TERRAVIIS – LEGAL & COMPLIANCE POLICY

Last updated: 13 November 2025

Version: 1.0

This page sets out the legally binding terms that govern the use of the website
terraviis.com and related online services operated by Terraviis Ltd.
It includes:

• Privacy Policy
• Terms of Use
• Compliance & Ethics Policy

By accessing or using this website, submitting information through it, or communicating with
Terraviis via channels linked from this website, you confirm that you have read, understood and
agree to this Legal & Compliance Policy.

Terraviis Ltd. (“Terraviis”, “we”, “us”, “our”) is an international trading company with its registered office at
Buyukdere Avenue 193, 2nd Floor, Sisli District, Istanbul, Türkiye. Terraviis operates in and
with clients from the European Union, the United Arab Emirates, China and other jurisdictions
worldwide. Terraviis is committed to protecting personal data and complying with applicable laws,
including the EU General Data Protection Regulation (GDPR), UK GDPR, UAE Federal Decree-Law
No. 45 of 2021 on the Protection of Personal Data, and other relevant data protection and trade
regulations.

1. Privacy Policy

1.1 Scope of This Privacy Policy

This Privacy Policy applies to:

• Visitors and users of terraviis.com;
• Individuals contacting Terraviis through forms integrated into this website;
• Individuals contacting Terraviis via email, telephone, or other communication channels where the contact originates from or is linked to this website;
• Current and prospective clients, suppliers, logistics partners, agents, representatives and other business contacts whose data is processed in connection with Terraviis activities.

This Privacy Policy applies regardless of the user’s location (including but not limited to the
European Union, United Kingdom, United Arab Emirates, China and other countries worldwide).

1.2 Personal Data We Collect

1.2.1 Data You Provide to Us

We collect and process personal data that you voluntarily provide, including:

• First name and last name;
• Email address and telephone number;
• Company name, position, country and city;
• Product interests, RFQs (requests for quotation), trade details and other business information you submit;
• Documents you upload or send to us (for example, company registration documents, export licenses, certificates, brochures, presentations);
• The content of communications you send to us (emails, messages, attachments, notes from calls or meetings).

1.2.2 Data Collected Automatically

When you visit our website, certain technical data may be collected automatically, such as:

• IP address and approximate geographical region;
• Device type, operating system and browser type;
• Language settings and referring URLs;
• Pages visited, date and time of access, time spent on the website and click paths;
• Cookie identifiers and similar tracking technologies.

This information may be collected via tools such as Google Analytics, Cloudflare and server logs
and is used for security, performance and analytics purposes.

1.2.3 Compliance and Due Diligence Data

In the context of international trade, compliance and risk management, Terraviis may collect and
process additional information relating to legal and regulatory requirements, such as:

• Corporate registration documents and licenses;
• Export and import permits, product certificates (e.g. ISO, Halal, SGS, quality certificates);
• Information obtained from publicly available or licensed databases (e.g. sanctions lists and watchlists);
• Records and results of sanctions screening, risk assessments and compliance checks.

1.3 Purposes of Processing

We process personal data for the following purposes:

• To respond to general inquiries, RFQs and requests for information;
• To prepare and send commercial offers, contracts, pro forma invoices and related trade documentation;
• To perform supplier and buyer verification, due diligence and compliance checks;
• To coordinate logistics, sampling, quality control and other operational steps in a trade;
• To manage customer and supplier relationships and maintain internal CRM records;
• To operate, maintain and improve our website, digital infrastructure and security;
• To compile statistics and analytics about website usage;
• To comply with legal obligations, regulatory requirements and requests from competent authorities;
• To send newsletters or informational communications where you have subscribed or otherwise provided consent.

We do not sell or rent your personal data to third parties.

1.4 Legal Basis for Processing

Where the GDPR, UK GDPR or similar legislation applies, Terraviis relies on the following legal
bases for processing personal data:

• Performance of a contract or steps prior to entering into a contract – for example, when we process RFQs, prepare offers, negotiate or execute commercial agreements.
• Legitimate interests – including ensuring the security of our systems, preventing fraud, conducting business analytics, and managing business relationships, provided that such interests are not overridden by your fundamental rights and freedoms.
• Compliance with legal obligations – including compliance with trade, customs, tax, sanctions, anti-money laundering and other regulatory requirements.
• Consent – for certain marketing activities (such as newsletters) and, where required by law, for specific analytics or cookies. You may withdraw your consent at any time with effect for the future.

1.5 Data Sharing and International Transfers

1.5.1 Sharing Within Terraviis

Personal data may be shared within Terraviis and its affiliated entities and offices where necessary
for the purposes described in this Privacy Policy, including entities located in the European Union,
United Arab Emirates, Türkiye and other countries where Terraviis operates.

1.5.2 Third-Party Service Providers

We may share personal data with carefully selected third-party service providers that support our
operations, such as:

• Cloud hosting and infrastructure providers;
• CRM and business management platforms;
• Email and communication service providers;
• Analytics providers (including Google Analytics);
• Security and anti-fraud service providers;
• Logistics, inspection and quality-control partners where necessary to perform a trade.

These service providers act as data processors or independent controllers in accordance with
applicable law and are contractually obliged to process personal data only in accordance with our
instructions and to implement appropriate security measures.

1.5.3 International Data Transfers

Because Terraviis operates internationally, personal data may be transferred to and processed in
countries outside your country of residence, including countries outside the European Economic Area
(EEA). Where personal data is transferred from the EEA or UK to a country that is not considered to
provide an adequate level of protection, we implement appropriate safeguards, such as:

• Standard Contractual Clauses adopted by the European Commission;
• Contractual protections and data processing agreements;
• Technical and organisational security measures (including encryption and access controls);
• Data minimisation and limited retention periods.

1.6 Data Retention

We retain personal data only for as long as necessary for the purposes described in this Privacy
Policy or as required by applicable law. Retention periods will vary depending on the type of data
and context of processing, and may include:

• General inquiries: up to 24 months after the last active contact;
• Trade and contractual documentation: generally up to 7 years after completion of a transaction, or longer where required by tax, accounting or regulatory obligations;
• Compliance and risk management records: up to 10 years or as required by applicable law;
• Marketing subscriptions: until you unsubscribe or object to processing;
• Website logs and analytics data: for periods necessary for security and analytics, typically up to 12 months in identifiable form.

1.7 Your Rights

Depending on your location and applicable law (including GDPR, UK GDPR, UAE data protection law
and, where relevant, China’s PIPL), you may have some or all of the following rights in relation
to your personal data:

• The right of access – to obtain confirmation of whether we process your personal data and a copy of that data;
• The right to rectification – to request correction of inaccurate or incomplete data;
• The right to erasure – to request deletion of your personal data in certain circumstances;
• The right to restriction of processing – to request that we limit the processing of your data in certain circumstances;
• The right to data portability – to receive your personal data in a structured, commonly used and machine-readable format where legally applicable;
• The right to object – to object to processing based on legitimate interests or for direct marketing;
• The right to withdraw consent – where processing is based on your consent, you may withdraw it at any time;
• The right to lodge a complaint – with a competent data protection authority in your country or region.

To exercise your rights or make a privacy-related request, please contact us at:
privacy@terraviis.com. We will respond to your request
in accordance with applicable legal requirements and within the time frames provided by law.

1.8 Cookies and Tracking Technologies

Terraviis uses cookies and similar technologies to operate and improve the website, analyse usage
and enhance security. Certain cookies are essential for the functioning of the site; others are
used for analytics or performance.

When required by law, you will be presented with a cookie banner or pop-up where you can accept or
manage your cookie preferences. You can also control cookies through your browser settings.

For more detailed information about the types of cookies and similar technologies we use, their
purposes and your choices, please refer to our separate Cookie Policy available on this website.

1.9 Do Not Sell or Share Personal Data

Terraviis does not sell personal data and does not share personal data with third parties for
their own direct marketing or for cross-context behavioural advertising. Any sharing of data with
service providers is carried out for the purposes described in this Privacy Policy and subject to
appropriate contractual and security safeguards.

1.10 Children’s Privacy

Our website and services are intended for business users and are not directed to children. We do
not knowingly collect personal data from individuals under the age of 16. If we become aware that
we have collected personal data from a child, we will take steps to delete such data as soon as
reasonably practicable.

2. Terms of Use

2.1 Acceptance of Terms

By accessing or using terraviis.com, you agree to be legally bound by these Terms
of Use and all applicable laws and regulations. If you do not agree with any part of these Terms
of Use, you must not use this website.

2.2 Nature of Services

Terraviis operates as a principal international trading company. We manage, among other things,
procurement, quality control coordination, logistics coordination and trade execution for
agricultural and natural commodities. Terraviis is not a brokerage platform, financial institution
or payment service provider.

Nothing on this website constitutes legal, financial, investment or tax advice. All commercial
transactions, including purchases and sales of goods, are subject to separate written contracts
negotiated and executed between the relevant parties.

2.3 Intellectual Property Rights

The content and materials available on this website, including but not limited to text, graphics,
logos, icons, images, videos, layouts and design, are owned by or licensed to Terraviis and are
protected by copyright, trademark and other intellectual property laws.

You must not, without our prior written consent:

• Copy, reproduce, modify, adapt or create derivative works from any part of the website or its content;
• Distribute, transmit, publish, display or otherwise exploit any content for commercial purposes;
• Use any Terraviis trademark, logo or brand element in a way that may cause confusion or imply endorsement where none exists.

2.4 Website Availability and Content

We endeavour to ensure that the information on this website is accurate and up to date, but we do
not guarantee the completeness, accuracy or availability of the website or its content. We may
modify, update, suspend or discontinue any part of the website at any time without prior notice.

2.5 Disclaimer of Warranties

This website and its content are provided on an “as is” and “as available” basis. To the fullest
extent permitted by applicable law, Terraviis disclaims all warranties of any kind, whether
express, implied or statutory, including but not limited to any implied warranties of
merchantability, fitness for a particular purpose, non-infringement, accuracy and availability.

2.6 Limitation of Liability

To the fullest extent permitted by applicable law, Terraviis, its directors, officers, employees,
agents and affiliates shall not be liable for any indirect, incidental, consequential, special,
punitive or exemplary damages, including without limitation loss of profit, loss of revenue, loss
of data, business interruption or loss of opportunity, arising out of or in connection with your
use of, or inability to use, this website or its content, even if we have been advised of the
possibility of such damages.

Nothing in these Terms of Use shall exclude or limit liability where such exclusion or limitation
is not permitted under applicable law.

2.7 User Obligations

You agree that you will not:

• Use the website for any unlawful, fraudulent or malicious purpose;
• Attempt to gain unauthorised access to any part of the website, server or connected systems;
• Interfere with or disrupt the operation of the website or the servers or networks used to make the website available;
• Introduce viruses, malware or any other harmful code;
• Use automated means (including bots, crawlers, scrapers or similar tools) to access or extract data from the website, except where explicitly permitted by us.

2.8 External Links

This website may contain links to third-party websites or resources. These links are provided for
convenience only and do not signify endorsement or responsibility for the content, products,
services or security practices of such third parties. You access any third-party websites at your
own risk.

2.9 Governing Law and Jurisdiction

These Terms of Use, your use of this website and any dispute or claim arising out of or in
connection with them (including non-contractual disputes or claims) shall be governed by and
construed in accordance with the laws of the United Arab Emirates.

The courts of Dubai, United Arab Emirates, shall have exclusive jurisdiction to settle any dispute
or claim arising out of or in connection with these Terms of Use or your use of the website,
including any non-contractual disputes or claims.

3. Compliance & Ethics Policy

3.1 Commitment to Compliance

Terraviis conducts its business in accordance with applicable international, regional and local
laws and regulations, including but not limited to:

• European Union trade and export regulations;
• UK sanctions and trade controls;
• United States sanctions programs administered by OFAC (to the extent applicable);
• United Arab Emirates laws and regulations related to trade, customs and financial crime;
• Anti-money laundering and counter-terrorist financing (AML/CFT) obligations;
• Anti-corruption laws, including the UK Bribery Act and, where applicable, the US FCPA.

3.2 Sanctions Screening and Due Diligence

Terraviis may conduct sanctions screening and due diligence on counterparties, vessels, transactions
and relevant individuals using publicly available information and licensed databases. This may
include screening against sanctions lists issued by the European Union, United Nations, United
Kingdom, United States and other relevant authorities.

Terraviis reserves the right to decline or terminate any relationship or transaction where
sanctions, compliance concerns or unacceptable levels of risk are identified.

3.3 Anti-Corruption and Ethical Conduct

Terraviis has zero tolerance for bribery, corruption, facilitation payments, kickbacks, fraud or
any other unethical conduct. Employees, officers, agents, partners and representatives are required
to conduct business honestly, transparently and in compliance with all applicable anti-corruption
and ethical standards.

Offering, giving, soliciting or accepting any improper advantage, whether financial or otherwise,
in order to influence a business decision is strictly prohibited.

3.4 Responsible Sourcing and Product Integrity

Terraviis strives to source products responsibly and to work with suppliers and partners who
respect applicable laws, quality standards and ethical principles. We aim to:

• Ensure that products are accurately represented in terms of origin, quality and specifications;
• Encourage compliance with relevant quality, safety and certification standards;
• Promote fair dealing and respect for local communities and producers;
• Minimise environmental impact where reasonably possible in the context of our operations.

3.5 Reporting Concerns

If you become aware of or suspect any behaviour that may constitute a breach of this Compliance
& Ethics Policy, applicable laws or ethical standards, you are encouraged to report it to
Terraviis. Reports can be directed to:

compliance@terraviis.com

Terraviis will take reasonable steps to review and, where appropriate, investigate reported
concerns. To the extent permitted by law, Terraviis will seek to protect the confidentiality of
individuals who report concerns in good faith.

4. Changes to This Policy

Terraviis may update or amend this Legal & Compliance Policy from time to time to reflect
changes in legal requirements, our practices or our services. The “Last updated” date at the top
of this page indicates when this Policy was last revised.

Any changes will become effective when the revised Policy is posted on this website. Your
continued use of the website following such changes will constitute your acceptance of the updated
Policy.

5. Contact Information

If you have any questions about this Policy or our practices, you can contact us at:

General inquiries:
info@terraviis.com
Privacy and data protection:
privacy@terraviis.com
Compliance and sanctions:
compliance@terraviis.com

Registered office:
Terraviis Ltd.
Buyukdere Avenue 193, 2nd Floor,
Sisli District, Istanbul, Türkiye