Privacy Policy

Last Updated: 28 November 2025

Effective Date: 28 November 2025

1. Introduction

INTERTRADING HOLDING LIMITED ("we", "us", "our", or "Company") is committed to protecting your privacy and ensuring you have a positive experience on our website and platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website [www.scrapbull.com], use our mobile application, or engage with our services (collectively, the "Services").

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our Services. We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last Updated" date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting to the Services, and you waive the right to receive specific notice of each such change or modification.

2. Controller and Data Protection Officer

Data Controller

INTERTRADING HOLDING LIMITED
4 Crown Pl, London EC2A 4BT United Kingdom

Email: privacy@scrapbull.com

UK Data Protection Officer (DPO)

Name/Title: Mr O Bondarev
Email: dpo@scrapbull.com
Address: 4 Crown Pl, London EC2A 4BT, United Kingdom

3. Information We Collect

We collect information in the following ways:

3.1 Information You Provide Directly

Account Registration:

Name, email address, phone number
Business name and registration details (for business accounts)
Business address and billing address
Payment information (processed through secure third-party payment processors)
Company VAT number or tax identification
Bank account details (for sellers and payment settlements)

Marketplace Transactions:

Details of scrap materials for sale or purchase
Quantity, weight, grade, and specification of materials
Pricing information and quotations
RFQ (Request for Quote) and reverse auction data
Communications regarding negotiations and transactions
Shipping and logistics information
Invoices and payment records

User Communications:

Messages sent through our platform
Support tickets and customer service inquiries
Feedback, reviews, and ratings
Testimonials and case studies (if you consent)

Profile Information:

Company logo and branding materials
Business description and history
Certifications and compliance documentation
Industry credentials and qualifications
Photos and videos of materials (if applicable)

Academy and Educational Content:

Course enrollment and completion data
Certificates earned
Learning progress and quiz results
Interaction with educational materials

3.2 Information Collected Automatically

Technical Information:

IP address and device identifier
Browser type and version
Operating system
Pages visited and time spent
Referring/exit pages
Cookies and web beacons
Server logs
Click-stream data

Location Data:

Approximate location (derived from IP address)
Precise location (only with your explicit consent)
Geographic preferences and settings

Behavioral Data:

Search queries and filters used
Materials viewed and watchlists
Platform interaction patterns
Feature usage statistics
Document uploads and downloads

Device Information:

Device type and specifications
Mobile app version
Crash data and diagnostics
Hardware identifiers

3.3 Information from Third Parties

Payment Processors:

Transaction verification data
Payment status and confirmation

Authentication Services:

User authentication data (if using third-party sign-in)
Identity verification information

Business Databases:

Company registration information (public records)
Credit and financial standing data (if applicable)
Industry and sector classification

Communication Services:

Email delivery service data
SMS delivery confirmations

Analytics Providers:

Website analytics and usage statistics

Compliance and Verification Services:

Background check data (where legally permitted and consented)
Sanctions list data
AML/KYC verification information

4. Legal Basis for Processing

Under the UK GDPR and EU GDPR, we only process your personal data where we have a lawful basis to do so. The legal bases we rely upon are:

4.1 Performance of Contract

We process your personal data to:

Create and manage your account
Execute buy/sell transactions on our platform
Process payments and settlements
Provide customer support
Fulfill RFQ and auction services
Generate and deliver invoices and documentation
Arrange shipping and logistics

Legal Basis: Article 6(1)(b) UK GDPR / GDPR

4.2 Legitimate Interests

We process your personal data for:

Fraud prevention and detection
Platform security and integrity
Improving our Services and user experience
Aggregated analytics and business intelligence
Marketing (where you have not objected)
Compliance with legal obligations
Enforcement of our Terms of Service
Protection of our legal rights and interests
Business continuity and disaster recovery
Anti-money laundering (AML) and know-your-customer (KYC) compliance

Legal Basis: Article 6(1)(f) UK GDPR / GDPR

Balancing Test: We have assessed that our legitimate interests do not override your fundamental rights and freedoms, particularly your right to data privacy.

4.3 Legal Obligation

We process your personal data to:

Comply with UK tax and accounting regulations
Fulfill AML and counter-terrorism financing obligations
Respond to legal process (court orders, subpoenas)
Fulfill regulatory reporting requirements
Comply with environmental and carbon reporting mandates
Comply with industry-specific regulations

Legal Basis: Article 6(1)(c) UK GDPR / GDPR

4.4 Consent

Where applicable, we process your personal data based on:

Explicit consent for marketing communications
Consent to use precise location data
Consent to use of cookies and tracking technologies
Consent to automated decision-making

Legal Basis: Article 6(1)(a) UK GDPR / GDPR

You may withdraw consent at any time by contacting us at privacy@scrapbull.com.

4.5 Special Category Data

If we process special category data (such as health data related to material safety, or ethnic/national origin for regulatory purposes), we rely on:

Explicit consent (Article 9(2)(a))
Processing necessary for compliance with employment law (Article 9(2)(b))
Processing necessary for substantial public interest reasons (Article 9(2)(e))
Processing necessary for legal claims (Article 9(2)(f))

5. How We Use Your Information

We use the information we collect for the following purposes:

5.1 Service Delivery

Facilitating buy/sell transactions
Processing RFQs and reverse auctions
Managing pricing calculators and quotations
Providing educational academy content
Delivering logistics and shipping services
Processing payments and settlements
Sending transactional emails and confirmations
Providing customer support

5.2 Platform Management

Verifying user identity and credentials
Preventing fraud, abuse, and unauthorized access
Detecting and preventing security incidents
Managing access controls and permissions
Enforcing our Terms of Service and policies
Troubleshooting technical issues
Maintaining platform stability and performance
Conducting backups and system administration

5.3 Business Development

Understanding market trends in scrap metal trading
Analyzing supply and demand patterns
Developing new features and services
Improving pricing calculator accuracy
Enhancing platform user experience
Conducting market research (anonymized/aggregated)

5.4 Legal and Compliance

Meeting regulatory and legal obligations
AML/KYC compliance and verification
Tax and accounting compliance
Environmental and carbon reporting
Responding to legal requests and investigations
Protecting our legal interests and rights

5.5 Marketing and Communication

Sending promotional materials (with your consent or legitimate interests basis)
Communicating platform updates and feature announcements
Conducting surveys and gathering feedback
Sending newsletters and industry insights
Notifying you of policy changes

5.6 Analytics and Insights

Analyzing platform usage and behavior
Creating aggregated and anonymized reports
Improving search and recommendation algorithms
Understanding conversion funnels
Measuring campaign effectiveness
Training AI models and machine learning systems (anonymized data only)

6. Data Sharing and Third Parties

6.1 Who We Share Data With

Service Providers:

Payment processors and financial institutions
Email and communication service providers
Cloud hosting and storage providers
Analytics and data analytics platforms
Customer relationship management (CRM) platforms
Identity verification and background check providers
Logistics and shipping providers
Legal and compliance advisors

Buyers and Sellers:

In marketplace transactions, we share relevant product information, seller/buyer contact details, and transaction history as necessary to complete transactions
Your public profile information is visible to other platform users
Communications between buyers and sellers are facilitated through our platform

Business Partners and Integrations:

Affiliate partners (where applicable)
API integration partners
Strategic business partners (with your consent where required)

Legal and Regulatory Authorities:

Law enforcement agencies (where legally required)
Tax authorities and HMRC
Financial regulatory bodies (FCA, Bank of England)
Environmental regulators
Anti-money laundering/counter-terrorism authorities
Court-ordered disclosures and legal process

Data Aggregators and Analytics Providers:

Anonymized and aggregated data for market research
De-identified data for business intelligence

Corporate Transactions:

In the event of merger, acquisition, bankruptcy, or sale of assets, your data may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your data.

6.2 Third-Party Links

Our Services may contain links to third-party websites. We are not responsible for the privacy practices of third-party sites. We encourage you to review their privacy policies before providing any personal data.

6.3 Data Processors

We have Data Processing Agreements (DPAs) in place with all data processors who access your personal data. These agreements ensure appropriate technical and organizational safeguards are implemented.

Processor	Purpose	Jurisdiction & Safeguards
Vercel Inc.	Cloud hosting, deployment, serverless functions, and static site hosting	USA - Transfers protected via Standard Contractual Clauses (SCCs) and Data Privacy Framework compliance. Vercel maintains high security certifications (SOC 2 Type II).
Stripe Payments Europe Ltd	Payment processing, transactions, payouts, subscription management, and fraud prevention	Ireland (EU) - EU-regulated entity under PSD2. Stripe maintains GDPR compliance via Data Processing Agreement. Transfers of non-EU data protected via SCCs and Data Privacy Framework.
Resend	Transactional email and marketing email delivery (notifications, confirmations, alerts)	USA (Primary) / EU (Ireland - eu-west-1) - Resend allows multi-region email sending. EU region (eu-west-1) available for GDPR compliance. All customer data retained in USA with SCCs for transfers.
Convex.dev	Real-time database, API functions, transaction processing, and backend logic execution	USA (Cloud-hosted) - Convex cloud deployment with global edge infrastructure. Data transfers protected via SCCs. Self-hosting option available for customers requiring EU residency.
Google Analytics	Website analytics, user behavior tracking, aggregate traffic patterns, and conversion measurement	USA - Google Analytics 4 with Data Processing Agreement. Configured with IP anonymization enabled. Data transfers protected via SCCs and Data Privacy Framework compliance.
PostHog	Product analytics, feature usage, funnel analysis, and user behavior insights (alternative to/alongside Google Analytics)	USA - PostHog provides Data Processing Agreement and GDPR compliance. EU cloud option available. Transfers protected via SCCs.

Data Transfer Mechanisms:

Standard Contractual Clauses (SCCs) - approved transfer mechanism under UK GDPR and GDPR
Data Privacy Framework (DPF) - US companies certified under EU-U.S. and UK Extension DPF
EU Adequacy Decisions - applicable for EU-based processors
Supplementary Technical Safeguards - encryption in transit and at rest for all transfers

7. International Data Transfers

7.1 Transfers Outside the UK/EU

Where we transfer your personal data outside the UK and European Economic Area (EEA), we ensure appropriate safeguards are in place:

Transfer Mechanisms:

Standard Contractual Clauses (SCCs) - approved transfer mechanism under UK GDPR and GDPR
Adequacy decisions - where UK/EU have determined the destination country has adequate privacy protections
Binding Corporate Rules (BCRs) - for transfers within our corporate group
Your explicit consent - in other circumstances

Recipient Countries:

[List countries where data is transferred to]

Safeguards:

Contractual safeguards in Data Processing Agreements
Technical encryption and security measures
Regular compliance audits and assessments

7.2 Transfers to the United States

If we transfer data to US-based processors, we use Standard Contractual Clauses and may supplement these with additional technical and organizational safeguards to address risks identified in the Schrems II ruling.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by law.

8.1 Retention Periods by Data Category

Data Category	Retention Period	Justification
Account Information	Duration of account + 3 years	Legal/tax obligations
Transaction Records	7 years	UK tax and accounting records requirements
Payment Data	3 years	Payment dispute resolution
Communications	3 years	Legal claims and compliance
Marketing Consent Records	3 years after last consent	PECR and marketing compliance
Support Tickets	3 years	Legal claims and customer service
Academy/Certificates	Duration of account + 1 year	Educational records
Location Data	1 year	Fraud prevention and analytics
Cookie Data	1 year (or session)	Technical and analytics purposes
Log Files	6-12 months	Security and system administration
Aggregated/Anonymized Data	Indefinite	No personal data after anonymization
IP Addresses	6 months	Technical troubleshooting and security
AML/KYC Records	7 years	Legal and regulatory obligations

8.2 Exception for Legal Claims

If personal data is subject to legal proceedings or investigations, we may retain it for the duration of such proceedings plus 3 additional years.

8.3 Data Deletion

Upon expiry of retention periods, we securely delete or anonymize your personal data. If you request deletion, we will comply with your request subject to legal retention obligations.

9. Your Privacy Rights

Under the UK GDPR and EU GDPR, you have the following rights regarding your personal data:

9.1 Right of Access (Subject Access Request)

You have the right to request and receive a copy of your personal data held by us, including:

The purpose of processing
Categories of data held
Recipients of your data
Retention periods

How to Exercise: Submit a written request to privacy@scrapbull.com with the subject line "Subject Access Request"

Timeline: 30 calendar days from receipt of a clear and complete request

Cost: Free (unless requests are manifestly unfounded, repetitive, or excessive)

9.2 Right to Rectification

You have the right to request that we correct inaccurate or incomplete personal data. You can also request we update or supplement information.

How to Exercise: Send a request to privacy@scrapbull.com with:

Specific data to be corrected
Corrected information
Supporting evidence (if applicable)

Timeline: 30 calendar days for consideration

9.3 Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal data in certain circumstances:

Data is no longer necessary for the purposes collected
You withdraw consent (where consent is the legal basis)
You object to processing and we have no overriding legitimate interest
Data was processed unlawfully
Legal or regulatory obligation requires deletion

Exceptions: We may not delete data if:

Necessary to fulfill a contract
Required by law or regulatory obligation
Necessary for legal claims or defense
Necessary for fraud prevention
Public interest reasons apply

How to Exercise: Submit a deletion request to privacy@scrapbull.com with "Erasure Request" in the subject line

9.4 Right to Restrict Processing

You may request we suspend processing of your personal data in specific circumstances:

You contest the accuracy of data
Processing is unlawful but you prefer restriction to deletion
Data is no longer necessary but you require it for legal claims
You have objected to processing pending verification of legitimate interest

How to Exercise: Contact privacy@scrapbull.com with "Restrict Processing Request"

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly-used, machine-readable format and have it transmitted to another organization. This applies where:

Processing is based on consent or contract
Processing is carried out by automated means

How to Exercise: Request data portability from privacy@scrapbull.com

Format: Data will be provided in CSV or JSON format

9.6 Right to Object

You have the right to object to processing of your personal data:

Marketing: Object to marketing communications at any time (one-click unsubscribe)
Legitimate Interests: Object to processing based on our legitimate interests
Direct Marketing: Object to direct marketing communications
Profiling: Object to automated decision-making and profiling with legal effects

How to Exercise: Contact privacy@scrapbull.com or use unsubscribe links in marketing communications

9.7 Right to Withdraw Consent

If processing is based on your consent, you may withdraw that consent at any time by:

Contacting privacy@scrapbull.com
Adjusting account settings
Using opt-out mechanisms in emails or our platform

Effect: Withdrawal does not affect the lawfulness of processing before withdrawal.

9.8 Right to Lodge a Complaint

Under the Data (Use and Access) Act 2025, you have the right to lodge a complaint directly with us:

Our Internal Complaint Mechanism:

Email: privacy@scrapbull.com with "Complaint" in subject line
Response Time: We will acknowledge and respond to complaints within 30 calendar days

Supervisory Authorities:

You also have the right to lodge a complaint with:

UK - Information Commissioner's Office (ICO):

Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Website: https://www.ico.org.uk
Phone: 0303 123 1113

EU/EEA - Relevant Data Protection Authority:

Each member state has its own DPA
Find yours: https://edpb.europa.eu/about-edpb/board/members_en

9.9 Right to Automated Decision-Making

Under the UK GDPR and EU GDPR, you have rights regarding automated decision-making and profiling that has legal or similarly significant effects on you.

Your Rights:

Right to meaningful human review
Right to contest automated decisions
Right to express your views and have them considered
Right to know the logic and significance of automated processing

Applicable Processing:

Automated account approval/rejection
Automated suspension or restricted access
Automated pricing or quotation decisions
Fraud detection flags

How to Exercise: Contact privacy@scrapbull.com to request human review of any automated decision

10. Cookies and Tracking Technologies

10.1 Cookies Policy

We use cookies and similar tracking technologies to:

Remember user preferences and login information
Measure website analytics
Deliver personalized content
Prevent fraud and maintain security
Optimize our Services

10.2 Types of Cookies

Essential/Functional Cookies (no consent required under 2025 DUAA):

Session management
Security and fraud detection
Site optimization and functionality
Analytics for service improvement

Preference Cookies:

Language and timezone preferences
Dark mode settings
Accessibility preferences

Marketing Cookies (opt-in consent required):

Advertising and retargeting
Social media integration
Campaign tracking
Behavior-based recommendations

Third-Party Cookies:

Analytics providers (Google Analytics)
Payment processors
Advertising networks
Social media platforms

10.3 Cookie Consent

Default Position (Updated 2025 DUAA): Functional cookies are enabled by default with clear information provided. Marketing cookies require opt-in consent.

Manage Cookies:

Use cookie banner on website
Adjust settings in account preferences
Browser privacy settings
Withdraw consent at any time

10.4 Do Not Track (DNT)

We honor Do Not Track signals where technically feasible. However, most browsers' DNT implementation is incomplete or non-standard.

11. Security Measures

We implement comprehensive technical and organizational security measures to protect your personal data:

11.1 Technical Safeguards

Encryption: TLS/SSL encryption for data in transit
Data Encryption: AES-256 encryption for sensitive data at rest
Access Controls: Role-based access control (RBAC)
Authentication: Multi-factor authentication (MFA) for sensitive accounts
Firewalls: Enterprise-grade firewalls and intrusion detection
Database Security: Database-level encryption and access logging
API Security: OAuth 2.0 and API key management
Backup: Regular encrypted backups with disaster recovery protocols
Monitoring: 24/7 security monitoring and incident response
Vulnerability Testing: Regular penetration testing and vulnerability scanning

11.2 Organizational Safeguards

Access Limitation: Data access restricted to authorized personnel only
Staff Training: Regular data protection and security training
Background Checks: Security clearance for privileged access staff
Data Protection Impact Assessments (DPIA): Conducted for high-risk processing
Incident Response Plan: Documented procedures for data breaches
Third-Party Audits: Annual security audits by independent parties
Data Minimization: We collect only necessary data
Data Protection by Design: Privacy considerations in all system design

11.3 Data Breach Response

In the event of a confirmed data breach that compromises personal data security:

For UK Data:

Notify affected individuals without undue delay (generally within 72 hours)
Notify the ICO within 72 hours (where required)
Provide breach details, potential impact, and remedial actions
Special notification for high-risk breaches

For EU Data:

Notify affected individuals without undue delay
Notify relevant DPA within 72 hours of becoming aware
Follow equivalent notification procedures

Breach Documentation:

Document nature, scope, and consequences
Record remedial actions taken
Maintain incident records for 3 years

11.4 Limitations

While we implement reasonable security measures, no internet-based service is 100% secure. We cannot guarantee absolute security against sophisticated attacks or insider threats.

12. Children's Privacy

12.1 Age Restrictions

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from children under 18. If we become aware that a child has provided us with personal data, we will delete such information without undue delay.

12.2 Parental Contact

If you are a parent or guardian and believe your child has provided personal data to us:

Contact us immediately at privacy@scrapbull.com
Provide child's email/account details
We will delete the account and associated data

12.3 Special Safeguards for Under-18s

Per Data (Use and Access) Act 2025, we specifically consider children's needs when designing our information society services:

Age-appropriate privacy controls
Clear, accessible privacy information
Limitations on marketing to minors
Restricted automated decision-making affecting minors

13. Automated Decision-Making and Profiling

13.1 Automated Decisions

We use automated decision-making in the following scenarios:

Account Approval/Restrictions:

Fraud detection and account suspension
Platform eligibility verification
Access level determination

Pricing and Quotations:

Automated pricing calculator decisions
Dynamic pricing based on material specifications
Market-based quotation generation

Auction Systems:

Automated bid processing
Automated reserve price validation

13.2 Profiling

We engage in limited profiling for:

Personalized content recommendations
Search result optimization
Relevant opportunity matching (buyer/seller)

13.3 Your Rights

You have the right to:

Request human review of automated decisions affecting you significantly
Contest an automated decision
Obtain an explanation of the logic, significance, and consequences
Request meaningful human involvement in the decision process

How to Request Review:

Email privacy@scrapbull.com with "Request for Human Review"
Include the specific decision you wish to appeal
Provide supporting information or context

Timeline: We will review and respond within 30 calendar days

13.4 Exceptions

Automated decision-making without human review is permitted where:

Necessary for contract performance (with appropriate safeguards)
Authorized by law
You have given explicit consent

14. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Right to Know: What personal information we collect and how it's used
Right to Delete: Request deletion of personal information (with exceptions)
Right to Opt-Out: Opt-out of the sale or sharing of personal information
Right to Correct: Correct inaccurate personal information
Right to Limit: Limit our use of sensitive personal information
Right to Appeal: Appeal our decision regarding your privacy rights

How to Exercise CCPA Rights: Contact privacy@scrapbull.com with "CCPA Request" in subject line

Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

15. Other Jurisdictions

Depending on your location and applicable laws, you may have additional privacy rights including:

Canadian PIPEDA: Residents of Canada
Australian Privacy Act: Australian residents
Singapore PDPA: Singapore residents
Other jurisdiction-specific regulations

Contact privacy@scrapbull.com for information about your specific jurisdiction.

16. Legitimate Interests Assessment

We have conducted assessments to ensure our legitimate interests do not override your fundamental rights. Below is a summary:

Processing Activity	Legitimate Interest	Rights Assessment	Conclusion
Fraud Prevention	Protecting platform integrity and preventing financial loss	Interest in security outweighs minor privacy intrusion	Permitted with safeguards
Platform Analytics	Improving user experience and service optimization	Non-intrusive, anonymized, proportionate	Permitted
Marketing	Business development and customer engagement	Outweighed by recipient privacy rights if objected	Permitted with opt-out
Legal Claims	Protecting our legal interests	Necessary for dispute resolution	Permitted

17. Contact Us

17.1 General Privacy Inquiries

Email: privacy@scrapbull.com

Mailing Address:
INTERTRADING HOLDING LIMITED
4 Crown Pl, London EC2A 4BT
United Kingdom

Phone: [Phone Number]

Response Time: We respond to privacy inquiries within 5-10 business days

17.2 Data Protection Officer

Email: dpo@scrapbull.com

Mailing Address:
INTERTRADING HOLDING LIMITED - DPO
4 Crown Pl, London EC2A 4BT
United Kingdom

18. Policy Changes and Updates

18.1 Modifications

We may update this Privacy Policy periodically to reflect:

Changes in our data processing practices
New technology or security measures
Legal or regulatory changes
User feedback and requests

18.2 Notification

Minor Changes: Updated with new "Last Updated" date
Significant Changes: Notification via email, banner notice, or other prominent method
Material Changes: Require renewed consent if required by law

18.3 Previous Versions

Previous versions of this Privacy Policy are available upon request from privacy@scrapbull.com

19. Definitions

Personal Data: Any information relating to an identified or identifiable natural person

Processing: Any operation performed on personal data (collection, storage, use, sharing, deletion)

Data Controller: The organization determining the purposes and means of processing (INTERTRADING HOLDING LIMITED)

Data Processor: Organization processing data on behalf of the controller

Data Subject: The individual whose personal data is being processed

Supervisory Authority: Independent public authority (e.g., ICO in UK, national DPA in EU)

Special Category Data: Personal data revealing racial/ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, health data, sex life data

Legitimate Interests: Balanced interests of the organization that don't override individual privacy rights

Lawful Basis: Legal justification for processing personal data under GDPR

20. Acknowledgments

This Privacy Policy complies with:

✓ UK GDPR (retained EU GDPR post-Brexit)
✓ Data Protection Act 2018
✓ Data (Use and Access) Act 2025
✓ PECR (Privacy and Electronic Communications Regulations)
✓ ICO Guidance and Recommendations
✓ EU GDPR (Article 13/14 requirements)
✓ International data transfer safeguards
✓ Emerging regulations and best practices

Version: 1.0
Effective Date: 28 November 2025
Last Review Date: 28 November 2025
Next Review Date: 28 November 2026

This Privacy Policy is provided in English. For translations into other languages, please contact privacy@scrapbull.com. In the event of conflicting interpretations, the English version prevails.