Privacy Policy

1. Data We Collect

We may collect the following categories of personal data:

• Identity data: full name, title, date of birth, passport or government ID details
• Contact data: email address, telephone number, business address
• Corporate data: company name, registration number, beneficial ownership information
• Financial data: bank account details, transaction history, source of funds documentation
• Technical data: IP address, browser type, device identifiers, website usage data
• Communications data: correspondence, enquiry forms, and recorded communications

2. How We Use Your Data

• Conducting KYC, AML, and sanctions screening as required by applicable law
• Establishing and managing business relationships with counterparties
• Executing commodity transactions and associated trade finance activities
• Communicating with clients, partners, and prospects about our services
• Complying with legal and regulatory obligations across all operating jurisdictions
• Improving the functionality and security of our website and digital platforms

3. Legal Basis for Processing

We process personal data on the basis of: (i) contractual necessity; (ii) legal obligation — to comply with AML, KYC, sanctions, and reporting requirements; (iii) legitimate interests — to operate our business, manage risk, and prevent fraud; and (iv) consent — where we have obtained your explicit agreement.

4. Data Retention

We retain personal data for as long as required by applicable law and regulation. KYC and AML records are typically retained for a minimum of five (5) years following the end of a business relationship.

5. Data Sharing

We do not sell personal data. We may share data with: regulatory authorities and law enforcement agencies as required by law; banking and financial institution partners for transaction processing; third-party compliance and screening service providers; and professional advisors, subject to confidentiality obligations.

6. Your Rights

• Access the personal data we hold about you
• Correct inaccurate or incomplete data
• Request erasure of data where no longer required
• Object to processing based on legitimate interests
• Lodge a complaint with the relevant supervisory authority

7. Contact

For data protection enquiries, contact our Compliance team at compliance@thekaustubh.com.