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Legal

Privacy Policy

Effective Date: [Effective Date]

Triaurum Co. LTD operates this website, related inquiry channels, and a restricted portal for qualified counterparties. In this Privacy Policy, “Triaurum Co. LTD,” “we,” “us,” and “our” refer to the operator of the website. Triaurum Co. LTD's full legal entity details, registered address, company registration number, and tax details are currently unspecified and will be updated when available.

1. Scope and Purpose

This Privacy Policy explains how Triaurum Co. LTD collects, uses, stores, shares, and protects personal data in connection with:

  1. 1.use of this website
  2. 2.institutional inquiries
  3. 3.public document download requests
  4. 4.KYC and AML review
  5. 5.onboarding and contract administration
  6. 6.restricted portal access
  7. 7.logistics, assay, settlement, and related communications
  8. 8.legal, compliance, and security management

2. Personal Data We May Collect

We may collect the following categories of personal data, depending on your interaction with us:

A. Inquiry and contact data

Name, business email, phone number, job title, company name, country, message content, and company details provided when requesting downloadable briefing documents.

B. Counterparty and KYC data

Company registration documents, corporate structure information, beneficial ownership information, authorised signatory information, identification documents, source of funds information, financial capability records, bank references, compliance contact details, legal representative details, and due diligence materials.

C. Portal and technical data

Email address, account credentials, login records, IP address, browser and device information, timestamps, security logs, and similar website or portal usage data.

D. Transaction and document data

LOI, offer documents, SPA related records, bank instrument records, shipment details, assay records, settlement confirmations, correspondence, and audit trail records.

E. Cookies and similar technologies

We may use cookies and similar technologies for website functionality, security, preferences, analytics, and consent management, subject to applicable law.

3. Purposes of Processing

We process personal data to:

  1. 1.respond to inquiries and communicate with counterparties
  2. 2.provide downloadable briefing documents and maintain related access records
  3. 3.verify identity, authority, ownership, and eligibility
  4. 4.conduct KYC, AML, sanctions, fraud, and risk checks
  5. 5.prepare, negotiate, execute, and administer contracts and transactions
  6. 6.manage portal access and account security
  7. 7.coordinate with banks, logistics providers, assay or refinery providers, storage providers, advisers, and service providers
  8. 8.comply with legal, regulatory, accounting, audit, and dispute related obligations
  9. 9.protect our website, systems, records, users, and legal rights
  10. 10.maintain records, evidence, and internal controls
  11. 11.operate cookies and website features as permitted by law

4. Legal Bases

Where applicable, we process personal data on one or more of the following legal bases:

  1. 1.performance of a contract or steps requested before entering into a contract
  2. 2.compliance with legal obligations
  3. 3.our legitimate interests in operating, securing, and improving the website and managing commercial relationships, provided those interests do not override your rights
  4. 4.establishment, exercise, or defence of legal claims
  5. 5.explicit consent, where consent is required by applicable law, including for non essential cookies or optional communications

5. Data Sharing

We may share personal data, on a need to know basis, with:

  1. 1.banks and financial counterparties
  2. 2.logistics, custody, assay, refinery, inspection, storage, and insurance counterparties
  3. 3.legal, compliance, audit, and professional advisers
  4. 4.IT, hosting, security, communications, and support vendors
  5. 5.public authorities, courts, regulators, law enforcement bodies, and supervisory authorities where legally required
  6. 6.transaction counterparties and their advisers where necessary for a proposed or concluded transaction

We do not sell personal data.

6. International Transfers

Because our activities may involve international counterparties and service providers, personal data may be transferred outside your country. Where such transfers occur, Triaurum Co. LTD will use the lawful transfer mechanism required by applicable law, including, where relevant, KVKK transfer rules and GDPR transfer safeguards. Transfer countries and mechanisms are currently unspecified and will be published or updated when available.

7. Retention

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy, including contract management, legal compliance, accounting, audit, dispute handling, fraud prevention, and recordkeeping. Specific retention periods are currently unspecified and will be added in a retention schedule when available.

8. Security

We apply appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. These measures may include access controls, role based permissions, secure transmission, logging, due diligence on service providers, confidentiality obligations, and incident response procedures. No system can be guaranteed to be completely secure.

9. Your Rights

Subject to applicable law, you may have the right to:

  1. 1.learn whether we process your personal data
  2. 2.request access to your personal data
  3. 3.request correction of inaccurate or incomplete data
  4. 4.request deletion or destruction where the legal conditions are met
  5. 5.request restriction of processing
  6. 6.object to certain processing
  7. 7.request data portability where applicable
  8. 8.withdraw consent at any time where processing is based on consent
  9. 9.lodge a complaint with the relevant supervisory authority

Under Turkish law, requests may need to be submitted in Turkish where required by law.

10. Cookies

If cookies or similar technologies are used, Triaurum Co. LTD will provide cookie information and, where required, obtain consent for non essential cookies. If no non essential cookies are active, only strictly necessary cookies may be used for security, session management, and website operation.

11. Minors

This website and portal are intended for business users and qualified counterparties. They are not directed to children under 18, and Triaurum Co. LTD does not knowingly collect personal data from children through the website.

12. Contact

For privacy, data protection, or rights requests, please contact:

Triaurum Co. LTD

Email: [Privacy Contact Email]

Compliance Email: [Compliance Contact Email]

Address: [Registered Address]

DPO or Privacy Lead: [Name, if applicable]

13. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be published on this website with a revised effective date. Material changes may also be communicated through appropriate website notices or other reasonable means.

Last Updated: [Effective Date]