Legal

Privacy Policy

Sustainable Commodities B.V. - Data Protection & Privacy

Last Updated: December 30, 2024 | Version 1.0

Introduction

Sustainable Commodities B.V. ("we", "us", "our", or the "Operator") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our platform at Sustainable.Bid (the "Platform").

By using our Platform, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our Platform.

1. Data Controller

The data controller responsible for your personal data is:

Sustainable Commodities B.V.

Lemsterpad 54-A1, Unit 103

8531 AA Lemmer, Netherlands

Email: [email protected]

2. Data We Collect

2.1 Information You Provide

• Account Information: Name, email address, phone number, company name, job title
• Company Information: Business registration details, VAT number, address, certifications
• KYC Documentation: Identity documents, proof of address, company registration documents
• Transaction Data: Bids, offers, requests, pricing information, delivery terms
• Communications: Messages sent through the Platform, support inquiries

2.2 Information Collected Automatically

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, features used, time spent on Platform, click patterns
• Session Data: Login times, session duration, activity logs
• Location Data: Approximate location based on IP address (country/region level)

3. How We Use Your Data

We use your personal data for the following purposes:

• Platform Operation: To provide, maintain, and improve our services
• Account Management: To create and manage your account, verify your identity
• Transaction Facilitation: To enable trading activities between users
• Communication: To send notifications, updates, and respond to inquiries
• Security: To detect and prevent fraud, unauthorized access, and other illegal activities
• Compliance: To comply with legal obligations, including AML/KYC requirements
• Analytics: To understand usage patterns and improve user experience
• Marketing: To send promotional communications (with your consent)

4. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process your data based on:

• Contract Performance: Processing necessary to provide our services to you
• Legal Obligation: Processing required by law (e.g., AML, tax reporting)
• Legitimate Interest: Processing for fraud prevention, security, and platform improvement
• Consent: Processing based on your explicit consent (e.g., marketing emails)

5. Data Sharing & Disclosure

We may share your personal data with:

• Trading Counterparties: Limited information necessary to facilitate transactions (company name, contact details)
• Service Providers: Third-party vendors who assist with hosting, analytics, email delivery
• Legal Authorities: When required by law, court order, or regulatory request
• Professional Advisors: Lawyers, accountants, auditors under confidentiality obligations

We do NOT sell your personal data to third parties for marketing purposes.

6. Data Retention

We retain your personal data for as long as necessary to:

• Provide our services to you
• Comply with legal obligations (minimum 5 years for financial records)
• Resolve disputes and enforce agreements
• Maintain security and fraud prevention records

After account termination, we may retain certain data for legal compliance purposes. You may request deletion of your data subject to legal retention requirements.

7. Your Rights (GDPR)

Under GDPR, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data ("right to be forgotten")
• Right to Restrict Processing: Request limitation of data processing
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time for consent-based processing

To exercise these rights, contact us at: [email protected]

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

8. Cookies & Tracking

We use cookies and similar technologies for:

• Essential Cookies: Required for Platform functionality (login, session management)
• Analytics Cookies: To understand how users interact with our Platform
• Preference Cookies: To remember your settings and preferences

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may affect Platform functionality.

9. Data Security

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

• Encryption of data in transit (TLS/SSL) and at rest
• Secure data centers within the European Union
• Access controls and authentication mechanisms
• Regular security assessments and monitoring
• Employee training on data protection

While we strive to protect your data, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

10. International Data Transfers

Your data is primarily stored and processed within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions for countries with equivalent data protection
• Binding Corporate Rules for intra-group transfers

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Email notification to your registered email address
• Prominent notice on our Platform
• Updating the "Last Updated" date at the top of this policy

Continued use of the Platform after changes constitutes acceptance of the updated policy.

12. Contact Us

For privacy-related inquiries, requests, or complaints, please contact:

Sustainable Commodities B.V.

Data Protection Contact

Lemsterpad 54-A1, Unit 103

8531 AA Lemmer, Netherlands

Email: [email protected]

We aim to respond to all privacy requests within 30 days.

We value your privacy

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