# Privacy Policy

Last updated: November 2026

### 1. Who we are

Rathmar Trading, LLC, a Delaware limited liability company with offices in Houston, Texas, Zurich, Switzerland and Istanbul, Türkiye ("Rathmar"), is the controller of personal data processed through this website and in the course of our business. Rathmar Metals Ltd, a company registered in England and Wales with its registered office in London, and Rathmar Metals A.Ş., a company incorporated in Türkiye with its registered office in Istanbul, are each controllers of personal data processed in the course of their own business. Contact for data protection matters: [compliance@rathmar.com](mailto:compliance@rathmar.com).

### 2. Laws that apply

We process personal data in line with the Swiss Federal Act on Data Protection (FADP), the EU and UK General Data Protection Regulation (GDPR) where they apply, the Turkish Law on the Protection of Personal Data No. 6698 (KVKK) for our Istanbul office, and applicable U.S. law.

### 3. Data we collect

Enquiry form: name, company, job title, email address, phone number and the content of your enquiry. Business contacts: contact details exchanged in the course of trading relationships. Due diligence: identity, ownership, directorship and screening information about counterparties and their representatives, which may include politically exposed person status and adverse-media results. Server logs: IP address, browser type, pages requested and time of request, kept by our hosting provider for security.

### 4. Purposes and legal bases

We use personal data to answer enquiries (our legitimate interest in responding, or steps taken at your request before a contract); to perform contracts; to meet legal obligations, including sanctions screening, anti-money-laundering checks, trade controls, tax and record-keeping; and to keep this website secure (our legitimate interest). Where we rely on consent, you may withdraw it at any time.

### 5. Retention

Enquiries that do not lead to a business relationship are deleted within 24 months of the last contact. Contract, due-diligence and screening records are kept for ten years after the relationship ends, in line with sanctions and anti-money-laundering record-keeping rules, or longer where law requires. Server logs are kept for short periods set by our hosting provider.

### 6. Sharing

We share personal data with service providers under contract (hosting, email, IT and screening databases); with banks, insurers, inspection companies and logistics providers where needed to perform a trade; with professional advisers; and with regulators or authorities where law requires. We do not sell personal data.

### 7. International transfers

Personal data is processed in the United States, Switzerland and Türkiye, and may be processed in other countries where our service providers operate. Transfers from Switzerland, the EU or the UK to a country without an adequacy decision rely on the Swiss-U.S. or EU-U.S. Data Privacy Framework (including the UK Extension) where the recipient is certified, or on standard contractual clauses. Transfers out of Türkiye follow the transfer rules of the KVKK.

### 8. Third-party content

Fonts and images on this website are served from our own hosting. No third-party content providers receive your IP address when you visit.

### 9. Your rights

Subject to applicable law, you may request access to, correction, deletion or restriction of your personal data, object to its processing, or ask for a copy in a portable format, by writing to [compliance@rathmar.com](mailto:compliance@rathmar.com). You may also complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC), the Turkish Personal Data Protection Authority, or the data protection authority where you live or work.

### 10. Security

We use technical and organizational measures appropriate to the risk, including access controls and encrypted connections to this website.

### 11. Changes

We update this policy when our processing changes. The date at the top shows the latest version.

### 12. Cookies

See our [Cookie Policy](https://rathmar.com/cookies).

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Source: https://rathmar.com/privacy