Privacy Policy

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

This policy details how we handle your personal information regarding the Website and the services we provide. It is incorporated into the Goldmoney Client Agreement (for clients with Goldmoney Holdings) and the Goldmoney Personal Account Terms of Service (for existing clients of Goldmoney Personal).

By using our Website, using or applying for a Goldmoney Holding, and/or using a Goldmoney Personal Account (together, “Goldmoney Services” or “goldmoney.com”), you are consenting to be bound by this Privacy Policy.

This policy sets out:

• What information we collect, and why we collect it;
• How we use that information and how we secure it;
• Any third parties with access to it and use of cookies;
• The rights you have concerning your personal information.

If you're not familiar with terms like cookies, IP addresses, and browsers, then 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 get to know our practices, and, if you have any questions, please contact us at [email protected].

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 and password details;
• 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, phone ID, mobile user name, password, and contacts;
• 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;
• Data mining and financial profiling.

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 computer, 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. How we use your personal information

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

• Carrying out obligations arising from any contracts entered into with you and to provide you with the information and services that you request from us;
• Ascertaining whether to approve you for use of the Goldmoney Services when you apply to use the Goldmoney Services;
• 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, Know Your Client (“KYC”), Anti-Money Laundering (“AML”) and reporting obligations, requirements applicable to Goldmoney Inc as a Dealer in Precious Metals and its subsidiaries;
• 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);
• Detection of suspicious transactions, including transactions involving fraud, money laundering, or terrorist financing activities;
• Providing you and other Website users with information about goods or services that may interest you. If you do not want us to use your data in this way, please contact us as set out below;
• 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 computer;
• 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. We may use this information and the combined information for the abovementioned purpose.

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

3. You can contact us at any time to:

• Request information that Goldmoney has about you;
• Correct any information Goldmoney has about you;

Please contact us at [email protected] with any questions relating to your information that we control.

C. 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 confirmed in this Privacy Policy. We will not sell, rent, loan, trade, or lease any of your personal information collected, including application forms, financial data, or email addresses.

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 you have a Goldmoney Personal account, or your Goldmoney Holding is administered by Goldmoney Vault Inc, the data controller is based in Canada. If Goldmoney Vault (UK) Ltd administers your Goldmoney Holding, the data controller is based in the United Kingdom. By signing up for Goldmoney Services, you agree to the data controllers sharing information. Should you not consent to such disclosures, please do not utilize Goldmoney Services.

4. We may share with or disclose your personal information with unaffiliated third parties and their affiliates, business partners, professional advisors, suppliers, agents, and subcontractors ("Service Providers") to perform technological or administrative services in connection with the performance of any contract we entered with you. For example, Service Providers that 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 fulfill similar technology-related functions on our behalf. The personal information shared with or disclosed to the Service Provider is limited to the personal information needed to render their service to us. A Service Provider may be collecting your personal information from other sources on our behalf to fulfill the purposes set out in section B.

5. We may ask for permission to disclose your personal data to service providers not affiliated with Goldmoney, but you have the right to refuse.

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

7. 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 of such business or assets. 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.

D. How we communicate with you

1. Communications between you and Goldmoney may be conducted by mail or by 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. You agree that all telephone calls and electronic communications may be recorded and kept by us as a record of your instructions. You also agree that we may contact you electronically in response to a request, inquiry, or complaint as otherwise 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. If you wish to unsubscribe from Goldmoney's marketing emails, please contact [email protected]. We will strive to honour your request as soon as possible, and in any event, within the next 10 business days. Please note that this request will apply only to marketing emails and not to account-based information emails which will continue to be sent to account holders. 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 and policies before disclosing information to them.

E. How we store and retain your information

1. All information you provide to us is securely stored on an encrypted storage server. Although we have implemented reasonable measures to protect your personal information, the security of your information while 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. We may process your personal information on a server located outside the country where you live, and such personal information may be transferred to and stored at a destination outside the EEA. Your personal information may be processed by employees or consultants of the Group who are located outside of the EEA. Wherever we process or store your personal information, we will comply with this Privacy Policy, in addition to complying with all applicable laws and regulations in that jurisdiction, including the UK and EU General Data Protection Regulation (“GDPR”). By submitting your personal information, you agree to this processing, storing, and transfer.

3. We will retain and use your personal information as long as you are a client of Goldmoney. We may keep your personal information for up to 10 years after you stop being a client. The reasons we may do this are:

• To respond to a question or complaint or to show whether we gave you fair treatment;
• To obey rules that apply to us about keeping records. For example, certain regulations may require us to retain certain data up to 10 years.

We may also keep your data for longer than 10 years if we cannot delete it for legal or regulatory reasons.

We will only use your personal information for those purposes and ensure your privacy is protected.

F. Your Rights

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

1. The right to request access to any data held on your behalf;
2. The right to ask us not to process your data for marketing purposes;
3. The right to request we correct any personal data if it is found to be inaccurate or out of date;
4. The right to request your data is erased where it is no longer necessary for us to retain such data;
5. The right to transfer your personal data;
6. You have the right to request a restriction on further processing where there is a dispute regarding the accuracy or processing of your data.

If you are located in the American State of California, the California Consumer Protection Act (“CCPA”) gives California residents the right to request the deletion of their Personal Information.

In addition, clients outside these areas can be confident that Goldmoney remains fully compliant with all applicable data protection laws and regulations worldwide. These may vary by jurisdiction but apply with equal importance to the data subjects covered therein.

G. How you can exercise your rights

1. Requests related to personal information can be made by any means, including by email to [email protected].

2. EEA residents—We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative Prighter or use your data subject rights, please visit:

• For clients of Goldmoney Inc/Goldmoney Vault Inc: https://prighter.com/q/18228538
• For clients of Goldmoney Vault (UK) Ltd: https://prighter.com/q/11174552328

H. Cookies and Other Tracking Technologies

1. You can visit our Website without giving away your personal information. Goldmoney uses Google Analytics and Cookies to improve our service and user experience and analyze how the Website is used. Like most websites, but subject to your browser 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, age, gender, interests, device information, date/time stamp, and clickstream data.

2. We use this information, which does not identify individual users, to analyze trends, administer the site, track users' 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.

4. We reserve the right to use a third-party tracking service, Google Analytics, which uses cookies to track non-personally identifiable information about visitors to our site, such as the number of visits, searched pages, and browser type, to improve our Website and client experience.

5. 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, to identify your browser type, to keep track of online patterns and preferences to better understand you as a customer, and to 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 computer but not who is using it. However, by associating the identification numbers in the cookies with other customer information when, for example, you log in to the Goldmoney Services, we know that the cookie information relates to you.

• It is always open to you to modify your web browser settings to prevent the placing of cookies or to notify you each time a cookie is set. The website www.allaboutcookies.org contains additional useful information on how to block or control cookies using different browsers. However, by blocking or deleting cookies used on the Goldmoney Services, you may not be able to take full advantage of the Goldmoney Services.
• 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 filtered between Goldmoney and social media sites. Your use of these plugins will be governed by each social media site's privacy policy and not this privacy policy. We encourage you to become familiar with each social media site's privacy and security practices and policies before enabling such plugins.

6. Goldmoney uses, through its Website, the Google Adwords and Adroll Remarketing services to advertise on third-party websites (including Google) to previous visitors to the Website. Google AdWords Remarketing is a remarketing and behavioural targeting service provided by Google. It connects activity on www.goldmoney.com with the Adwords advertising network.

7. Google AdWords Remarketing displays relevant advertisements based on pages of the Goldmoney Website that you have viewed by placing a cookie on your computer. This cookie does not identify you or give us access to your computer. The cookie allows us to show you relevant advertisements across the Google Advertising Network based on your previous browsing of the Goldmoney Website.

8. Any data that we collect will be used in accordance with this Privacy Policy and Google's privacy policy.

You can opt out of Google Adwords Remarketing by visiting:

• http://www.google.com/settings/ads

You can opt out of all third party cookie advertising by visiting:

• http://www.networkadvertising.org/choices

G. 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 change this Privacy Policy as necessary to comply with the law or for legitimate business purposes. By continuing to use the Goldmoney Services, you agree to be bound by the updates to this Privacy Policy. Please check back frequently; you can see if changes have been made by looking at the top of the Privacy Policy for the date it was last updated.