Privacy Policy

Dairy-Broker.ai is a B2B commodity brokerage platform operated by Cedaris LLC, a Nevada Limited Liability Company. The service is exclusively wholesale business-to-business and is not directed at consumers.

Cedaris LLC is the data controller for all personal data processed through the platform.

The Platform is intended exclusively for adults acting in a professional capacity on behalf of a registered business entity. The Platform is not directed at children under the age of 18, and we do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected personal data of a minor, we will delete such data without undue delay.

As Cedaris LLC is established outside the European Economic Area but processes personal data of individuals in the EEA, we have appointed an EU Representative pursuant to Art. 27 GDPR:

Rik Hanssen, Appointed EU Representative for Cedaris LLC (Art. 27 GDPR)

• Email: rik.hanssen@dairy-broker.ai
• For formal correspondence (e.g. supervisory-authority filings) a postal address is available on request via privacy@cedaris-ai.com.

EU residents may contact the EU Representative directly for any GDPR-related enquiries.

3.1 Application data

When you apply for access via /apply, we collect:

• First and last name, company name, company website, country
• WhatsApp number (primary contact channel)
• Business email address (optional fallback channel)
• Trading role (buyer / seller / both) and dairy products you typically transact in
• Estimated trading volume and any free-form context you provide
• Referral source
• Technical metadata (IP address and user agent of the submission, used solely for spam triage and abuse prevention)

3.2 Platform usage data

After approval and onboarding, we additionally collect:

• WhatsApp messages between you and our broker assistant, plus the technical metadata necessary for delivery and audit purposes
• In-app Cockpit chat messages
• Your bids, offers and trade interests (product, quantity, price, incoterm, origin, delivery period)
• Your trading profile preferences (set in the Cockpit)
• Price alert settings
• Engagement data with our daily market routine (such as whether you confirmed the morning briefing)
• Notification preferences
• Usage logs (page views, timestamps, session data) for service operation
• Job title (if provided during admin setup)

3.3 Trade execution data

When a trade is confirmed (Snap), we record:

• Product, origin, incoterm, quantity, executed price, delivery period
• Identities of both parties (shared with each other only at this point)
• Confirmation timestamps from both parties
• Technical metadata associated with the negotiation, which is deleted when the queue entry is closed

3.4 Behavioural and reliability data

The platform automatically derives a Reliability Score from your trading behaviour. The score reflects your general trading behaviour on the Platform. You can view how your individual score is composed in your Cockpit under Datenschutz & Rechte ("Privacy & Rights"). See Section 11.

3.5 Account authentication and access logs

To secure access to the Cockpit web interface, we use industry-standard authentication credentials (login codes, magic links and session cookies). Verification codes may be delivered via WhatsApp, email, or SMS depending on the channel you choose. Codes are stored in non-reversible (hashed) form and expire after a short time for security purposes. We retain minimal abuse-prevention metadata (such as IP addresses and user-agent strings) associated with verification attempts.

3.6 Multi-seat / company admin data

If your company designates an admin who adds team members as additional seats on dairy-broker.ai, the admin enters the team member's name, WhatsApp number, business email and job title. We will then send the team member a WhatsApp onboarding message so they can review and consent to the platform terms before any further processing. The company admin is responsible for ensuring the team member is informed in advance. See Section 2 of our Terms of Service.

3.7 Counterparty preferences (block lists)

You may indicate counterparties (by company name, brand, website or country) with whom you do not wish to be matched. We store this list against your account and use it to filter match proposals. Block-list entries reference other customers indirectly via internal IDs; the names of blocked competitors are visible only to you and to platform administrators.

3.8 Partner preferences and per-counterparty notes

In addition to blocking, you may mark counterparties as 'preferred' or 'avoid' and add private notes. These preferences influence match prioritisation. The notes are visible only to you and to platform administrators; they are NOT shown to the counterparty being marked. A counterparty marked 'avoid' is not notified of the marking, but you can request, through your access rights, whether other members have flagged you in this way.

3.9 Pending briefs and message-pipeline metadata

When you communicate with our broker assistant across multiple messages, we may temporarily aggregate partial information (e.g. product mentioned in message 1, quantity in message 2) into a 'pending brief' that helps Bo understand your intent. Pending briefs are deleted automatically after 7 days if not converted into a position, or earlier on your request.

5.1 Message understanding and trade-data extraction

We use the Anthropic Claude AI service (United States) to understand the messages you send to our broker assistant and to extract structured trade data such as product, quantity, price, incoterm, origin and delivery period. All AI processing is governed by Standard Contractual Clauses and the Anthropic Data Processing Addendum. We do not use your data to train AI models.

5.2 Match evaluation

A combination of rule-based and AI-assisted logic evaluates potential trade matches between counterparties. Matches are subject to meaningful human review before any outbound communication takes place (see Section 6 for important detail on how automation is involved in this workflow).

5.3 Negotiation assistance

Once a negotiation between two parties is initiated, AI assistance helps to draft the broker messages sent to each side. Outbound messages are subject to meaningful human review before they are sent. Your identity is never revealed to the counterparty during this stage.

5.4 Hard Limits extraction

During active negotiations, the AI may infer signals about your price and quantity limits from what you write (e.g. "I can't go below 2,800"). These inferred limits are used to improve matching accuracy for your positions. Hard-limits data is deleted when the underlying queue entry is closed, and at any time on your request.

5.5 Identity reveal at firm-confirm

Within the Platform anonymity model (see Section 8), counterparty identities remain private during matching and negotiation. Once BOTH sides confirm a trade as firm and the Snap takes place, an automated identity-reveal email is sent to both parties containing the name, company, email address and phone number of the other counterparty. This is necessary to enable trade execution under Art. 6(1)(b) GDPR (contract performance). You acknowledge this disclosure each time you upgrade a position to firm status.

5.6 Hidden walk-away signals

We may store internal preference signals derived from your negotiation behaviour to improve match quality. These signals are stored under strict access control, used solely for internal matching purposes, and are never disclosed to counterparties. You may view your stored signals in your Cockpit under Datenschutz & Rechte ("Privacy & Rights"). See Section 11.

5.7 AI usage tracking

We keep technical operational logs of AI service usage for cost control, audit and abuse-prevention purposes. These logs do not contain message content, only operational metadata.

5.8 Learning loop

We use de-identified historical platform interactions to improve our matching service over time. Identifying information is removed from these datasets within 24 months.

The Reliability Score is calculated automatically from your trading activity on the Platform (see Section 3.4). It influences match prioritisation: when the Platform proposes matches, more reliable traders are weighted ahead of less reliable ones for otherwise comparable matches. This prioritisation step is automated.

Meaningful human review is provided as part of the matching workflow before any match is communicated to counterparties. The Reliability Score does not, on its own, reject your bids or offers and does not determine whether you can access the platform.

Because the score-based prioritisation has automated effects within the meaning of Art. 22 GDPR, you have the following safeguards:

• Right to an explanation of how your score was calculated. View in Cockpit at /account/privacy or email privacy@cedaris-ai.com
• Right to object (Art. 21 GDPR). Exercise via Cockpit at /account/privacy(button "Profiling widersprechen") or email; on objection your matches will be ranked without considering your reliability score. You acknowledge that, because score-based prioritisation is part of the platform's core matching mechanism, this may result in lower match priority, longer matching times, or fewer match proposals than for members who do not object
• Right to contest the score if you believe it was calculated on incorrect data
• Human review of any contested decision

The platform communicates with you primarily via WhatsApp through our broker assistant Bo, using the Meta WhatsApp Business Cloud API directly (no third-party messaging provider is interposed).

During onboarding you are shown an explicit opt-in step for our daily market routine. The routine consists of a small number of WhatsApp touchpoints on weekdays (typically a morning briefing, optional mid-day updates, and a close-of-day summary), together with an email reminder if you have not responded to the morning briefing. Exact times and frequency may vary.

Your consent and the timestamp are recorded in our database. You can pause individual days via the WhatsApp quick-reply buttons, mute individual channels in your Cockpit under Datenschutz & Rechte ( /account/privacy), or revoke the daily-routine subscription entirely there.

Trade-related messages (enrichment requests, match notifications, negotiation messages, Terms Sheet confirmations) are sent as part of the service and do not require a separate subscription. They can still be paused if you suspend or close your account.

WhatsApp messages are transmitted via Meta's WhatsApp Business Cloud API. Meta processes message metadata according to their own privacy policy. We retain the content of messages on our own servers for 24 months unless deletion is requested earlier.

Your identity (name, company, phone, email) is never disclosed to counterparties without your explicit per-trade confirmation at the Snap stage. During the matching and negotiation process, the broker discusses your prices, quantities, delivery terms and product specifications with potential counterparties anonymously.

You agree to treat any market information you receive from the platform (including indicative prices and availability from other traders) as confidential, and not to use it outside the platform.

Cedaris LLC is based in the United States. We use the following third-party services to operate the platform. Some of these services may involve transferring your data outside the EEA:

We also rely on Trading Economics (USA) as a public market-data source for the daily routine. No personal data is sent to Trading Economics; we only retrieve publicly available commodity quotes via automated requests.

All transfers are governed by Standard Contractual Clauses (SCCs) approved by the European Commission under Art. 46 GDPR. Cedaris does not rely on the EU-US Data Privacy Framework. The Supabase Transfer Impact Assessment, the SCC transfer note and the underlying DPAs are available on request.

• Active customer records: duration of the business relationship plus up to 7 years for trade-audit purposes (HGB §257 / AO §147)
• Rejected applications: deleted within 90 days
• WhatsApp messages: stored for up to 24 months on our servers; Meta's own retention rules apply separately to message metadata on their infrastructure
• Reliability Score history: duration of relationship; anonymised score snapshots kept for up to 3 years for audit purposes
• Admin audit log: up to 3 years
• AI training signals (learning loop): de-identified after up to 24 months
• Hard Limits data and underlying message snippets: deleted when the associated queue entry is closed or on your request
• Authentication logs (login codes, IPs, user agents) including SMS verification metadata at Twilio: purged within 24 hours after expiry on our side; vendor-side retention per Twilio standard policy
• Trades: pseudonymised on erasure request but retained for up to 7 years to satisfy commercial book-keeping obligations under HGB §257 and AO §147

Under the GDPR (and equivalent laws in other jurisdictions) you have the following rights. Formal requests must be submitted to privacy@cedaris-ai.com or to our EU Representative (see Section 2). For any request you wish to formally enforce within statutory deadlines, please use the Cockpit Privacy Page or the email channel listed below.

We respond to rights requests within the timeframe required by applicable law (typically one month under Art. 12(3) GDPR, extendable by two further months for complex requests). If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority. As Cedaris LLC has appointed an EU Representative based in the Netherlands, the Dutch Autoriteit Persoonsgegevens (AP) is the lead supervisory authority for EEA-related complaints; you may also contact your national DPA directly.

The platform uses strictly necessary cookies for session management and authentication only. We do not currently use analytics, advertising or tracking cookies. Detailed cookie information is available on request via privacy@cedaris-ai.com.

If we introduce optional cookies in the future, we will update this policy and request your consent through a granular cookie banner before any non-essential cookie is set.

Non-sensitive assets such as your uploaded company logo may be hosted on publicly accessible URLs to allow display within the platform. Logos are only uploaded by your explicit action.

Data Protection Contact

Cedaris LLC · 732 S 6th St Ste N, Las Vegas, NV 89101, USA · privacy@cedaris-ai.com

EU Representative

Rik Hanssen · rik.hanssen@dairy-broker.ai. For formal postal correspondence please request the EU representative's service address via privacy@cedaris-ai.com.

Suspected data incident: If you have reason to believe that your personal data has been compromised, accessed without authorisation, or otherwise unlawfully processed in the context of the Platform, please contact us immediately at privacy@cedaris-ai.com with the subject line "INCIDENT REPORT". We will acknowledge receipt within 24 hours and assess the situation under our internal incident response procedure.

We will notify Cockpit users of any material change to this policy in advance, and we keep a versioned change-log on file. The current version is 2.8 (11 May 2026); previous versions (2.0, 2.1, 2.2, 2.3 of April 2026, 2.4 of 30 April 2026, 2.5 of 5 May 2026, 2.6 and 2.7 of 11 May 2026) are archived for reference.