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Privacy Policy – Gold Rush Refinery Zambia

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Gold Rush Refinery: Comprehensive Privacy Policy

 

Effective Date: November 1, 2006

At Gold Rush Refinery, your privacy and the confidentiality of your commercial activities are paramount. This detailed policy outlines how we collect, use, process, secure, and disclose your personal and sensitive commercial information ("Personal Data") when you use our website, secure portal, or engage with our gold refining, trading, and storage services.

 

1. Information We Collect

 

We collect information necessary for compliance, security, and the provision of our specialized refining services.

 

1.1. Personal Identification and Contact Information

 

  • Identity Data: Full legal name, date of birth, nationality, photograph, national identity card or passport number, and copies of official identification documents required for Know-Your-Customer (KYC) and Anti-Money Laundering (AML) compliance.

  • Contact Data: Postal address, email address, telephone number(s), and corporate contact information.

 

1.2. Financial and Transactional Information

 

  • Financial Data: Bank account details, payment methods, and financial transaction history relevant to payments for our services or payouts for gold purchases.

  • Commercial Data: Volume, purity, origin (source mine/license), and type of gold-bearing material submitted for refining; Assay Reports; final transaction values; and vaulting records.

 

1.3. Technical and Usage Information

 

  • Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website or secure client portal.

  • Usage Data: Information about how you use our website, products, and services, including navigation patterns, referral sources, pages viewed, and access times.

 

2. How We Collect Your Information

 

We collect Personal Data through various methods:

  • Direct Interactions: You provide information directly when you:

    • Apply to become a client (KYC/AML documentation).

    • Complete forms related to material submission or vaulting.

    • Communicate with us via email, phone, or in person.

    • Provide feedback or respond to surveys.

  • Automated Technologies: As you interact with our website, we automatically collect Technical Data via cookies, server logs, and other similar technologies.

  • Third Parties or Publicly Available Sources: We may receive Personal Data about you from third parties, such as regulatory bodies, credit reference agencies, or publicly available registers, for the purposes of performing due diligence and regulatory compliance.

 

3. How We Use Your Information (Legal Basis and Purpose)

 

We use your Personal Data only when legally permitted and for the specific purposes outlined below:

Purpose of Use Legal Basis for Processing

Service Provision (Refining, Assaying, Vaulting, Logistics) Performance of a contract with you or to take steps at your request before entering a contract. Regulatory Compliance (KYC/AML Checks, Source Audits, Reporting to Authorities) Compliance with a necessary legal or regulatory obligation in Zambia (e.g., Financial Intelligence Centre Act). Security and Fraud Prevention (Securing our facilities, client portals, and transactions) Necessary for our legitimate interests (e.g., protecting our business from fraud and maintaining a compliant operation). Communication (Responding to inquiries, sending service updates) Necessary for our legitimate interests (e.g., growing our business, keeping our records updated). Website Improvement (Analysis of usage patterns, troubleshooting) Consent (for non-essential cookies) or necessary for our legitimate interests (e.g., running our business, network security).

 

4. Protection and Security of Information

 

We are committed to protecting your data with a high standard of security appropriate for handling sensitive financial and commercial information.

  • Security Measures: We implement comprehensive industry-standard security measures, including:

    • Physical Security: Secure, access-controlled data storage facilities.

    • Technical Security: Encryption (SSL/TLS) for data in transit, firewalls, intrusion detection systems, and strong access controls for internal systems.

    • Organizational Measures: Regular staff training on data protection, and strict internal policies limiting data access to only those who require it for their duties.

  • Data Retention: We retain your Personal Data only for as long as necessary to fulfill the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements (e.g., seven years for certain AML records, as required by Zambian law).

 

5. Sharing and Disclosure of Information

 

We do not sell or rent your Personal Data to any third party for marketing purposes. Your information may only be shared under the following limited circumstances:

  • Service Providers: We may share data with trusted third-party service providers (e.g., secure logistics/transport companies, banking partners, IT maintenance providers) who assist us in operating our business and providing services. These providers are bound by strict confidentiality agreements and are only permitted to use your data for the specified purpose.

  • Regulatory and Legal Requirements: We will disclose Personal Data when required to do so by law, court order, or when we believe such action is necessary to comply with a legal obligation, protect our rights or property, or ensure the safety of our clients or the public (e.g., mandatory reporting to the Bank of Zambia or the Financial Intelligence Centre).

  • Corporate Transactions: In the event of a merger, acquisition, or sale of all or a portion of our assets, your Personal Data may be transferred as part of the transaction, subject to the new entity adhering to this Privacy Policy.

 

6. International Data Transfers

 

Given the international nature of the gold market, your data may be processed or stored outside of Zambia by our international banking partners or third-party service providers. When this occurs, we ensure that appropriate safeguards are in place to afford your Personal Data a similar degree of protection as it would receive in Zambia.

 

7. Your Rights Regarding Your Personal Data

 

Under applicable data protection laws, you have the following rights regarding your Personal Data:

  • Right of Access: You have the right to request a copy of the Personal Data we hold about you.

  • Right to Rectification: You can request that we correct any inaccurate or incomplete Personal Data.

  • Right to Erasure (Right to be Forgotten): You may request the deletion of your Personal Data where there is no good reason for us to continue processing it (though this right is subject to our legal and regulatory retention obligations, particularly regarding AML/KYC data).

  • Right to Object: You have the right to object to the processing of your Personal Data for direct marketing or where we are relying on a legitimate interest.

  • Right to Withdraw Consent: Where we are relying on consent to process your data, you may withdraw that consent at any time.

To exercise any of these rights, please submit a written request to the contact details provided in Section 9.

 

8. Changes to This Privacy Policy

 

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new policy on this page and updating the "Effective Date" at the top. We encourage you to review this page periodically to stay informed about how we are protecting your data.

 

9. Contact and Privacy Inquiries

 

If you have any questions about this Privacy Policy, our data processing practices, or wish to exercise any of your rights, please contact our Compliance Officer:

Gold Rush Refinery Compliance Officer

  • Email: info@goldrushrefinery.com