Golden Harvest Trade ("we", "our", "us") is a commodity and agricultural trading company engaged in the sourcing, distribution and trade of premium agricultural produce, raw commodities and related products across domestic and international markets.

For the purposes of applicable data protection legislation — including the General Data Protection Regulation (GDPR) and any applicable national implementing legislation — Golden Harvest Trade acts as the Data Controller in respect of personal data collected through our website, business operations, client and supplier relationships, and communications.

Our registered business address and principal place of operations serve as our primary data controller contact. Details for contacting our Data Protection representative are provided in Section 14 of this Policy.

2.1 Information You Provide Directly

• Identity Data: Full name, job title, company name, trading registration number.
• Contact Data: Business and personal email address, telephone number, mailing address, office address.
• Transaction Data: Purchase orders, invoices, payment details, bank account information (business accounts only), trade documents, commodity specifications and contract terms.
• Correspondence Data: Emails, letters, messages, enquiries and any content you send us through our communication channels.
• Account Data: Login credentials, account preferences and settings if you register for a client or supplier portal.
• Compliance and Verification Data: Identity documents, business registration certificates, compliance questionnaires, anti-money laundering (AML) and know-your-customer (KYC) documentation required by law.
• Employment and Recruitment Data: CVs, cover letters, references and employment history provided in connection with job applications.

2.2 Information We Collect Automatically

• Usage Data: Pages visited, time spent on pages, links clicked, referring URLs and navigation paths on our website.
• Technical Data: IP address, browser type and version, operating system, device type and screen resolution.
• Cookie Data: Information collected through cookies and similar tracking technologies as described in Section 9.
• Location Data: Approximate geographic location derived from your IP address.

2.3 Information from Third Parties

• Credit reference agencies and trade credit verification services.
• Regulatory bodies, licensing authorities and compliance databases (for AML/KYC checks).
• Business partners, referrers and introductory agents who facilitate a commercial relationship with us.
• Publicly available sources including company registries, trade directories and professional networks.

We use the personal data we collect for the following purposes:

We only process your personal data where we have a lawful basis to do so. Our legal bases are:

• Contractual Necessity: Processing is necessary to perform a contract with you or to take steps at your request before entering into a contract — for example, executing a trade agreement or fulfilling a purchase order.
• Legal Obligation: Processing is necessary to comply with a legal obligation — including AML/KYC obligations, tax reporting, export licensing and trade sanctions compliance.
• Legitimate Interests: Processing is necessary for our legitimate business interests — including fraud prevention, network security, business development, improving our services and maintaining business records — provided these interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent — for example, for direct marketing emails or non-essential cookies — you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Vital Interests: In rare cases, processing may be necessary to protect the vital interests of an individual — for example, in a health emergency.

Golden Harvest Trade does not sell, rent or trade your personal data to third parties for their own marketing purposes. We may share your personal data in the following circumstances:

5.1 Service Providers and Processors

• Logistics and freight partners who require consignee and contact details to arrange commodity shipments.
• Payment processors and banking partners who process trade payments and manage escrow or letter of credit arrangements.
• IT and cloud infrastructure providers who host our systems, data and communications platforms.
• Legal, audit and professional advisors who provide compliance, legal or accountancy services in connection with our business.
• Credit and compliance verification agencies used to conduct KYC, AML and credit risk assessments.

5.2 Regulatory and Legal Disclosure

• Disclosure to regulatory authorities, government bodies, law enforcement agencies or courts where required by law or a valid legal process.
• Disclosure to trade sanctions compliance authorities in connection with international commodity trading regulations.
• Disclosure required by tax authorities in jurisdictions where we operate.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of our business, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer where required by law.

All third parties with whom we share personal data are required to maintain appropriate technical and organisational security measures and to process your data only on our documented instructions.

As an international trading company, Golden Harvest Trade may transfer your personal data to countries outside your country of residence, including countries that may not have data protection laws equivalent to those in your jurisdiction.

Where we transfer personal data internationally, we ensure that appropriate safeguards are in place, including:

• Transfers to countries recognised by the relevant authority as providing an adequate level of data protection.
• Standard Contractual Clauses (SCCs) approved by the European Commission or equivalent authorities, incorporated into our agreements with overseas data processors and recipients.
• Binding Corporate Rules where applicable within our group of companies.
• Your explicit consent to the transfer, where required and where no other safeguard applies.

You may request a copy of the safeguards we have put in place for international transfers by contacting us at the details in Section 14.

We retain personal data only for as long as is necessary for the purposes for which it was collected and to comply with our legal, regulatory and contractual obligations. Our general retention periods are:

At the end of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data destruction policy. Where data is anonymised, it may be retained indefinitely for analytical purposes as it no longer constitutes personal data.

Subject to applicable law, you have the following rights in relation to your personal data held by Golden Harvest Trade:

To exercise any of these rights, please contact us using the details in Section 14. We will respond to verified requests within 30 days. We may need to verify your identity before processing your request.

Our website uses cookies and similar tracking technologies to improve your browsing experience, analyse site traffic and support our marketing activities. A cookie is a small text file stored on your device when you visit a website.

You can manage your cookie preferences at any time through your browser settings or via our Cookie Consent tool displayed on your first visit to our website. Please note that disabling certain cookies may affect the functionality of our website.

Golden Harvest Trade takes the security of your personal data seriously. We have implemented appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

• Encryption of personal data in transit using TLS/SSL protocols and at rest using AES-256 encryption standards.
• Role-based access controls ensuring that personal data is accessible only to authorised personnel who require access for their job functions.
• Regular security assessments, vulnerability scanning and penetration testing of our IT systems and infrastructure.
• Mandatory data protection and cybersecurity training for all staff with access to personal data.
• A documented Data Breach Response Policy and incident management procedure, including notification to affected individuals and supervisory authorities where required by law.
• Secure physical document management, including locked storage for physical records and secure destruction of paper documents containing personal data.

Our website may contain links to third-party websites, trade directories, commodity exchanges, industry portals and partner platforms. These links are provided for your convenience and information only.

Golden Harvest Trade does not control the content, privacy practices or data handling of any third-party website. We are not responsible for the privacy policies or practices of any third-party site and encourage you to review the privacy policy of any website you visit before providing any personal data.

A link from our website to a third-party site does not constitute an endorsement of that site, its content, or its privacy practices.

The website and services of Golden Harvest Trade are directed exclusively at businesses and adult individuals engaged in commercial trade activities. Our website is not intended for use by children under the age of 18.

We do not knowingly collect, process or retain personal data from individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take prompt steps to delete such data from our records.

If you believe that we may have collected personal data from a minor, please contact us immediately at the details provided in Section 14.

Golden Harvest Trade reserves the right to update or amend this Privacy Policy at any time to reflect changes in our business practices, applicable legislation, regulatory requirements or the nature of the personal data we process.

Where we make material changes to this Policy, we will notify you by one or more of the following means:

• Posting a prominent notice on our website homepage or within your client or supplier portal.
• Sending an email notification to registered users and active account holders.
• Displaying a pop-up or banner notification on first visit to our website following the update.

The effective date of the current version of this Policy is stated at the top of this page. We encourage you to review this Policy periodically to stay informed of how we protect and handle your personal data. Your continued use of our website or services following notification of changes constitutes your acknowledgement of the revised Policy.

If you have any questions, concerns or requests relating to this Privacy Policy or the way in which Golden Harvest Trade processes your personal data, please contact our Data Protection team by email. Email is our sole means of communication for all privacy-related enquiries.

You also have the right to lodge a complaint with your local data protection supervisory authority if you are not satisfied with our response or believe that we are not processing your personal data in accordance with applicable law. In the United Kingdom, the supervisory authority is the Information Commissioner's Office (ICO) at www.ico.org.uk. In the European Union, you may contact the supervisory authority in your member state of residence.