HUTKA SA (“we,” “our,” or “us”) is committed to protecting your privacy and ensuring that your personal and corporate data is handled in a secure and responsible manner. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you visit our website (hutka-sa.com), interact with our digital platforms, or engage with us in our capacity as a global physical commodity trading and logistics firm.

By accessing our website or utilizing our services, you consent to the data practices described in this policy.

1. Information We Collect

Given the B2B nature of our operations, the majority of the information we collect pertains to corporate entities; however, we may collect personal data from individuals acting on behalf of those entities. We collect the following types of information:

• Identity & Contact Data: Names, job titles, employer/company name, corporate email addresses, physical business addresses, and telephone numbers.
• Compliance & Due Diligence Data: Information required for Know Your Customer (KYC), Anti-Money Laundering (AML), and Anti-Bribery and Corruption (ABAC) protocols, which may include identification documents and background check information of corporate officers.
• Technical Data: IP addresses, browser types, operating systems, referring URLs, and interaction metrics gathered through cookies and analytical tracking when you use our website.
• Commercial Data: Records of logistics contracts, physical commodity transactions, inquiries, and communications between you and our trading desks.

2. How We Use Your Information

HUTKA SA strictly limits the use of your data to legitimate business and legal purposes, including:

• Executing physical commodity trades, processing facility operations, and managing global logistics.
• Fulfilling legal and regulatory mandates, including international trade sanctions screening and supply chain integrity audits (e.g., OECD Due Diligence).
• Improving our website infrastructure, digital portals, and user experience.
• Communicating critical corporate, market, or operational updates.

3. Data Sharing & Third-Party Disclosures

We do not sell your personal or corporate data. We may share your information with trusted third parties strictly under the following circumstances:

• Operational Partners: Logistics providers, port authorities, maritime charterers, and third-party processing hubs necessary to execute your contracts.
• Compliance & Auditing: Independent auditing firms (e.g., BQCIS), legal counsel, and regulatory bodies to ensure adherence to international trade laws and ESG frameworks.
• Service Providers: IT infrastructure providers and secure data hosting services acting under strict confidentiality agreements.

4. International Data Transfers

HUTKA SA operates trans-hemispheric commodity networks. Your data may be transferred to, and processed in, countries outside of your jurisdiction (including our international offices in North America, Mesoamerica, and South America). When we transfer data internationally, we implement strict safeguards, including Standard Contractual Clauses (SCCs), to ensure your information receives a level of protection consistent with global privacy standards (such as GDPR or CCPA frameworks).

6. Your Privacy Rights

Depending on your jurisdiction, you may possess specific rights regarding your personal data, including:

• The right to access, update, or correct your personal information.
• The right to request the deletion of your data (subject to our legal and regulatory retention obligations).
• The right to restrict or object to certain types of processing.
• The right to data portability.

To exercise any of these rights, please contact our Data Protection Officer using the information provided below.