Privacy Policy
This Privacy Policy explains how SCV Commodities Pte Ltd (a company incorporated in Singapore) and SCV Enterprises LLC (a limited liability company registered in Delaware, USA) — together “SCV”, “we”, “us” or “our” — collect, use, disclose and protect personal data when you visit scvcommodities.com (the “Website”), contact us, or deal with us in connection with our physical commodity brokerage and trade finance introduction services.
We handle personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other data protection laws that apply to us. By using the Website or providing personal data to us, you acknowledge that your personal data will be handled as described in this Policy.
1. Who is responsible for your data
SCV Commodities Pte Ltd is the organisation primarily responsible for personal data collected through the Website. Where you deal with SCV Enterprises LLC, it is also responsible for the personal data it handles. Contact details for both entities are set out in section 13.
2. Personal data we collect
We collect only the personal data that is reasonably necessary for the purposes set out in this Policy. This may include:
- Contact and identity details — your name, job title, organisation, business email address, telephone number and business address.
- Enquiry details — the commodity sector you are interested in and any information you provide in your enquiry, such as volumes, specifications, delivery terms and trade requirements.
- Know-your-customer (KYC) and compliance information — where we progress a transaction or trade finance introduction, identification documents, company registration details, ownership and directorship information, and information needed for anti-money laundering, counter-terrorist financing and sanctions screening.
- Transaction information — details of cargoes, contracts, counterparties, invoices, shipping and payment terms relating to transactions we broker or introduce.
- Correspondence — records of emails, calls and messages you exchange with us.
- Technical data — your IP address, browser type, device information, pages visited and the date and time of your visit, collected automatically when you use the Website.
3. How we collect personal data
- Directly from you, for example when you submit the enquiry form, email or call us, or send us documents.
- From your organisation, or from counterparties, financiers, factoring providers or other intermediaries involved in a transaction.
- From publicly available sources such as company registries, sanctions lists and commercial databases, for compliance and due diligence purposes.
- Automatically through the Website, including through cookies and similar technologies (see section 9).
4. Purposes for which we use personal data
We collect, use and disclose personal data for the following purposes:
- Responding to your enquiry and routing it to the relevant sector broker.
- Identifying suitable counterparties and brokering physical commodity transactions.
- Facilitating introductions to trade finance, invoice financing and invoice factoring providers.
- Carrying out due diligence, KYC, anti-money laundering, counter-terrorist financing and sanctions checks.
- Coordinating trade documentation, shipping and delivery matters.
- Managing our business relationship with you, including invoicing and record keeping.
- Sending you market information or service updates, where you have agreed to receive them.
- Operating, securing and improving the Website.
- Complying with legal and regulatory obligations, and establishing, exercising or defending legal claims.
5. Consent
Where required by law, we obtain your consent before collecting, using or disclosing your personal data. You give consent when you submit the enquiry form and tick the consent box, or when you voluntarily provide personal data to us for a stated purpose. We may also rely on exceptions permitted under the PDPA, such as where processing is necessary to perform a contract with you, for our legitimate interests, or to comply with the law.
You may withdraw your consent at any time by writing to us at info@scvcommodities.com. We will process your request within a reasonable time and inform you of the likely consequences — for example, we may be unable to continue brokering a transaction or introduction for you. Withdrawal does not affect processing that took place before it, or processing we are permitted or required to carry out by law.
6. Disclosure of personal data
We treat counterparty and transaction information as strictly confidential. We disclose personal data only where it is necessary for the purposes above, and only to:
- Prospective counterparties to a transaction, to the extent needed to progress that transaction and with your agreement.
- Banks, trade financiers, invoice financing and factoring providers, insurers, inspection companies, shipping agents and logistics providers involved in a transaction.
- Our affiliated entity (SCV Commodities Pte Ltd or SCV Enterprises LLC, as applicable).
- Service providers who support our business, such as website hosting, email and IT providers, professional advisers and auditors, who are bound to keep the data confidential.
- Regulators, law enforcement agencies, courts and other authorities where required or permitted by law.
We do not sell personal data.
7. Transfers outside Singapore
Because we operate internationally, your personal data may be transferred to and stored in countries outside Singapore, including the United States and the jurisdictions of counterparties and service providers involved in a transaction. When we transfer personal data outside Singapore, we take appropriate steps to ensure that the recipient provides a standard of protection comparable to that under the PDPA, for example through contractual safeguards.
8. Retention
We keep personal data only for as long as it is needed for the purposes for which it was collected, or as required for legal, regulatory, tax, accounting or compliance reasons. Enquiries that do not lead to a business relationship are generally deleted within 24 months. KYC and transaction records may be kept for at least five years after the relationship or transaction ends, as required by applicable anti-money laundering rules. When personal data is no longer needed, we securely delete or anonymise it.
9. Cookies and website analytics
The Website uses cookies and similar technologies that are necessary for it to function securely and efficiently, including caching and security features provided by our hosting provider. The Website also loads fonts from Google Fonts, which means your IP address is shared with Google when a page loads. You can set your browser to refuse or delete cookies; some parts of the Website may not work correctly if you do. If we introduce analytics or marketing cookies in future, we will update this Policy and, where required, ask for your consent.
10. Protection of personal data
We use reasonable administrative, physical and technical security arrangements to protect personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. These include encrypted (HTTPS) connections to the Website, access controls and confidentiality obligations on our staff and service providers. No method of transmission over the internet is completely secure, however, and we cannot guarantee absolute security.
If a data breach occurs that is likely to cause you significant harm, we will notify you and the Personal Data Protection Commission of Singapore where required by the PDPA.
11. Your rights: access and correction
Subject to applicable law, you may ask us:
- for access to the personal data we hold about you, and information about how it has been used or disclosed in the past year;
- to correct an error or omission in your personal data;
- to withdraw your consent to our use of your personal data; and
- to stop sending you marketing communications.
To make a request, email info@scvcommodities.com with enough detail for us to identify you and your request. We may need to verify your identity before responding. We will respond as soon as reasonably possible, and in any case within 30 days; if we need longer, we will let you know. We may charge a reasonable fee for an access request, and will tell you the fee in advance.
12. Third-party websites
The Website may contain links to websites operated by third parties. We are not responsible for the privacy practices of those websites, and we encourage you to read their privacy policies.
13. Contact us and Data Protection Officer
If you have questions about this Policy, or wish to make a request or complaint about your personal data, please contact our Data Protection Officer:
- Email: info@scvcommodities.com
- Asia Pacific: SCV Commodities Pte Ltd, 77 High Street #09-15, High Street Plaza, Singapore 179433. Telephone +65 9383 5877.
- Registered office (USA): SCV Enterprises LLC, 16192 Coastal Highway, Lewes, Delaware 19958, United States. Telephone +1 573 495 4678.
If you are not satisfied with our response, you may contact the Personal Data Protection Commission of Singapore.
14. Changes to this Policy
We may update this Policy from time to time. The updated version will be posted on this page with a revised “Last updated” date. Your continued use of the Website after an update means you acknowledge the revised Policy.