Privacy notice and cookies

What is the purpose of this notice?

Tullow Oil plc and its subsidiaries (together, the Tullow Group) are committed to protecting the privacy and security of your personal data. This notice is to be read in conjunction with the legal notice of the website.

Who does this notice apply to?

This page contains important information about how your personal data is treated if you:

• provide personal data to the Tullow Group through this website; or
• are a current or former shareholder of Tullow Oil plc, whether your interest is legal or beneficial.

The data controller of your personal data if you are a current or former shareholder of Tullow Oil plc is Tullow Oil plc. Tullow Oil plc’s representative for the purposes of this privacy notice is its Data Protection Officer, who can be contacted using the contact details at the end of this notice.

The data controller for users of this website in relation to any personal data collected by this website is Tullow Oil plc. The data controller for personal data provided to the Tullow Group through the contact details listed at https://www.tullowoil.com/contact are as follows:

Data protection principles

We will comply with data protection law.

This means that the personal information we hold about you must be:

• used lawfully, fairly and in a transparent way
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
• relevant to the purposes we have told you about and limited only to those purposes
• accurate and kept up to date
• kept only as long as necessary for the purposes we have told you about
• kept securely

What kind of personal data do we process?

If you are a current or former shareholder, we process the following types of personal data about you:

• your name
• your address
• details of your past or current shareholding in Tullow Oil plc, including purchases and sales, and the nature of your shareholding
• your history of exercising your voting rights attached to your shares, and your choices relating to dividends and other forms of capital return or restructure, including any currency choices, and including any bank or building society details you provided in relation to such activity
• your contact details where you have provided these to us
• your voice if this is captured by audio recording at a shareholder event or call

If you are a user of this website and/or use the contact details referred to in the “Who does this notice apply to?” section above, we only process personal data that you provide to us and limited information captured by cookies (see the “Cookies” section below). This typically includes:

• your name
• your mobile telephone number
• your email address
• your occupation
• your domain and IP address

We do not automatically link your domain and IP address to any personal data which you choose to provide us.

How do we obtain your personal data?

If you are a current or former shareholder, we collect your personal information:

• by you providing it, either voluntarily, at our request, or at our demand, to us or to our registrar, Computershare, including directly or indirectly via the CREST system
• if you are also an employee of the Tullow Group, from the relevant Data Controller
• by third parties acting on your behalf, such as stock brokers and other agents through whom you may have acquired or manage your interest in Tullow Oil plc shares
• when you exercise your rights in respect of Tullow Oil plc shares, including when casting votes and/or attending the Annual General Meeting or other shareholder events
• by recording the audio of certain calls, such as analyst and shareholder calls, and events, such as the Annual General Meeting

If you are a user of this website or use the contact details in the “Who does this notice apply to?” section above, we collect your personal data when you voluntarily provide it by using the contact details and through any subsequence correspondence.

For what purposes do we process your personal data?

We only process your personal data if the law allows us to do so.

If you are a current or former shareholder, we process your personal data:

• to comply with a legal obligation such as maintaining and administering Tullow Oil plc’s register of members or maintaining, administering Tullow Oil plc’s register of beneficial ownership and making any filings in relation to your shareholding required by law or by the rules of a stock exchange on which Tullow Oil plc is listed and/or its shares admitted to trading
• to comply with a contractual obligation including where required by the provisions of Tullow Oil plc’s articles of association
• where it is necessary for our legitimate interests, such as:
  • preventing, investigating, detecting and reporting theft, fraud or other criminal activity
  • analysing the make-up of our share register
• Where we rely on our legitimate interests, we will ensure that your rights are appropriately balanced against these interests.

If you are a user of this website or use the contact details in the “Who does this notice apply to?” section above, we process your data to respond to your queries and to analyse the number, types of sources of queries coming in to the Tullow Group. If you sign up for alerts or for other communications, we will use your contact details to provide you with these alerts or other communications.

What happens if you do not provide your personal data?

If you are a current or former shareholder, you may have a legal obligation to provide us with certain information about you, for example where we make a statutory demand to ascertain the beneficial ownership of shares or the number of shares you hold. If you fail to provide certain information when requested to enable us to comply with our legal obligations, you may not be recognised as a shareholder of Tullow Oil plc and/or you may not be entitled to exercise or enjoy your rights attaching to your shares in Tullow Oil plc plc and/or we may not be able to fulfil our other obligations to you.

If you are a user of this website or use the contact details in the “Who does this notice apply to?” section above and you do not provide us with relevant personal data or personal data which we request from you, our ability to respond to your query in a useful or timely manner or to provide you with the alerts or other communications that you have requested may be compromised.

Who do we share your personal data with?

If you are a current or former shareholder, we will share your personal data:

• with third parties where we are legally required to, for example to government or regulatory bodies, stock exchanges, courts or tribunals or parties to legal proceedings
• with subsidiaries of Tullow Oil plc to assist the Tullow Group with complying with its legal obligations or managing its relationship with you
• with third party advisors such as lawyers and auditors, and with third party service providers such as our registrar and our investor relations consultancy.

If you are a user of this website or use the contact details in the “Who does this notice apply to?” section above, we will share your data:

• with other teams or companies within the Tullow Group to assist in responding to your query
• with third party service providers to assist in responding to your query or to assist with the distribution of alerts and other communications and the maintenance of contact lists.

How long will we process your personal data?

If you are a shareholder, we will retain your personal data for as long as you are a shareholder of Tullow Oil plc and after you cease to be a shareholder in Tullow Oil plc for as long as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise in connection with your shareholding.

If you are a user of this website or use the contact details in the “Who does this notice apply to?” section above, we will retain your personal data for as long as necessary to respond to your query, and for up to six months afterwards. Copies of any email correspondence may be retained through automated IT back up systems for periods of up to seven years. If you sign up for alerts or other communications, we will retain the details provided when you signed up until you ask us not to.

What rights do you have?

Under the General Data Protection Regulation, which came into effect on 25 May 2018, and the UK’s Data Protection Act 2018, you have the right, in certain circumstances:

• to request access to personal data that we hold about you
• to request correction of the personal data that we hold about you
• to request deletion of your personal data
• to object to the processing of your personal data (where we are relying on a legitimate interest)
• to request the restriction of your personal information
• request the transfer of your personal information to another party

Depending on your country of residence and which legal entity your request relates to, you may have additional or similar rights under the data protection laws of other countries such as Ghana, Kenya, South Africa and Uganda.

Who can you contact?

For any questions relating to the this privacy notice, the treatment of your personal data, or to exercise any of your rights under the General Data Protection Regulation or the UK’s Data Protection Act 2018, you should contact Tullow Oil plc’s Data Protection Officer at Tullow Oil plc, 9 Chiswick Park, 566 Chiswick High Road, London W4 5XT, or by email at dataprotectionoffice@tullowoil.com.

You have the right to make a complaint at any time through the Data Protection Officer or the Information Commissioner’s Office, the UK’s supervisory authority. The Information Commissioner’s Office’s contact details can be found at https://ico.org.uk/.

This privacy notice

Any changes to this privacy notice will be posted on the https://www.tullowoil.com/ website. This privacy notice was last updated in December 2019.

Cookies

We operate cookies on this website in line with applicable legal requirements and the UK’s Information Commissioner Office’s recommendations, which can be found at https://ico.org.uk/about-the-ico/news-and-events/news-and-blogs/2019/07/blog-cookies-what-does-good-look-like/.

We ask for your opt-in consent to accept either all or only functionally necessary cookies. Your consent is stored for 12 months and you will then be asked to opt-in again.

For more information please refer to the Cookie declaration.

This privacy policy was last updated on 26 March 2020.