We at Prebro Ltd (hereinafter, “our”, “us”, “we” or “Prebro”) know you care about how your information is used and shared, and we take your privacy seriously. Please read the following to learn more about how we collect, store, use, disclose, and otherwise protect and process information about you when you interact or use our website (the “Site”) or any related events, trade shows, sales or marketing, and/or if you use any of our products, including mobile applications (collectively the “Services”) in any manner. Prebro is a trade facilitator for export and import of commodities in bulk commerce using major marine logistical bases. We respect your private information and undertake to protect your information as provided herein. Therefore, we request you to carefully read the terms of our Privacy Policy (this “Privacy Policy”).

Our Privacy Policy is an agreement between us and the users/ registrants (hereinafter “you”, “your”, “yourself” or “User”) of our Site www.Prebro.com and Services. You may provide information to us voluntarily or we may automatically collect information when you access our Site or use our Services. This Privacy Policy does not apply to information that you provide to or that is collected by any third-party site that you access or use in connection with using our Services.

By visiting our Site or using our Services, you hereby signify your acceptance of the terms of this Privacy Policy and your agreement to be bound by the same.

1. Collection of Information:

This Privacy Policy applies to information that:

(i) You may provide information to us voluntarily while registering on the Site or using our Services, such as:

• Personal Data.Demographic and other personally identifiable information (such as your name, email address, physical addresses, postal addresses, telephone numbers etc., “Personal Information”) that you voluntarily give to us when participating in activities related to the Site, such as chat, posting messages in comment sections or in our forums, liking posts, sending feedback, and responding to surveys. If you choose to share data about yourself via your profile, online chat, or other interactive areas of the Site, please be advised that all data you disclose in these areas is public and your data will be accessible to anyone who accesses the Site. We also maintain your usernames, passwords, email addresses and other security-related information provided by you in relation to our services.
• Business and Trading Data.Your business-related information, such as company details, management details, documents and the commodities you carry on your trade in
• Derivative Data.Information our servers automatically collect when you access the Site, such as your native actions that are integral to the Site, as well as other interactions with the Site and other users via server log files. We may also collect and maintain contact information of people you notify of our Service and communications between you and other users of the Site through the Site, posts, etc.
• Financial Data.Financial information, such as data related to your payment method (e.g. credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our Services from the Site. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processor. We also collect your payment and account information including account history with us, all billing information and communications, payment history etc.
• Geo-Location Information.We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Site, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data.Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.
• Push Notifications.We may request to send you push notifications regarding your account or the Site. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
• Third-Party Data.Information from third-parties, such as Personal Information or network friends, if you connect your account to the third-party and grant the Site permission to access this information. We also collect and maintain third-party data either created by you or by a third-party and which you wish to store on our servers such as image files, documents etc.
• Data from Contests, Giveaways, and Surveys.Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.
• Biometric Information.Including measurements and calculations related to human characteristics. Biometrics authentication may be used as a form of identification and access control.

 

All information that you disclose shall be deemed to be disclosed willingly and without any coercion. Prebro  shall have no liability regarding any User’s lack of authenticity, misrepresentation, fraud, negligence, etc. of the information disclosed.

 

(ii) We may collect information automatically from you when you access or use the Site or Services. For example, we may automatically collect your location, computer operating system, Internet Protocol (IP) address, information about your Internet connection and mobile device, access times and the browser type and language. We may also collect information about your navigation using our Services, for example the URLs of websites that you visit and from which you request downloads. Further, we may collect information about your preferences and settings such as time zone and language, your searches and the results you selected from the search, your browsing information and your transactional information. We also collect information about your usage and activity on the Site using certain technologies, such as: Cookies. Cookies are small data files that may have unique identifiers and reside, among other places, on your computer or mobile device, in emails we send to you, and on the Site. Among other things, cookies help us improve the Site and your experience.

Web Beacons. We may collect information using web beacons. Web beacons are electronic images that may be used on the Site or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness, and tell whether you open an email and act upon it.

All information that we gather shall be stored on servers, log files and any other storage system owned by Prebro or by third-parties. Additionally, information may be stored on Prebro ’s computers, hard drives, hard copies, etc.

We shall collect information from you, during but not limited to the following stages:

• a) When you subscribe/register for any of our Services;
• b) When you browse, access or use the Site;
• c) When you avail any of our Services;
• d) When you invite others to use the Site; and
• e) When you make any payments using the payment system on the Site.

2. Usage of Information

You agree and acknowledge that all your information, whether voluntarily provided by you or automatically collected, may be used by Prebro for the following purposes:

• (i) to create and manage your account;
• (ii) to contact you regarding your account or orders;
• (iii) to fulfill and manage purchases, orders, payments, and other transactions that you conduct on the Site.
• (iv) to provide, maintain, develop, protect and improve our Services, manage your account/orders/subscriptions, etc.;
• (v) to understand you and your preferences and to enhance, personalize, and customize your experience using the Site;
• (vi) to respond to your comments, reviews and questions and provide better customer service;
• (vii) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection of amounts;
• (viii) for communication regarding important notices, changes in our Services, any of our Terms and Conditions and other User-related conditions and policies;
• (ix) to offer new products, services, mobile applications, and/or recommendations to you
• (x) to facilitate user-to-user communications;
• (xi) to compile anonymous statistical data and analysis for use internally or with third-parties. Such data may be used for auditing, data analysis and research relating to the Site or Services;
• (xii) for promotion and marketing purposes;
• (xiii) for sharing such information with third-parties in the course of providing our Services;
• (xiv) to compile statistical and demographical profiles for our business and marketing purposes;
• (xv) to comply with any statutory or regulatory requirements, including to assist law enforcement and respond to subpoena;
• (xvi) to monitor your use of the Site or Services for the purposes of ensuring compliance with our Privacy Policy and Terms and Conditions;
• (xvii) to prevent fraudulent transactions, monitor against theft, and protect against criminal activity; and
• (xviii) for any other purpose with your consent.

 

3. Collection of Information by Third-Party Sites and Advertisers

Our Site may contain links to other sites/applications, whose privacy policies may be different than ours. You should consult the other sites'/applications’ privacy policies as we have no control over information that is submitted to, or collected by, such third-parties.

4. DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

• (i)By Law or to Protect Rights. If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety our rights or the rights of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
• (ii)Third-Party Service Providers. We may share your information with third-parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
• (iii)Marketing Communications. With your consent, or with an opportunity for you to withdraw consent, we may share your information with third-parties for marketing purposes, as permitted by law.
• (iv)Interactions with Other Users. If you interact with other users of the Site, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.
• (v)Online Postings. When you post comments, contributions or other content to the Sites, your posts may be viewed by all users and may be publicly distributed outside the Site in perpetuity.
• (vi)Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to the Site and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.
• (vii)Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• (viii)Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
• (ix)Other Third-parties. We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third-parties for marketing purposes, as permitted by law.
• (x)Sale or Bankruptcy. If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third-party. You acknowledge that such transfers may occur, and that the transferee may decline honor commitments we made in this Privacy Policy.

 

We are not responsible for the actions of third-parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third-parties, you are responsible for contacting the third-party directly. We may also share aggregated or de-identified information with third-parties in our discretion.

5. TRACKING TECHNOLOGIES

• (i)Cookies and Web Beacons. We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. When you access the Site, your Personal Information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis. You may opt out of receiving promotional emails from Prebro  by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your account. Should you desire to opt out of disclosing your information to Prebro , we request you to close your User account and stop accessing the Site and using our Services. Thereafter, we may delete your Personal Information or de-identify it so that it is anonymous and not attributed to you.
• (ii)Internet-Based Advertising. We may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us. For more information about opting-out of interest-based ads, visit the [Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.]
• (iii)Website Analytics. We may also partner with selected third-party vendors, such as Google Analytics and others, to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content, and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer Personal Information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can install and/or update your settings for one of the following: Google Analytics Opt-Out Plugin or Google Ads Settings Page

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

6. Security

We use administrative, technical, and physical security measures to help protect your information. While we have taken reasonable steps to secure the Personal Information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide Personal Information.

Specifically, we may require you to share your credit or debit card account information to make payments for the Services availed by you through the Site. When payment card account information is being transmitted on or through the Site, it will be protected by encryption technology. You expressly consent to the sharing of your information with registered product vendors and other third-party service providers, including payment gateways, to process payments and manage payment card information. To be clear, Prebro does not itself store your payment card account information and does not have direct control over or responsibility for your payment card account information. We therefore cannot guarantee that transmissions of your payment card account information or Personal Information will always be secure or that unauthorized third-parties will never be able to defeat the security measures we or our third-party service providers take. Prebro assumes no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control. You play an important role in keeping your Personal Information secure. You should not share your user's name, password, or other security information for your account with anyone.

We undertake regular checks and tests to bolster our security safeguards. We test and update our Site to make it less susceptible to tampering. We employ firewalls and other security technologies to protect our servers from external attack and securely store your Personal Information. Some of our protective measures are listed below. Because the area of data protection is constantly evolving, the below list remains subject to frequent change and update.

• We use encryption and decryption certificates to protect website-server communication and ensure highest available trust. Data is encrypted via Transport Layer Security protocol and protects from phishing and man-in-middle attacks.
• Your valuable passwords are hashed, salted and protected with proven algorithm therefore resistant to dictionary, rainbow table, brute force etc.
• Protection against leakage of user information: login or password recovery attempts will not reveal any account information, including the existence of an account.
• Sensitive data, including documents are protected with military grade encryption and access is enabled through information security governance policy.
• Prebro ’s servers reside in the cloud inside the top-tier professional data center where Amazon host’s data.
• Data is replicated in real-time and backed up on daily basis.
• Front-office and Back office are in different location therefore separate networks for separate purposes. User role, responsibilities and access are defined based on sensitivity and priority.

 

7. Grievances

In the event you have any grievances relating to the Privacy Policy, please inform us within 24 hours of occurrence of the instance from which the grievance has arisen, by writing an email to the Grievance Officer at info@prebro.com. We will use best efforts to respond to all such grievances within 36 hours through email, telephone, personal visits, etc., and shall do our best to address your grievance expeditiously.

 

8. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third-parties for direct marketing purposes and the names and addresses of all third-parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

 

If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.

 

9. YOUR EUROPEAN PERSONAL DATA RIGHTS

European Users have the following rights with respect to your personal data where it applies to the particular processing of your Personal Information:

• The right to request a copy of your personal data that Prebro holds about you;
• The right to request that Prebro correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary for Prebro to retain such data;
• The right to withdraw your consent to the processing of your personal data at any time, which is further outlined right below;
• The right to request that Prebro provide you with your personal data and where possible, to transmit that data directly to another data controller where applicable;
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing; and
• The right to lodge a complaint with a European Union Data Protection or Supervisory Authority. Please see below, “EU Complaints to Supervisory Authorities”, for details.

 

When you consent to Prebro ’s processing of your personal data, you may withdraw your consent at any time. You can withdraw your consent per the request form here, or you can withdraw your consent either by postal mail to the “EU Contact Information” below or by email info@prebro.com  both instances specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal data, in particular where (i) you contest the accuracy of your personal data; (ii) the processing is unlawful and you oppose the erasure of your personal data; (iii) we no longer need your personal data for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and pending the verification whether the legitimate grounds of Prebro  override your own.

If you would like to access, review, update, rectify, and delete any Personal Information that we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), you can request via email info@prebro.com

Our Privacy team will examine your request and respond to you as quickly as possible, and within 30 days. Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

EU Contact Information

Prebro Ltd Data Protection Officer: Eng. Hamza Jayyab

KEMP HOUSE 160 CITY ROAD LONDON

UNITED KINGDOM EC1V 2NX

Telephone: +44 7459 622366

Telephone: +1 (909) 332-5330
Telephone: +90 55 3877 3085

 

EU Complaints to Supervisory Authorities. We invite you to let us know about any and all issues either directly by writing to Prebro ’s Data Protection Officer at info@prebro.com . We will respond through our Data Privacy Officer in writing within 30 days.

 

If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement. For example, in the United Kingdom this is the Information Commissioner’s Office, and in Ireland this is the Data Protection Commissioner.

 

10. International Data Transfers

We transfer your Personal Information to destinations outside the European Union on the basis of an adequacy decision, subject to appropriate safeguards, or pursuant to derogations for specific situations such as your consent or the transfer being necessary with regard to your contractual relationship with Prebro, as applicable.

 

Personal Information you submit on the Site or through the Services is sent to [UK] and will be primarily processed by us in [Uk] and potentially in other countries, on our servers or on our hosted service providers’ cloud servers on our behalf. These countries may not have similar data protection laws to those in your country of residence. However, we will always protect your information in accordance with this Privacy Policy wherever it is processed.

 

11. Amendments

Prebro retains unconditional right to modify or amend this Privacy Policy without any recourse or any requirement of notice of the same to you. You can determine when this Privacy Policy was last modified by referring to the “Last Updated” legend above. It shall be your responsibility to check this Privacy Policy periodically for changes. Your continued use of the Services provided on the Site following the posting of changes to this Privacy Policy will constitute your consent and acceptance of those changes