PRIVACY POLICY
This Privacy Policy explains how Rollo Energy ("we", "our", or "the firm") collects, uses, stores, and protects personal information obtained through our business activities, website, and direct counterparty engagement.
1. Who We Are
Rollo Energy is an independent energy trade facilitation firm operating as a sole trader. We act exclusively as a mandated intermediary in physical energy transactions. Our correspondence address is Geneva, Switzerland, with operational activities conducted from Berlin, Germany.
2. Information We Collect
We may collect and process the following categories of personal and business data:
Contact details: name, title, company, email address, phone number
Business credentials: company registration documents, KYC/AML documentation
Transaction-related data: counterparty details, deal parameters, commercial terms
Communications: email correspondence, meeting notes, WhatsApp messages exchanged in a professional context
Website usage data: IP address, browser type, pages visited (if applicable)
3. Legal Basis for Processing
We process personal data on the following legal grounds:
Contractual necessity: where processing is required to fulfil or negotiate a mandate or commercial agreement
Legitimate interests: to maintain our counterparty relationships, conduct due diligence, and protect the firm's commercial position
Legal obligation: to comply with applicable anti-money laundering (AML), sanctions screening, and know-your-customer (KYC) requirements
Consent: where you have explicitly provided consent for a specific processing activity
4. How We Use Your Information
Your data is used strictly for the following purposes:
Evaluating and executing trade mandates and facilitating introductions between verified counterparties
Conducting sanctions and compliance screening against OFAC SDN, EU Consolidated, OFSI, and Equasis/AIS lists
Maintaining counterparty records as required by applicable law
Communicating with you regarding active or prospective transactions
Protecting the firm's commercial interests, including the preservation of intermediary confidentiality
5. Confidentiality and Counterparty Separation
Rollo Energy operates under a strict information separation policy. Counterparty identities and commercial details are not disclosed to third parties without prior execution of a Non-Circumvention Non-Disclosure Agreement (NCNDA). No buyer-side or seller-side details are shared prematurely. This is a core operational principle of the firm.
6. Data Sharing
We do not sell, rent, or trade personal data. We may share information only in the following limited circumstances:
With verified counterparties under an executed NCNDA, on a need-to-know basis
With professional advisors (legal, compliance, accounting) bound by confidentiality obligations
With competent authorities where required by applicable sanctions, AML, or financial crime legislation
In connection with a business transfer, merger, or restructuring, subject to equivalent data protections
7. International Transfers
Our business activities span multiple jurisdictions including the EU, UK, Switzerland, Asia, and the Gulf region. Where personal data is transferred internationally, we ensure appropriate safeguards are in place consistent with applicable data protection law, including EU GDPR Chapter V requirements where applicable.
8. Data Retention
We retain personal and transactional data for as long as is necessary for the purposes for which it was collected, and for a minimum period of five (5) years following the conclusion of a mandate or engagement, in accordance with applicable AML and commercial record-keeping obligations.
9. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. All sensitive counterparty information is handled with strict access controls and communicated only through secure, encrypted channels.
10. Your Rights
Subject to applicable law, you may have the right to:
Access the personal data we hold about you
Request correction of inaccurate data
Request erasure of data, where there is no overriding legal basis for retention
Object to or restrict certain processing activities
Withdraw consent at any time, without affecting prior lawful processing