Counsel by mail at Assistant General Counsel, Total Petrochemicals & Refining USA, Inc., 1201 Louisiana, Suite 1800, Houston, TX 77002 to resolve your concern. Prospective employees also have the right to contact their local or national data protection or other authorities in the event that they remain dissatisfied after attempts to address their concerns directly with TPRI. TPRI commits to cooperating with these authorities in any investigation resulting from a complaint under this Statement and to complying with any advice or recommendations they may offer. Contact information for these authorities may be obtained from TPRI’s U.S. Legal Department (Import/Export Compliance Group). Additional information pertaining to the U.S.-EU Safe Harbor program can be found at http://export.gov/safeharbor/.