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Privacy Policy

How Eutopio do Brasil trading LTDA handles your data, in plain language and in compliance with Brazil's LGPD, the EU GDPR, and applicable Chinese data regulations.

Contents

  1. Who This Policy Applies To
  2. Information We Collect
  3. How We Use Your Information
  4. Legal Bases for Processing (LGPD / GDPR)
  5. Data Sharing
  6. International Data Transfers
  7. Data Retention
  8. Your Rights
  9. Security
  10. Cookies and Tracking

Eutopio do Brasil trading LTDA and its affiliates (Eutopio) are committed to protecting the privacy of individuals who interact with our Services. This Privacy Policy explains how we collect, use, share, and protect information when you use our website, platform, and related services. Eutopio primarily operates as a B2B trade and infrastructure company. Most data we process relates to commercial counterparties, trade execution, and supply-chain operations, not consumer personal data.

Please read this policy carefully and often as it is subject to change.

1. Who This Policy Applies To

This policy applies to:

  • Business counterparties and their authorized representatives who engage with Eutopio as suppliers, buyers, logistics providers, laboratories, or service providers.
  • Visitors to the Eutopio website and related web properties.
  • Individuals whose personal data is incidentally processed as part of trade execution, shipping, or documentation activities.

This policy does not apply to the practices of companies that Eutopio does not own or control, or to individuals that Eutopio does not employ or manage.

2. Information We Collect

Account and Contact Information. When you register for our Services or contact us, we collect your name, job title, company name, work email address, phone number, and billing or payment information (processed by our PCI-compliant payment providers).

Trade and Operational Data. In the course of providing Services, we process Shipment Data on your behalf, which may include commodity origin, agronomic inputs, processing timelines, laboratory certifications, container ID, port and shipment milestones, and contractual off-take documentation. This data is processed solely to provide the Services. Eutopio does not own this data; see Section 4 of our Terms of Use.

Usage and Technical Data. When you access the Eutopio platform or our website, we automatically collect log data (IP address, browser type, pages visited, timestamps), device and connection information, and feature usage and interaction patterns, used for platform improvement and support.

Communications. We retain records of communications you send us, including inquiries, support requests, and email correspondence.

3. How We Use Your Information

We use the information we collect to provide, maintain, and improve the Services; process transactions and send related information; respond to inquiries and provide customer support; send operational communications such as service updates and security notices; comply with legal obligations; and detect and prevent fraud, abuse, and security incidents.

We do not use your Shipment Data or operational data to train general AI models, or for any purpose beyond delivering your contracted Services. We do not sell personal data or operational data to any third party.

4. Legal Bases for Processing (LGPD / GDPR)

For individuals in Brazil, the European Economic Area, the United Kingdom, the People's Republic of China, or other jurisdictions with similar requirements, we process personal data on the following legal bases:

  • Contract performance. To fulfill our contractual obligations to you.
  • Legitimate interests. To operate our business, improve our Services, and prevent fraud, provided such interests are not overridden by your rights.
  • Legal obligation. To comply with applicable laws and regulations, including LGPD, GDPR, and Chinese data protection requirements.
  • Consent. Where you have provided explicit consent, such as for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing

Service Providers. We share data with trusted third-party service providers who assist in delivering the Services, including cloud infrastructure providers, payment processors, banking partners (including Banco do Brasil and BOCOM BBM), and security tools. All such providers are bound by confidentiality and data processing agreements consistent with this policy.

Business Transfers. In the event of a merger, acquisition, reorganization, or sale of assets, your data may be transferred as part of that transaction. We will notify affected counterparties and provide choices where required by applicable law.

Legal Requirements. We may disclose data if required by law, regulation, legal process, or governmental request, or where necessary to protect the rights, property, or safety of Eutopio, its counterparties, or the public.

No Sale of Data. Eutopio does not sell personal data or operational data to third parties. This commitment is unconditional and applies regardless of changes to ownership or corporate structure.

6. International Data Transfers

Eutopio operates with offices in Jundiaí (São Paulo state, Brazil) and Shanghai (People's Republic of China). Data may be processed in any of these locations. For transfers from Brazil, the EEA, the UK, or China to other jurisdictions, we rely on Standard Contractual Clauses (SCCs) or equivalent mechanisms as approved by relevant data protection authorities.

Counterparties requiring data to remain within a specific geographic region should contact us to discuss regional deployment options. We support data residency requirements for Brazilian, EU, US, and Chinese clients.

7. Data Retention

We retain personal data for as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, or as directed by counterparties in the applicable Order Form:

  • Account data, retained for the duration of the relationship plus 3 years.
  • Shipment Data, retained as agreed in the applicable Order Form; upon termination, a full export is provided within 30 days of request, followed by secure deletion within 90 days, with written confirmation.
  • Usage logs, retained for 12 months, then aggregated or permanently deleted.
  • Communications, retained for 3 years from the date of last interaction.

8. Your Rights

Depending on your location, you may have the following rights regarding your personal data. You may exercise these rights at any time by contacting us at privacy@eutopio.trade. We will respond within 30 days, or sooner as required by applicable law.

  • Access, request a copy of the personal data we hold about you.
  • Rectification, request correction of inaccurate or incomplete data.
  • Erasure, request deletion of your personal data, subject to legal retention obligations.
  • Restriction, request that we limit our processing in certain circumstances.
  • Data portability, receive your personal data in a structured, commonly used, machine-readable format.
  • Objection, object to processing based on legitimate interests.
  • Withdraw consent, where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

For complaints regarding our data practices, you may contact your local data protection authority. In Brazil, the Autoridade Nacional de Proteção de Dados (ANPD). In the EU, your national supervisory authority; in Italy the Garante, in France the CNIL, in the UK the ICO. In China, the Cyberspace Administration of China (CAC).

9. Security

Eutopio employs industry-standard technical and organizational measures to protect your data, including AES-256 encryption at rest, TLS 1.2+ for all data in transit, role-based access controls, multi-factor authentication, and continuous security monitoring. For a full description of our security architecture, controls, and incident response procedures, see our Security Policy.

No method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

10. Cookies and Tracking

Our website uses cookies and similar tracking technologies for essential functionality, analytics, and marketing purposes. You can manage your cookie preferences through your browser settings or our cookie consent tool, which is presented on your first visit to the website.

We do not use cross-site tracking technologies on the Eutopio platform itself. Session data within the platform is used solely for operational purposes and audit logging.

© 2026 Eutopio do Brasil trading LTDA. All rights reserved. Eutopio and Axiom are trademarks of Eutopio do Brasil trading LTDA.

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