ConocoPhillips Privacy Policy

Effective – December 22, 2022

ConocoPhillips is committed to protecting your privacy. This Privacy Policy provides information regarding how we treat your personal information collected and your associated rights when using websites, platforms and other services that link to this Privacy Policy, or when purchasing products from, conducting business with, or otherwise interacting with ConocoPhillips and various affiliates and subsidiaries of ConocoPhillips. When referring to these entities, the terms “ConocoPhillips”, “company”, “we”, “us”, and “our” are used only for convenience and are not intended to be an accurate description of ownership, operation, or corporate/legal relationship.

This Privacy Policy applies to our practices, both online and offline, regarding the collection, use, and disclosure of personal information and of the rights of individuals regarding their own personal information. This includes job applicants and visitors to ConocoPhillips’s website, recipients of electronic communications from us, individuals that interact with us through social media websites and other platforms or website applications. By accessing our services linked to this Privacy Policy, you acknowledge that you have read and understood the terms described herein.

If you are an employee, contractor, spouse/dependent of an employee, please refer to the ConocoPhillips Employee Information Privacy Policy or the ConocoPhillips Non-Employee Information Privacy Policy posted on our internal policy portal for information regarding your privacy with respect to personal information collected pursuant to your relationship with ConocoPhillips.

Please note that some U.S. states provide their residents additional rights regarding the use of their personal information. For residents of the U.S., see the U.S. Privacy Rights section below.

For residents of the European Union (“EU”) and the United Kingdom (“UK”), see the Notice to EU/UK Residents section below.

Personal Information Collection

The types of information we collect depend on which product or service you use.

Categories of Personal Information You May Provide to Us or Our Service Providers

  • Identifiers, such as real name, alias or display/username, password, postal address, telephone number, email address, telephone number, and company name.  See below under “Categories of Personal Information Collected Automatically by Us or Our Service Providers” for more information.
  • Internet or Other Electronic Network Activity Information, such as browsing history. See below under “Categories of Personal Information Collected Automatically by Us or Our Service Providers” for more information.
  • Professional or Employment Information, such as your job title, job function, skills company/organization name and information, and other information about yourself.
  • Education information, such as highest education level, degree attained, and institution attended.
  • Demographic Information/Characteristics of Protected Classifications under state or federal law, such as your nationality and country of residence, with your consent.
  • Identification Numbers, such as your social security number and driver’s license number.

You are not required to provide information we may request, but if you choose not to provide it, we may not be able to provide you the requested service or to complete your application.  Your state or country of residence may consider some of the information described above, e.g., Demographic Information and/or Identification Numbers, sections to be sensitive personal information and, as such, may require that you provide additional consent for us to use that information.  We will only use this information as allowed by applicable law.

Categories of Personal Information Collected Automatically by Us or Our Service Providers (more information on Identifiers and Internet or Other Electronic Network Activity Information)

  • Information about your browsing behavior on our websites, platforms, or applications, such as the date and time you visit, the areas or pages you visit, the amount of time you spend viewing or using our site, platform or application, and the number of times you return.  We may connect this information with your identity to determine your potential interests in our products and services.
  • We also collect certain standard information that your browser sends to every website you visit, such as your internet protocol (IP) address, your browser type and capabilities, your preferred language, your operating system, software version, the date and time you access the site, and the website from which you linked to our site(s) or application(s), if any.

Categories of Data We Collect About You from Third Parties

If you link to us through a third-party service, we may receive information about you, such as the above-listed identifiers, for example from an internet service provider (subject to your privacy settings on those third-party services),

Cookies and Other Tracking

What is a cookie?

A cookie is a small file placed onto your device when you visit our website that enables the website to remember information about you, such as your language preference or login information.

What cookies and other technologies are used?

Our websites may use cookies to track the number of times you have visited our website, to track the number of visitors to our site, to analyze visitors’ experience with our site, to store data that you may provide (such as preferences), and to store technical information related to your interactions with our websites, platforms and applications and for marketing and advertising purposes.  These cookies may be provided by us or by third parties that we permit to place cookies on our website, as discussed further below.   We use session cookies, which are deleted when you close your browser, to facilitate movement around our site, and to collect other information used in administering the session on our site.  We may also permit the use of local storage technologies, like ad pixels, to show you our ads as you browse the internet and visit various other websites such as social media websites, search engines and news websites.

Tracking and Opting Out

Most internet browsers automatically accept cookies, but you may be able to adjust your browser, operating system, or mobile device settings to limit certain tracking, decline cookies, or notify you when a cookie is being placed on your computer or device.  If you choose not to accept cookies, you may not be able to experience all the features of our website and related services.  You can typically delete existing cookies in your browser settings, although this means that your existing settings, such as stored preferences will be lost.  To adjust cookie settings while browsing this website, visit the Privacy Center or in our footer.  You can opt-out of each cookie category as defined in the table below, except for Strictly Necessary Cookies.   For more information visit (www.conocophillips.com/cookie-policy/).

Our Use of Personal Information

We use your personal information for the following purposes only (broken out by categories of personal information):

  • Identifiers, Internet or Other Electronic Network Activity Information, Professional or Employment Information, & Demographic Information/Characteristics of Protected Classifications under state or federal law are used for performing services on behalf of the business or service provider, including answering your questions and responding to your requests made through our websites, call centers, job applications, or through third-party websites (including social media).
  • Identifiers & Internet or Other Electronic Network Activity Information are used to improve/develop products or services (including websites, platforms and applications).  We use your personal information to develop or improve our services; to determine how to best provide services to you; and to improve our websites, platforms, and applications to make them easier to use. 
  • Identifiers & Internet or Other Electronic Network Activity Information are used for fraud and security purposes.  We use your personal information to protect the security and integrity of our services and our business, as well as to safeguard your personal information. 

We may also use your personal information in other ways as required or permitted by law or with your consent prior to the point of collection, or in an aggregated and non-specific format (where you cannot be reasonably identified) for analytical and demographic purposes.

We use your personal information in a lawful manner only because it is necessary for the performance of an agreement with you, for our or a third party’s legitimate interests, or with your consent.

With Whom We Disclose Your Personal Information

We may have disclosed to other parties, for business purposes, all categories of personal information in the last twelve (12) months as described below.

To Service Providers.  We may disclose your personal information to our service providers for legitimate business purposes to provide services to us or on our behalf, such as data hosting, cloud services, sending out information and communications, processing transactions, analyzing data, technical support, and other business and professional services.  We provide these companies with only those elements of personal information they need to provide their services to us.   We generally require that services providers use personal information only for that purpose, and we also require assurances that they will appropriately protect personal information entrusted to them.

As Directed By You.  We may also disclose personal information to third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Required Disclosures.  We may disclose your personal information if required to do so by law or regulation or in our good-faith belief that such action is necessary to comply with legal requirements or with legal process served on us, and to protect our or others’ rights, property, or safety.

Business, Merger, Sale, or Other Asset Transfers.  If we undertake or are involved in any merger, acquisition, reorganization, sale of assets, financing due diligence, bankruptcy, receivership, transition of service to another provider, or other business transfer event, then we may sell, transfer, or share some or all our assets, including your personal information, in connection with such transaction or in contemplation of such transaction.  We will make reasonable efforts to notify you before your personal information is transferred if any material change in the terms of the applicable privacy policy is contemplated as applicable to your personal information.

Operating Globally and International Transfers

We may transfer personal information to and store personal information in countries other than the country where it was collected or where you accessed our websites, platforms, or applications.  Those countries may have different data privacy and protection laws than the country in which the personal information was collected or from which you accessed our websites, platforms, or applications.  To the extent required by applicable law, we will take measures to protect personal information so transferred or stored.  To the extent permissible under applicable law, by choosing to use our services, including our websites, platforms, and applications, and submitting personal information to us, you consent to the transfer of such personal information outside of your country of residence in accordance with this Privacy Policy.

Personal Information Retention

As a general matter, we only keep information for as long as reasonably necessary to fulfill the purposes for which it was collected, as permitted or required by applicable law (such as to comply with recordkeeping and other legal obligations), in accordance with the provisions of this Privacy Policy, and as per our retention policy and schedules.   There may also be residual information that will remain within our backup files, databases, and other records, which will not be removed or changed, except in accordance with our retention policy and schedules.

Security Measures

We strive to process your personal information securely, in accordance with this Privacy Policy and in accordance with information security requirements imposed by applicable law.  To this end, we adopt appropriate technical and organizational measures designed to protect your personal information from the risk of disclosure, destruction, loss or accidental, unlawful and unauthorized alteration, access, disclosure and use.  We cannot, however, be responsible for Internet communications that are inherently not completely secure.

Linked Websites

Our websites, platforms and applications may contain links to other websites, including those of other companies, organizations, and publications.  These websites operate independently from our websites, platforms, and applications, and we do not control and are not responsible for the content, security, or data privacy practices used by other entities.  You should review the privacy policies of those websites to determine how they protect and use your personal information.

No Use by Children Under the Age of 16

Our services, including our websites, platforms, and applications, are not directed at children and we do not knowingly collect any personal information from children.  If we learn that we collected the personal information of a child under the age of 16, we will use reasonable efforts to delete such information from our systems promptly.

Privacy Rights

Generally

Certain jurisdictions impose specific legal requirements and privacy rights with respect to personal information, and depending upon the laws applicable where you reside, we will comply with restrictions and any requests you may submit as required by applicable law.  We are committed to protecting your privacy and will make reasonable efforts to honor your exercise of your rights as required by applicable law.  The rights that may be available to you include:

Right to Know and Access

You may have a right to request information about our collection, use, and disclosure of your personal information, and ask that we provide you with certain information, such as:

  • Categories and specific pieces of personal information we have collected about you.
  • Categories of sources from which we collect personal information.
  • Purposes for collecting personal information.
  • Categories of third parties with which we share personal information.
  • Categories of personal information disclosed about you for a business purpose.
  • If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

To make a verifiable request for information about the personal information we have collected about you, you may reach out to privacy@conocophillips.com.  We will do our best to assist you without undue delay and within the time required by applicable laws.  However, to the extent permitted by applicable laws, we reserve the right to charge a fee or decline requests that are unreasonable or excessive, where providing the personal information would be prohibited by law or could adversely affect the privacy or other rights of another person, or where we are unable to authenticate you as the person to whom the personal information relates.

Right to Portability.  You may have the right to request that we provide a copy of the personal information we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.  Once we receive your request and confirm your identity, we will provide to you a copy of your personal information as required under applicable laws.  We may provide this data to you through email to the email address you have provided with your request.

Right to Delete

You may also have a right to request that we delete your personal information, subject to certain exceptions.  To make a verifiable request to delete the personal information we have collected about you, you may reach out at: privacy@conocophillips.com.

Right to Correct.

Subject to certain exceptions, you may have the right to request that we correct inaccurate personal information that we have collected about you.  Once we receive your request and confirm your identity, we will review your request, taking into account the nature of the personal information and the purposes of the processing of the personal information to see if we can correct the data.  We may also request additional information showing that the personal information you want to correct is inaccurate.

Right to Non-Discrimination

Your state may prohibit treating you different than other customers for exercising your rights regarding your personal information under applicable laws.  This includes by denying or providing a different level or quality of goods or services, or charging (or suggesting that we will charge) different prices, rates, or impose penalties on residents of such states who exercise their rights regarding their personal information, unless doing so is reasonably related to the value provided to us by your personal information.

Right to Opt-out

You may have the right to opt-out of processing of your personal information for the purpose of (i) targeted advertising, (ii) sale or sharing of personal information, or (iii) profiling to provide you with tailored content, including suggested advertising. We do not process your personal information for the purpose of (i) targeted advertising, (ii) selling or sharing your personal information, or (iii) profiling, as those terms are defined under applicable laws.  

Requests Made Through Agents

Your state of residence may allow you to designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise the rights provided by your state of residence regarding your personal information.  Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Do Not Track

Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked.  Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals.  Instead, you can use the range of other tools to control data collection and use.  If you are a U.S. resident, see our U.S. Privacy Rights section below for additional information.  If you are located in the EU or UK, see our Notice to EU/UK Residents section below for additional information.

Submitting a Data Subject Request

If you would like to make a data subject request (e.g., request to access personal information or to update, correct, or delete any such information), you may submit a request here, or email us at privacy@conocophillips.com or call us at 866-887-7217.  We will comply with requests you submit as required by applicable law.

When you make a request, we may require that you provide information (such as your name, email address and/or zip code) and follow procedures so that we can verify a request you make and your jurisdiction before responding to it.  The verification steps we take may differ depending on your jurisdiction and the request you make.  We will match the information that you provide in your request to information we already have on file to verify your identity.  If we are able to verify your request, we will process it in accordance with applicable law.  If we cannot verify your request, we may ask you for additional information to help us verify your request.

We will respond to your request within the time period required by applicable law.  However, we may not always be able to fully comply with your request, and we will notify you in that event when required.

U.S. Privacy Rights

We do not sell your personal information for money or other consideration.  We also do not share your personal information with other people or unaffiliated companies for their direct marketing purposes or for targeted or cross-context behavioral advertising.

Our organization strives to limit the collection of sensitive personal information. However, certain programs accessible through our websites may request some sensitive personal information in order to fulfill our business obligations or support certain diversity initiatives.  Providing such information is voluntary. To continue to limit the unnecessary collection of sensitive personal information, we request you do not submit any sensitive personal information to our websites, platforms or applications unless requested. We will honor requests to limit sensitive personal information as allowed by applicable law as requested through the Privacy Center.

For Nevada residents. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request using the contact information above. However, please know we do not sell personal information triggering that statute's opt-out requirements.

Notice to EU/UK Residents

This notice applies to residents located in the EU and/or the UK.  This notice supplements our Privacy Policy above, however, where this notice conflicts with the Privacy Policy, this notice will prevail as to residents located in the EU and the UK.  For purposes of this Notice to EU/UK Residents section, the term “personal information” shall mean personally identifiable information.

Controller of Personal Information

ConocoPhillips is the controller of your personal information it collects, however, in accordance with applicable data privacy laws, we have appointed representatives within the EU and the UK.

Contact Details of ConocoPhillips EU and UK Representatives

The contact details of our EU representative are:

Attn: Sandhya Heide

Sandhya.Heide@conocophillips.com

+47-52 02 1367

The contact details of our UK representative are:

Attn: Anne Willis

Anne.Willis@conocophillips.com

+44-1642 541375

Legal Basis for the Processing of Your Personal Information

We rely on the following legal grounds for the collection, processing, and use of your Personal Data:

  • the processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract;
  • the processing is necessary for compliance with a legal obligation to which we are subject;
  • the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of which you require protection of Personal Information, such as legitimate interests are the fulfilment of the processing purposes described in this Privacy Policy that are not necessary for the performance of a contract or for our compliance with a legal obligation to which we are subject; or
  • other applicable legal basis for data processing, especially provisions set out by member state law.

To the extent that a legal ground described above would not apply to specific purpose of processing of your Personal Information by us, we will seek your consent for such specific purpose(s) in accordance with applicable law.

If you do not provide us with certain Personal Information, we may not be able to fulfill the requested purpose of collection, such as to respond to your queries or provide our website to you. However, unless otherwise specified, not providing your Personal Information will not result in legal consequences for you.

YOUR RIGHTS

Right to withdraw your consent: To the extent a specific element of our processing of your  Personal Information relies upon your consent, you may withdraw such consent at any time with future effect.  Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

Additional data privacy rights:  Pursuant to applicable data protection law, you may have the right to (i) request access to your Personal Information; (ii) request rectification of your Personal Information; (iii) request erasure of your Personal Information; (iv) request restriction of processing of your Personal Information; (v) request data portability; and/or (vi) object to the processing of your Personal Information (including objection to profiling). 

Please note that these aforementioned rights might be limited under the applicable local data protection law. Below please find further information on your rights to the extent that the EU/UK GDPR applies:

Right to request access to your Personal Information: You may have the right to obtain from us confirmation as to whether or not Personal Information concerning you is being processed, and, where that is the case, to request access to the Personal Information. This access information includes - inter alia - the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.  You may have the right to obtain a copy of the Personal Information undergoing processing free of charge. For further copies requested by you, we may charge a reasonable fee based on administrative costs.

Right to request rectification: You may have the right to obtain from us the rectification of inaccurate Personal Information concerning you.  Depending on the purposes of the processing, you may have the right to have incomplete personal information completed, including by means of providing a supplementary statement.

Right to request erasure (right to be forgotten): Under certain circumstances, you may have the right to obtain from us the erasure of Personal Information concerning you and we may be obliged to erase such Personal Information.

Right to request restriction of processing: Under certain circumstances, you may have the right to obtain from us restriction of processing your Personal Information.  In such case, the respective data will be marked and may only be processed by us for certain purposes.

Right to request data portability: Under certain circumstances, you may have the right to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.

Right to object: Under certain circumstances, you may have the right to object, on grounds of relating to your particular situation, at any time to the processing of your Personal Information by us and we can be required to no longer process your Personal Information. Such right to object may especially apply if we collect and process your Personal Information for profiling purposes in order to better understand your interests in our products and services or for direct marketing. If you have a right to object and you exercise this right, your Personal Information will no longer be processed for such purposes by us. You may exercise this right by contacting us as stated at the end of the Privacy Policy. Such a right to object may, in particular, not exist if the processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

To exercise your rights, please contact us as stated at the end of the Privacy Policy.  You also have the right to lodge a complaint with the competent data protection supervisory authority.

INTERNATIONAL TRANSFERS

The Personal Information that we collect or receive about you may be transferred to and processed by recipients that are located inside or outside the EU and the UK.  When we store or transfer your personal information outside of the EU or the UK, we take precautions that your Personal Data is protected in accordance with the applicable data protection law.

For recipients located outside of the EU or the UK, some may be located in countries with adequacy decisions, and, in each case, the transfer is thereby recognized as providing an adequate level of data protection. With respect to transfers to countries not providing an adequate level of data protection, we will base the transfer on appropriate safeguards, such as standard contractual clauses adopted by the EU and the UK or any other appropriate safeguards as permitted by the applicable data protection law. You may request a copy of such appropriate safeguards by contacting us as set out at the end of the Privacy Policy.

Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time at our discretion and will review and update it as may be necessary and at least annually.  When we decide to materially change this Privacy Policy, notice of the change will be posted on our websites, platforms and other services that link to this Privacy Policy for a reasonable period of time or provided to you using other means, and we will revise the effective date at the top of this Privacy Policy.  Please revisit this page periodically to become aware of the most recent privacy terms - your use of our services linked to this Privacy Policy after such changes have been posted constitutes your agreement to such terms.

Contact Us

Customer questions, comments and feedback are very important to us. If you have questions regarding this Privacy Policy, please email us at privacy@conocophillips.com or call 866-887-7217.