Privacy Policy

1. Introduction

Trade Steel ("we", "us", or "our") operates the Trade Steel marketplace platform (the "Platform"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform, in compliance with applicable international data protection laws including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA/CPRA), Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Brazil's Lei Geral de Proteção de Dados (LGPD), and India's Digital Personal Data Protection Act (DPDP).

2. Information We Collect

We collect information you provide directly, information collected automatically, and information from third parties:

• Account Information: Name, email, phone number, company name, business registration number, tax ID, and role (buyer, seller, manufacturer, trader, etc.).
• Profile & Listing Data: Product listings, certifications, inventory data, pricing, company descriptions, and images.
• Transaction Data: Orders, quotations, invoices, payment records, shipping details, and communication history.
• Device & Usage Data: IP address, browser type, device identifiers, pages visited, and interaction logs.
• Verification Data: Government-issued IDs, business licenses, bank statements, and KYC documents for identity and business verification.
• Communications: Emails, chat messages, support tickets, and feedback submitted through the Platform.

3. Legal Basis for Processing (GDPR)

Under GDPR, we process personal data based on the following legal grounds:

• Contractual necessity: To provide Platform services and fulfill transactions between buyers and sellers.
• Legitimate interests: Fraud prevention, network security, service improvement, and marketing where permitted.
• Legal obligation: Tax reporting, regulatory compliance, and law enforcement requests.
• Consent: For marketing communications, cookies (where required), and optional data processing.

4. How We Use Your Information

• To operate, maintain, and improve the Platform and its features.
• To verify identities and businesses, ensuring a trusted marketplace environment.
• To process transactions, payments, and escrow services.
• To facilitate communication between buyers and sellers.
• To provide customer support and respond to inquiries.
• To detect, prevent, and address fraud, security breaches, and prohibited activities.
• To comply with legal obligations and enforce our Terms & Conditions.
• To send service-related notices, updates, and promotional communications (with opt-out options).
• To personalize user experience and analyze Platform usage trends.

5. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to enhance user experience, analyze traffic, and personalize content. Categories include:

• Essential cookies: Required for Platform functionality (e.g., login sessions, security).
• Analytics cookies: Help us understand how users interact with the Platform.
• Preference cookies: Remember language settings, region, and display preferences.
• Marketing cookies: Used to deliver relevant advertisements and measure campaign effectiveness.

You can manage cookie preferences through your browser settings or our cookie consent banner. For EU users, non-essential cookies require explicit consent under GDPR.

6. Data Sharing and Disclosure

We do not sell personal data. We may share information with:

• Other Users: Buyers and sellers share business contact details, listings, and transaction information as necessary to complete trades.
• Service Providers: Payment processors, cloud hosting providers, analytics services, email delivery, and verification agencies under strict confidentiality agreements.
• Legal Authorities: When required by law, court order, or to protect our rights, safety, and property.
• Business Transfers: In connection with mergers, acquisitions, or asset sales, with notice to affected users.
• Affiliates: Within our corporate group for operational and service continuity purposes.

7. International Data Transfers

Trade Steel operates globally. Your data may be transferred to and processed in countries outside your jurisdiction, including countries that may not have equivalent data protection laws. We ensure such transfers comply with applicable laws through:

• Standard Contractual Clauses (SCCs) approved by the European Commission for EU data transfers.
• Adequacy decisions where recognized by relevant authorities.
• Appropriate technical and organizational safeguards.

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy or as required by law:

• Account data: retained while your account is active and for 2 years after closure for legal compliance.
• Transaction records: retained for 7 years to meet tax and accounting obligations.
• Verification documents: retained for the duration of account activity plus 3 years for fraud prevention.
• Marketing data: retained until you withdraw consent or unsubscribe.

9. Data Security

We implement industry-standard security measures including SSL/TLS encryption, access controls, regular security audits, and employee training. However, no internet-based system is completely secure. Users are responsible for maintaining the confidentiality of their account credentials.

10. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data ("right to be forgotten"), subject to legal retention obligations.
• Restriction: Request limited processing of your data in certain circumstances.
• Portability: Receive your data in a structured, commonly used format.
• Objection: Object to processing based on legitimate interests or direct marketing.
• Withdraw Consent: Withdraw previously given consent at any time.
• Non-Discrimination: Exercise your rights without discriminatory treatment (CCPA).

To exercise these rights, contact us at privacy@tradesteel.com. We respond within 30 days as required by applicable law.

11. Children's Privacy

The Platform is intended for business use and not directed at individuals under 18 years of age. We do not knowingly collect data from minors. If we learn we have collected data from a minor, we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be notified via email or Platform notice at least 30 days before taking effect. Continued use after changes constitutes acceptance.

13. Contact Us

For privacy-related inquiries, data subject requests, or complaints:

• Email: privacy@tradesteel.com
• Address: Trade Steel Global Headquarters, [Business Address Placeholder]
• Data Protection Officer (DPO): dpo@tradesteel.com

EU residents may also lodge complaints with their local supervisory authority.