ExxonMobil Global Services Company Safe Harbor Privacy Notice

ExxonMobil Global Services Company (“EMGSC”)

October 2, 2012

ExxonMobil Global Services Company (“EMGSC”) respects your privacy. EMGSC has certified that it abides by the Safe Harbor privacy principles as set forth by the U.S. Department of Commerce, regarding the collection, storage, use, transfer and other processing of Personal Information transferred from the European Economic Area ("EEA") or Switzerland to the United States about:
 
(i)            Employees for purposes which are necessary for the performance of the employment relationship and the operation of the business interests of Exxon Mobil Corporation or any of its affiliates (“ExxonMobil”) worldwide;
 
(ii)           Contractors for the purposes of administering the contractor and the operation of ExxonMobil business interests worldwide;
 
(iii)          Vendors for the purposes of managing the purchase and delivery of goods or services and the associated contractual relationship with ExxonMobil;
 
(iv)          Customers for the purposes of managing the sale of goods or services and the associated contractual relationship with ExxonMobil; and
 
(v)           Other Third Parties for the purposes of managing the relationship and interactions with ExxonMobil.
 
This Notice outlines EMGSC’s general practices for implementing the Safe Harbor privacy principles with respect to the use of Personal Information for the above purposes. 
 
For purposes of this Notice:
“Employee” means any current, former or prospective employee of Exxon Mobil Corporation or any of its European affiliates who is located in the EEA or Switzerland.
 
“Contractor” means any authorized contractorof Exxon Mobil Corporation or any of its European affiliates who is located in the EEA or Switzerland.
 
“Vendor” means any natural person located in the EEA or Switzerland acting in their capacity as a current, former or prospective vendor to ExxonMobil, whether as a sole proprietor or as a representative of a company.
 
 “Customer” means any natural person located in the EEA or Switzerland acting in their capacity as a current, former or prospective purchaser of ExxonMobil products or services, whether as a private customer, a sole proprietor or as a representative of a company.
 
“Other Third Party” means any natural person located in the EEA or Switzerland who is not an Employee, Contractor, Vendor or Customer.
 
“Individual” means anyone who is an Employee, Contractor, Vendor, Customer or Other Third Party.
 
 “Personal Information” means any information that (i) is transferred from the EEA or Switzerland to EMGSC in the United States, (ii) is recorded in any form, (iii) is about, or relates to, an identified or identifiable Individual, and (iv) can be linked to that Individual.
 
EMGSC’s Safe Harbor certification can be found at safeharbor.export.gov/companyinfo.aspx?id=13705.  For more information about the Safe Harbor privacy principles, please visit www.export.gov/safeharbor.

Notice
We notify Individuals about the purposes for which we collect and use Personal Information, the types of third parties to which we disclose the information, the choices Individuals have for limiting the use and disclosure of their information, and how to contact us about our practices concerning the processing of  Personal Information.
 
Employees and Contractors may find this information in this Safe Harbor Privacy Notice, in the ExxonMobil General Data Privacy Notice (which isavailable on the ExxonMobil Intranetand from the ExxonMobil Data Privacy Office) and also in ExxonMobil privacy notices relating to specific processing activities.
 
Vendors may find this information in this Safe Harbor Privacy Notice, which is distributed to vendor companies either electronically or in hard copy and as referenced on ExxonMobil order forms for goods and services.
 
Customers and Other Third Parties may find this information in this Safe Harbor Privacy Notice, as well as in ExxonMobil’s Privacy Statement, which are posted on the website www.exxonmobil.com and on various other ExxonMobil websites.

Purpose of Collection and Use of Personal Information
EMGSC collects certain Personal Information from Employees and Contractors such as contact details, demographic data, employee career history, organization details, time recording data, financial data, social details, health related data and IT related data.
 
We use Personal Information of Employees for employment related purposes which are necessary for the performance of the employment relationship (or similar relationship covering temporary employees or interns), or which are necessary and relevant to recruit, evaluate, develop and terminate employees.  We also use Personal Information about employees for business-related purposes which are necessary for the safe, effective and efficient operation of ExxonMobil business interests worldwide.
 
We use Personal Information of Contractors who work for ExxonMobil affiliates to administer the contractor, for the contractor’s safety, health and security and for business-related purposes which are necessary for the safe, effective and efficient operation of ExxonMobil business interests worldwide.
 
EMGSC collects certain Personal Information from Vendors such as name and contact details.  We use Personal Information of Vendors for managing the purchase and delivery of goods or services and the associated contractual relationship between Exxon Mobil Corporation or any of its affiliates.
 
EMGSC collects certain Personal Information from Customers such as name, contact details, organizational details, security and authentication information, payment, credit, tax and transaction details and feedback and opinions.  We use Personal Information of Customers for managing the sale of goods or services and the associated contractual relationship with Exxon Mobil Corporation or any of its affiliates, including:
•         to receive and fulfill orders;
•         to validate, authorize and manage payments;
•         to provide relevant aftercare services, including technical assistance and analysis, for products purchased from us;
•         to provide secure online access for the purpose of logging onto ExxonMobil electronic systems;
•         for internal administrative and analytics purposes;
•         to evaluate the quality of our products and services;
•         to respond to requests; and
•         to communicate with Customers about our products, services, upcoming events and related issues.
 
EMGSC collects certain personal information from Other Third Parties such as name, contact details, organizational details, security and authentication information, payment, tax and transaction details and feedback and opinions.  We use Personal Information of Other Third Parties for managing the relationship and interactions with Exxon Mobil Corporation or any of its affiliates, including:
•       to respond to requests;
•       to communicate with Other Third Parties about our products, services, upcoming events and related issues;
•       for public affairs and profile raising;
•       to evaluate the quality of our products and services;
•       to provide secure online access for the purpose of logging onto ExxonMobil electronic systems;
•       to manage business related travel; and
•       to administer schemes and benefits programs that relate to Employees.
 
We also use Personal Information about Vendors, Customers and Other Third Parties:
•       to manage access and ensure security at our facilities;
•       for the management of potential or actual legal claims; and
•       to provide information and training relating to our products, services, standards and procedures.
 
In addition to the purposes listed above, much of the Personal Information collected by EMGSC is collected and stored on behalf of EEA and Swiss based affiliates of Exxon Mobil Corporation.  For example, many ExxonMobil websites are hosted in the United States and any information submitted through those websites will be transferred to the United States.  Similarly, EMGSC operates, maintains and supports many centrally hosted IT systems which are used by EEA and Swiss based affiliates of Exxon Mobil Corporation for their own business purposes.
 
EMGSC may share Personal Information with its service providers and among its parent, subsidiaries and affiliates.  We do not use Personal Information for purposes incompatible with the purposes for which the information was originally collected by EMGSC without notifying the relevant Individuals and offering an opportunity to opt out.
 
Onward Transfers
Unless otherwise permitted by the Safe Harbor principles, EMGSC requires third party agents (including service providers and affiliates) to whom it discloses Personal Information and who are not subject to laws based on the European Union Data Protection Directive 95/46 or Swiss Federal Data Protection Law to either (i) subscribe to the Safe Harbor principles or (ii) contractually agree to provide at least the same level of protection for Personal Information as is required by the relevant Safe Harbor principles.
 
Unless otherwise permitted by the Safe Harbor principles, with respect to Personal Information we may share with third parties not acting as agents, we provide Individuals with an opportunity to opt out of such sharing.
 
In addition, we may disclose Personal Information (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on an enforceable government request or as may be required under applicable law, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity.
 
Access
EMGSC provides Individuals with reasonable access to their Personal Information.  We also provide a reasonable opportunity for Individuals to correct, amend or delete that information where it is inaccurate.  EMGSC may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor principles.
 
To obtain access to Personal Information, Individuals may contact EMGSC as specified in the "How to Contact Us" section of this Notice.
 
Security
EMGSC takes reasonable precautions to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
 
Data Integrity
EMGSC takes reasonable steps to ensure that Personal Information we collect is relevant for the purposes for which it is to be used and that the information is reliable for intended use and is accurate, complete and current.  We depend on Individuals to update or correct their Personal Information whenever necessary.
 
Enforcement and Oversight
EMGSC has established procedures for periodically verifying its implementation of and compliance with the Safe Harbor principles. We conduct an annual self-assessment of our practices with respect to Personal Information to verify that representations we make about our privacy practices are true and that EMGSC’s privacy practices have been implemented as represented.
 
Individuals may file a complaint concerning EMGSC’s processing of their Personal Information with the ExxonMobil Data Privacy Office.  If we cannot resolve the complaint though our internal processes, we will cooperate with the Joint Arbitration and Mediation Service (“JAMS”) under the JAMS International Mediation Rules to try and resolve the complaint.  See www.jamsadr.com for further information.
 
EMGSC will take steps to resolve complaints and will cooperate with the relevant EEA and Swiss data protection authorities in investigating and resolving complaints regarding Personal Information of our Employees and Contractors based in the EEA and Switzerland.

How to Contact Us
To contact EMGSC regarding questions or concerns about this Safe Harbor Privacy Notice or our practices concerning Personal Information, or you may write to us at:

ExxonMobil Global Services Company
Data Privacy Office
Care of: Esso Petroleum Company, Limited
Mailpoint 5A
ExxonMobil House
Ermyn Way
Leatherhead
Surrey          
KT22 8UX
United Kingdom