Privacy Policy


Social Chorus


January 28, 2019


This Data Privacy Notice (Notice) is in addition to the General Data Privacy Notice(s) (GDPN) of the relevant ExxonMobil affiliate(s). This Notice uses terms defined in the GDPN.  The terms Personal data and Personal information are used interchangeably.                 


This Notice describes the processing by the relevant ExxonMobil affiliate(s) of Personal data of ExxonMobil employees and contractors in Social Chorus which is an ambassadorship tool that allows employees and contractors to share ExxonMobil information provided by Public and Government Affairs (P&GA) to their own social networks.




Personal data is collected by the ExxonMobil affiliate with which you have/had your employment contract/relationship, or in the event you are a contractor, the ExxonMobil affiliate to whom you provide your services. This ExxonMobil affiliate determines the purpose of the processing of your Personal data.

This ExxonMobil affiliate may transfer the Personal data to other ExxonMobil affiliates which in turn may process the Personal data they have received. Refer to the GDPN for additional information in this regard.


Data elements


Legitimate interest






















The following table describes the Personal data we process, and for each of the Personal data elements we set out (i.) the reason (purpose) why we process the data, and (ii.) a description of the legal basis (as applicable,  e.g. in the European Economic Area (“EEA”), UK or Switzerland) which justifies the processing by ExxonMobil. When we rely on our legitimate interest as a legal basis for the processing, we have verified that the processing does not disproportionately and negatively impact your fundamental rights and freedoms.   Note that some of the services may not be available if you fail to provide the Personal data necessary to deliver them.



Legal basis

Personal data

The purpose of this  P&GA  platform is to keep employees and contractors informed, engaged and to facilitate the sharing of company-approved content to their social networks, e.g. Twitter, Facebook, LinkedIn, etc. (employees and contractors)


ExxonMobil’s legitimate business interest to create organizational alignment and achieve its communications goals by facilitating social media sharing of approved company content to increase reach and brand favorability.


Use of Social Chorus for purposes of social media sharing networking, is voluntary. By providing Personal data, you are consenting to the processing and transfer of Personal data for the purposes of social media sharing.

Business Contact details; name, likes on content.


Legal basis

Personal data

Information and System Integrity and  Security and  Identity Verification

(employees and contractors)


ExxonMobil’s legitimate interest to ensure information / system integrity through automated verification, control or recording of actions. 

ExxonMobil’s legitimate interest to validate the identity and access permissions of a user of Social Chorus, to be in compliance with the ExxonMobil IT Security and Controls standards.

Business Contact details; name.





Data access & Data transfer








Duration of data processing


For the above purposes, and on a need to know basis, ExxonMobil will share your Personal data with: P&GA personnel who will administer the content.  


In order to achieve the business purpose, your Personal data may be made accessible to other ExxonMobil affiliates worldwide. For more information regarding international transfers, see the GDPN.


·         Personal data will also be shared with Social Chorus to provide the service; we have agreements in place with the third party which protect your Personal data consistent with applicable laws.


For more information about the specific transfer mechanisms used for transfers between affiliates and transfers to third parties, please contact the ExxonMobil Data Privacy Office at


ExxonMobil processes Personal data only as long as necessary to achieve the purposes stated above, and in line with its Records Management Guidelines and in order to ensure compliance with applicable law.  

Rights of data subjects and Remedies

If you have any questions about this Notice or about ExxonMobil’s handling of your Personal data, please refer to the GDPN where your rights are described in detail together with contact information.