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Privacy, Data Protection & Commercial Information Handling Policy

1. Scope & Commitment

SAI AGRO BRAZIL LTDA (“the Company”) recognizes that international trade involves the exchange of commercially sensitive and personally identifiable information.

This policy governs:

  • Personal data submitted through the website
  • Commercial trade inquiry information
  • Uploaded business documentation
  • Electronic communications
  • Cross-border data handling related to export operations

The Company is committed to lawful, transparent, and secure processing of such information.

2. Legal Framework

As a Brazilian company, SAI AGRO BRAZIL LTDA operates under:

  • Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados – LGPD, Law No. 13.709/2018)

Where applicable, and particularly in relation to inquiries originating from the European Union, processing principles reflect alignment with:

  • General Data Protection Regulation (GDPR – Regulation (EU) 2016/679)

The Company does not claim establishment within the European Union but acknowledges that cross-border commercial interactions may require adherence to recognized international data protection principles.

3. Categories of Data Collected

A. Identification & Contact Data
  • Company name
  • Registration number
  • Business address
  • Official contact email
  • Representative contact details
B. Commercial Trade Information
  • Product interest
  • Volume requirements
  • Delivery ports
  • Incoterms preferences
  • Contractual discussions
C. Uploaded Documentation

Where voluntarily submitted:

  • Business registration certificates
  • Import/export licenses
  • Letters of Intent (LOIs)
  • Company profiles
  • Other trade qualification materials

Uploaded documents may contain sensitive commercial intelligence and are handled accordingly.

4. Purpose of Processing

Data collected is used exclusively for:

  • Evaluation of structured trade inquiries
  • Commercial qualification of partners
  • Compliance verification for regulated exports
  • Contract negotiation and execution
  • Regulatory documentation where legally required

The Company does not sell, rent, or commercially exploit submitted data for marketing resale purposes.

5. Legal Basis for Processing (LGPD Framework)

Under LGPD, processing may rely on:

  • Consent (when voluntarily submitted)
  • Legitimate interest for commercial engagement
  • Contractual necessity
  • Compliance with legal or regulatory obligations

Processing is limited to what is proportionate and necessary for commercial evaluation.

6. Commercial Confidentiality

Trade inquiry information and uploaded documentation may contain commercially sensitive information.

SAI AGRO BRAZIL LTDA:

  • Restricts internal access to authorized personnel
  • Uses secure administrative systems
  • Avoids disclosure to third parties unless required for contractual execution or regulatory compliance

The Company does not publish or distribute confidential inquiry information.

7. Cross-Border Data Handling

Given the Company’s focus on Africa, Asia, Europe, and Middle Eastern markets:

  • Submitted data may be accessed by authorized personnel involved in export coordination.
  • Where cross-border handling is necessary, it is conducted under commercially reasonable safeguards consistent with international trade practices.

No international transfer occurs for marketing resale purposes.

8. Data Retention

Commercial inquiry data is retained:

  • For the duration necessary to evaluate trade viability
  • For the term of contractual engagement (if applicable)
  • For regulatory compliance periods required under applicable law

Data not leading to commercial engagement may be periodically reviewed and securely deleted.

9. Website Technology & Cookies

The website may use:

  • Essential technical cookies for functionality
  • Security measures to protect form submissions

If analytics or marketing tracking technologies are implemented in the future, this policy will be updated accordingly to reflect:

  • Type of data collected
  • Purpose of tracking
  • User opt-out mechanisms

10. Data Subject Rights

Under LGPD and applicable international principles, individuals may request:

  • Confirmation of data processing
  • Access to stored information
  • Correction of inaccurate data
  • Anonymization or deletion where legally permissible

Requests may be submitted via official contact channels.

11. Security Measures

The Company applies commercially reasonable administrative and technical safeguards, including:

  • Restricted system access
  • Password-protected administrative environments
  • Secure hosting infrastructure
  • Controlled access to uploaded documents

While no system can guarantee absolute security, risk mitigation practices are implemented proportionate to operational scale.

12. Limitation of Liability

The Company is not responsible for data submitted voluntarily beyond its systems, including:

  • Email forwarding by third parties
  • External communication platforms not controlled by the Company
  • Third-party website links

13. Policy Updates

This policy may be updated to reflect:

  • Regulatory changes
  • Operational updates
  • Website technology modifications

The current version published on the website remains authoritative.

14. Data Protection Contact

For data protection inquiries:

SAI AGRO BRAZIL LTDA
Cotegipe, Bahia, Brazil
Email: info@saiagrobrazil.com

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