describes in detail our policy and practices regarding our collection, use, and disclosure of your personal data.
We understand that providing information online involves a great deal of trust on your part. We take this trust very seriously and make it a high priority to ensure the security and confidentiality of the personal data you provide us when you visit our Website or use our services.
Collection of your personal data
How we use your personal data
With whom we share your personal data
How long we keep your personal data
Cookies and other web technologies
How we protect your personal data
Information concerning minors
How you can contact us
2. Collection of your personal data
Personal data means any information about an individual from which that person can be identified, electronic addresses, date of birth, password, and payment information. It does not include data where the identity has been removed or otherwise anonymized (anonymous data).
In the course of our business, we collect and process personal data in different ways. We may collect personal data you give us directly but we also collect data by logging how you interact with our services. For example by using cookies on our Websites. We may also receive information from third parties who partner with us, as more fully described below.
The personal data we collect about you may include, but is not limited to: your name, email address, postal address, phone number, billing information, survey responses, booking details and other information you may provide about yourself to our Websites, and your IP address and web browser software.
You can choose not to provide us with your personal data. However, in general, you need to provide us with certain information about you in order to take advantage of many features of the Websites. For example, only registered members are able to post travel reviews, participate in discussion forums, email cactus content to themselves and others, access members-only newsletters and travel planning content, and enter surveys, contests, or sweepstakes. In addition, some information is also required in order for you to ask us a question or initiate other transactions on our Websites. We also collect personal data for security purposes.
Information that you provide us: as described below, we may receive and store any information you enter on our Website or give us in any other way.
Information About Others: You will have the opportunity to provide contact and travel-related information for other people through our Websites. If you use the website on behalf of someone else, you will need to submit that individual's personal data. You must obtain the consent of other individuals prior to providing us with their personal data. If another Cactus member grants you access to their data through a shared password, you should treat that information appropriately.
Automatic collection of information: We automatically collect some information from your computer or mobile device when you visit Cactus. For example, we collect your session data, including your IP address, the navigation software used, and the reference site. We may also collect information about your online activity, such as reviewed content, pages visited, and searches. We automatically collect this type of information to try to better understand your interests and preferences and to better personalize your experience. We also collect personal data in order to help protect our site and other users from misuse.
Location information and other information from devices: When you use our Websites on a device, whether through mobile web or application, we will collect and use information about you in generally similar ways and for similar purposes as when you use the Cactus Website. In addition, we may collect certain information about your location if you have instructed your Device to send such information to the application via the privacy settings on that device, or if you have uploaded photos tagged with location information. For example, we may use your location to inform you of contacts, trade partners, warehouses near you. You can change the privacy settings of your device at any time in order to turn off the functionality to share location information with the application and/or the functionality to tag your photos with location information. Please note that turning off location sharing may affect certain features of our application or mobile experience. If you have any queries about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.
3. How we use your personal data
A. Specific purposes.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
With your consent.
Where we need to comply with a legal or regulatory obligation.
We want to make it easy for you to take advantage of trade opportunities on our Websites. One way we do this is by sending you email messages that contain information about your trade interest. For example, you search for specific product type on our Websites, we may send you an email about such products or other alternatives. We believe these emails will provide you with useful information about credible offers available through our sites.
You will receive trade advice messages from us if you have given your consent if you have requested or if you have not opted out of receiving trade advice.
Each time you receive an email of this type, you will be able to tell us if you no longer wish to receive them. You will be able to unsubscribe from each of those marketing communications at any time by clicking on the unsubscribe link that you will find at the bottom of each communication you receive from Cactus.
Please note that we may continue to send you service communications, such as service and administrative messages related to your trade department. It is not possible to unsubscribe from these service communications.
5. With whom we share your personal data
Cactus-global may share your information with other parties, including other group companies and the types of third parties listed below. For instance, if we sell or divest our business or any part of it, and your personal data relates to such sold or divested part of our business, or if we merge with another business, we will share your personal data with the new owner of the business or our merger partner, respectively.
Separately, if we are legally obliged to do so, we will share personal data to protect our customers, the site, as well as our company and our rights and property.
If you choose to create a profile on the cactus website, certain information in your profile will be publicly viewable and identifiable by clicking your screen name. You will have the ability to view your profile as members of the public will see it. Additionally, if you choose to participate in our member-to-member communications programs (e.g. Business to Business networks and private messaging), other Cactus-Global members may contact you by using Cactus-Global as an intermediary; however, Cactus-Global will not share your email address with any other members nor display it any public manner. All Cactus-Global members have the option to turn off the member-to-member communication features at any time.
Third-party service providers who provide services or functions on our behalf, including business analytics, payment processing, customer service, marketing, public relations, distribution of surveys or sweepstakes programs, and fraud prevention. We may also authorize third-party service providers to collect information on our behalf, including, for example, as necessary to operate features of our Website or to facilitate the delivery of online advertising tailored to your interests. Third-party service providers have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.
Business partners with whom we may offer products or services in conjunction. You can tell when a third party is involved in a product or service you have requested because their name will appear either with ours or separately. If you choose to access these optional services, we may share information about you, including your personal data, with those partners. Please note that we do not control the privacy practices of these third-party business partners.
Affiliated Websites. If you were referred to Cactus-Global from another website, we may share your registration information, such as your name, email address, mailing address, telephone number, and travel preferences with that referring website. We encourage you to review the privacy policies of any website that referred you to Cactus-Global.
We also may share your information if we believe, in our sole discretion, that such disclosure is necessary:
to comply with legitimate and enforceable subpoenas, court orders, or another legal process; to establish or exercise our legal rights; to defend against legal claims or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us;
in connection with a corporate transaction, such as a divestiture, merger, consolidation or asset sale or in the unlikely event of bankruptcy.
Other than as set out above, you will be notified when personal data about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.
We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our Website receives or the most popular hotels and holiday destinations. This information does not contain any personal data and is used to develop content and services we hope you will find of interest.
6. How long we keep your personal data
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or statutory reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.
We may retain certain information subsequent to the closing of your account, for example, if it is necessary to fulfill our legal obligations or to exercise, to maintain security, to prevent fraud and abuse, and to defend or enforce our rights. If you choose to close your account, your personal data will generally stop being visible to others on our Website within 30 days.
7. Cookies and other web technologies
We collect information via cookies and other similar technologies (such as web beacons). Cookies are small text files that are automatically placed on your computer or mobile device when you visit a website. They are stored by your internet browser. Cookies contain basic information about your use of the internet. Your browser sends these cookies back to our Website every time you visit it, so it can recognize your computer or mobile device and personalize and enhance your browsing experience.
8. Your rights
You can check, supplement, and update the information you have provided by accessing your "Settings" section of your account. You may also terminate your Cactus-Global association by contacting us using the methods provided below.
If you decide to divorce your relationship with us at Cactus-Global, we will remove your personal data. Remember that once your account is closed, you will no longer be able to log in, access your personal information. If you save such payment details in your account on Cactus-Global, you will be able to add, delete, or modify that information at any time during which your account remains open in Account Settings.
You can change your marketing preferences at any time during which your account remains open through the Subscription page in your member account.
In accordance with applicable law, you may have the right of access, the right of rectification, the right to erasure, the right to restrict processing, the right to data portability and the right to object. Please find below more details and information on how and when you can exercise your rights. We will respond to your request within one month but have the right to extend this period with two months.
In accordance with applicable law, you may have the following rights with regard to your personal data:
The right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
The right to request to correct your personal data if it is inaccurate. You may also supplement any incomplete personal data we have, taking into account the purposes of the processing.
The right to request deletion of your personal data if:
your personal data is no longer necessary for the purposes for which we collected or processed them; or
you withdraw your consent if the processing of your personal data is based on consent and no other legal ground exists; or
you object to the processing of your personal data and we do not have an overriding legitimate ground for processing; or
your personal data is unlawfully processed; or
your personal data has to be deleted for compliance with a legal obligation.
The right to object to the processing of your personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise, or defend a legal claim.
The right to restrict the processing of personal data, if:
the accuracy of your personal data is contested by you, for the period in which we have to verify the accuracy of the personal data; or
the processing is unlawful and you oppose the deletion of your personal data and request restriction; or
we no longer need your personal data for the purposes of the processing, but your personal data is required by you for legal claims; or
you have objected to the processing, for the period in which we have to verify overriding legitimate grounds.
The right to data portability. You may request us to receive the personal data that concern you. You may also request us to send this personal data to a third party, where feasible. You only have this right if it regards personal data you have provided us, the processing is based on consent or necessary for the performance of a contract between you and us, and the processing is done by automated means.
You can exercise several of your rights through the personal information section of your account. To exercise your other rights you can file a request by email to .
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In an effort to speed up our response, we may also contact you to ask you for further information in relation to your request.
9. How we protect your personal data
We want you to feel confident about using Cactus-Global Inc., and we are committed to protecting the personal data we collect. While no website can guarantee perfect security, we have implemented and maintain appropriate physical, administrative, technical, and organizational measures to protect the personal data you provide us against unauthorized or unlawful access, use of disclosure and against accidental loss, damage, alteration or destruction.
For example, only authorized employees are permitted to access personal data, and they may do so for permitted business functions. In addition, we use encryption when transmitting your personal data between your system and ours, and between our system and those of the parties with whom we share sensitive information, and we employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your personal data.
10. Information concerning minors
We do not knowingly collect data relating to minors. If a person whom we know is under 13 years of age sends us personal data, we will delete or destroy this information as soon as reasonably possible.
11. External links
12. International transfers
Whenever we store or transfer your personal data outside the European Economic Area, we will do so in accordance with applicable law and we will ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. Transfers of personal data are made:
to a country recognized by the European Commission as providing an adequate level of protection; or
to a country that does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
14. How you can contact us
If you have any questions or complaints about the processing of your personal data by us, please contact us at . You may also have the right to lodge a complaint to the supervisory authority about the way we process your personal data. We would, however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.
Our full details are:
Cactus-Global role in this respect is limited solely to being a contact person for questions on data protection from EU citizens and data protection supervisory authorities. For the avoidance of doubt, Cactus-Global Commodities Group. cannot field other communications or legal processes on behalf of the Cactus-Global commodities group.
Call Recording and Monitoring
©2020 Cactus-Global Commodities Group. All rights reserved.
The disclaimer describes the Terms and Conditions governing the use of Cactus' Website.
Contents of this website including text, graphics, images, photographs, and any other information here made available, are property of Cactus and Cactus alone, and therefore are protected by copyright laws and the intellectual property laws.
This website cannot be reproduced or copied in whole or part in any form or process, whether electronic, photographic or mechanic, without express written permission from Cactus.
The site user agrees not to use the website content in any way that could damage the good image of Cactus. By using the Cactus site, the user explicitly agrees not to engage in actions that could constitute defamation, fraud, violence, and other illegal activities.
The user is only allowed to use the site's content for personal endeavors. Thus the use of our content for commercial purposes by way of distribution, modification, and alteration is strictly prohibited.
16:The use of Cactus Content
All information contained on this site is offered for information purposes only hence it is neither to be construed as advice nor does it establish any contractual binding.
Also, Cactus makes no representations or warranties as to the completeness or accuracy of the website information. In no event will Cactus be responsible for damages of any nature whatsoever resulting from the use or reliance of the information in third-party websites accessed through hypertext links from this website.
Cactus-Global reminds its Global partners and associates that they should follow specific procedures when raising claims regarding the corporate activity of other partners and associates. These procedures provide guidance on how and when to file a claim, depending on the circumstances. Non-compliance with the procedures may prevent us from duly instructing a claim, thus potentially delaying the investigation of the claim and a decision being reached. In an extreme case, it could lead to the claim being time-barred.
Claims should always be submitted in writing and should be filed as close as possible to the event giving rise to the claim, ideally within 2 weeks of the event.
All complaints duly received will be investigated by the corporation members, which reserves the right to require the complainant to provide further information upon request. A failure to do so may lead to the complaint being rejected.
The complainant will be advised of the outcome of the investigation, and the consequent decision, as soon as practicable.
Complaints should be sent in writing to
Any document issued by or on behalf of the Cactus-Global Commodities Group. must be signed and sealed with the company seal to make it legal.
Professional Profile Policy
Pros on Cactus are expected to treat others with respect, be responsive to current and prospective clients, and conduct business in accordance with applicable laws and regulations.
By creating a Professional Profile (including by claiming an unclaimed Professional Profile), you acknowledge and agree to each of the following:
Authorized Person. You are a principal or employee authorized to create a Professional Profile for the business. You are responsible for any and all activity on your account, including as a result of you choosing to share your account credentials, not keeping your account credentials confidential, or not keeping your account credentials updated.
i. You will provide accurate, truthful, and complete information regarding your business, and keep all business information up to date;
ii. You will create only one Professional Profile for your business;
iii. You will pick a business category that accurately describes your products and services;
iv. Professional Profiles created for business categories not supported by Cactus will be removed without notice.
License Information. If your profession or business requires licensure, you agree to provide all licensing information necessary to list or advertise your business online on Cactus. In addition, you represent that any licensing information you provide is accurate and up to date.
Projects. You agree that any Projects posted on your Professional Profile represent your own work, and you will not claim credit for the work of others.
Affiliations. Cactus may enable you to display your affiliation with certain trade associations relevant to your business. You agree that you will only choose those organizations with which you are actually affiliated for display on your Professional Profile, and promptly remove any affiliations if no longer current. You agree that in certain circumstances Cactus may display your affiliation with certain trade association partners on your Professional Profile on your behalf, e.g. upon verification of membership by the trade association.
No Guaranteed placement. The appearance of your Professional Profile in Cactus search results is not guaranteed and is dependent on a number of factors, including without limitation the popularity and volume of photos, reviews, and user interactions. Cactus does not guarantee specific placements on Cactus except as part of paid marketing packages. More information on the main parameters for determining the placement or ranking of Professional Profiles on the Cactus Platform is available here.
Reviews. Customers may review your business on your Professional Profile. You understand and agree that while all Reviews must follow our Review Policy, Cactus does not remove negative Reviews that do not violate our Review Policy, regardless of whether a Pro is a paying customer or not, except as may be required by law. If you attempt to create new or additional Professional Profiles for the same business, we reserve the right to link your prior reviews to your new or additional Professional Profiles.
Communications Preferences. When you create an account on Cactus, please note that any prior communications preferences you may have conveyed to Cactus will not be transferred to your Cactus account. We reserve the right to communicate with you using the contact information you provide or that is publicly or commercially available, including to provide you with information about our services and products and with tips and offers.
Cactus Trade Program and Business Program. You may be eligible to enroll in the Cactus Trade Program or the Cactus Business Program. By applying or enrolling in the Cactus Trade Program or Business Program, you agree to the Cactus Trade Program and Business Program Terms and Conditions, which are also incorporated into this Professional Profile Policy.
User Disputes. You agree that you are solely responsible for your agreements or interactions with any Cactus user, and we will have no liability or responsibility in connection with such agreements or interactions. We reserve the right but have no obligation, to become involved in any way with disputes between you and any Cactus user.
For European Union customers, Cactus uses your content as an online intermediation service provider under the European Regulation on the platform to business relations ("P2B")* to include your business in our Project Match tool that matches trade with companies.
*Regulation (EU) 2019/1150 of the European Parliament and of the Council of 20 June 2019 on promoting fairness and transparency for business users of online intermediation services
Updated 17 July 2020. For all Pros who joined Cactus community prior to 17 July 2020 this version of the Professional Policy is effective 14 August 2020