Privacy Policy

We may collect the following categories of personal information:

1. Personal identifiers, including
   • Legal name, business name, and trading entity information, email addresses and telephone numbers, physical addresses (business, mailing, and billing), government-issued identification numbers (SSN, tax ID, EIN, driver’s license number, passport number), account usernames and passwords, device identifiers and IP addresses, and customer identification numbers and account numbers.
2. Commercial information, including
   • Copper purchase, sale, and reserve transaction records, trading account balances and transaction history, payment information (card numbers, bank account details, routing numbers), credit and financial account information purchase history and trading patterns.
3. Financial information, including
   • Banking and payment account details, collateral information, anti-money laundering (AML) and Know Your Customer (KYC) documentation, internet or network activity, website usage analytics and browsing behavior, search history and interaction data, log files and system access records, device and browser information, and cookies and similar tracking technologies.
4. Geolocation data, including
   • Precise location information from mobile devices, general location derived from IP addresses, and shipping and delivery addresses.
5. Audio, visual, or similar information, including
   • Recording phone calls (where legally permitted), photographs for identity verification, video conference recordings, and security camera footage.
6. Inferences, including
   • Customer preferences, risk assessment and fraud detection and security risk profiles.

We may collect the following categories of sensitive personal information:

1. Government identifiers, including Social Security numbers, driver’s license numbers, passport numbers, and tax identification numbers.
2. Financial account access, including account log-in credentials combined with passwords or access codes.
3. Precise real-time geolocation data accurate within 1,850 feet.
4. Communications contents, including contents of email, mail, and text messages (only when we are the intended recipient).
5. Health information, including medical information related to account accommodations.

We limit the use and disclosure of sensitive personal information to specific business purposes in Section 2, below, unless you provide separate consent for additional uses.

We collect personal information via:

1. Direct collection, such as account registration and onboarding processes, copper trading platform interactions and order submissions, customer service communications via phone, email, chat, or mail surveys, feedback forms, and marketing preferences, document uploads for identity verification and compliance, and event registrations and newsletter subscriptions.
2. Automatic collection, such as website and application usage through analytics tools, security monitoring and fraud detection systems, trading platform performance and optimization tools, marketing attribution and effectiveness measurement, cookies, web beacons, and similar tracking technologies.
3. Third-party sources, such as identity verification and background check services, credit reporting agencies and financial institutions, regulatory databases and government watchlists, market data providers and pricing services, business partners and referral sources, and social media platforms and public databases.

We may use the information set out above to:

1. Create and manage your account with us;
2. Verify your identity and protect against, identify, and prevent fraud and other unlawful activity, claims, and other liabilities;
3. Assist us in responding to your enquiries;
4. Provide Kilo Reserve products and services to you;
5. Process your payments;
6. Communicate with you about, and administer your participation in, special events, contests, programs, offers, surveys, and market research;
7. Operate, evaluate, and improve business, including developing new products and services;
8. Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations, and our policies;
9. Other purposes in respect of which you will be notified at the time of collection.

When you contact Kilo Reserve, we may keep a record of your communication to assist us and you in ensuring that you get the best from our services.

1. From time to time, we engage unaffiliated third parties and their affiliates, agents, subcontractors, including social media platforms (“Service Providers”) to perform certain technological or administrative services. In some cases, a Service Provider will be collecting your personal information from other sources on our behalf to fulfil the purposes set out in Section B. We also may use a Service Provider to host and administer one or more of our Websites, process and store data, and fulfil similar technology-related functions on our behalf. In these circumstances, the personal information that the Service Provider receives is limited to the personal information needed to render their service to us.
2. In certain cases, we may also share some of the personal information we collect with carefully selected business partners, who are first required to sign an agreement that obligates them to keep the information confidential and secure, and prohibits them from using it for unauthorized purposes.
3. We may disclose personal information without notice to you if a law, regulation, search warrant, subpoena, court order, or regulatory notice permits or requires us to do so. We may also disclose personal information without notice to you to prevent fraud or abuse, or to protect the rights, property, or personal safety of Kilo Reserve, its customers, employees, service providers, or the public.
4. Kilo Reserve will treat as confidential all information it holds in relation to a customer where that information is not in the public domain. Subject to this clause, Kilo Reserve will not disclose such confidential information to third parties.
5. We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We will not sell, rent, loan, trade, or lease any personal information collected, including application forms, financial data, or email addresses. Kilo Reserve may ask for your permission by email to disclose your personal data to service providers not affiliated with Kilo Reserve, but you have the right to refuse.
6. We may provide your personal information to companies that deliver services to help us with our business activities such as emailing newsletters, social media advertising or offering client service. These companies are authorized to use your personal information only as necessary to provide these services to us.
7. We will disclose otherwise confidential personal data and confidential information if we are compelled to do so by laws and regulations applicable to us and/or our agents, whether in the U.S., Canada, or elsewhere.

1. Communications between you and Kilo Reserve may be conducted via live chat, email, mail, phone, fax, text message, or by other online or 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 Kilo Reserve, regarding either Kilo Reserve or its selected partners. If you wish to unsubscribe to marketing emails from Kilo Reserve please contact support@kiloreserve.com. We will strive to honor your request as soon as possible, and in any event within the following 10 business days. Please note, however, that this request will apply only to marketing emails and not to certain account-based information emails which will continue to be sent to account holders. We are not responsible for any additional 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.
3. SMS Communications – If you choose to receive text messages (SMS) from Kilo Reserve, you acknowledge and agree that message frequency may vary. Message and data rates may apply. You may reply STOP to opt out or HELP for assistance..We do not sell or share mobile numbers, SMS consent, or message data with third parties or affiliates for their marketing or promotional purposes. We may share this information only with service providers as necessary to operate our SMS program and to fulfill your requests.

1. 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 European Economic Area (“EEA”). Wherever we process or store your personal information we will, in addition to complying with all applicable laws and regulations in that jurisdiction, comply with this Privacy Policy.
2. Your information may also be processed by employees or consultants of the Group who are located outside of the EEA. By submitting your personal data, you agree to this processing, storing, and transfer.
3. If you have questions or comments about this Privacy Policy, please email us at support@kiloreserve.com.

Log Files

1. As is true of 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, date/time stamp, and clickstream data.
2. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site, and to gather demographic information about our user base as a whole.
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 aggregate non-personally identifiable information about visitors to our site such as number of visits, searched pages and browser type to improve our website and client experience.

Cookies

1. Cookies are small pieces of information which are placed in your computer’s memory when you visit a website. Kilo Reserve uses cookies to recognize you as a repeat visitor, to identify your browser type, to keep track of online patterns and preferences in order to better understand you as a customer, and to improve the quality of the Website and our 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 into your account, we know that the cookie information relates to you.
2. 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, you may not be able to take full advantage of Kilo Reserve’s services.
3. The Website may allow you to interact with plugins from social media sites such as Facebook, X (formerly Twitter), YouTube, Instagram, or other similar sites. In such cases, there may be a flow of your personal information between Kilo Reserve and such social media sites. Your use of these plugins will be governed by each site’s privacy policy and not this privacy policy. We encourage you to become familiar with each site’s privacy and security practices and policies before enabling such plugins.

Remarketing

1. Kilo Reserve may use, through its Website, remarketing services to advertise on third-party websites (including Google) to previous visitors to the Website.
2. Any data that we collect will be used in accordance with this Privacy Policy and any third-party website privacy policy, as applicable.

You can opt out of all third-party cookie advertising by visiting: http://www.networkadvertising.org/choices

You have the following rights regarding your personal information

1. Right to know (access)
   • You may request disclosure of personal information categories we have collected about you in the past 12 months, obtain specific pieces of information we have collected about you, learn about our data collecting sources, business purposes, and sharing practices, and receive information about third parties with whom we share your personal information.
2. Right to Delete
   • You may request deletion of personal information we have collected from you and receive confirmation of deletion or explanation of legal expectations that prevent deletion, understanding that deletion may result in your inability to access certain services offered by Kilo Reserve.
3. Right to Correct
   • You may request correction of inaccurate personal information in our records (provided that proper documentation is provided by you), and are entitled to confirmation that corrections have been made to your information.
4. Right to opt out of sharing
   • You may opt out of sharing personal information for cross-context behavioral advertising.
   • You may exercise these opt-out rights via our link on our Website.
5. Right to limit sensitive personal information
   • You may request that we limit our use and disclosure of your sensitive personal information to specific permitted purposes, restrict processing what is beyond necessary to perform requested services or ensure security, and receive information about how we handle your sensitive personal information.
6. Right to non-discrimination
   • You are entitled to receive equal service and pricing regardless of exercising your privacy rights. You shall not be denied goods or services or receive different prices for exercising your privacy rights and are entitled to chilled any practices that may constitute unlawful discrimination.

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 law or for legitimate business purposes. By continuing to use Kilo Reserve’s services, you agree to be bound by the updates to this Privacy Policy. Please check back frequently; you will be able to see if changes have been made by looking at the top of the Privacy Policy for the date it was last updated.