Privacy policy

Who is responsible for your data?

Union Trade LLC is the controller of the personal data described in this policy. We are a Wyoming limited liability company and part of Functional Brands Group.

• Legal name: Union Trade LLC
• Registered office: 2120 Carey Ave, Cheyenne, WY 82001, USA
• Email: eugene@union-trade.net

This policy covers union-trade.net, our contact form, our email correspondence and our business-to-business (B2B) outreach. It applies to people in the United States, the United Kingdom, the European Union and anywhere else we work.

If you are in the UK or EU and have a question about how we handle your personal data, contact us at eugene@union-trade.net. If we appoint a representative in the UK or EU, we will publish their details in this section.

What personal data do we collect?

We collect business contact details and the information you choose to share about your company's needs. We do not ask for sensitive information, such as health data, and we ask you not to send it.

When you use our contact form

• All inquiries: your name, company, business email address, country and message. Your phone number and role are optional.
• Quote and sourcing requests: product or category, specification notes, estimated volume, destination market and target timing.
• Brand representation inquiries: brand name, website, product category, current and target markets, and current certifications.
• Your confirmation that we may use your details to respond to your inquiry.
• Technical details sent with the form: the page you sent it from, campaign tags in the link you followed (for example UTM parameters), the date and time, and your IP address, which we use to block spam and abuse.

When you email us, meet us or work with us

• Your name, job title, company and contact details.
• The content of our emails, calls and meetings, including notes from trade shows and business cards you give us.
• Records of quotes, contracts, orders and shipments you are involved in.

When we contact you first (B2B outreach)

• Your name, job title, employer, business email address, business phone number, work location and professional profile link.
• Records of the emails we send and your replies. Where our outreach tools record it, this includes whether an email was delivered or opened.

When you browse the website

• Our hosting provider processes the technical data needed to deliver and protect the website, such as IP address, browser type, the pages requested and the time of each request.
• If you accept analytics cookies, Google Analytics 4 collects usage data such as pages viewed, approximate location, device and browser type, the site that referred you and whether a form was submitted. It does not receive what you type into the form. See our Cookie policy.

Where do we get personal data from?

• From you: through our contact form, emails, calls, meetings and trade shows.
• From your company or our business partners: for example, when a producer, brand, buyer or Functional Brands Group company introduces you to us.
• From public and commercial business sources: company websites, professional networking sites such as LinkedIn, trade-show exhibitor directories, and B2B contact databases such as Apollo.io.
• From our website technology: hosting logs and, with your consent, Google Analytics.

If we contacted you first and you want to know where we found your details, ask us and we will tell you.

How do we use your data, and on what legal basis?

Under the UK GDPR and the EU GDPR, we need a lawful basis for each use of personal data. These are the bases we rely on:

• Responding to inquiries and quote requests. Legitimate interests: answering business inquiries and preparing proposals for the companies that send them.
• Running business relationships. Quotes, orders, shipments, representation agreements and invoices. If you contract with us in your own name, the basis is performing that contract or taking steps you ask for before entering into it. Otherwise, it is our legitimate interest in managing our dealings with your company.
• B2B outreach. Legitimate interests: introducing our services, and the brands we represent, to people whose roles make them relevant, such as buyers, category managers, importers and distributors in the food and beverage trade. You can object at any time.
• Keeping the website and forms secure. Legitimate interests: preventing spam, fraud and abuse.
• Website analytics. Consent, which you give or refuse through our cookie banner. You can withdraw it at any time through the Cookie settings link in the footer.
• Legal, tax and accounting duties. Legal obligation.
• Legal claims. Legitimate interests: establishing, exercising or defending legal claims.
• Working with Functional Brands Group. Legitimate interests: delivering joint work, such as brand development, where your inquiry calls for it.

Where we rely on legitimate interests, we have weighed them against your rights. We contact people only in their business capacity, keep messages relevant to their role, and stop when asked. You can ask us for more detail on this assessment.

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

How can you stop our business emails?

If we have emailed you about a business opportunity, it is because your role suggests that our services, or a brand we represent, may be relevant to your company. We aim to keep each message short, specific and relevant, and to follow the email marketing rules that apply where you are.

You can object at any time, and we will stop. To opt out:

• reply to any of our emails with "unsubscribe", or
• email eugene@union-trade.net with the subject "Opt out".

We keep a minimal record, your email address and the date you opted out, on a suppression list so that we do not contact you again. If you also want the rest of your data deleted, say so in the same message.

Who do we share your data with?

We share personal data only where needed for the purposes above. We do not sell your personal data.

Service providers (processors) that act on our instructions:

• Website hosting: Hetzner Online GmbH, which hosts this website and the contact form submissions on servers in the European Union (Finland).
• Email: Google Workspace, for business email and calendars, including the notifications we receive when you submit a form.
• Analytics: Google Analytics 4, only if you accept analytics cookies.
• CRM and outreach: tools such as Apollo.io, which store B2B contact records and send outreach emails.

Other recipients, where relevant:

• Functional Brands Group companies, when your inquiry relates to work we deliver together.
• Producers, brands and buyers, when you ask us to make an introduction or to progress a deal, limited to what that requires.
• Trade partners such as freight forwarders, warehouses, testing laboratories, licensed customs brokers and regulatory consultants, when a transaction you are part of needs them.
• Professional advisers, such as lawyers and accountants.
• Courts, regulators and other authorities, where the law requires it or to protect our legal rights.
• A buyer or successor, if our business is reorganized, merged or sold, on condition that your data stays protected to the same standard.

Do we transfer your data outside the UK and EU?

Yes. Union Trade LLC is registered in the United States, so information you send us is transferred to the US. Our team and our service providers may also access or process it in other countries.

When we transfer personal data from the UK or EU to a country or recipient not covered by an adequacy decision, we use appropriate safeguards, such as:

• the European Commission's standard contractual clauses, together with the UK's International Data Transfer Addendum for UK data; or
• a provider's certification under the EU-U.S. Data Privacy Framework and its UK Extension, where that applies.

You can ask us for more information about the safeguards we use.

How long do we keep your data?

We keep personal data only for as long as we need it. Our standard periods are:

• Inquiries that do not lead to business: 24 months from our last contact.
• Business relationship records (correspondence, quotes, contracts, orders and invoices): for the length of the relationship, then up to seven years, or longer if the law requires.
• B2B outreach records: up to 24 months from our last contact, unless a conversation is ongoing.
• Opt-out (suppression) records: for as long as we carry out outreach, so that we can honor your request.
• Google Analytics data: up to 14 months. Analytics cookies expire as listed in our Cookie policy.
• Security data, such as IP addresses used to block spam: only as long as needed for that purpose.

At the end of each period, we delete the data or anonymize it.

What are your rights?

If you are in the UK or EU, you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased;
• restrict how we use it;
• receive data you gave us in a portable format;
• object to processing based on legitimate interests, and object at any time to direct marketing, which we will then stop;
• withdraw consent at any time, for example to analytics cookies, without affecting processing that took place before.

To use any of these rights, email eugene@union-trade.net. We may ask you to confirm your identity. We reply within one month. If a request is complex, we may extend this by up to two further months, and we will tell you why. We do not charge a fee for most requests.

Some rights have limits. For example, we may need to keep records that the law requires. If a limit applies, we will explain it.

How can you complain?

Please contact us first at eugene@union-trade.net so that we can try to put things right. You also have the right to complain to a data protection authority:

• UK: the Information Commissioner's Office (ICO), ico.org.uk.
• EU: the supervisory authority in the country where you live or work, or where the issue happened. The European Data Protection Board lists them at edpb.europa.eu.

Information for US residents

Several US states have consumer privacy laws. Depending on where you live, and on whether a state law applies to us and to the information involved, you may have the right to:

• know what personal information we collect, use and disclose, and get a copy of it;
• correct inaccurate information;
• delete your information;
• opt out of the sale of personal information, targeted advertising and certain types of profiling;
• not be treated differently for using these rights.

We do not sell personal information, share it for cross-context behavioral advertising or use it for targeted advertising. We do not knowingly collect sensitive personal information.

The categories of personal information we collect are: identifiers, such as name, email address, phone number and IP address; professional information, such as job title and employer; commercial information, such as records of inquiries and deals; internet activity, such as website usage (analytics only with consent); and approximate location derived from an IP address. The sources, purposes, recipients and retention periods are described in the sections above.

Wherever you live, you can ask us to access, correct or delete your personal information, or to stop contacting you. To make a request, email eugene@union-trade.net. We verify requests using information we already hold. You can use an authorized agent, and we may ask for proof that they act for you. If we decline your request, you can appeal by replying to our decision. If you are not satisfied with the outcome, and your state's law provides for it, you can contact your state attorney general.

How do we protect your data?

• Encrypted connections (HTTPS) across the website.
• Form submissions stored in a database that the public cannot read.
• Access limited to the people who need it for their work.
• Service providers chosen for the data protection terms they offer.

No system is completely secure. If you think your data has been put at risk, contact us right away.

Children

Our website and services are for businesses. They are not directed at children, and we do not knowingly collect personal data from anyone under 16.

Changes to this policy

We may update this policy when our services, our tools or the law change. The "Last updated" date at the top of this page shows the current version. If a change significantly affects how we use your data, we will take reasonable steps to tell you.

How to contact us

• Union Trade LLC
• Registered office: 2120 Carey Ave, Cheyenne, WY 82001, USA
• Email: eugene@union-trade.net

Email is the fastest way to reach us about privacy.