PRIVACY POLICY & COMMERCIAL DATA STATEMENT

1. Overview & Data Controller

Stallion Gulf Limited ("SGL", "we", "us"), incorporated under the Companies Act and headquartered at Laiboni Centre, 4th Floor, Lenana Road, Kilimani, Nairobi, Kenya, operates as the Data Controller under the Kenya Data Protection Act (KDPA). We are committed to safeguarding corporate identity, commercial contract submissions, and counterparty data collected via our website and physical trading desks.

2. Commercial & Operational Information We Process

• Corporate Identity & Contact Records: Entity name, KRA PIN, Certificate of Incorporation, designated procurement officer name, business email address, and physical telephone/WhatsApp line.
• Consignment & Offtake Parameters: Target petroleum product grades (e.g., AGO Diesel 50ppm, Bitumen 60/70, Jet A-1, HFO), volume metrics, discharge terminal, and destination transit corridors.
• Regulatory & Customs Submissions: Tax compliance certificates, transit bond numbers, and driver/vehicle manifest documentation necessary for cross-border corridor clearance.
• Telemetry & Access Data: Electronic Cargo Tracking System (ECTS) seal telemetry, IP address, and platform usage metrics to monitor dispatch security.

3. Lawful Basis & Commercial Purpose

We process commercial counterparty data strictly under the legitimate requirements of executing wholesale petroleum sales contracts, issuing official pro-forma commercial invoices, verifying KEBS KS 130 laboratory testing compliance, and executing border clearance declarations with the Kenya Revenue Authority (KRA) and regional customs authorities.

4. Data Retention, Storage & Security Controls

All counterparty dossiers, trade documents, and invoice records are maintained in encrypted enterprise systems. Stallion Gulf Limited does not sell, license, or monetize commercial contact information. Records are disclosed exclusively to accredited regulatory bodies (EPRA, KEBS, KRA, COMESA customs authorities) where legally mandated for custody transfer or bonded clearance.