Privacy Policy

1. Information We Collect

1.1 Information You Provide Directly

When you interact with our websites, submit inquiries, or engage with our services, we may collect:

• Company Information: Company name, registration number, registered address, country of incorporation, website URL, and business type
• Contact Information: Name, title/position, email address, phone number, and correspondence address
• Transaction Information: Product interests, quantity requirements, delivery specifications, and facilitation preferences
• Compliance Documentation: Sanctions screening certificates, company registration documents, and verification materials
• Communication Records: Content of emails, messages, and inquiries submitted through our platforms

1.2 Information Collected Automatically

When you visit our websites, we automatically collect certain technical information:

• IP address and geographic location (country/region level)
• Browser type and version
• Operating system
• Device type and identifiers
• Pages visited, time spent, and navigation paths
• Referring website or source
• Date and time of access

1.3 Information from Third Parties

We may receive information from third-party sources including:

• Sanctions screening databases and compliance verification services
• Company registration verification services
• Credit reference agencies (for business verification purposes)
• Government regulatory databases (NATO, SAM.gov, EORI systems)

2. How We Use Your Information

We use collected information for the following purposes:

2.1 Business Operations

• Processing and responding to inquiries from buyers and sellers
• Facilitating petroleum product transactions between verified parties
• Communicating about products, services, and transaction status
• Managing business relationships with partners and clients

2.2 Compliance and Security

• Conducting sanctions screening and due diligence verification
• Complying with anti-money laundering (AML) and know-your-customer (KYC) requirements
• Verifying company registration and legitimacy
• Detecting and preventing fraud, unauthorized access, and illegal activities
• Meeting regulatory and legal obligations across all jurisdictions

2.3 Service Improvement

• Analyzing website usage to improve user experience
• Developing new features and services
• Conducting internal research and analysis

2.4 Communication

• Sending service-related notifications and updates
• Responding to questions, feedback, and support requests
• Providing information about relevant products and services (with consent where required)

3. Legal Basis for Processing (GDPR)

For individuals in the European Economic Area (EEA), United Kingdom, and other jurisdictions requiring lawful basis for processing, we rely on the following grounds:

• Contractual Necessity: Processing necessary to perform contracts or take pre-contractual steps at your request
• Legal Obligation: Processing required to comply with legal obligations, including sanctions compliance, AML requirements, and regulatory reporting
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, security, and business development, where these interests are not overridden by your rights
• Consent: Where you have provided explicit consent for specific processing activities

4. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share information in the following circumstances:

4.1 Within Eurabelt Fuels Group

Information may be shared between Eurabelt Fuels entities in the United Kingdom, Canada, Trinidad & Tobago, and South Africa for operational purposes and to provide seamless service across jurisdictions.

4.2 Service Providers

We engage trusted third-party service providers who process data on our behalf, including:

• Sanctions screening and compliance verification services
• Web hosting and cloud infrastructure providers
• Email and communication service providers
• Professional advisors (legal, accounting, audit)

4.3 Legal Requirements

We may disclose information when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations, court orders, or regulatory requests
• Protect our rights, property, or safety
• Prevent or investigate illegal activities
• Respond to government authorities

4.4 Business Transactions

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, subject to appropriate confidentiality protections.

5. International Data Transfers

As a multinational organization operating in the United Kingdom, Canada, Trinidad & Tobago, and South Africa, your information may be transferred to and processed in countries other than your country of residence.

5.1 Safeguards

When transferring personal data internationally, we implement appropriate safeguards including:

• Standard Contractual Clauses approved by the European Commission
• Binding Corporate Rules where applicable
• Adequacy decisions where the destination country provides adequate protection
• Contractual commitments with recipients to protect your data

5.2 Specific Transfer Routes

• UK ↔ EU: Covered by UK adequacy regulations and SCCs where required
• UK/EU ↔ Canada: Canada has an adequacy decision for commercial organizations under PIPEDA
• UK/EU ↔ South Africa: Transfers subject to SCCs and POPIA compliance
• UK/EU ↔ Trinidad & Tobago: Transfers subject to SCCs and contractual protections

6. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required by law.

Retention Periods

• Inquiry Records: 7 years from last interaction (compliance requirement)
• Transaction Records: 10 years (AML compliance requirement)
• Sanctions Screening Results: Duration of business relationship plus 7 years
• Website Analytics: 26 months
• Communication Records: 7 years from date of communication

7. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information:

7.1 Universal Rights

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate or incomplete information
• Withdrawal of Consent: Withdraw consent where processing is based on consent
• Complaint: Lodge a complaint with a supervisory authority

7.2 Additional Rights (GDPR/UK GDPR)

Individuals in the EEA and UK also have the right to:

• Erasure: Request deletion of personal information in certain circumstances
• Restriction: Request restriction of processing
• Portability: Receive your data in a structured, machine-readable format
• Object: Object to processing based on legitimate interests

7.3 Canadian Rights (PIPEDA)

Canadian residents have the right to access and correct their personal information and to challenge our compliance with PIPEDA.

7.4 South African Rights (POPIA)

South African residents have the right to request correction, deletion, or destruction of personal information, and to object to processing.

7.5 Exercising Your Rights

To exercise any of these rights, please contact us using the details provided in Section 15. We will respond within the timeframes required by applicable law.

8. Security Measures

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, or destruction:

• Encryption of data in transit and at rest
• Secure access controls and authentication
• Regular security assessments and penetration testing
• Employee training on data protection and security
• Incident response procedures
• Physical security measures for premises and equipment

While we strive to protect your information, no system is completely secure. We cannot guarantee absolute security of your data.

9. Cookies and Tracking Technologies

Our websites use cookies and similar technologies to enhance your experience:

9.1 Types of Cookies

• Essential Cookies: Required for website functionality (session management, security)
• Analytics Cookies: Help us understand website usage and performance
• Preference Cookies: Remember your settings and preferences

9.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling certain cookies may affect website functionality.

10. Third-Party Links

Our websites may contain links to third-party websites, including:

• NATO CAGE verification portal
• SAM.gov registration system
• UK Government EORI checker
• Partner and reference websites

These third parties have their own privacy policies. We are not responsible for their privacy practices or content.

11. Children's Privacy

Our services are designed for business entities and their adult representatives. We do not knowingly collect personal information from individuals under 18 years of age. If we learn that we have collected information from a child, we will promptly delete it.

12. Sanctions Screening and Compliance

12.1 Purpose of Screening

As part of our commitment to regulatory compliance and ethical business practices, we conduct sanctions screening on all individuals and companies seeking to do business with Eurabelt Fuels. This screening checks against:

• OFAC (Office of Foreign Assets Control) sanctions lists
• EU consolidated sanctions list
• UN Security Council sanctions
• UK sanctions list
• Politically Exposed Persons (PEP) databases
• Other relevant national and international sanctions lists

12.2 Free Service Declaration

12.3 Screening Results

Approval or disapproval of screening is determined solely by documentation verification and compliance with international sanctions regulations. Eurabelt Fuels custodians and facilitators do not make subjective approval decisions—all determinations are based on objective compliance criteria.

13. Regional Specific Provisions

13.1 United Kingdom

Data Controller: Eurabelt Fuels Ltd, Flat 11 Clothier House, Kinveachy Gardens, London SE7 8EF, United Kingdom

Supervisory Authority: Information Commissioner's Office (ICO), ico.org.uk

Applicable Law: UK GDPR and Data Protection Act 2018

13.2 European Union

Applicable Law: General Data Protection Regulation (GDPR)

EU residents can contact our UK entity as the lead supervisory authority contact or their local data protection authority.

13.3 Canada

Data Controller: Eurabelt Fuels Ltd., 13741 Humber Station Rd, Caledon, ON L7E 0Z8, Canada

Supervisory Authority: Office of the Privacy Commissioner of Canada, priv.gc.ca

Applicable Law: Personal Information Protection and Electronic Documents Act (PIPEDA)

13.4 South Africa

Data Controller (Responsible Party): Eurabelt Fuels (PTY) Ltd, 8 Uit Oos Street, Pacaltsdorp, George, Western Cape 6529, South Africa

Regulator: Information Regulator, inforegulator.org.za

Applicable Law: Protection of Personal Information Act (POPIA)

13.5 Trinidad & Tobago

Data Controller: Eurabelt Fuels Ltd, 72 Blue Basin Road, Diego Martin, Port of Spain, Trinidad and Tobago

Applicable Law: Data Protection Act 2011 (Trinidad and Tobago)

14. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:

• We will update the "Last Updated" date at the top of this Policy
• We may notify you via email or prominent notice on our websites
• We encourage you to review this Policy periodically

Your continued use of our services after changes become effective constitutes acceptance of the updated Policy.

15. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We aim to respond to all legitimate requests within 30 days (or within shorter timeframes where required by law).