1. About This Policy

This Privacy Policy and Terms of Use applies to Expanio Limited ("Expanio", "we", "us", or "our"), a company registered in England & Wales, operating from 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

We are committed to protecting the personal data of everyone who interacts with us — including farmers, suppliers, traders, importers, exporters, and business enquirers — in full compliance with:

• UK General Data Protection Regulation (UK GDPR)

• Data Protection Act 2018

• Privacy and Electronic Communications Regulations (PECR)

• The Information Commissioner's Office (ICO) guidelines

2. What Data We Collect

We collect only the minimum personal data necessary for our legitimate business activities. This may include:

• Full name and business name

• Email address and phone number

• Country and city of operation

• Product or commodity interests (e.g. spices, essential oils, cocoa)

• Communication history with Expanio

• Webinar registration and attendance records

• Enquiry and consultation booking details

3. How We Use Your Data

We collect and use personal data for the following specific purposes:

• To respond to trade enquiries and consultation requests

• To match buyers with Indonesian suppliers or farm representatives

• To onboard members into the Expanio farmer and supplier community

• To send relevant trade information, commodity updates, and market insights

• To invite registered contacts to webinars, trade sessions, or sourcing events hosted by Expanio

• To facilitate export mentoring and programme enrolment

• To fulfil legal and compliance obligations as a UK-registered company

We do not use your data for automated decision-making or profiling.

4. Legal Basis for Processing

Under UK GDPR, we rely on the following lawful bases:

• Legitimate Interests — to communicate trade opportunities relevant to your business

• Contractual Necessity — to fulfil agreements or consultations you have entered into with us

• Consent — where you have explicitly opted in to receive communications from Expanio

• Legal Obligation — where we are required by law to process or retain certain data

5. Data Sharing & Third Parties

Expanio does not sell, rent, or trade your personal data to any third party.

We will only share your data in the following limited circumstances:

• With your explicit prior consent — for example, introducing a buyer to a specific Indonesian supplier

• With trusted service providers who process data on our behalf (e.g. email platforms, scheduling tools) under strict data processing agreements

• Where required by law, court order, or regulatory authority in the United Kingdom

Any third-party tools we use are vetted for UK GDPR compliance. We do not transfer personal data outside the UK/EEA without adequate safeguards in place.

6. Data Retention

We retain personal data only for as long as necessary for the purpose it was collected:

• Active contacts & community members — for the duration of the relationship plus 2 years

• Webinar and event registrations — up to 12 months after the event

• Consultation and booking records — up to 3 years for business records

• Inactive contacts (no engagement) — reviewed and deleted after 24 months

You may request deletion of your data at any time (see Section 8).

7. Data Security

Expanio takes appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. These measures include encrypted communications, access-controlled systems, and regular security reviews.

In the event of a data breach that is likely to result in risk to your rights and freedoms, we will notify the relevant parties in accordance with our obligations under UK GDPR (within 72 hours of becoming aware).

8. Your Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights:

• Right of Access — request a copy of the data we hold about you

• Right to Rectification — request correction of inaccurate data

• Right to Erasure — request deletion of your personal data

• Right to Restrict Processing — request we limit how we use your data

• Right to Data Portability — receive your data in a portable format

• Right to Object — object to processing based on legitimate interests

• Right to Withdraw Consent — at any time, without affecting prior processing

To exercise any of these rights, please contact us at: hi@expanio.co.uk

We will respond within 15 days of receiving your request, in line with ICO guidelines.

9. Cookies & Website Data

Our website may use essential cookies to ensure basic functionality. Where non-essential cookies are used (e.g. analytics), we will request your consent via a clearly visible cookie notice. You may manage or withdraw cookie consent at any time through your browser settings.

10. Webinars & Community Events

When you register for an Expanio webinar, trade session, or community event, we collect your registration details for the sole purpose of managing attendance and sending event-related communications. Your data will not be used for unrelated purposes or shared with other attendees without your consent.

Webinar sessions may be recorded. Participants will be informed in advance, and recordings will only be used for internal training or shared with attendees unless otherwise stated.

11. Contact & Complaints

If you have any questions about this policy or how your data is handled, please contact:

Expanio Limited

71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom

Email: hi@expanio.co.uk

Indonesia Representative: +6285121595071

12. Terms of Use

By accessing or using Expanio's website, services, or communications, you agree to the following terms:

• All content on the Expanio website and communications is the intellectual property of Expanio Limited and may not be reproduced without written permission.

• Expanio acts as a trade connector and mentoring service. We do not guarantee specific trade outcomes, revenue, or deal completion beyond our stated service commitments.

• Users are responsible for ensuring their own compliance with export and import regulations applicable in their country of operation.

• Expanio reserves the right to update these terms at any time. Continued use of our services constitutes acceptance of the revised terms.

• These terms are governed by the laws of England & Wales. Any disputes shall be subject to the exclusive jurisdiction of the courts of England & Wales.