1. Scope Of This Policy

This Privacy Policy applies to personal information that Bougainvillea Trading LLC processes through the website located at bougainvilleatrade.surf, through email and telephone communications, and through the professional services the Company provides to partners, suppliers and other business contacts. It also applies to information collected during supplier vetting and audits, import logistics coordination, wholesale distribution support, trade compliance support and market entry consulting engagements.

The policy does not apply to information that has been fully anonymised so that it can no longer be linked to an identifiable person, nor to information handled by third parties under their own privacy notices. Where the Company processes information on behalf of a partner under a written services agreement, that agreement may contain additional privacy terms, and the partner may be the party responsible for answering individual privacy requests.

This policy is intended to be read together with the Terms of Service that govern use of this website. Together those documents describe the full framework of the relationship between a visitor or partner and the Company.

2. Who Controls Your Information

The entity responsible for the personal information described in this policy is Bougainvillea Trading LLC, with its registered place of business at 513 E 800 N, American Fork - 84003-1405, United States (US). The Company determines why and how personal information is processed in connection with this website and its service engagements.

Questions about this policy, requests to exercise privacy rights, and concerns about how information is handled may be directed to the privacy contact at the Company by email at partners@bougainvilleatrade.surf or by telephone at +17192983602. The Company will acknowledge a privacy enquiry within a reasonable period and will work to resolve the matter promptly and transparently.

Where the Company acts as a processor or service provider on behalf of a partner, the partner remains the controller for the relevant information. In that situation the Company follows the partner instructions, applies the safeguards described in the services agreement, and refers individual requests to the partner where appropriate.

3. Information We Collect

The categories of personal information the Company may collect include identity information such as name and job title, contact information such as email address, telephone number and postal address, business information such as company name, role, department and purchasing authority, and the content of messages sent to the Company through the contact form, by email or during a call.

When a supplier is vetted or audited, the Company may collect business contact details for the individuals who work at that supplier, along with information about their roles, responsibilities and the records needed to complete the audit. This may include names of quality managers, production supervisors and compliance officers, together with declarations and certificates that contain personal data.

The Company may also collect technical information that is generated automatically when a website is visited. This can include internet protocol address, browser type and version, device type, operating system, referring pages, pages viewed and the dates and times of visits. Technical information of this kind is used to keep the site secure, to understand aggregate usage patterns and to improve the experience for all visitors.

The Company does not intentionally collect special categories of personal data such as health information, political opinions or religious beliefs, and does not ask for them through this website. Please do not submit such information through the contact form or by email unless a specific service engagement genuinely requires it and the Company has requested it in writing.

4. How We Obtain Information

Most personal information reaches the Company directly from the individual concerned, for example when a visitor completes the contact form, sends an email, calls the office, requests a proposal or provides documentation during an audit or onboarding process. Information is also created by the Company in the ordinary course of running a service engagement, such as notes of meetings, records of correspondence and audit findings.

In some situations information is obtained from a partner or supplier organisation rather than from the individual directly. For example, a partner may provide the names and work contact details of its staff who will manage a sourcing programme, and a supplier may provide the contact details of the people who will host an audit. When the Company receives information this way, it relies on the providing organisation to have a lawful basis for sharing it.

The Company may also obtain information from publicly available sources, business directories, trade registers and professional networks when researching a supplier, verifying a company registration or assessing a market. This kind of research is limited to information that is relevant to the professional relationship being considered.

5. Why We Use Information

The Company uses personal information to respond to enquiries, prepare proposals, provide the services described on this website, manage supplier relationships, coordinate audits and logistics, administer agreements and invoices, and maintain accurate business records. Information is also used to communicate about service changes, to answer support questions and to improve the quality of the work delivered.

Personal information may be used to protect the rights, property and safety of the Company, its partners, its suppliers and the public, to detect and prevent fraud, and to comply with legal, tax, customs and regulatory obligations. Where a trade compliance engagement requires it, information may be used to prepare and retain documents demanded by customs authorities or other competent bodies.

The Company may use information to assess and improve its website and internal systems, to understand which pages and services attract the most interest, and to plan future service development. Where this analysis can be performed with aggregated or anonymised data, the Company takes that approach so that individual identities are not exposed.

The Company will not use personal information for a new purpose that is incompatible with the purpose for which it was collected, unless it first provides notice and, where required, obtains consent.

6. Legal Bases For Processing

Where applicable law requires a legal basis for processing, the Company relies on one or more of the following. Processing may be necessary to perform a contract with the individual or with the organisation the individual represents, or to take steps at that party request before entering a contract. Processing may also be necessary for the legitimate interests of the Company in running a professional trading house, provided those interests are not outweighed by the rights and freedoms of the individual.

Processing may be necessary to comply with a legal obligation, such as tax, accounting, customs, sanctions and record keeping requirements. In limited circumstances the Company may rely on consent, for example where a visitor chooses to receive a newsletter or where special information is voluntarily provided for a specific purpose. Where consent is the basis, it may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

Where the Company relies on legitimate interests, it considers the nature of the information, the expectations of the individual, the sensitivity of the data and the safeguards available. The Company keeps records of its assessment so that the balance can be reviewed if circumstances change.

7. Cookies And Similar Technologies

This website is designed to be lightweight and respectful of visitor privacy. It may use a small number of essential cookies or similar storage mechanisms needed for basic site operation, such as remembering a preference or maintaining the security of a session. Essential cookies of this kind do not track visitors across unrelated websites and are not used to build advertising profiles.

If the Company introduces analytics or other non essential cookies in the future, it will provide clear notice and, where required by law, obtain consent before those cookies are placed. Visitors can control cookies through their browser settings, including blocking cookies, deleting existing cookies and receiving a warning before a cookie is stored. Blocking essential cookies may affect how parts of the site function.

The website does not use cookies to collect special categories of personal data, and it does not sell cookie information to data brokers. Any third party service used to support the site is expected to meet the standards described in this policy.

8. When We Share Information

The Company does not sell personal information. Information is shared only in the limited circumstances described in this policy. Information may be shared with service providers and vendors who help the Company operate, such as email hosting providers, information technology support, accounting and legal advisors, freight forwarders, customs brokers, auditors and translation services, but only to the extent needed to perform their function.

Information may be shared with a partner or supplier organisation where that sharing is necessary to deliver a service, complete an audit, coordinate a shipment or resolve an issue. For example, an audit finding may be shared with the supplier concerned, and logistics details may be shared with a freight forwarder and a customs broker so that goods can move.

Information may be disclosed to professional advisers, to a prospective buyer or successor in the event of a corporate transaction, and to courts, regulators, customs authorities or law enforcement where the Company is required by law or where disclosure is necessary to protect legal rights. Where disclosure is compelled, the Company seeks to limit the disclosure to what is legally required.

Aggregated or anonymised information that cannot reasonably be used to identify an individual may be shared for research, reporting or service improvement purposes.

9. Service Providers And Vendors

The Company engages vendors who process personal information on its behalf. These vendors are selected with care and are expected to provide a level of protection consistent with this policy. Vendors are required to process information only for the agreed purposes, to apply appropriate security measures, to restrict access to authorised personnel and to assist the Company in meeting its own obligations.

Typical vendor categories include cloud and email providers, website hosting providers, document storage providers, accounting platforms, payment processors and logistics partners. Some of these vendors are located in the United States and others may be located abroad. The Company takes steps to ensure that transfers to vendors are supported by appropriate safeguards.

The Company reviews vendor arrangements periodically and will end a relationship where a vendor cannot demonstrate adequate protection for the information it handles. Vendors that no longer have a legitimate purpose for holding information are instructed to delete or return it.

10. International Transfers

Because the Company runs international sourcing, auditing and import programmes, personal information may be transferred to and processed in countries other than the country where it was collected. Those countries may have privacy laws that differ from the laws of the individual home jurisdiction, and in some cases may offer a lower level of protection.

When the Company transfers personal information internationally, it takes reasonable steps to ensure that the information remains protected. These steps may include relying on recognised transfer mechanisms, entering into appropriate contractual clauses with recipients, limiting the information transferred to what is necessary, and applying additional technical and organisational safeguards.

By using this website or engaging the Company for services that require cross border coordination, you understand that information may be transferred as described in this section. If you have questions about a specific transfer, please contact the Company using the details in the final section of this policy.

11. How Long We Keep Information

The Company keeps personal information only for as long as a legitimate business, legal or operational purpose requires. Retention periods are set by considering the nature of the information, the purpose for which it was collected, the risk of harm if it were misused, and the legal, tax, customs and accounting rules that apply to the Company.

Enquiry records and general correspondence are typically kept for a period sufficient to handle the matter and to maintain a reasonable record of the relationship. Contractual, audit, logistics and compliance records are kept for longer, because customs and tax rules often require records to be retained for several years after the relevant transaction or audit.

When a retention period ends, the Company deletes or anonymises the information using methods appropriate to the medium. Where information cannot be deleted immediately, for example because it is contained in a secure backup, the Company isolates it and limits further processing until deletion is possible.

12. How We Protect Information

The Company applies technical and organisational measures designed to protect personal information against accidental loss, unauthorised access, misuse, alteration and disclosure. Measures include access controls that limit information to staff and vendors who need it, secure transmission where information is sent over networks, careful handling of credentials, and periodic review of the systems that hold information.

Staff and contractors who handle personal information receive guidance on their responsibilities. The Company maintains procedures for responding to a suspected data incident, including steps to contain the issue, assess the risk, notify affected parties and regulators where required, and record the response for future improvement.

No method of transmission or storage is completely secure, and no organisation can guarantee absolute protection. The Company works to reduce risk to a reasonable level and asks that individuals also take sensible precautions, such as using a secure network and avoiding the sharing of sensitive information through unencrypted channels.

13. Your Privacy Rights

Depending on where you live, you may have rights regarding your personal information. These may include the right to be informed about how information is used, the right to request access to the information the Company holds about you, the right to request correction of inaccurate information, and the right to request deletion of information that is no longer needed.

You may also have the right to request restriction of processing, the right to object to processing based on legitimate interests, the right to request a portable copy of information you provided, and the right to withdraw consent where consent was the basis for processing. Some jurisdictions also provide rights relating to automated decision making and profiling, although the Company does not use this website to make automated decisions that produce legal or similarly significant effects.

To exercise a right, contact the Company using the details in the final section. The Company may ask for information needed to verify identity before acting on a request, so that information is not disclosed to the wrong person. The Company will respond within the period required by applicable law and will explain any lawful reason why a request cannot be fully met.

14. Your Choices And Controls

Individuals control much of the information they provide. You may choose not to submit information through the contact form, and you may contact the Company by telephone or email instead. You may request that the Company correct or update the details it holds, and you may ask that non essential communications stop at any time.

Browser settings provide additional control over cookies and similar technologies, including the ability to block third party cookies and to clear stored data. Email clients similarly allow a reader to disable remote content, which prevents certain tracking techniques from working.

If a request involves information the Company holds on behalf of a partner, the Company may refer the request to that partner, because the partner is responsible for the information in question. The Company will explain the referral so that the individual knows where the request has been directed.

15. Privacy For Children

This website and the services described on it are intended for businesses and professional parties. They are not directed at children, and the Company does not knowingly collect personal information from children. If the Company becomes aware that it has collected information from a child without appropriate authorisation, it will take reasonable steps to delete that information promptly.

Parents and guardians who believe that a child has provided personal information to the Company should contact the privacy contact using the details in the final section so that the matter can be reviewed and resolved.

16. Marketing Communications

The Company may send professional communications such as service updates, programme announcements and information about supplier review cycles to business contacts where there is a legitimate interest or where consent has been provided. Each such communication explains how to opt out, and opt out requests are honoured promptly.

Transactional and service related messages, such as confirmations, audit scheduling notes and logistics updates, are not marketing and may continue as long as an engagement requires them. The Company keeps a record of marketing preferences so that choices are respected.

The Company does not sell contact lists and does not permit its communications to be used by unrelated third parties for their own marketing.

17. Third Party Websites

This website may contain links to websites operated by other organisations, including suppliers, trade bodies and professional resources. The Company does not control those websites and is not responsible for their content or for the way they handle personal information. A link does not imply endorsement of the linked site.

Visitors who follow a link are encouraged to read the privacy notice of the destination website before providing any personal information. The practices described in this policy apply only to information processed by the Company through its own site and services.

18. Changes To This Policy

The Company may update this Privacy Policy from time to time to reflect changes in its services, its systems or the law. When an update is made, the revised policy will be posted on this page with a new effective date. Where a change is material, the Company will take reasonable steps to bring it to the attention of affected parties.

Continuing to use the website or the services after an updated policy takes effect indicates acceptance of the revised terms. Visitors are encouraged to review this page periodically so that they remain informed about how personal information is handled.

19. How To Contact Us

For any question about this Privacy Policy, for a request to exercise a privacy right, or for a concern about how personal information is handled, please contact Bougainvillea Trading LLC using the details below. The Company welcomes the opportunity to resolve any issue directly and promptly.

Bougainvillea Trading LLC
513 E 800 N, American Fork - 84003-1405, United States (US)
Email: partners@bougainvilleatrade.surf
Telephone: +17192983602