Privacy Policy

A. Identity of the Controller

This Privacy Policy applies to the website www.agrodelta.com (the “Website”).

The controller of personal data collected through the Website is AD Ventures Enterprise, S.L., a company incorporated under the laws of Spain, with registered office at Calle Notarias 22, Palamós, Girona (the “Company”, “we”, “us”, or “our”).

You may contact us regarding privacy matters at:
Email: legal@agrodelta.com

B. Scope of This Privacy Policy

This Privacy Policy explains how we collect, use, store, disclose, and otherwise process personal data when you visit and use the Website, contact us through the Website, or otherwise interact with us through the channels made available on the Website.

This Privacy Policy does not govern any separate processing carried out in the context of commodity trading transactions, supplier onboarding, customer due diligence, recruitment processes, or contractual negotiations, which may be subject to separate privacy notices, contractual documentation, or compliance disclosures.

C. Categories of Personal Data We May Collect

Depending on how you interact with the Website, we may collect and process the following categories of personal data:

1. Identification and contact data: such as your name, company name, job title, email address, telephone number, and any other information you choose to provide when contacting us.
2. Correspondence data: the content of your messages, requests, queries, and any attachments or documents you send to us.
3. Technical and usage data: such as IP address, browser type, device information, operating system, language settings, referral URL, pages visited, date and time of access, and approximate geolocation derived from IP address.
4. Cookie and tracking data: data collected through cookies or similar technologies, subject to your consent preferences where required.
5. Compliance-related data voluntarily submitted by you: where you provide information relevant to sanctions, AML, KYC, conflict checks, or business suitability through a web inquiry or initial contact.

D. How We Collect Personal Data

We collect personal data:

1. directly from you, when you contact us by email, through a contact form, or through any other communication channel made available on the Website;
2. automatically, through your use of the Website, including through server logs, cookies, and analytics tools; and
3. in limited cases, from third parties such as analytics, spam-prevention, hosting, or website security providers, where their tools are integrated into the Website.

E. Purposes and Legal Bases for Processing

We process personal data for the following purposes and on the following legal bases:

1. To respond to inquiries and communications.
2. To operate, maintain, protect, and improve the Website.
3. To manage analytics and understand Website usage.
4. To prevent fraud, spam, misuse, or cybersecurity incidents.
5. To establish, exercise, or defend legal claims and to ensure compliance with applicable laws, regulations, and internal policies.
6. To manage cookies and consent records.

F. Cookies and Similar Technologies

The Website uses cookies and similar technologies. Essential cookies may be used where necessary for the functioning and security of the Website. Analytics, advertising, embedded media, mapping, or other non-essential cookies will only be used where valid consent has been obtained, where required by law.

Further information about the cookies used on the Website, their providers, purposes, storage periods, and how to withdraw consent should be set out in the Cookie Policy and reflected accurately in the cookie banner and consent management platform.

G. Recipients of Personal Data

We may share personal data, on a need-to-know basis, with:

1. hosting providers, IT providers, website developers, and website maintenance providers;
2. analytics, spam-filtering, security, and consent-management service providers;
3. professional advisers, including lawyers, auditors, insurers, and compliance advisers;
4. competent authorities, regulators, courts, law enforcement bodies, or other third parties where disclosure is required by law or necessary to protect our rights; and
5. other group companies or affiliates, where relevant for internal administration, business management, or compliance purposes and where lawful to do so.

We do not sell your personal data.

H. International Transfers

Where personal data is transferred outside the European Economic Area or the United Kingdom, as applicable, we will ensure that appropriate safeguards are implemented in accordance with applicable data protection law. Such safeguards may include an adequacy decision, the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or another lawful transfer mechanism.

I. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including for the purpose of satisfying legal, regulatory, tax, accounting, reporting, and evidentiary requirements.

As a general principle:

1. contact and inquiry data will be retained for as long as reasonably necessary to handle and follow up on the request;
2. technical logs will be retained for the period appropriate for security, troubleshooting, and system administration purposes;
3. consent records will be retained for as long as necessary to demonstrate compliance; and
4. where data is relevant to legal claims, disputes, audits, sanctions screening, or compliance matters, it may be retained for a longer period as necessary.

J. Your Rights

Under Regulation (EU) 2016/679 (General Data Protection Regulation or GDPR) and applicable Spanish data protection law, you may exercise your rights in relation to your personal data at any time. In particular, you may request access to your personal data, rectification of inaccurate or incomplete data, erasure of your data, restriction of processing, objection to processing, and data portability where applicable by law. You also have the right not to be subject to a decision based solely on automated processing, including profiling, where this applies.

Where we process your personal data on the basis of your consent, you may withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before your consent was withdrawn.

To exercise any of these rights, you may contact us using the contact details provided in this Privacy Policy. Please indicate clearly which right you wish to exercise and provide sufficient information to allow us to verify your identity and respond to your request. As a general rule, we will reply within one month, although this period may be extended where permitted by law.

If you believe that your personal data has been processed in breach of applicable data protection law, you also have the right to lodge a complaint with the Agencia Española de Protección de Datos (AEPD), the Spanish supervisory authority. Further information about your rights is available on the AEPD website.

K. Security

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. However, no internet-based transmission or storage system can be guaranteed to be completely secure.

L. Third-Party Links

The Website may contain links to third-party websites or services. We are not responsible for the privacy practices, content, or security of third-party websites. Users should review the privacy notices of such third parties before providing personal data to them.

M. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect legal, technical, or business developments. The updated version will be published on the Website together with its effective date. Material changes may also be highlighted through the Website where appropriate.

Contact

If you have any questions about this Privacy Policy or our processing of personal data, please contact:
legal@agrodelta.com