Privacy Policy



This document has been designed using the guidance procedures provided by the National Commission for Informatics and Liberties (Commission Informatique et Liberté - CNIL) and in relation to the statutory requirements with regards our obligations to the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

We are committed to safeguarding the privacy of our customers. Libra Fearnley Energy is committed to upholding the five recognised Data Protection Principles of the “Loi Informatique et Liberté” (1978).  Any and all data submitted to Libra Fearnley Energy will be held in accordance with the 1978 French law, for computer files and freedom and held in secure domains at all times.

Our principal form of business is Brokerage services. Our registered office address is 47 Bis Avenue Hoche, 75008 Paris, and is the address to which all formal communication should be addressed.

Our website address is

Our main contact number is +33 1 58 05 51 02 and our Data Protection Officer is Mrs Claire BERCHER to whom all formal communication and relevant enquiries should be addressed.




About this Privacy Notice

Effective Date: 1st May 2018


What Libra Fearnley Energy and its subsidiaries do with your company/personal information: 

In the course of serving you as a customer, Libra Fearnley Energy may obtain confidential information about your company and/or employees. Obtaining this information is important to our ability to deliver the highest level of financial and customer services to your company, but we also recognize that your company expects us to treat this information appropriately and keep it confidential. These goals are our highest priority.

This present Privacy Policy describes the types of information (the customer information) we may collect about your company and/or employees, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard that information. The Policy applies to former customers as well as our current customers.


Information we collect about you:

If your company deals with us, the typical information we collect about you, whether written or electronic form or whatever form they may take, would include:

  • Information we receive from you on account applications;
  • All information about the transaction(s) with and through Libra Fearnley Energy, whether written or electronic (e-mail), or on other forms (i.e. by phone if applicable): history of calls with our teams, and your use of services and products that we provide etc.


If you are a company, the following information should be collected: 

  • Your name, address and other contact details such as Tax ID or European Tax number (for VAT) etc.;
  • Corporate information such as financial statements, corporate shareholdings and directorships etc.;
  • Whether your organization is a member of a clearing houses or not;
  • The type of business that your organization is engaged in the oil and petroleum markets and other relevant markets;
  • Extensive financial information, including source of income, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources; and
  • Outside entity, including credit reporting agencies, in order to obtain information (i.e. verification of identity, creditworthiness, credit history, purchasing and investment preferences).


If you are a person or the representative/an employee etc. of a company we are dealing with, we might collect personal information about you would include: 

  • Your name and business contact details, social security number, investment experience etc;
  • Your role/position/title and area of responsibility; and
  • Certain identifying information as required by laws and regulations (depending of the country in which the company is incorporated) addressing money laundering and related matters if applicable.
  • We endeavor to keep our customer files complete and accurate. However, you can help us in this regard by promptly notifying us if you believe any information should be corrected or updated.
  • To conclude, in the provision of financial services to your company and subject to strict compliance with all applicable laws and regulations (money laundering and related matters if applicable), information may be collected about your company indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring e-mails).


Use of your information: 

We may use your company’s or personal information to:

  • Administer, operate, facilitate and manage your relationship and/or account with Libra Fearnley Energy in order to gain more flexibility and speed up the process with the clearing house. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
  • Contact you or, if applicable, your designated representative(s) by post, telephone, e-mail, etc., in connection with your relationship and/or your business activity;
  • Provide you with information or advice concerning products and services offered by Libra Fearnley Energy and its subsidiaries;
  • Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

Disclosures of your information within Libra Fearnley Energy’s subsidiaries: 

For the purpose of this article, “subsidiary” means entities in which Libra Fearnley Energy is majority shareholder.

In order to provide efficient and reliable services to you, Libra Fearnley Energy’s subsidiaries may be given, or granted access to, your information (i.e. one Libra Fearnley Energy subsidiary might share your information with another in order to facilitate settlement of your transactions or as part of its arranging for the performance of services).

However, we limit access to your information to employees who need to know some information in connection of your business and/or our services we provide to you.


Disclosures of your information to third parties: 

Libra Fearnley Energy does not disclose your company’s information (and without your consent) to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your or facilitate your transactions with us. Such non-affiliated companies that assist Libra Fearnley Energy in providing services to your company are required to maintain the confidentiality of such information to the extent they receive it, and to use your company’s information only in the course of providing such services and only for the purposes that Libra Fearnley Energy has previously determined.

Under limited circumstances, your company’s information may be disclosed to third parties as permitted by, or to comply with: 

  • Inquiries from government agencies or other relevant regulators;
  • When responding to a subpoena or similar legal process;
  • To prevent fraud;
  • In order to complete a transaction which you initiated and authorized;
  • Cooperation with law enforcement or regulatory authorities, or with organizations such as exchanges and clearing houses;
  • For other legal purposes.  


How long we’ll keep your information: 

We keep your information in line with our data retention policy. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes such as managing your account and dealing with any disputes or concerns that may arise. We may need to retain your information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc. If we don’t need to retain information for this period of time, we may destroy, delete or anonymise it more promptly.

If your relationship with Libra Fearnley Energy ends, Libra Fearnley Energy will continue to treat your company’s information, to the extent we retain it, as described in this Policy. In that case, the period for which information is to be stored will not exceed five (5) years.

The criteria used for determining how long your data will be stored for can be found here: 


Other Privacy Policies or Statements: 

This Policy provides a general statement of the ways in which Libra Fearnley Energy protects your company’s information. You may, however, in connection with specific products or services offered by Libra Fearnley Energy and its subsidiaries, be provided with privacy policies or statements that supplement this Policy.

To protect your company/personal information from unauthorized access and use, we use security measures that comply with appropriate laws and regulation. These measures include computer safeguards and secured buildings.


Accessing and queries about your information: 

We will grant you access to information we have about you. If you have a query about your information or this privacy policy, please contact your Libra Fearnley Energy representative or the person mentioned bellow. 


Your rights: 

You have a number of rights in relation to the information that we hold about you. These rights include:

  • the right to access information we hold about you and to obtain information about how we process it;
  • in some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so, although this may impact your ability to continue to have access to our products and services;
  • in some circumstances, the right to receive certain information in an electronic format and/or request we transmit it to a third party where this is technically feasible. The right only applies to information provided to us.
  • the right to request that we rectify your information if it’s inaccurate or incomplete;
  • in some circumstances, the right to request that we erase your information. We may continue to retain your information if we are entitled or required to retain it; and
  • the right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we are entitled to continue processing your information and / or to refuse that request.

You can exercise your rights by contacting us using the details set out below. You may also have a right to complain to the relevant data protection regulator in the country in which you live or work. 

How we keep your information secure: 

We use a range of measures to keep your information safe and secure which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.


More details about your information: 

Of course, Libra Fearnley Energy will not sell or rent your information to other companies.

If you require further information regarding our privacy policy, you are welcome to contact:



Mrs Claire BERCHER

Data Protection Officer

+33 1 58 05 51 02

47 Bis Avenue Hoche

75008 Paris




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Privacy Notice and changes to our Privacy Policy

A copy of Libra Fearnley’s privacy notice may be obtained by visiting or contacting our office and by download from our website -

Libra Fearnley Energy regularly provides notices to our customers regarding our privacy policy. Libra Fearnley Energy reserves the right to change this policy, and to apply changes to information previously collected, as permitted by laws and regulations. If there is any change to this policy, Libra Fearnley Energy will provide our customers with a revised privacy notice. To obtain further information, please call +331 58 05 51 02.

The revised Policy will be effective immediately upon posting to our Web site as described above. This version of the Policy is effective as at May 1st, 2018.

Right to opt out of your information

You may opt out of any disclosure we may make of non public personal information to non-affiliated third parties. That is, you may direct Libra Fearnley Energy not to make those disclosures, other than disclosures permitted or required by laws and regulations. Any customer who decides to opt out of these disclosures to non-affiliated third parties must send an e-mail to with the opt out notice fulfilled.




In order to opt out, please provide the information requested below and return this notice within 30 days following the receipt of the privacy policy and opt out notice to

Please do not share any non public personal information about me with unaffiliated third parties.

I understand that you may still share this information for any services necessary to process any transaction in my account, or as otherwise permitted or required by the law.


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