DESKS ACTIVE
Direct Trade Desk
GOVERNANCE & LEGAL CODEXLast Revised: September 2026

Global Commercial Privacy & Data Governance Framework

Standards for handling counterparty identification, trade manifests, and corporate entity data across our international trading operations.

General Counsel & Risk Desk

Regulatory Verification & KYC

For counterparty verification, sanctions screening documentation, or designated escrow agreements:

compliance@visionvibeglobal.com
London HQ: 100 Bishopsgate, Level 24
Official Policy Document
Reference: VVG-REG-PRIVACY-

1. Scope & Regulatory Framework

Vision Vibe Global and its operating subsidiaries adhere to stringent data protection standards across all jurisdictions where we originate, store, or clear physical commodities. Our privacy governance architecture aligns with the European Union General Data Protection Regulation (EU GDPR), United Kingdom Data Protection Act 2018, Singapore Personal Data Protection Act (PDPA), and Dubai International Financial Centre (DIFC) Data Protection Law.

2. Categories of Commercial Counterparty Data Collected

In the course of executing wholesale physical transactions, documentary letters of credit, and vessel charters, we collect and process specific entity and representative data, including:

  • Corporate Know-Your-Customer (KYC) records, certificates of incorporation, and beneficial ownership declarations.
  • Authorized signatory credentials, specimen signatures, and corporate power-of-attorney documents.
  • Trade transaction manifests, bills of lading, customs declarations, and cargo assay certificates.
  • Banking information, SWIFT BIC codes, and designated escrow account details for documentary settlement.
  • Vessel telemetry, captain and chartering officer identification, and discharge port agent manifests.

3. Lawful Basis for Processing Commercial Data

All counterparty data is processed under strict lawful bases: (a) Performance of physical purchase, sale, and charterparty contracts; (b) Compliance with statutory anti-money laundering (AML) and international trade sanctions regulations; and (c) Legitimate commercial interests in securing cross-border trade finance.

4. Cross-Border Data Transfers & Security Measures

Given the multinational footprint of our commodity desks (Geneva, London, Dubai, Singapore, and Houston), trade documentation is transferred securely across borders. Transfers outside the EEA/UK rely on approved Standard Contractual Clauses (SCCs) and end-to-end TLS 1.3 encryption. We never sell, lease, or monetize commercial counterparty data to third-party data brokers.

5. Statutory Retention & Archival Policies

In accordance with maritime commerce conventions and customs regulations, trade manifests, Bills of Lading, and inspection assays are retained in secure, access-controlled digital vaults for a minimum of seven (7) years following discharge and final commercial settlement.

6. Counterparty Data Rights & Governance Officer

Corporate counterparties and their designated personnel may request verification, correction, or audit of stored records by contacting our Corporate Data Governance Officer at privacy@visionvibeglobal.com.

Vision Vibe Global Executive Risk CommitteeOffice of the General Counsel • International Merchant Operations

These statutes are periodically audited against prevailing ICC Paris guidelines, GAFTA arbitration rules, and international maritime safety protocols.