Privacy Policy

1. Introduction

Pure Grain Exports ("we", "us", "our") is a registered business entity based in Sialkot, Punjab, Pakistan. This Privacy Policy applies to our website (www.puregrainexports.com) and governs the collection, use, and protection of information in the context of our B2B commercial engagements. Our primary audience includes corporate clients, trade buyers, freight forwarders, and sourcing agents worldwide.

2. Information We Collect

2.1 Business Contact Information

We collect business contact details such as contact name and title, company name, registration details, email address, phone number, business address, and tax identification numbers as required for B2B transactions.

2.2 Commercial & Transactional Data

We process commercial data including purchase orders, quotations, letters of credit (LC) details, payment references, and shipping instructions to facilitate trade operations.

2.3 Website Usage Data

We collect technical data such as IP address, browser type, device information, pages visited, cookies, and session data to improve website functionality and security.

2.4 Communications Data

We retain records of email correspondence, inquiry forms, meeting notes, and feedback to ensure effective business communication and service quality.

3. How We Use Your Information

• Order fulfilment, export documentation, and shipment tracking
• Credit checks, trade reference verification, and commercial risk assessment
• LC and trade finance management
• Export control and anti-money laundering (AML) compliance
• Quotations, pricing negotiations, and business communications
• Website analytics and improvement
• Marketing communications (with opt-out option)
• Accounting, audit, and legal compliance

4. Legal Basis for Processing (GDPR)

We process personal and business data under contractual necessity, legitimate business interests, legal obligations, and explicit consent — in line with Articles 6(1)(a)–(f) of the GDPR for EU/EEA data subjects.

The detailed legal bases are as follows:

• Contractual necessity for fulfilling trade agreements
• Legitimate interests, including fraud prevention, trade compliance, and business development
• Legal obligations under export regulations and tax laws
• Consent for marketing communications and non-essential cookies

5. Data Sharing and Disclosure

5.1 Supply Chain & Logistics Partners

We may share data with freight forwarders, shipping lines, and customs agents strictly for order fulfilment and logistics purposes.

5.2 Financial Institutions

Data may be shared with banks, LC-issuing banks, and payment processors to facilitate secure financial transactions.

5.3 Regulatory & Government Authorities

We may disclose information to regulatory bodies such as the Trade Development Authority of Pakistan (TDAP), State Bank of Pakistan, Federal Board of Revenue (FBR), and customs authorities as required by law.

5.4 Professional Advisors

Professional advisors, including legal counsel and auditors, may access data for compliance and audit purposes.

5.5 Technology Service Providers

We use technology service providers (CRM, email, analytics, hosting) as data processors under strict contractual obligations. We never sell, rent, or trade personal data.

6. International Data Transfers

Your data may be transferred to and processed in Pakistan and other countries where our logistics and banking partners operate. For transfers from the EEA, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission to ensure an adequate level of data protection.

7. Cookie Policy

We use strictly necessary cookies for website functionality, analytics cookies (such as Google Analytics, with user consent), and preference cookies. Users can manage cookie preferences via their browser settings or our cookie consent banner.

8. Data Retention

• Commercial transaction records: retained for 7 years in accordance with Pakistani tax and commercial law
• Correspondence: retained for 3 years from last interaction
• Website analytics: retained for 26 months on a rolling basis
• Marketing lists: retained until consent is withdrawn
• Data is securely deleted or anonymised upon expiry of retention periods

9. Data Security

• SSL/TLS encrypted transmission of data
• Role-based access controls for internal systems
• Secure email channels for sensitive trade documents
• Regular security reviews and staff training
• Commitment to timely breach notification

10. Your Rights

You have the right to access, rectify, erase, restrict, or port your data, object to processing, and withdraw consent at any time. We commit to responding to all requests within 30 days, subject to identity verification.

11. Third-Party Websites

Our website may contain links to third-party trade portals or partner platforms. We are not responsible for the privacy practices of these external sites. Users are encouraged to review the privacy policies of any third-party sites they visit.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via an updated "Last Reviewed" date and, where appropriate, by email. Continued use of our services constitutes acceptance of the revised policy.

13. Contact Us

For any questions or concerns regarding this Privacy Policy or your data rights, please contact:

• Pure Grain Exports, Sialkot, Punjab, Pakistan
• Email: trade@puregrainexports.com
• Website: www.puregrainexports.com
• EEA users: You have the right to lodge a complaint with your local data protection supervisory authority.