Le document complet est présenté dans sa version originale en anglais.
MBG TRADING INTERNATIONAL, INC. PRIVACY POLICY Effective Date: January 1, 2025 | Version: 2.0 | Last Updated: 2025 www.mbgti.com | info@mbgti.com | +1.305.393.8751 This Privacy Policy applies to all personal data processed by MBG Trading International, Inc. and its joint venture partners across all platforms, channels, and tools, including the MBG website, Vendor Portal, Customer Platform, WhatsApp and electronic messaging communications, and the MBG AI-powered trading and pricing system. Please read this policy carefully. If you have any questions, contact us at support@mbgti.com.
1. WHO WE ARE
MBG Trading International, Inc. ("MBG," "we," "us," or "our") is a meat trading company incorporated in the State of Florida, United States of America, with its principal place of business at 66 West Flagler Street, Suite 900-8179, Miami, FL 33130. MBG exports US pork, chicken, and beef to markets primarily in Mexico, Colombia, and El Salvador, operating through direct sales, joint venture arrangements, and digital trading platforms.
For transactions invoiced in Mexican Pesos (MXN) to buyers in the Mexican market, MBG operates through a joint venture arrangement with Cristin Alberto Guerra Garza (RFC: GUGC521028ID1), located at Blvd. Alvaro Obregon 1802/23, Altavista, C.P. 88720, Reynosa, Tamaulipas, Mexico. For those transactions, Cristin Alberto Guerra Garza acts as a joint data controller alongside MBG with respect to personal data of buyers and contacts in Mexico. References to "MBG" or "we" in this Privacy Policy include this joint venture arrangement where the context so requires.
You can reach our Data Protection contact at:
• Email: support@mbgti.com
• Mail: MBG Trading International, Inc., Data Protection, 66 W. Flagler Street, Suite 900-8179, Miami, FL 33130
• Phone: +1.305.393.8751
2. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to the collection, use, storage, and disclosure of personal data by MBG in connection with all of the following channels and tools (collectively, "MBG Platforms"):
• The MBG public website at www.mbgti.com
• The MBG Vendor Portal, accessible at https://mbgti.com/privacy-policy/ and related subdomains
• The MBG Customer Platform, including any buyer-facing pricing portal or ordering system
• WhatsApp and other electronic messaging platforms used to distribute product availability, pricing information, and commercial communications to buyers, vendors, and business contacts
• The MBG AI-powered trading and pricing system (the "Platform"), which employs automated systems and artificial intelligence tools to process supplier offer data, generate pricing recommendations, and facilitate customer-facing communications
• Email communications, telephone calls, and any other direct contact initiated through or in connection with MBG's commercial activities
• Sales Confirmations, Invoices, and any other commercial documentation referencing this Privacy Policy
This Privacy Policy covers personal data relating to natural persons, including employees, officers, and representatives of corporate entities who interact with MBG in a business context.
3. APPLICABLE LEGAL FRAMEWORKS
MBG operates across multiple jurisdictions and is subject to a range of data protection and privacy laws. The following frameworks are the primary legal bases governing our data processing activities:
FDBR
Florida, USA
Florida Digital Bill of Rights (effective July 1, 2024) — primary framework for Florida-based operations and processing of Florida residents’ data.
LFPDPPP
Mexico
Ley Federal de Protección de Datos Personales en Posesión de los Particulares (Federal Law on Protection of Personal Data Held by Private Parties) and its Regulations — mandatory for processing personal data of individuals in Mexico.
Law 1581
Colombia
Ley 1581 de 2012 (Ley de Habeas Data) and Decree 1377 of 2013 — governs processing of personal data of Colombian individuals.
CAN-SPAM / TCPA
USA (Federal)
CAN-SPAM Act and Telephone Consumer Protection Act (TCPA) — govern commercial electronic messaging, including email and WhatsApp communications, to contacts in the United States.
GDPR
EU / EEA
General Data Protection Regulation — applies to the extent MBG processes personal data of individuals located in the European Union or European Economic Area.
LAIP
El Salvador
Ley de Acceso a la Información Pública — referenced as applicable guidance for El Salvador-based contacts; all transactions in El Salvador are denominated in USD.
Where this Privacy Policy refers to specific legal articles or rights, we identify the applicable framework. In cases where multiple frameworks apply, we apply the standard that affords the highest level of protection to the individual.
4. PERSONAL DATA WE COLLECT
4.1 Website Visitors
When you visit www.mbgti.com or any related subdomain without logging in, your browser automatically transmits certain technical data to our web server, including:
• Browser type and version
• Date and time of access
• Pages visited and referring URL
• The IP address of your requesting device (temporarily stored for less than 30 days and not retained in log files beyond that period)
This data is used solely for technical administration, connection stability, security monitoring, and to detect and respond to unauthorized access attempts. It is not used to identify you personally.
4.2 Vendor Portal Users
When you register as a user on the MBG Vendor Portal, we collect the following categories of data:
Company Data:
• Company name, address, telephone number, and website
• Email addresses for orders and payment transactions
• Fax number (optional) and business address if different from registration address
• Main products, services, and business activities
Personal Data of Portal Users:
• Salutation, first name, and last name
• Business email address and telephone number
• Business mobile number (optional) and fax number (optional)
• Job function or title (optional)
• Administrator status (determines which notifications and communications you receive)
Access and Usage Data:
• User ID and encrypted password credentials
• Login timestamps and session data
• Actions performed within the portal (clicks, entries, settings changes, pages accessed)
• Session log files (automatically deleted after less than 30 days; IP addresses are not retained in log files)
4.3 Customer Platform Users
When you access the MBG Customer Platform (buyer-facing pricing and ordering system), we collect data equivalent to the Vendor Portal categories above, as well as:
• Purchase inquiry history and product preferences
• Pricing acknowledgements and Sales Confirmation acceptances
• Electronic acceptance records, including timestamps and device identifiers, for Sales Confirmations and Invoices accepted through the Platform
• Communication records generated within the Platform
4.4 WhatsApp and Electronic Messaging
When you receive or respond to commercial communications from MBG via WhatsApp, email, or other electronic messaging platforms, we collect and retain:
• Your mobile number or messaging account identifier
• Your name and business details as provided to MBG
• The content of messages you send to MBG in a business context, including pricing inquiries, purchase confirmations, and complaints
• Message delivery and read receipt metadata (where available through the messaging platform)
• Your opt-in status and the date on which you consented to receive commercial communications
• Your opt-out requests and the date on which those requests were received
We do not retain the content of personal or non-business-related messages. WhatsApp message histories related to commercial transactions are retained for a minimum of seven (7) years in accordance with our record retention obligations under the MBG International Terms and Conditions of Sale and Purchase.
4.5 AI Platform and Automated Systems
The MBG AI-powered trading and pricing system (the "Platform") processes data from multiple sources to support MBG's commercial operations. The Platform processes:
• Vendor offer data, including supplier contact names, email addresses, and pricing information submitted to MBG by suppliers
• Product pricing and availability data compiled from supplier communications
• Customer inquiry data and preferences, where such data has been provided to MBG in the context of a commercial relationship
• Translated and formatted content generated by AI tools from supplier offer data
• Interaction logs generated by users of the Platform
The Platform uses artificial intelligence and algorithmic processing to parse supplier offers, generate pricing recommendations, translate content, and route commercial information to appropriate buyers. See Section 10 (Automated Processing and AI) for a full disclosure of how this works and your rights in relation to it.
4.6 Data We Do Not Collect
MBG does not collect, process, or store any of the following categories of sensitive personal data through its commercial platforms:
• National identity numbers, passport numbers, or government-issued ID numbers (other than RFC numbers for Mexican tax compliance purposes)
• Financial account numbers, credit card numbers, or banking credentials
• Health, medical, or biometric data
• Religious beliefs, political opinions, or trade union membership
• Data relating to minors under the age of 18
5. HOW WE USE YOUR PERSONAL DATA
We use personal data collected through the MBG Platforms for the following purposes:
• To establish and manage commercial relationships with suppliers and buyers, including issuing Sales Confirmations and Invoices
• To operate and maintain the Vendor Portal, Customer Platform, and AI trading system
• To distribute product availability and pricing information via WhatsApp, email, and other electronic channels
• To process and respond to purchase inquiries, complaints, and other business communications
• To maintain records of transactions, acceptances, and communications as required by our Terms and Conditions and applicable law
• To comply with export control, customs, tax, and anti-money laundering obligations
• To monitor and improve the security, functionality, and performance of our platforms
• To detect and prevent fraudulent activity, unauthorized access, or misuse of our systems
• To fulfill our obligations under the MBG International Terms and Conditions of Sale and Purchase, including dispute resolution and arbitration
• To generate and refine AI-based pricing tools, subject to the limitations described in Section 10
6. LEGAL BASIS FOR PROCESSING
We process personal data only where we have a valid legal basis to do so. Depending on the applicable jurisdiction and the nature of the processing, the legal bases we rely on include:
• Performance of a contract (Art. 6(1)(b) GDPR; Art. 7 LFPDPPP; FDBR legitimate business purposes): processing necessary to enter into or perform a Sales Confirmation, manage portal access, or respond to purchase inquiries
• Legitimate interests (Art. 6(1)(f) GDPR; FDBR): operating and securing our platforms, distributing commercial communications to existing business contacts, maintaining transaction records, and improving our systems — where our interests are not overridden by the rights of the individual
• Legal obligation (Art. 6(1)(c) GDPR; FDBR): processing required to comply with export regulations, tax law, anti-money laundering rules, customs requirements, or court or arbitral orders
• Consent (Art. 6(1)(a) GDPR; Art. 9 LFPDPPP; TCPA): where we send commercial electronic communications to contacts who have not previously transacted with MBG, or where required by applicable law for specific processing activities
Where we rely on consent as the legal basis, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
7. SHARING AND DISCLOSURE OF PERSONAL DATA
7.1 Service Providers and Data Processors
We engage third-party service providers who process personal data on our behalf in the following areas:
• Web hosting, cloud infrastructure, and application deployment
• Customer relationship management (CRM) and ERP systems
• Freight forwarding, customs brokerage, and logistics
• Financial institutions, banks, and payment processors
• AI and software development partners supporting the MBG Platform
All service providers are bound by data processing agreements that require them to process data only on MBG's instructions, to maintain appropriate security measures, and to comply with applicable data protection law.
7.2 Necessary Disclosure for Transaction Execution
In the ordinary course of trade, we share limited personal data (typically company name, contact name, and contact details) with the following parties as strictly necessary to execute a transaction:
• Freight forwarders and shipping companies
• Customs brokers and government authorities (US Customs and Border Protection, SENASICA, INVIMA, and equivalent agencies)
• Port authorities and logistics providers
• Financial institutions processing letters of credit or wire transfers
7.3 Legal Disclosure
We may disclose personal data to law enforcement, regulatory authorities, or courts where required by applicable law, court order, arbitral process, or government demand. We will notify you of such a disclosure where permitted by law.
7.4 No Sale of Personal Data
MBG does not sell, rent, or trade personal data to any third party for marketing or commercial purposes. This applies to all data collected through any MBG Platform or channel.
8. INTERNATIONAL DATA TRANSFERS
MBG is headquartered in Miami, Florida, USA, and operates commercially in Mexico, Colombia, and El Salvador. Personal data may therefore be transferred between these jurisdictions in the ordinary course of business. When we transfer personal data internationally, we ensure that appropriate safeguards are in place, which may include:
• Standard Contractual Clauses (SCCs) approved by the relevant regulatory authority
• Data processing agreements with contractual guarantees of an equivalent level of protection
• Transfers that are strictly necessary for the performance of a contract between MBG and the data subject (for example, transmitting buyer contact details to a freight forwarder for delivery purposes)
• Express consent of the data subject, where required and where no other basis applies
For the purposes of this Privacy Policy, the term "third country" refers to any country outside the jurisdiction whose data protection law applies to the relevant processing activity. For example, for Mexican data subjects, a "third country" transfer is a transfer of their data outside of Mexico. For EU/EEA data subjects, a "third country" transfer is a transfer outside the European Economic Area. We apply the appropriate safeguard standard for each jurisdiction.
We do not transfer personal data to any jurisdiction that has been assessed as providing inadequate protection without first ensuring one of the above safeguards is in place.
9. WHATSAPP AND COMMERCIAL MESSAGING
MBG uses WhatsApp and other electronic messaging platforms as a primary channel for distributing product availability, pricing information, and commercial communications to buyers and business contacts. The following specific provisions apply to this channel:
9.1 Opt-In and Consent
By providing your mobile number to MBG and engaging in commercial communications via WhatsApp or equivalent platforms, you consent to receive commercial electronic messages from MBG. For contacts in the United States, this constitutes consent under the Telephone Consumer Protection Act (TCPA). For contacts in Mexico, this constitutes consent for the processing of your personal data under Article 8 of the LFPDPPP. For contacts in Colombia, this constitutes authorization under Law 1581 of 2012.
9.2 Nature of Communications
Communications sent via WhatsApp or other electronic messaging platforms may include:
• Product availability lists and indicative pricing
• Sales Confirmations and related commercial documents
• Delivery notifications and logistics updates
• Requests for information or confirmation in connection with an active transaction
All pricing communicated via these channels is indicative only and does not constitute a binding offer until confirmed by a formal Sales Confirmation issued by an authorized representative of MBG.
9.3 Opt-Out
You may opt out of commercial electronic communications from MBG at any time by:
• Sending a written opt-out request to support@mbgti.com
• Responding directly to any WhatsApp message with the word "STOP" or "UNSUBSCRIBE"
Opting out of commercial communications does not affect any obligations you have under an existing Sales Confirmation or commercial agreement with MBG. We will process your opt-out within five (5) business days.
9.4 Data Retention for Messaging
Message content and metadata related to commercial transactions are retained for a minimum of seven (7) years from the date of the relevant transaction, consistent with our record retention obligations. Message content unrelated to commercial transactions is not retained beyond thirty (30) days.
10. AUTOMATED PROCESSING AND ARTIFICIAL INTELLIGENCE
MBG operates an AI-powered trading and pricing platform (the "Platform") that uses automated systems and machine learning tools to support its commercial operations. In the interest of full transparency, we disclose the following:
10.1 What the Platform Does
The Platform performs the following automated functions:
• Parses and extracts product and pricing data from supplier offer communications (email and other formats)
• Generates formatted, translated pricing lists for distribution to buyers via WhatsApp and other channels
• Suggests pricing recommendations based on market data and supplier offer inputs
• Manages product taxonomy and supplier offer records
• Facilitates buyer-facing interactions and purchase inquiry routing
10.2 Use of Personal Data in Automated Processing
The Platform processes the personal data of supplier contacts (name, email address, company, and pricing data) and buyer contacts (name, mobile number, purchase history, and pricing preferences) as part of its automated functions. This processing is carried out on the basis of our legitimate interests in operating an efficient commercial platform, and in the performance of our contracts with suppliers and buyers.
10.3 No Automated Decision-Making with Legal Effect
MBG does not use automated processing or profiling to make decisions that produce legal effects concerning individuals or that significantly affect them, within the meaning of Article 22 of the GDPR or equivalent provisions under applicable law. All commercially binding decisions — including acceptance of offers, issuance of Sales Confirmations, and pricing commitments — are reviewed and authorized by a human representative of MBG before they become binding. AI-generated pricing and recommendations are always subject to human review and override.
10.4 Training and Model Improvement
MBG may use anonymized and aggregated transaction data to improve the accuracy and performance of its AI tools. Personal data is not used in identifiable form for AI model training without your explicit consent. If you have questions about how your data may be used in this context, contact us at support@mbgti.com.
11. COOKIES AND TRACKING TECHNOLOGIES
MBG uses technically necessary cookies on its website and portal to enable core platform functionality. We do not use advertising cookies, behavioral tracking cookies, or third-party analytics cookies that would require your prior consent.
The session cookies we use are classified as strictly necessary for the operation of the platform. They are automatically deleted when you log out or when your session expires. These cookies do not contain personal information and are not used to build user profiles or for any purpose other than maintaining your authenticated session.
Cookie usage on the MBG website and portal is governed by applicable US law. We do not rely on any provisions of German telecommunications law (such as the TTDSG) or any other non-applicable national legislation for our cookie practices.
If and when we introduce any non-essential cookies or tracking technologies, we will update this Privacy Policy and request your consent as required by applicable law before deploying them.
12. DATA SECURITY
MBG maintains commercially reasonable technical and organizational security measures to protect personal data against unauthorized access, loss, alteration, destruction, or disclosure. Our security practices include:
• Transmission of data using TLS (Transport Layer Security) encryption across all MBG web platforms
• Access controls limiting personal data access to authorized personnel only
• Regular review and updating of security measures in line with technological developments
• Data processing agreements with all third-party processors requiring equivalent security standards
• Internal procedures for detecting, investigating, and responding to data security incidents
In the event of a data security incident that materially affects your personal data, MBG will notify you within a commercially reasonable timeframe and will take appropriate remedial steps. Notification timelines will comply with the requirements of applicable law in the relevant jurisdiction (for example, 72 hours under the GDPR for EU data subjects; the timeframes required under the LFPDPPP for Mexican data subjects).
13. DATA RETENTION
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law. Our standard retention periods are:
• Transaction records (Sales Confirmations, Invoices, and related communications): seven (7) years from the date of the transaction, consistent with our commercial record retention obligations and applicable tax law
• Portal user accounts: maintained for as long as the commercial relationship is active, or until you request deletion. Accounts that have been inactive for two (2) years will be deleted, with prior notice to the account holder
• WhatsApp and messaging records relating to commercial transactions: seven (7) years
• WhatsApp and messaging records unrelated to commercial transactions: thirty (30) days
• Website and portal access log files: less than thirty (30) days; IP addresses are not retained in log files
• AI platform processing logs: thirty (30) days for operational logs; anonymized aggregated data may be retained indefinitely for system improvement purposes
• Consent records and opt-in/opt-out logs: retained for as long as necessary to demonstrate compliance, and in any event for a minimum of five (5) years
14. YOUR RIGHTS
Depending on your jurisdiction, you have the following rights with respect to your personal data. To exercise any of these rights, contact us at support@mbgti.com.
14.1 Rights Under Florida Law (FDBR)
If you are a Florida resident, you have the right to:
• Know what personal data MBG has collected about you
• Correct inaccurate personal data
• Delete personal data we hold about you (subject to legal retention obligations)
• Opt out of the sale or sharing of your personal data (MBG does not sell personal data)
• Non-discrimination for exercising your privacy rights
14.2 Rights Under Mexican Law (LFPDPPP) — Aviso de Privacidad
This section constitutes the Aviso de Privacidad required under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP) for individuals whose personal data is processed in connection with transactions in Mexico.
MBG Trading International, Inc. and Cristin Alberto Guerra Garza (RFC: GUGC521028ID1), Blvd. Alvaro Obregon 1802/23, Altavista, C.P. 88720, Reynosa, Tamaulipas, Mexico, are jointly responsible for the processing of your personal data in connection with commercial transactions in the Mexican market.
Your personal data is processed for the purposes described in Section 5 of this Privacy Policy. Your data will not be transferred to third parties without your consent, except as necessary to execute a commercial transaction or as required by law.
As a data subject under the LFPDPPP, you have the ARCO rights:
• Acceso (Access): the right to know what personal data we hold about you and how it is used
• Rectificación (Rectification): the right to correct inaccurate or incomplete data
• Cancelación (Cancellation): the right to request deletion of your personal data, subject to legal retention obligations
• Oposición (Objection): the right to object to the processing of your data for specific purposes
To exercise your ARCO rights, submit a written request to support@mbgti.com or to the address at Blvd. Alvaro Obregon 1802/23, Altavista, C.P. 88720, Reynosa, Tamaulipas, Mexico. We will respond within twenty (20) business days as required by the LFPDPPP. You may also file a complaint with the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI) at www.inai.org.mx.
14.3 Rights Under Colombian Law (Law 1581 of 2012)
If you are located in Colombia, you have the right to:
• Know, update, and correct your personal data held by MBG
• Request proof of the authorization granted for the processing of your data
• File complaints with the Superintendencia de Industria y Comercio (SIC) regarding violations of applicable data protection law
• Revoke authorization and request deletion of your data, where no legal or contractual obligation requires retention
To exercise your rights under Colombian law, contact us at support@mbgti.com. We will respond within the timeframes required by applicable Colombian law.
14.4 Rights Under the GDPR (EU/EEA Residents)
If you are located in the European Union or European Economic Area, you have the following rights under the General Data Protection Regulation (GDPR):
• Right of access (Art. 15 GDPR): to receive a copy of your personal data and information about how it is processed
• Right to rectification (Art. 16 GDPR): to correct inaccurate or incomplete data without undue delay
• Right to erasure (Art. 17 GDPR): to request deletion of your data where it is no longer necessary, consent has been withdrawn, or processing is unlawful
• Right to restriction of processing (Art. 18 GDPR): to limit how we use your data in certain circumstances
• Right to data portability (Art. 20 GDPR): to receive your data in a structured, machine-readable format
• Right to object (Art. 21 GDPR): to object to processing based on legitimate interests or for direct marketing purposes
• Right to withdraw consent (Art. 7(3) GDPR): at any time, without affecting the lawfulness of prior processing
• Right to lodge a complaint (Art. 77 GDPR): with the supervisory authority of your country of residence or workplace
14.5 How to Exercise Your Rights
To exercise any of the rights described in this Section, please contact us at:
• Email: support@mbgti.com (preferred — we aim to respond within 5 business days for initial acknowledgement)
• Mail: MBG Trading International, Inc., Data Protection, 66 W. Flagler Street, Suite 900-8179, Miami, FL 33130
We will respond to all verified requests within the timeframes required by the applicable law of your jurisdiction. We may need to verify your identity before processing a request. We will not charge a fee for responding to a reasonable rights request, but reserve the right to charge a reasonable fee for requests that are manifestly unfounded or excessive.
15. LINKS TO THIRD-PARTY PLATFORMS
The MBG website and portal may contain links to third-party platforms, including WhatsApp (Meta Platforms, Inc.), logistics and freight portals, and government agency websites. MBG is not responsible for the privacy practices of any third-party platform. We encourage you to review the privacy policies of any third-party platforms you visit through links on our site.
When using WhatsApp to communicate with MBG, Meta Platforms, Inc. processes data in accordance with its own privacy policy and terms of service. MBG has no control over Meta's data processing practices and is not responsible for them.
16. CHILDREN'S PRIVACY
The MBG Platforms are intended for use by businesses and business professionals and are not directed at individuals under the age of 18. MBG does not knowingly collect personal data from minors. If you believe we have inadvertently collected data relating to a minor, please contact us at support@mbgti.com and we will take steps to delete it promptly.
17. UPDATES TO THIS PRIVACY POLICY
MBG reserves the right to update this Privacy Policy at any time to reflect changes in our business practices, platform features, or applicable legal requirements. The updated policy will be published at www.mbgti.com/privacy-policy/ with a revised effective date. Where changes are material, we will provide notice via email or through a notice on the relevant platform.
The version of this Privacy Policy in effect on the date a Sales Confirmation is issued shall govern the processing of personal data in connection with that transaction, consistent with the MBG International Terms and Conditions of Sale and Purchase.
This Privacy Policy was last updated in 2025 and supersedes all prior versions, including the version dated July 2024.
MBG Trading International, Inc. | 66 West Flagler Street, Suite 900-8179, Miami, FL 33130
Tel: +1.305.393.8751 | info@mbgti.com | support@mbgti.com | www.mbgti.com