(March 2019)

Blkcommodities.com ("Site", “us”, “our”) is an e-commerce platform mainly used by business entities to facilitate trade for business purposes only. At Blkcommodities.com we keep the privacy of individuals in the highest regards and we protect it via a number of different means. Any information you provide us is treated as confidential and maintained and used in accordance with the EU GDPR 2018 regulation.

Any and all data collected through the Site at all times is encrypted and transmitted to us via secure double-encryption VPN.

This Privacy Policy applies to all products and services provided by us and details how we may collect, use and disclose information in relation to users of the Sites.

All and any policy not defined in this document shall have the meanings ascribed to them in the Terms of Use.

1. 1 .Collection of Information

   1. 1.1Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our services and to protect your account.

   2. 1.2In connection with any transaction and payment services provided on the Site, we may collect information including but not limited to, bank account details, billing and delivery information, credit/debit card numbers, expiration dates and tracking information from cheques or money orders ("Account Information"). This data is necessary to allow the sale and purchase of the products and/or services transacted on or procured through the Site and enable us to fulfil our contractual obligations to you.

   3. 1.3We may record and retain details of users’ activities on the Site. Information relating to such transactions including, but not limited to, the types and specifications of the goods, pricing and delivery information, any trade dispute records and any information disclosed in any discussion forum provided by us and/or other affiliated companies (“Activities Information”) may be collected transactions are executed on through the Site.

   4. 1.4From time to time, we may collect information about our users and prospective users during industry events, seminars, workshops and other events. The information we may collect at these locations may include, but is not limited to, name, address, phone number, fax number and email address ("Event Information").

   5. 1.5In order to provide you with a better service and optimise the Site’s functions so as to show always content that is relevant to you, we may record and retain records of users' buying and browsing activities on the Site, including but not limited to IP addresses, browsing patterns and buyer behavioural patterns. We may also gather statistical information about the Site and visitors to the Sites including, but not limited to, IP addresses, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors (together "Browsing Information").

   6. 1.6Registration Information, Account Information, Activities Information, Event Information and Browsing Information generally relate to business entities and are together referred to as business data (“Business Data”). Given that the Business Data may contain personally identifiable information of living individuals, such information is together referred to as personal data (“Personal Data”).

   7. 1.7In order to use certain services within the Site users may need to provide Business Data and Personal Data (for example during the registration phase).

2. 2 .How we use your Personal Data

   1. 2.1If you provide any Personal Data to us, you are deemed to have authorised us to collect, retain and use that Personal Data for the following purposes:

      1. a) verifying your identity;

      2. b)verifying your eligibility to register as a user of the Sites;

      3. c) processing your registration as a user, providing you with a log-in ID for the Site and maintaining and managing your registration;

      4. d)performing the contract we are to enter into or have entered into with you;

      5. e)complying with a legal obligation;

      6. f)providing you with customer service and responding to your queries, feedback, claims or disputes;

      7. g)to facilitate communication between buyers and sellers on the Sites and processing your transactions on the Site;

      8. h) performing research or statistical analysis in order to improve the content and layout of the Sites, to improve our product offerings and services and for marketing and promotional purposes;

   2. 2.2We may not, without having first obtained your consent; use your name, phone number, residential address, email address, fax number and other data ("Marketing Data") to provide notices, surveys, alerts, communications and/or marketing material to you relating to goods and services offered by us on the Site including but not limited to products and services offered by us and/or our affiliated companies and their designated Service Providers from time to time to members of the Site. If you grant us your consent to use Marketing Data specified above, you agree and understand that we may, from time to time, use affiliated companies or other third-party providers and their designated Service Providers (as defined in section 3).

   3. 2.3If you voluntarily submit any information to the Site for publication on the Site through the publishing tools, including but not limited to, Company or Business Profile, Catalogues, Payment Performance, etc., then you are deemed to have given consent to the publication of such information on the Site ("Voluntary Information"); and

   4. 2.4Making such disclosures as may be required for any of the above purposes or as required by law, regulations and guidelines or in respect of any investigations, claims or potential claims brought on or against us.

   5. 2.5The lawful basis upon which we may rely on to process your personal data are:

      Consent	you have given your express consent for us to process your personal data for a specific purpose
      Contract	the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you
      legal obligation	the processing is necessary for us to comply with legal or regulatory obligation
      legitimate interests	the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our Site. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest

   6. 2.6Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this:

      Purpose/Activity	Lawful basis for processing
      to register you as a new customer	to perform our contract with you
      to process and deliver your order, manage payments, fees and charges and debt recovery	(i) to perform our contract with you; (ii) as necessary for our legitimate interest in recovering debts due to us.
      to manage our relationship with you, notifying you about changes to our Terms or Privacy Policy and ask you to leave a review or take a survey	(i) to perform our contract with you (ii) as necessary to comply with a legal obligation (iii) as necessary for our legitimate interests in keeping our records updated and analysing how customers use our products/services.
      to administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(i) as necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (ii) as necessary to comply with any legal obligations
      to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising	as necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
      to use data analytics to improve our website, products/services, marketing, customer relationships and experiences	as necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
      to make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers	as necessary for our legitimate interests to develop our products/services and grow our business

3. 3 .Disclosure

   1. 3.1You agree that we may disclose and transfer (whether within or outside the jurisdiction of the Bukcommodities.com entity that you are contracting with) your Personal Data to service providers engaged by us and/or other affiliated companies to assist us with providing you with our services (including but not limited to data entry, database management, promotions, products and services alerts, delivery services, payment services, membership authentication and verification services and logistics services) ("Service Providers"). These Service Providers are under a duty of confidentiality to us and are only permitted to use your Personal Data in connection with the purposes specified in section 2.

   2. 3.2We may disclose and transfer (whether within or outside the jurisdiction of the Bukcommodities.com entity that you are contracting with) your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organisations for the purposes specified in section 2.

   3. 3.3Any Personal Data supplied by you will be retained by us and will be accessible by our employees, any Service Providers engaged by us and third parties referred to in section 3, for or in relation to any of the purposes stated in section 2.

   4. 3.4All Voluntary Information may be made publicly available on the Site. Any Voluntary Information that you disclose to us becomes public information and you grant us a perpetual, worldwide, non-exclusive, no-charge, royalty-free, irrevocable copyright license to reproduce, prepare Derivative Works of, publicly display, publicly perform, sublicense, and distribute the Voluntary Information and any such Derivative Works. Please exercise caution when deciding to include personal or proprietary information in the Voluntary Information that you submit to us.

   5. 3.5We may share your Account Information with banks or third-party transaction service providers to enable your transactions on the Site to be executed. In addition, we may use your Account Information to determine your credit-worthiness and, in the process of such determination, we may need to make such Account Information available to banks or credit agencies. While we have in place up-to-date technology and internal procedures to keep your Account Information and other Personal Data secure from intruders, there is no guarantee that such technology or procedures can eliminate all of the risks of theft, loss or misuse. We undertake to communicate to you, as soon as reasonably practicable, of any breach that may result in risk of theft and/or loss of your Personal Data.

   6. 3.6We may provide statistical information to third parties, but when we do so, we do not provide personally-identifying information without your permission.

   7. 3.7This Privacy Policy does not apply to third-party sites that you may reach by clicking on hyperlinks on the Site. You should carefully read and accept third-party websites privacy policies and relevant terms and conditions prior to start using third-party sites. The privacy policies of third-party sites may differ from ours and we have no control over the information that you submit to those third parties.

4. 4 .Data Security

   1. 4.1We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.

   2. 4.2We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

5. 5 .Data retention

   1. 5.1We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

   2. 5.2Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.

   3. 5.3We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.

6. 6 .Access and correct Personal Data and your legal rights

   1. 6.1Under the applicable laws, you have the right of access to personal information held by us and to request correction of the information.

   2. 6.2If you have any questions regarding this Privacy Policy or if you wish to access or correct your Personal Data, you may send your request in writing to the following address:

      Subject: Personal Data
      Att. Data Management Team
      Email: info@blk-global.com
      
      BLK Global Ltd.
      42 Laighpark View
      Paisley
      PA3 2PE
      Renfrewshire
      United Kingdom

   3. 6.3You have certain rights in certain circumstances under data protection law. These are set out in section 6.7. If you wish to exercise any of your rights, please contact us using the details provided in section 6.2.

   4. 6.4You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.

   5. 6.5We may request specific information from you to help us confirm your identity when you contact us and ensure. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.

   6. 6.6We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

   7. 6.7You have the following legal rights in relation to your personal data:

      access your data	you can ask for access to and a copy of your personal data and can check we are lawfully processing it
      correction	you can ask us to correct any incomplete or inaccurate personal data we hold about you
      erasure	you can ask us to delete or remove your personal data where: (a) there is no good reason for us continuing to process it; (b) you have successfully exercised your right to object (see below); (c) we may have processed your information unlawfully; or (d) we are required to erase your personal data to comply with local law. (e) We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request
      object	you can object to the processing of your personal data where: (a) where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms; (b) where we are processing your personal data for direct marketing purposes. (c) in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and, in such circumstances, we can continue to process your persona data for such purposes
      restrict processing	you can ask us to us to suspend or restrict the processing of your personal data, if: (a) you want us to establish the accuracy of your personal data; (b) our use of your personal data is unlawful, but you do not want us to erase it; (c) you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it
      request a transfer	you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format
      withdraw your consent	you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent

7. 7 .Cookie Policy

   1. 7.1We make use of "cookies" to store information about you, your activities and track your visits to the Site. It is not uncommon for web-sites to use cookies to enhance identification of their users.

   2. 7.2A "cookie" is a small amount of data that is sent to your browser and stored on your computer. If you do not de-activate or erase the cookies, each time you use the same computer to access the Site, our web servers will be notified of your visit so that we may have knowledge of your visit and the pattern of your usage.

   3. 7.3Generally, we use cookies to identify you and enable us to:

      1. a)Promptly access your Registration Information or Account Information so you do not have to re-enter it;

      2. b)gather statistical information about usage by users;

      3. c)study navigation patterns and help target advertisements based on user interests, so that you will be shown what is most relevant to you;

      4. d)help our partners to track user visits to the Site and process orders; and

      5. e)track progress and participation in promotions.

   4. 7.4You can determine if and how a cookie will be accepted by configuring the browser you are using to access the Site. You can change the browser configuration by setting your preferences in the browser; you can accept all cookies, you can choose to be notified when a cookie is sent or you can choose to reject all cookies. If you choose to reject all cookies, you may be required to re-enter information on the Sites more often and certain features of the Sites may be unavailable.

   5. 7.5By giving your consent to the setting of our Cookies you are enabling us to provide the best possible experience and service to you through our Site. If you wish to deny your consent to the placing of Cookies, certain features of the Site may not function fully or as intended.

   6. 7.6Certain features of the Site depend upon Cookies to function and are deemed, within the law, to be strictly necessary. You may disable cookies via your web browser’s settings.

   7. 7.7You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies, however this can be altered. For further details please consult the help menu in your browser. Disabling Cookies may prevent you from using the full range of Services available on the Web Site.

   8. 7.8You may delete Cookies at any time however you may lose any information that enables you to access the Site more quickly.

   9. 7.9The Site may use third-party Cookies that are not integral to the services provided by the Site to you and may be blocked at your choosing via your internet browser’s privacy settings or via your response to the request.

   10. 7.10It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure as to how to adjust your privacy settings.

8. 8 .Minimum Age to use the Site

   1. 8.1The Site and its functionalities are not intended for use of any person under the age of 18 (or the minimum legal age in your jurisdiction). We do not intend to sell any of products or services to any people not of legal age. However, we have no way of distinguishing the age of individuals who access our Site.

9. 9 .Security

   1. 9.1We employ commercially-available security methods to prevent unauthorised access to the Site, maintain data accuracy and to ensure the security of the information processed through the Site.

   2. 9.2Your Registration Information and Account Information can be viewed and edited through your account, which is protected by a password. You are responsible of taking all reasonable steps to protect the access to your account and not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you use a shared computer terminal, you should choose not to save your log-in information (e.g., user ID and password) in order to prevent unauthorised access to your account. You should always sign out of your account and close your browser window when you have finished your session.

   3. 9.3No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect the information we hold for you, we cannot guarantee the security of any information you transmit to us and you do so at your sole risk and liability. You agree not to hold us liable for any loss or damage, including but not limited to loss of profit, arising out of or in connection with any information transmitted through the Site.

10. 10 .Changes and Amendments

    1. 10.1Any changes to this Privacy Policy will be communicated by us posting an amended version of the Privacy Policy on the Site. Once posted on the Sites the new Privacy Policy will be effective immediately.

    2. 10.2Any information we hold about you (as described in this Privacy Policy and whether or not collected prior to or after the new Privacy Policy became effective) will be governed by the latest version of the Privacy Policy.

11. 11 .Feedback

    1. 11.1In line with our commitment to continual improvement, we welcome your input regarding our Privacy Policy and any comments on the services we provide to you. You may send us your comments and responses by post to the address stated in section 6.2 or by email at the address info@blk-global.com