Privacy Policy

1. Information We Collect

Information You Provide Directly

When you interact with us, we may collect the following personal data:

• Contact information (name, email address, phone number, company name)
• Business information (company registration, trade references, shipping addresses)
• Communication records (emails, WhatsApp messages, phone call records)
• Transaction data (purchase orders, invoices, payment information, Letters of Credit details)
• Identity verification documents (as required for international trade compliance)

Information Collected Automatically

When you visit our Site, we automatically collect:

• Device information (browser type, operating system, device identifiers)
• Usage data (pages visited, time spent, click patterns, referral sources)
• IP address and approximate geographic location
• Cookies and similar tracking technologies (see Section 4)

WhatsApp Communications

When you contact us via WhatsApp, Meta Platforms Inc. processes certain metadata including your phone number, message timestamps, and delivery status. We store the content of WhatsApp conversations to manage trade inquiries and customer support. Please refer to WhatsApp's own privacy policy for details on their data processing.

2. How We Use Your Information

We use your personal data for the following purposes:

• Processing and fulfilling commodity trade orders and inquiries
• Communicating with you about products, pricing, and shipment status
• Generating proforma invoices and managing Letters of Credit
• Complying with international trade regulations, export controls, and sanctions screening
• Verifying identity and conducting due diligence as required by law
• Improving our website, products, and services
• Analyzing website usage to enhance user experience (via Vercel Analytics)
• Sending relevant trade updates and market insights (with your consent)
• Defending legal claims and enforcing our agreements

3. How We Share Your Information

We do not sell your personal data. We may share your information with:

• Logistics partners and shipping companies to fulfill orders
• Banking and financial institutions for payment processing and L/C verification
• Quality inspection bodies (SGS, Bureau Veritas) as part of trade documentation
• Legal and regulatory authorities when required by law
• Professional advisors (legal, accounting, insurance) as needed
• Technology providers: Vercel (website hosting and analytics), Cookiebot (consent management)

4. Cookies and Tracking Technologies

Our Site uses cookies and similar technologies to enhance your experience. We use Cookiebot for cookie consent management. The types of cookies we use include:

• Essential cookies: Required for the Site to function properly (session management, security)
• Analytics cookies: Help us understand how visitors use our Site (Vercel Web Analytics)
• Preference cookies: Remember your settings such as language and region

You can manage your cookie preferences at any time through the Cookiebot consent banner or your browser settings. Disabling certain cookies may limit functionality of the Site.

5. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law. Specifically:

• Trade transaction records: Retained for a minimum of 7 years as required by Nigerian commercial law and international trade regulations
• Website analytics data: Retained for up to 24 months
• Marketing communications records: Retained until you withdraw consent
• Contact form inquiries: Retained for 2 years from last interaction

6. International Data Transfers

As a global commodity trading company operating across 40+ countries, your data may be transferred to and processed in countries outside your country of residence. We ensure appropriate safeguards are in place for such transfers, including:

• Standard Contractual Clauses (SCCs) for transfers from the EU/EEA
• Compliance with the NDPA requirements for cross-border transfers from Nigeria
• Compliance with PIPL requirements for cross-border transfers from China, including security assessments where required
• Ensuring recipient countries provide adequate data protection or implementing supplementary measures

7. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights:

• Right to access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate or incomplete data
• Right to erasure: Request deletion of your personal data (subject to legal retention requirements)
• Right to restrict processing: Request limitation of how we use your data
• Right to data portability: Receive your data in a structured, machine-readable format
• Right to object: Object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent: Withdraw previously given consent at any time

To exercise any of these rights, please contact us using the details in Section 11. We will respond to your request within 30 days.

Nigeria-Specific Rights (NDPA)

Under the Nigeria Data Protection Act 2023, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data has been processed unlawfully.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• TLS/SSL encryption for all data transmitted through our website
• Secure storage of trade documents and financial information
• Access controls limiting data access to authorized personnel only
• Regular security assessments of our systems and processes

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. We encourage you to take precautions with your own data when communicating online.

9. Children's Privacy

Our Site and services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will promptly delete it.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The "Last updated" date at the top of this policy indicates when it was last materially revised. We encourage you to review this policy periodically. Continued use of our Site after changes constitutes acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy, wish to exercise your data protection rights, or have concerns about how we handle your personal data, please contact us: