Privacy Policy

Gilded Precious Minerals Ltd ("Gilded", "we", "us" or "our") is a company incorporated in the Republic of Sierra Leone under company number SL040626GILDE30483, with its registered office at 1 Council Road, Kailahun, Sierra Leone.

We are the data controller responsible for the personal information described in this Policy. If you have any questions about this Policy or how we handle your information, please contact us at info@lumarajewels.com.

This Policy applies to personal information we process in connection with our business activities, including the sourcing, refining, import, export and trading of gold and other precious minerals, our website at this domain, enquiries and correspondence received through any channel, and mandatory regulatory reporting.

It does not cover the practices of third parties we do not own or control, including refiners, freight forwarders, insurers, banking partners, government agencies and independent assayers, each of which operates under their own privacy notices.

We collect the following categories of personal information:

• Identity data, including full legal name, date of birth, nationality, government identification numbers and copies of passports or national identity documents required for Know Your Customer ("KYC") checks.
• Contact data, including postal address, email address and telephone numbers.
• Business data, including company name, registration number, trading licence details, beneficial ownership information, tax identifiers and banking references.
• Transaction data, including consignment references, weights, assay results, purchase and sale prices, invoices, shipping documents and customs declarations.
• Compliance data, including sanctions screening results, adverse-media checks, source-of-funds and source-of-wealth information collected to satisfy anti-money-laundering ("AML") and counter-terrorist-financing ("CTF") obligations.
• Correspondence data, including the contents of enquiries, emails, calls, messages and meeting notes.
• Technical data, including IP address, browser type, device identifiers, referring URL and interaction logs when you visit our website, as further described in our Cookies Policy.

We collect personal information directly from you when you submit an enquiry, request a quotation, enter into a commercial agreement, provide KYC documentation, or otherwise communicate with us. We also receive information from third parties, including sanctions and PEP screening providers, credit reference agencies, banking partners, refiners, government registries and publicly available sources.

We process personal information only where we have a lawful basis to do so. The purposes and corresponding legal bases include:

• Performance of a contract, to negotiate, execute and administer purchase, sale, refining and logistics agreements.
• Compliance with legal obligations, including AML, CTF, sanctions, export licensing, customs, tax and record-keeping requirements under the laws of Sierra Leone, the United Arab Emirates and other jurisdictions relevant to a transaction.
• Legitimate interests, including due diligence on counterparties, risk management, fraud prevention, network security, dispute resolution and the day-to-day operation of our business, balanced against your rights and freedoms.
• Consent, where required, for example for certain marketing communications or non-essential cookies, which you may withdraw at any time.

We may share personal information with:

• Regulators, tax authorities, customs authorities, licensing bodies, law enforcement and courts where disclosure is required by law or is necessary to establish, exercise or defend legal claims.
• Banking, payment, insurance, logistics, refining, assaying, security and audit partners engaged in the ordinary course of a transaction.
• Professional advisers, including legal counsel, accountants and compliance consultants, subject to duties of confidentiality.
• Prospective or actual purchasers of all or part of our business or assets, subject to appropriate safeguards.

We do not sell personal information and we do not disclose it for third-party marketing purposes.

Our business is international by nature. Personal information may be transferred to, stored in or accessed from jurisdictions outside Sierra Leone, including the United Arab Emirates and other markets where our counterparties, refiners and service providers operate. Where we transfer personal information across borders, we take steps to ensure it receives an appropriate level of protection, including through contractual safeguards and by verifying the recipient's security posture.

We retain personal information for as long as is necessary to fulfil the purposes for which it was collected, to comply with our legal, regulatory, tax, accounting and reporting obligations, and to establish, exercise or defend legal claims. AML, KYC and transaction records are typically retained for a minimum of seven years after the end of the business relationship or completion of the relevant transaction, or for such longer period as applicable law requires.

We maintain organisational, technical and physical safeguards designed to protect personal information against unauthorised access, disclosure, alteration and destruction. These include access controls, encryption in transit, secured storage of physical documents, staff training and vendor due diligence. No system is completely secure, and we cannot guarantee the security of information transmitted to us over the internet.

Subject to applicable law, you may have the right to request access to the personal information we hold about you, to request correction of inaccurate information, to request deletion, to object to or restrict certain processing, to withdraw consent where processing is based on consent, and to lodge a complaint with a competent supervisory authority.

To exercise any of these rights, please contact us at info@lumarajewels.com. We may need to verify your identity before responding. Some rights are qualified where we are required by law to retain information or where other legal grounds apply.

Our services are directed to businesses and professional counterparties. We do not knowingly collect personal information from children under the age of 18. If you believe a child has provided us with personal information, please contact us so we can take appropriate action.

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements or other operational factors. The "Last updated" date at the top of this page indicates when the Policy was most recently revised. Material changes will be communicated by appropriate means.

Gilded Precious Minerals Ltd
1 Council Road, Kailahun, Sierra Leone
Email, info@lumarajewels.com
Telephone, +232 78415870 or +232 31318725