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Privacy Policy

Effective Date: November 25, 2026; Last Updated: October 26, 2026

This website, www.goldmoney.com (the "Website"), is owned and operated by Goldmoney Inc.

This policy details how we handle your personal information in relation to the Website and the services we provide. It is incorporated into the Goldmoney Client Agreement.

This Privacy Policy applies when you use our Website or use or apply for a Goldmoney Holding (together, “Goldmoney Services” or “goldmoney.com”). It also applies to personal information we continue to hold about former Goldmoney Personal or Business Account holders. Where the law requires your consent for a particular use of your personal information, we will ask for that consent separately.

This policy sets out:

  • What information we collect, and why we collect it;
  • The legal bases on which we rely to process it;
  • How we use that information and how we secure it;
  • Any third parties with access to it, and our use of cookies;
  • The rights you have concerning your personal information, including how to complain.

If you are not familiar with terms like cookies, IP addresses, and browsers, you can read about these key terms first. Your privacy matters to Goldmoney, whether you are new to Goldmoney or a long-time user. Please take the time to understand our practices, and if you have any questions, contact us at privacy@goldmoney.com.

A. What we collect

1. Depending on the type of Goldmoney Services you use, the information we collect about you may include:

  • Contact information (such as your name, email and postal addresses, telephone number, and country of residence) that you provide by completing forms on the Website, by telephone, or through a paper application form;
  • Information permitting us to offer the Goldmoney Services to you, including details relating to your personal bank accounts, details allowing us to prevent and detect money laundering and terrorist financing activities, copies of your current valid government-issued photo identification, and/or such other identifying and verifying information as we require from time to time in our discretion, and credit bureau information about you for purposes of confirming your identity under applicable "know-your-client" rules;
  • Details about your finances that you provide to us or permit us to collect through third-party service providers;
  • Your login credentials (passwords are stored only in hashed form);
  • Details of any transactions you make through the Goldmoney Services;
  • Information about your activity on the Website, such as your IP address, the pages you have visited, and the device or browser you use;
  • Information provided via your mobile devices, such as your location and device identifiers;
  • Communications with us (for example, when you ask for support, send us requests, questions, or comments, or report a problem, whether by mail, telephone, fax, online, or by any other means);
  • Information that you submit through the Website, including in the form of comments, contributions to discussions, or messages to other users;
  • Demographic information;
  • Geolocation information.

2. When you opt in for our Newsletter or marketing materials, we collect your email address and name.

3. As is true of most websites, but subject to your browser settings, we automatically gather information about your device, such as your IP address, browser type, referring/exit pages, and operating system.

4. We may ask you to complete surveys we use for research purposes, although you do not have to respond.

B. The legal bases on which we process your information

We only process your personal information where we have a lawful basis to do so. For clients and visitors in the UK and EU, the lawful bases under the UK GDPR and EU GDPR on which we rely are:

  • Performance of a contract – to carry out our obligations under the Goldmoney Client Agreement, to administer your account, and to process your transactions and instructions.
  • Compliance with a legal obligation – to meet our tax, Know Your Client ("KYC"), Anti-Money Laundering ("AML"), counter-terrorist-financing, reporting, and recordkeeping obligations, including those applicable to Goldmoney Vault Inc. as a reporting entity under Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act, and to Goldmoney Vault (UK) Ltd as a reporting entity to the UK National Crime Agency.
  • Legitimate interests – to operate, secure, and improve the Goldmoney Services, prevent fraud and financial crime, and manage our business, provided these interests are not overridden by your rights and freedoms.
  • Consent – for direct marketing communications and for the use of non-essential cookies and similar technologies. You may withdraw your consent at any time (see Sections D and I).

Where we rely on consent, you are free to decline or withdraw it without affecting any processing carried out before withdrawal or on another lawful basis.

C. How we use your personal information

1. We use the personal information described in Section A to provide the Goldmoney Services to you, including for the following purposes:

  • Carrying out obligations arising from any contracts entered into with you and providing you with the information and services that you request from us;
  • Determining whether to approve you for use of the Goldmoney Services when you apply;
  • Complying with legal requirements, including those imposed by laws, regulations, court orders, and regulatory guidelines, policies and procedures in the countries in which we operate, including tax, KYC, AML and reporting obligations, and requirements applicable to Goldmoney Vault Inc. as a reporting entity under Canadian anti-money-laundering law, and to Goldmoney Vault (UK) Ltd as a reporting entity to the UK National Crime Agency;
  • Verifying your identity and other information you have provided to us, including your bank account information and (if relevant) the identity of your business associates;
  • Identifying you when you sign in to goldmoney.com;
  • Processing transactions on goldmoney.com and communicating with recognized counterparties, bullion-dealers, bullion-banks, and vault operators in respect of the Goldmoney Services;
  • Administering your Goldmoney Services, understanding your needs as a client, and monitoring your satisfaction with the Goldmoney Services;
  • Contacting you about the status of the Goldmoney Services (for example, to inform you of changes to or the termination of particular Goldmoney Services, or to respond to a question, comment, or complaint);
  • Detecting suspicious transactions, including transactions involving fraud, money laundering, or terrorist financing;
  • Providing you and other Website users with information about goods or services that may interest you (you can opt out at any time — see Section D);
  • Managing invoicing, accounting, and information security services related to our transactions with you;
  • Protecting against harm to the rights, property, or safety of Goldmoney, its clients, employees, service providers, or the public;
  • Internal management purposes, including planning, resource allocation, policy development, data analysis, statistical purposes, troubleshooting, quality improvement, compliance, monitoring, audit, evaluation and reporting;
  • Improving the Goldmoney Services;
  • Keeping the Website safe and secure;
  • Ensuring that the content of the Website is presented in the most effective manner for you and your device;
  • Allowing you to participate in interactive features when you choose to do so;
  • Managing your communications preferences; and
  • Maintaining ownership records.

We may combine information from other sources with information you provide and information we collect about you, and use the combined information for the purposes set out above.

2. When you contact Goldmoney, we may record your communication to assist us and to ensure you get the best from our services.

3. We use automated tools to help detect fraud, money laundering, and other suspicious activity, and to support account onboarding. These tools may flag matters for review, but we do not make decisions producing legal or similarly significant effects about you based solely on automated processing — a member of our team is always involved in any decision to decline an application or restrict an account.

4. You can contact us at any time to request access to, or correction of, information we hold about you. Please contact us at privacy@goldmoney.com with any questions relating to information that we control. See Section F for the full list of your rights, and Section G for how to exercise them and how quickly we will respond.

D. How we communicate with you

1. Communications between you and Goldmoney may be conducted by mail, telephone, text message, online, or by other electronic means. Any instructions that you give to us in any such manner will have the same legal effect as if you gave them to us in original written form. Telephone calls and electronic communications may be recorded and kept by us as a record of your instructions; where required by law, we will notify you at the time of recording. We may contact you electronically in response to a request, inquiry, or complaint, as solicited by you or as permitted or required by law.

2. We may also communicate with you from time to time electronically about news, promotions, special offers, and other information from Goldmoney regarding either Goldmoney or its selected partners. We are not responsible for any information you provide directly to these partners, and we encourage you to become familiar with their privacy and security practices before disclosing information to them. If you wish to unsubscribe from Goldmoney's marketing emails, please use the unsubscribe link in any marketing email or contact privacy@goldmoney.com. We will honour your request as soon as possible, and in any event within 10 business days. This request applies only to marketing emails and not to account-based information emails, which will continue to be sent to account holders.

E. How we share your personal information

1. We treat all information we hold on your behalf as confidential where that information is not in the public domain. We will share or disclose confidential information only in the ways set out in this Privacy Policy. We will not sell, rent, loan, trade, or lease any of your personal information; see Sections F.4 and I.7 regarding advertising cookies.

2. We will disclose your personal information without notice if a law, regulation, search warrant, subpoena, court order, or regulatory notice requires us to do so.

3. If your Goldmoney Holding is administered by Goldmoney Vault Inc., or you previously held a Goldmoney Personal or Business Account (closed 15 April 2025), the data controller is Goldmoney Vault Inc., 334 Adelaide St W #307, Toronto, Ontario M5V 0M1, Canada. If Goldmoney Vault (UK) Ltd administers your Goldmoney Holding, the data controller is Goldmoney Vault (UK) Ltd, Advent House, Station Approach, Victoria, St Austell, Cornwall PL26 8LG, United Kingdom. The data controllers may share information with each other as described in this policy and as necessary to provide the Goldmoney Services. If you are a former Personal or Business Account holder, we continue to hold certain records about you as described in Section H.3, and your rights under Section F apply.

Although the Website is operated by Goldmoney Inc., personal information about clients collected through the Website is controlled by the Goldmoney Vault entity responsible for your relationship with us, and Goldmoney Inc. does not receive client-specific information. For Website visitors and marketing recipients who are not clients, the data controller is Goldmoney Inc.

4. We may share or disclose your personal information with service providers that process personal information on our behalf and on our instructions, including professional advisors, suppliers, agents, and subcontractors ("Service Providers"), to perform technological or administrative services in connection with the performance of any contract we have entered into with you. For example, Service Providers may serve as a Vault Operator, operate a Verification Network, process transactions, provide credit reports or assessments, verify customer identities, detect suspicious transactions, perform security services, and manage or audit our operations. We may use a Service Provider to host, administer, improve, and optimize one or more of our Websites, to process and store data, and to fulfil similar technology-related functions on our behalf. The personal information shared with or disclosed to a Service Provider is limited to what is needed to render their service to us. A Service Provider may collect your personal information from other sources on our behalf to fulfil the purposes set out in Section C.

5. We may share aggregated, non-personally identifiable information publicly and with our partners — such as publishers, advertisers, or connected sites. For example, we may share information publicly to show trends or publish market research.

6. We may disclose your personal information to third parties if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer. If all of our assets are acquired by a third party, the personal data held on your behalf will be one of the transferred assets. In that event, we will notify you — by email or through a prominent notice on the Website — before your personal information becomes subject to a different privacy policy, and we will require the recipient to protect your personal information on terms at least as protective as this policy.

F. Your rights

1. If you are located in the UK or the EU, you have the following rights with respect to your personal information under the UK GDPR or EU GDPR, respectively:

  1. The right to request access to any data held about you;
  2. The right to ask us not to process your data for marketing purposes;
  3. The right to request that we correct any personal data that is inaccurate or out of date;
  4. The right to request that your data is erased in the circumstances set out in the UK GDPR and EU GDPR (for example, where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other lawful basis applies). This right does not apply to information we are legally required to retain — for example, transaction records and identity-verification data that we must keep under tax, AML, and other financial-services recordkeeping rules; we will tell you if this is the reason we cannot erase your data;
  5. The right to receive and transfer your personal data (data portability);
  6. The right to request a restriction on further processing in the circumstances set out in the UK GDPR and EU GDPR (for example, while we verify the accuracy of data you have contested, or while we consider an objection you have raised to processing based on our legitimate interests). Where processing is restricted, we may still store your data, and may process it with your consent or where necessary to establish, exercise, or defend legal claims, to protect another person's rights, or to comply with our legal obligations;
  7. The right to object to processing carried out on the basis of our legitimate interests;
  8. Where processing is based on consent, the right to withdraw that consent at any time;
  9. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

2. Your right to complain. You have the right to make a data protection complaint directly to Goldmoney where you believe we have handled your personal data in a way that breaches the UK GDPR or the Data Protection Act 2018 or other applicable data protection law. You do not need to use any specific wording or refer to particular legislation for your complaint to be treated as a data protection complaint.

The entry point to our complaints process is complaints@goldmoney.com. You can also raise a complaint through any of the other contact methods set out in this policy, and we will recognise it as a data protection complaint where applicable.

When you make a data protection complaint, we will:

  • Acknowledge receipt within 30 days of receiving your complaint;
  • Investigate and respond without undue delay, and keep you informed of progress throughout;
  • Notify you of the outcome once we have reached a decision, and explain our reasoning.

Making a complaint to us does not affect your right to complain to the relevant supervisory authority (see Section F.3) or to seek a remedy through the courts. We would, however, encourage you to contact us first so that we have the opportunity to resolve your concern.

3. Complaining to a supervisory authority. You may also lodge a complaint with the data protection authority in your jurisdiction:

  • United Kingdom — the Information Commissioner's Office (ICO), https://www.ico.org.uk;
  • Canada — the Office of the Privacy Commissioner of Canada (OPC), https://www.priv.gc.ca; in Quebec — the Commission d’accès à l’information, https://www.cai.gouv.qc.ca;
  • European Union — the supervisory authority in your country of residence.

4. United States residents. If you are a resident of California, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), gives you the right to: know what personal information we collect, use, and disclose about you; request access to and deletion of your personal information; correct inaccurate personal information; opt out of the "sale" or "sharing" of your personal information; and not be discriminated against for exercising your rights. We do not sell your personal information, and we do not share it for cross-context behavioral advertising: third-party advertising and remarketing cookies are not used for visitors we identify as being in California. Residents of other US states with comprehensive privacy laws may have similar rights, including to access, correct, and delete their personal information. To exercise any of these rights, contact us as set out in Section G.

5. Canadian residents. We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy laws, including Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25). You have the right to request access to and correction of your personal information, and to withdraw consent subject to legal or contractual restrictions and reasonable notice. If you are in Quebec, you also have the right to receive computerized personal information you provided to us in a structured, commonly used technological format, and to request that we cease disseminating it. See Section G.2 for our privacy contact.

6. If you are located outside the regions named above, local data protection laws may give you rights regarding your personal information, including rights to access and correct it. You can exercise these rights, or ask which laws apply to you, by contacting us as set out in Section G. We will respond in accordance with the laws of your jurisdiction.

G. How you can exercise your rights

1. Requests related to your personal information, and data protection complaints, can be made by any reasonable means, including by email to privacy@goldmoney.com or, for complaints, complaints@goldmoney.com.

2. Our Privacy Officer. Our Privacy Officer is the COO, who also serves as the person in charge of the protection of personal information for the purposes of Quebec law. You can contact them with any question, request, or complaint about how we handle your personal information:

  • Privacy Officer, Goldmoney Vault Inc., 334 Adelaide St W #307, Toronto, Ontario M5V 0M1, Canada
  • Email: privacy@goldmoney.com

3. EEA and UK residents — our representative. We have appointed Prighter as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (for example, requests to access or erase personal data). To contact us via Prighter or to use your data subject rights, please visit:

  • For clients and former Personal or Business Account holders of Goldmoney Vault Inc.: https://app.prighter.com/portal/12942045660
  • For Website visitors and marketing recipients of Goldmoney Inc.: https://app.prighter.com/portal/18228538
  • For clients of Goldmoney Vault (UK) Ltd: https://app.prighter.com/portal/11174552328

4. We may need to verify your identity before responding to a request, and will only request the information necessary to do so.

5. Response times. We will respond to your request without undue delay and within the time required by the law that applies to you:

  • UK and EU: within one month of receiving your request. Where a request is complex, or you have made several requests, we may extend this by up to two further months. If we do, we will tell you within the first month and explain why.
  • Canada: within 30 days of receiving your request. Outside Quebec, we may extend this by up to a further 30 days where the law permits. If we do, we will tell you within the original 30 days, give the reason, and let you know of your right to complain to the Office of the Privacy Commissioner of Canada. Quebec residents will receive a response within 30 days.
  • California: we will confirm receipt within 10 business days and respond within 45 days. Where reasonably necessary, we may extend this by a further 45 days, and we will tell you if we do.

Where we need to verify your identity or need more information to locate your data, the time limit starts once we have received what we need. We do not charge a fee for responding to requests. The exception is where a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or decline to act, as the law permits.

H. How we store, retain, and transfer your information

1. We protect your personal information using encryption and other technical and organizational safeguards appropriate to its sensitivity. Although we have implemented reasonable measures to protect your personal information, the security of information transmitted to the Website cannot be guaranteed; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to prevent unauthorized access.

2. International transfers. We may process your personal information on servers located outside the country where you live, and your personal information may be transferred to and stored at a destination outside the UK or EEA — including in Canada — and may be processed by employees or service providers of the Group located outside the UK or EEA. Where we transfer personal data internationally, we put in place an appropriate safeguard recognised under the UK GDPR and EU GDPR, such as an adequacy decision, the UK International Data Transfer Agreement (or UK Addendum), or the EU Standard Contractual Clauses. Wherever we process or store your personal information, we will comply with this Privacy Policy and with all applicable laws and regulations in that jurisdiction, including the UK GDPR and EU GDPR. Your personal information may also be communicated outside the province of Quebec. Before doing so, we assess whether it will receive adequate protection, as Quebec law requires.

3. Retention. We retain and use your personal information for as long as you are a client of Goldmoney. After your relationship with us ends, we retain personal information as follows:

  • Records are generally retained for 5 years, in line with anti-money-laundering and other recordkeeping requirements applicable to us in Canada and the United Kingdom;
  • Records relating to holdings previously administered in Jersey, Channel Islands are retained for up to 10 years, in line with the retention obligations that applied to them there;
  • We may retain specific records for longer where we are required to do so by law, or where they are reasonably necessary to respond to a question or complaint, to demonstrate that we treated you fairly, or to establish, exercise, or defend legal claims. Where this applies, we will limit the information retained to what is necessary for that purpose.

I. Cookies and other tracking technologies

Log files

1. You can browse our Website without registering or actively submitting personal information; note, however, that we automatically collect the technical data described below, some of which (such as IP addresses) may be personal data under applicable law. Goldmoney uses Google Analytics and cookies to improve our service and user experience and to analyze how the Website is used. Like most websites, but subject to your browser and consent settings, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, languages, device information, date/time stamp, and clickstream data.

2. We use this information, which we do not use to identify individual users, to analyze trends, administer the site, track movements around the site, and gather demographic information about our user base.

3. We do not link this automatically collected data to personally identifiable information except as described in this policy.

Cookies and consent

4. Cookies are small pieces of information placed in your browser's memory when you visit a website. Goldmoney uses cookies to recognize you as a repeat visitor, identify your browser type, keep track of online patterns and preferences, and improve the quality of the Website and Goldmoney Services. When you enter our Website, our servers (or those of our Service Providers) will recognize your device but not who is using it; by associating the identification numbers in the cookies with other customer information when, for example, you log in, we are able to relate the cookie information to you.

5. Your choices. Strictly necessary cookies are required for the Website to function. For all non-essential cookies — including analytics, advertising, and remarketing cookies — we will ask for your consent before they are set, and you can change or withdraw your choices at any time through our cookie preferences tool. You can also modify your browser settings to prevent or be notified about cookies; https://www.allaboutcookies.org explains how to block or control cookies in different browsers. If you block or delete cookies, you may not be able to take full advantage of the Goldmoney Services.

6. The Website and the Goldmoney Services may allow you to interact with plugins from social media sites such as Facebook, X, LinkedIn, or Instagram. In such cases, your personal information may be shared between Goldmoney and those social media sites. Your use of these plugins is governed by each social media site's privacy policy and not this one. We encourage you to become familiar with each site's privacy and security practices before enabling such plugins.

Remarketing

7. Subject to your consent, Goldmoney uses the Google Ads and AdRoll remarketing services to advertise on third-party websites (including Google) to previous visitors to the Website. These services display relevant advertisements based on pages of the Goldmoney Website you have viewed, by placing a cookie on your device. We do not use these remarketing services for visitors we identify as being in California (see Section F.4). The cookie does not give us access to your device; cookie identifiers are treated as personal data and handled in accordance with this Privacy Policy. Any data we collect will be used in accordance with this Privacy Policy and the relevant provider's privacy policy.

You can opt out of Google Ads remarketing at https://www.google.com/settings/ads, and out of third-party advertising cookies more broadly at https://www.networkadvertising.org/choices.

J. Minors

The Goldmoney Services are directed to adults and are not intended for anyone under the age of 18 (or the age of majority in your jurisdiction, if higher). We do not knowingly collect personal information from minors. If you believe that a minor has provided us with personal information, please contact us at privacy@goldmoney.com and we will delete it.

K. Changes to this policy

It may become necessary to change the terms of this Privacy Policy from time to time. We reserve the right to do so to comply with the law or for legitimate business purposes. We take the following approach to changes:

  • Minor changes (for example, clarifications, corrections, or formatting): we will update the "Last Updated" date at the top of this policy and post the revised version on the Website.
  • Material changes (for example, new purposes for which we use your personal information, new categories of data we collect, new recipients with whom we share data, or changes to your rights or to our retention practices): we will notify affected clients directly — by email or through an account notice — before the changes take effect, and, where the law requires it, seek your consent.

You can always see whether changes have been made by checking the "Last Updated" date at the top of this policy. We encourage you to review it periodically.