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Privacy Policy Information Notice


Update: 10.01.2021


This Notice explains how APL Commodities, as a data controller, uses your Personal Information in a commercial context if you are:

• A Provider or if you represent an organization acting as a Provider.
• A Client or if you represent an organization acting as Client.
• Web users.

We refer to this as “Business Information”.

APL Commodities, Holder Corporation, Established in the United Arab Emirates, with headquarters or parent company in Addis Ababa, Ethiopia, its, Associated Companies, Agencies, Subsidiaries and Affiliates in the world make their contact information available to you at where you can access a list of the companies that make up the Corporation.

• Supplier means a current or prospective supplier, subcontractor or partner of APL Commodities.

• Client means a client, prospect or target client of APL Commodities.

• Web user means a user of the APL Commodities internet website.

• External Service Provider means an external provider outside of APL Commodities that may have access to Commercial Information during the provision of services to APL Commodities.

• Personal information means information related to an identified or identifiable natural person that is processed by APL Commodities, or on its behalf, through automatic means.

1. What commercial information does APL Commodities collect?
The type of Business Information that APL Commodities collects and uses depends on the specific business context and the purpose for which the information was collected. This may include the following:

• Contact information. (company name, contact name, title, work address, phone numbers, email addresses, fax numbers, etc.)
• Information about your relevant experience and / or your professional, Commercial or Banking references. (in the case of possible, objective or recurring Client)
• Details about your business and other interests and opinions. (information kept in a Customer Relationship Management database);
• For Web Users, information related to your use of the APL Commodities website, including the content of web forms, contributions made in discussion forums and browsing history, IP addresses and your route through the APL Commodities website.
• Financial Data, Credit or Payment Capacity, and other information related to financial matters, such as your bank account number and other relevant information related to payments collected to support a business transaction.
• Images obtained by closed circuit television (CCTV) and information of the visit for visitors to the Offices, Warehouses, Silos, Farms of APL Commodities or related to, and that the Corporation is consenting and has knowledge of said visit.

2. What will APL Commodities do with said Information?
In general, APL Commodities only uses Personal, Business or Financial Information for one or more of the following business-related purposes:

• Negotiation, conclusion and execution of contracts with Clients. (including Provision of Products, Advice, Planting, Production, Export, Distribution, Processing, Production, Logistics and other terms related to the Commercialization of Commodities)
• Manage APL Commodities accounts and records.
• Advertising, Marketing and public relations. (including Direct Marketing)
• Market research and competitor analysis.
• Negotiation, Conclusion and Execution of contracts with Suppliers, Clients or companies that will provide a service that has interference in said transaction.
• Communication with people who are Clients, Suppliers or Web Users.
• Operation of the APL Commodities website, including the use of analysis software.
• Support of APL Commodities corporate social responsibility activities.
• Facilitation of the security of the facilities, websites and other assets of APL Commodities.
• Legal and regulatory compliance and internal control evaluations and audits. (even when performed by APL Commodities internal and external audit service providers)
• Management of Debts and / or Accounts Payable or monetary commitments in direct or indirect relationship with the Corporation, and its Operations or Businesses.
• Obtaining legal advice, including for legal proceedings, litigation and also in connection with the sale, purchase or merger of a company.

We process Personal, Commercial or Financial Information for the purposes mentioned above, as necessary for our legitimate business interests and the interests of third parties with whom we interact, There are certain aspects of the processing that are also necessary for us to comply with the law or that are based on your consent or other legal grounds available for processing.

3. Data privacy principles of APL Commodities
APL Commodities respects the following principles related to Personal, Commercial or Financial Information:

• We process it fairly and lawfully.
• We process it for a specific legitimate business purpose and we do not process it in a manner incompatible with that purpose without your consent and / or knowledge.
• We use adequate, relevant and accurate Information, not excessive for the purpose for which it is processed.
• We keep it unaltered and if necessary, updated.
• We keep it in a way that allows identification for the period necessary for the purpose for which it was collected.
• We protect it against accidental or illegal destruction or accidental loss, alteration, unauthorized access or disclosure through appropriate technical and organizational measures.
• We process it in accordance with the rights of Persons, Companies, Entities or in relation.

4. Who is your business information disclosed to?

a) Within APL Commodities.
APL Commodities limits access to Commercial Information to persons within the company who have a “need to know” this information. As a global company doing business across national borders and with certain shared services and resources, there are many situations where this “need to know” requires the transfer of your information to APL Commodities in another country, including countries that do not provide legal protection for personal information. However, the purpose of the Data Privacy Policy for commercial information of the Corporation is to guarantee the protection of Information in all countries where APL Commodities carries out operations as Entity, Company or Private and Commercial as approved by relevant EEA data protection authorities as “Binding Corporate Rules”.

b) Outside APL Commodities
The Corporation shares Business Information with Authorized Third Party Service Providers. In this case, APL Commodities imposes the relevant contractual obligations on the Information and limits for its use. Apart from its Third Party Service Providers, APL Commodities will only disclose your Information to third parties in the following cases:
• When required by law.

• In response to a legitimate request for assistance from the police or other law enforcement agency.
• To protect the fundamental interests or safety of a person;
• To obtain legal advice from outside APL Commodities attorneys or in connection with litigation with a third party.
• In connection with the sale, purchase or merger of a business.
• To hire external auditors to validate the financial accounts of The Corporation.

By doing so, your Personal, Business or Financial Information may be transferred to other countries that do not have the same level of legal protection as your own country. However, we apply the appropriate protection measures to ensure it.

5. Exercise your rights

i) Web users, Clients and those who represent Clients.
If you wish to obtain a copy of your business information or if you wish to update or correct it or you wish to request APL Commodities not to send you further promotions or marketing communications, either in general or through a specific medium, please contact APL Commodities.
However, please note that we may continue to send you non-marketing communications (for example, those related to services) and that we will keep a record of your request and your contact details to ensure that your request is honored.
If you have concerns about how APL Commodities has used your information, as a first step, you should submit your concerns in writing to the Corporation Company you do business with or to APL Commodities in particular.

If your complaint is not resolved within a reasonable time after submission, it can´t be sent to the User Support Office at :

After investigating the submitted concern, the User Support Office will send you a written response within a reasonable time stating its conclusions along with details of any corrective action it proposes.
In some circumstances, you have the right to request that we delete your Information or a restriction on its use, to object to its use, to receive it in a portable format or to have it transmitted to another organization. If you wish to exercise any of these rights, please contact APL Commodities.
If your concern relates to Business Information subject to the laws of the European Economic Area and the Global Privacy Officer has not been able to resolve it in its entirety, you have the right to raise it with your local Data Privacy Authority or with the courts of your country, where you can seek compensation from APL Commodities for any loss or damage you have suffered.

ii) Suppliers and those persons who represent the Suppliers
If you would like a copy of your business information or if you would like to update or correct it, please contact user support at:

If you have concerns about how APL Commodities has used your information, as a first step, you should submit your concerns in writing to the company of the corporation with which you do business.
If your complaint is not resolved within a reasonable time after being sent to APL Commodities, it can be forwarded to the User Support Office at:

After investigating the submitted concern, the Global Privacy Office will send you a written response within a reasonable time stating its conclusions along with details of any corrective action it proposes.

6. Preservation of your Personal, Commercial or Financial Information.
Depending on the purposes for which we process your Information, we may retain it for as long as is necessary for such purposes and, in particular, to protect ourselves in the event that you bring any legal action. The timelines for filing legal actions vary from jurisdiction to jurisdiction. For example, the deadline for most contractual claims in the UK is six years from the alleged breach of contract.

Contact APL Commodities
If you want to access, update, correct or otherwise exercise your rights in relation to your Personal Information, including by withdrawing your consent.
If you have any questions about this Notice or our privacy practices, please contact us as follows:

Email User Support:

Write to us:

APL Commodities user support
Legal Department and Corporate Affairs
PO Box 10000
Dubai, United Arab Emirates


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