Privacy Policy

1. Introduction

Aurionyx Commodities FZCO (“Aurionyx,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information of individuals who visit our website, https://www.aurionyx.com/ (the “Website”), or communicate with us regarding our business activities and services.

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This Privacy Policy explains how we may collect, use, disclose, store, and protect personal information when you access our Website, submit an enquiry, communicate with our team, or otherwise interact with us.

By using our Website, you acknowledge that you have read this Privacy Policy. Where applicable law requires consent for specific processing activities, we will seek that consent separately.

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2. Information We Collect

Depending on how you interact with our Website and business, we may collect the following categories of information.

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2.2 Personal and Contact Information

When you contact us or submit an enquiry, we may collect information such as:

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• Full name

• Business email address

• Telephone number

• Company or organisation name

• Job title or professional role

• Country or region of residence or business

• Any information you choose to include in your message or enquiry

 

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In the course of our precious metals trading activities and business relationships, we may collect relevant professional or commercial information, including:

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• Company registration and business identification details

• Information about your organisation's activities and commercial requirements

• Information relating to prospective or existing trading relationships

• Due diligence, identity verification, and compliance documentation where required

• Correspondence, transaction records, and contractual information relevant to a business relationship

• We collect such information only where reasonably necessary for legitimate business purposes, contractual obligations, or compliance with applicable laws and regulations.

 

When you visit our Website, certain technical information may be collected automatically by our hosting provider or other website technologies. This may include:

• Internet Protocol (IP) address

• Browser type and version

• Device and operating system information

• Pages visited and time spent on those pages

• Referring website addresses

• Website interaction and diagnostic information

• Approximate location inferred from your IP address

• The information collected depends on the Website's configuration and the technologies enabled.

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2.4 Cookies and Similar Technologies

Our Website may use cookies and similar technologies to support website functionality, security, performance monitoring, and visitor analytics.

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For further information, please refer to Section 7 of this Privacy Policy.

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3. How We Use Your Information

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We may use personal information for the following purposes:

Responding to enquiries: To respond to questions, requests, and communications submitted through our Website or other channels.

Business development: To evaluate potential commercial relationships with refineries, suppliers, institutional counterparties, and other business partners.

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Providing services: To manage and administer business relationships, transactions, contractual arrangements, and related communications.

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Verification and due diligence: To conduct appropriate business verification, compliance checks, and counterparty screening where required.

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Website operations: To maintain, operate, troubleshoot, and improve our Website.

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Security and fraud prevention: To detect suspicious activity, prevent misuse, and protect our business, systems, and users.

Legal and regulatory compliance: To comply with applicable legal obligations, regulatory requirements, lawful requests, and recordkeeping duties.

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Business administration: To maintain business records, manage disputes, enforce agreements, and protect our legal rights.

We will not use personal information for purposes that are incompatible with the purposes described above unless permitted or required by applicable law.

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4. Legal Bases for Processing

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Where applicable data protection laws require a legal basis for processing personal information, we may rely on one or more of the following:

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Consent: Where you have provided consent for a specific processing activity.

Contractual necessity: Where processing is necessary to enter into or perform a contract with you or your organisation.

Legitimate interests: Where processing is necessary for legitimate business interests, provided those interests are not overridden by your applicable rights.

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Legal obligations: Where processing is necessary to comply with applicable laws or regulatory requirements.

Other lawful grounds: Where another legal basis is available under the laws applicable to the processing.

The appropriate legal basis will depend on the circumstances and the nature of the information concerned.

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5. How We Share Information

We do not disclose personal information indiscriminately. However, we may share information in the following circumstances, where appropriate and lawful.

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5.1 Service Providers

We may share relevant information with third-party service providers that support our operations, such as:

• Website hosting and website platform providers

• Information technology and cybersecurity providers

• Business communication and email service providers

• Data storage and technical support providers

• Professional advisers, including legal, accounting, and compliance advisers

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These providers may process personal information on our behalf or in accordance with their own applicable privacy obligations.

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5.2 Business Counterparties

Where necessary for a proposed or existing business relationship, we may share relevant information with refineries, suppliers, logistics providers, financial institutions, professional intermediaries, or other counterparties involved in a transaction.

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We will seek to limit such disclosures to information reasonably necessary for the relevant business purpose and subject to applicable confidentiality and legal requirements.

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5.3 Legal and Regulatory Disclosures

We may disclose personal information where reasonably necessary to:

• Comply with applicable laws, regulations, court orders, or lawful governmental requests

• Meet relevant anti-money laundering, sanctions, due diligence, or other regulatory obligations

• Investigate suspected fraud, unlawful conduct, or security incidents

• Establish, exercise, or defend legal claims

• Protect the rights, property, safety, or security of Aurionyx and others

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5.4 Corporate Transactions

If our business undergoes a merger, restructuring, financing, acquisition, sale of assets, or similar corporate transaction, relevant information may be disclosed to the parties involved, subject to appropriate confidentiality safeguards and applicable law.

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5.5 No Unauthorised Disclosure

We will handle personal information in accordance with this Privacy Policy and applicable law. Where consent is required for a particular disclosure, we will obtain it before proceeding.

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6. International Transfers of Information

Aurionyx operates from Dubai and engages with business counterparties across multiple countries. Consequently, personal information may be processed or transferred across national borders, depending on the nature of the enquiry, business relationship, service provider, or transaction.

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Where international transfers are subject to applicable data protection requirements, we will take reasonable steps to ensure that the transfers are lawful and that appropriate safeguards are in place.

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Such safeguards may include contractual protections, recognised transfer mechanisms, or other measures permitted by the relevant laws.

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7. Cookies and Website Technologies

Our Website may use cookies, pixels, and similar technologies to support its operation and understand how visitors interact with it.

 

These technologies may be used for the following purposes:

• Essential technologies: To enable core Website functions, security, and reliable navigation.

• Performance and analytics technologies: To understand Website traffic, usage patterns, and technical performance, where enabled.

• Preference technologies: To remember certain settings or preferences, where supported.

• Other technologies: Where applicable, to support additional functions enabled on the Website.

• The specific cookies and technologies in use may depend on the Website platform and its configuration.

• You may be able to manage cookies through your browser settings or through a cookie preference tool provided on the Website. Disabling certain cookies may affect the availability or functionality of some features.

• Where required by applicable law, we will obtain consent before placing or accessing non-essential cookies.

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8. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including business administration, contractual performance, regulatory compliance, dispute resolution, and the establishment or defence of legal claims.

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Retention periods may vary depending on:

• The type and sensitivity of the information

• The nature and duration of the business relationship

• Applicable legal, regulatory, accounting, and recordkeeping obligations

• Whether a dispute, investigation, or legal matter requires continued retention

• When personal information is no longer required, we will take reasonable steps to delete it, anonymise it, or otherwise dispose of it securely, subject to applicable legal requirements.

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9. Data Security

We take reasonable technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, loss, or destruction.

Depending on the nature of the information and the risks involved, these measures may include access controls, secure data transmission, restricted access to business records, and appropriate security procedures.

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However, no method of electronic transmission, online storage, or information processing can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security.

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If you intend to share confidential commercial, identity, or transaction documents with us, please use an appropriate communication channel and avoid submitting sensitive information through general website forms unless specifically requested.

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10. Your Privacy Rights

Depending on your location and the data protection laws applicable to you, you may have certain rights regarding your personal information, including the right to:

• Access: Request confirmation of whether we process your personal information and obtain a copy where legally available.

• Correction: Request correction of inaccurate or incomplete personal information.

• Deletion: Request the deletion of personal information in circumstances permitted by law.

• Restriction: Request that we restrict certain processing activities where applicable.

• Objection: Object to processing based on legitimate interests or other grounds where the law provides this right.

• Data portability: Request a copy of certain information in a portable format where applicable.

• Withdraw consent: Withdraw consent where processing relies on your consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

• Lodge a complaint: Submit a complaint to the relevant data protection authority where applicable.

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These rights are subject to legal conditions, exemptions, and limitations. For example, we may need to retain certain information to meet legal or regulatory obligations or to establish, exercise, or defend legal claims.

 

To exercise a privacy right, please contact us using the contact methods described in Section 15. We may request reasonable information to verify your identity and clarify your request before responding.

 

We will handle requests in accordance with the applicable legal deadlines and requirements.

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11. Third-Party Websites and Services

Our Website may contain links to external websites, platforms, or services operated by third parties.

These external services are not necessarily controlled by Aurionyx, and their privacy practices may differ from ours. We are not responsible for the privacy policies, security, content, or practices of third-party websites.

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12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business operations, Website functionality, data processing practices, or applicable legal requirements.

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Any revised version will be published on this page with an updated “Last Updated” date.

We encourage you to review this page periodically to remain informed about how we handle personal information. Where required by law, we will provide additional notice of material changes or seek renewed consent.

 

13. Contact Us

If you have questions about this Privacy Policy, wish to request information about our handling of personal data, or want to exercise an applicable privacy right, please contact Aurionyx through the contact or enquiry facilities available on our Website.