Privacy Policy

This Privacy Policy describes how Kilo Reserve LLC (“Kilo Reserve,” “we,” “us,” or “our”), a Kilo Capital Corp company, collects, uses, shares, and protects personal information about clients and prospective clients. Kilo Reserve provides physically backed beneficial ownership in investment-grade industrial metals to qualified investors in the United States.

By opening an account, using our services, or otherwise providing us with personal information, you acknowledge the practices described in this Privacy Policy. This policy applies to information collected through our website, our client portal, our metals desk, and our onboarding and account-servicing processes.

We collect the following categories of personal information:

• Identity and verification information: full legal name, date of birth, residential address, Social Security number or taxpayer identification number, and government-issued identification (such as a passport or driver’s license), including images or documentation provided for identity verification.
• Entity information: for accounts held by an LLC, trust, joint account, or other entity, formation and ownership documentation, beneficial ownership information, and information about authorized representatives.
• Financial information: bank account and wire transfer details, source-of-funds information, transaction and holdings history, and account balances.
• Communications: records of your communications with us, including recorded and monitored trade desk calls, emails, and messages submitted through our client portal or website.
• Technical and usage information: IP address, device and browser information, and usage information collected through cookies and analytics when you access our website or client portal.

We collect this information directly from you, from your authorized representatives or advisors, and through our internal identity-verification and anti-money-laundering screening processes.

We use personal information to:

• Establish, verify, and service your account, and execute and settle your transactions;
• Comply with our legal and regulatory obligations, including Know Your Customer (KYC), Customer Identification Program (CIP), anti-money-laundering (AML), and sanctions-screening requirements;
• Prepare and deliver tax reporting, including IRS Form 1099-B;
• Communicate with you about your account, transactions, and service matters;
• Detect, prevent, and address fraud, security issues, and prohibited or illegal activity;
• Maintain the security and integrity of our operations; and
• Comply with applicable law and enforce our agreements.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share personal information only as described below:

• Service providers: with third parties that perform services on our behalf, under contractual obligations to protect your information. Our principal service providers are identified in Section 5.
• Affiliates: with Kilo Capital Corp and its affiliates, as needed to provide and support our services.
• Custodians and storage facilities: as necessary to effect custody of your metal. Custody and storage providers hold and verify physical metal and do not require your sensitive personal information for that purpose.
• Regulators and law enforcement: with regulators, law enforcement, tax authorities, and other governmental bodies where required by law, regulation, legal process, or governmental request.
• Professional advisors: with our legal, accounting, and compliance advisors.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality protections.

We keep our use of third-party providers deliberately limited. Our principal providers are:

• Bank of America: banking services and wire transfer processing.
• HubSpot: customer relationship management and website analytics.
• Google Analytics: website usage analytics.
• Adobe: electronic signature and document handling.
• Microsoft: secure email and document storage.
• RingCentral: telephony and recording of trade desk calls.

Identity verification and anti-money-laundering screening are conducted internally by Kilo Reserve and are not outsourced to third-party screening vendors.

We retain personal information for as long as your account is active and for the period thereafter required to meet our legal, regulatory, tax, and recordkeeping obligations, including those under applicable anti-money-laundering laws. When information is no longer required, we take reasonable steps to securely delete or de-identify it.

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and disclosure. These include access controls, encryption of sensitive data in transit and at rest, secure document handling through Adobe and Microsoft systems, and a secure client portal for the submission of onboarding and identity documentation. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

This section applies to California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”).

In the past twelve months, we have collected the categories of personal information described in Section 2, including identifiers, financial information, government identifiers, and, where applicable, internet activity information. We collect this information for the business purposes described in Section 3. We do not sell personal information and do not share it for cross-context behavioral advertising.

We collect sensitive personal information, including your Social Security number or taxpayer identification number, government-issued identifiers, and financial account information. We use this information only as necessary to verify your identity, comply with legal and regulatory obligations, prevent fraud, and provide our services — uses that fall within the exceptions recognized under the CCPA/CPRA. We do not use or disclose sensitive personal information for purposes that would require us to offer a right to limit such use.

Subject to certain exceptions, California residents have the right to:

• Know and access the personal information we have collected about them;
• Request correction of inaccurate personal information;
• Request deletion of personal information, subject to legal and regulatory retention requirements;
• Opt out of the sale or sharing of personal information (note: we do not sell or share personal information); and
• Not receive discriminatory treatment for exercising these rights.

To exercise these rights, contact us using the details in Section 12. We will verify your request before acting on it, consistent with applicable law. You may use an authorized agent to submit a request on your behalf, subject to verification.

Our website uses cookies and similar technologies to operate the site, remember your preferences, and understand how the site is used. We use Google Analytics and HubSpot analytics for these purposes. Our website presents a cookie consent banner that allows you to manage your preferences, and you can also control cookies through your browser settings. Disabling certain cookies may affect site functionality.

Our services are intended solely for qualified investors who are adults. We do not knowingly collect personal information from individuals under the age of 18. If we learn that we have collected such information, we will take steps to delete it.

We may update this Privacy Policy from time to time. Changes will be posted on our website with an updated effective date. Material changes will be communicated to clients as required by applicable law.

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us at:

Kilo Reserve LLC

7300 Carmel Executive Park Dr, Suite 310
Charlotte, NC 28226 USA

privacy@kiloreserve.com  •  1-866-593-2815