Privacy Notice

1. Who We Are

This notice applies to personal information collected through the VIVAR International Trade website (trade.vivargroup.com). The data controller is VIVAR ASSET MANAGEMENT W.L.L., Kingdom of Bahrain, Commercial Registration No. 182222-1, Flat/Shop 21, Building 6, Road 355, Block 327, Manama / Al Adliyah, Kingdom of Bahrain. We process personal data in accordance with the Bahrain Personal Data Protection Law (Law No. 30 of 2018) (the “PDPL”).

Privacy contact: compliance@vivargroup.com. General correspondence: info@vivargroup.com.

This notice does not apply to the VIVAR corporate website, which has its own privacy policy.

2. Information We Collect

• From the Trade enquiry form: contact name, company or legal entity, country, email address, optional phone or WhatsApp number, and commercial details about your requirement or supply (product, specification, quantity, destination or origin, Incoterm, delivery timing or loading port, and any additional information you choose to add).
• Mandatory and optional fields: fields marked with an asterisk (*) on the enquiry form (for example name, company and email) are mandatory to fulfil your request, and we cannot process your enquiry without them. All other fields are optional.
• Technical information: when you use the website, our hosting provider processes technical data such as your IP address and request details to deliver the site and protect it from abuse. We use your IP address to limit repeated form submissions.
• The Trade website does not use cookies or analytics.
• Please do not send bank details, bank statements, identity documents, letters of credit or other confidential financial documents. The form has no upload facility.

3. How We Use It and Our Legal Grounds

We use personal information to assess and respond to your enquiry; to evaluate a requirement or supply opportunity; where appropriate, to discuss a possible transaction with you; to protect the website and prevent abuse; and to meet legal obligations. We process personal information on the following legal grounds under Article 4 of the PDPL:

• Responding to B2B enquiries: processing is necessary to take steps at the request of the data subject prior to entering into a contract, or for legitimate corporate commercial intent.
• Website security: processing is necessary for the pursuit of the legitimate business interests of the data controller, provided it does not override your individual privacy rights.

VIVAR does not engage in automated direct marketing, commercial tracking, or newsletter distribution via the data collected through this website.

4. Who Receives It

Your enquiry is sent by email to VIVAR's trade team. It is processed on our behalf by our website hosting provider (Vercel), our email-delivery provider (Resend) and our mailbox provider (Google Workspace). We may share information with professional advisers. We disclose your identity or enquiry details to another party only where commercially appropriate and authorised by you.

5. International Transfers

Your inbound web enquiry data is stored and processed across cloud infrastructure located in the United States (Vercel and Resend). Outbound and notification emails are actively routed and sent via Amazon SES infrastructure located in Tokyo, Japan. These operations are fully compliant with Bahrain cross-border data transfer frameworks, namely Article 12 of the Bahrain Personal Data Protection Law (PDPL) and Resolution No. (42) of 2022 Issuing the List of Countries and Territories Providing Personal Data with an Adequate Level of Protection.

6. Retention

We keep enquiries for 24 months after our last substantive interaction with you, subject to applicable legal requirements. Please note that data may be held longer if required to comply with Bahrain Anti-Money Laundering (AML) laws, corporate accounting decrees, or active litigation or statutory claims windows.

Our service providers keep technical logs and delivery records for the periods set by their service terms.

7. Security

The website is served over HTTPS. No transmission over the internet is completely secure.

8. Your Rights

Under the PDPL, you have the following rights:

• Right to object: specifically regarding direct marketing or automated business matchmaking.
• Right to rectification, access, blocking and erasure of your personal data.

Requests are processed free of charge. We will respond to data access requests within 15 working days. For requests regarding rectification, blocking, or erasure, VIVAR will evaluate and process your request within 10 working days of receipt. Please contact us at compliance@vivargroup.com regarding your information.

A request for erasure or blocking will not be fulfilled to the extent that we are legally bound to retain the information, including transaction details that we must retain under Bahrain Decree-Law No. (4) of 2001 with respect to Anti-Money Laundering (AML) or under corporate bookkeeping regulations.

9. Complaints

If you are not satisfied with our response, you have the right to lodge a formal complaint with the Personal Data Protection Authority (PDPA) of the Kingdom of Bahrain.

10. Children

The website is for business users and is not directed at children.

11. Changes

We may update this notice and will publish the current version on this page. Last updated: 11 October 2026.