Introduction

This Privacy Policy applies to KimberLite Trading and its affiliated companies ("KimberLite", "we", "our" or "us").

It explains how we collect, use, store, share and protect personal information when you use our websites, communicate with our team or access products and services within the KimberLite ecosystem.

We handle personal information fairly, lawfully and transparently, with appropriate safeguards to protect its confidentiality, integrity and security.

This Privacy Policy has been prepared in accordance with the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), together with other applicable privacy and data protection requirements.

Further information about your privacy rights is available from the Information Commissioner's Office (ICO).

Data Controller

KimberLite Token LLC is the data controller responsible for the personal information collected through this website and the KimberLite ecosystem.

Registered Office:

  • 203-2083 West 33rd Avenue
  • Vancouver, British Columbia
  • V6M4M6
  • Canada
  • Company Registration Number: FM1085040

Where this Privacy Policy refers to "KimberLite", "we", "our" or "us", it means KimberLite Token LLC and its affiliated companies responsible for processing your personal information.

A. Information We Collect

The information we collect depends on how you interact with KimberLite. Some information is provided directly by you, while other information is collected automatically when you use our website or services.

We only collect information that is necessary to provide our services, comply with legal obligations, improve our platform and communicate with you.

Identity Information

This may include your name, title, date of birth and other information that helps us identify you when providing our services.

Contact Information

This may include your email address, telephone number, residential or business address and any other contact details you choose to provide when communicating with KimberLite.

Account & Communication Information

If you contact us, subscribe to updates, submit an enquiry or register for any KimberLite service, we may collect the information you provide together with records of our communications.

Wallet & Blockchain Information

Where required to support blockchain transactions, we may collect wallet addresses, blockchain transaction identifiers and other information necessary to process purchases, transfers and related services within the KimberLite ecosystem.

Public blockchain records remain publicly accessible by design and are not controlled by KimberLite.

Technical Information

When you visit our website, we may collect technical information such as your IP address, browser type, operating system, device information, time zone settings and website usage data.

This information helps us maintain the security, performance and reliability of our website.

Website Usage Information

We may collect information about how visitors use our website, including pages viewed, referral sources, navigation paths and time spent on individual pages.

Where possible, this information is analysed in aggregated or anonymised form to help us improve the user experience.

Marketing Preferences

If you choose to receive newsletters, updates or promotional communications, we will retain your communication preferences and any related subscription information.

You may withdraw your consent or unsubscribe at any time.

Aggregated Information

We may create anonymous or aggregated statistical information that does not identify any individual. This information helps us understand website performance, improve our services and support business planning.

Information About Others

If you provide personal information relating to another individual, you confirm that you have the necessary authority or consent to share that information and for KimberLite to process it in accordance with this Privacy Policy.

B. How We Use Personal Information

KimberLite only processes personal information where there is a lawful basis for doing so. The information we collect helps us deliver our services, operate the KimberLite ecosystem, protect our users, comply with legal obligations and continually improve our platform.

We do not sell your personal information to third parties.

Fulfilling Our Agreement With You

When you create an account, purchase products or services, register for the KimberLite ecosystem or otherwise enter into an agreement with us, we process the information necessary to fulfil that agreement.

This may include:

  • Creating and managing your account
  • Processing purchases and payments
  • Delivering products or services
  • Managing wallet-related transactions
  • Providing customer support
  • Communicating important service updates

We only retain this information for as long as it is reasonably required to fulfil our contractual obligations or meet applicable legal requirements.

Processing Based on Your Consent

In some situations, we rely on your consent before processing personal information.

Examples include:

  • Subscribing to newsletters
  • Requesting product updates
  • Registering your interest in KimberLite services
  • Completing website enquiry forms
  • Receiving marketing communications

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Processing for Legitimate Business Interests

In certain circumstances, KimberLite processes personal information where doing so supports our legitimate business interests, provided those interests do not override your rights and freedoms.

These legitimate interests may include:

  • Operating and administering the KimberLite ecosystem
  • Maintaining accurate business records
  • Responding to enquiries and customer support requests
  • Protecting our legal rights
  • Preventing fraud, abuse or unauthorised access
  • Improving our products, services and website
  • Managing operational and commercial risks

Whenever we rely on legitimate interests, we carefully consider the potential impact on your privacy and ensure appropriate safeguards are in place.

Processing Required by Law

KimberLite may process personal information where required to comply with applicable laws, regulations or lawful requests from competent authorities.

Examples may include obligations relating to financial reporting, fraud prevention, legal proceedings, regulatory compliance or law enforcement requests.

Where legally permitted, we will only disclose the minimum amount of information necessary to satisfy those obligations.

C. Sharing Personal Information

KimberLite only shares personal information where it is necessary to provide our services, fulfil contractual obligations or comply with legal requirements.

We do not disclose personal information for unrelated commercial purposes.

Internal Companies

Personal information may be shared within the KimberLite group of companies where necessary to provide products, services and operational support.

Access is limited to authorised personnel with a legitimate business need.

Professional Advisers

Where appropriate, we may share information with trusted professional advisers, including legal advisers, accountants, auditors, insurers, payment providers and other professional service providers.

Each party is expected to protect personal information in accordance with applicable privacy laws and contractual confidentiality obligations.

Service Providers

KimberLite may engage carefully selected third-party service providers to assist with hosting, technology infrastructure, communications, customer support or other operational services.

These providers process personal information only on KimberLite's instructions and only where appropriate contractual safeguards are in place.

Legal Requirements

We may disclose personal information where required by law or where disclosure is necessary to:

  • Comply with legal obligations
  • Respond to lawful regulatory requests
  • Protect KimberLite's legal rights
  • Prevent fraud or unlawful activity
  • Protect the safety, rights or property of our users or third parties
D. Payment & Blockchain Information

Where transactions occur within the KimberLite ecosystem, we may process information necessary to complete those transactions.

Depending on the service being used, this may include:

  • Wallet addresses
  • Blockchain transaction identifiers (transaction hashes)
  • Payment confirmations
  • Banking information where applicable
  • Records required for accounting, compliance or audit purposes

Wallet addresses and blockchain transaction records may exist permanently on public blockchain networks. KimberLite cannot alter or remove information recorded on public blockchains.

E. Identity Verification (KYC) & Anti-Money Laundering (AML)

To help protect the KimberLite ecosystem and comply with applicable legal and regulatory requirements, certain services may require identity verification before they can be accessed.

Where Know Your Customer (KYC) or Anti-Money Laundering (AML) verification is required, KimberLite or its authorised verification providers may collect information including:

  • Government-issued identification
  • Proof of address
  • Date of birth
  • Verification photographs or biometric confirmation where required
  • Information necessary to comply with applicable financial crime regulations

Verification information is collected solely for identity verification, fraud prevention, regulatory compliance and the protection of the KimberLite ecosystem.

Where third-party verification providers are used, they process personal information only for authorised verification purposes and in accordance with applicable data protection laws.

Verification records are retained only for the period required by applicable legal and regulatory obligations.

F. Protecting Your Information

KimberLite applies appropriate technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, disclosure or alteration.

These measures may include secure infrastructure, restricted access controls, authentication procedures, firewalls and other industry-standard security practices.

While we continually work to protect the information entrusted to us, no internet transmission or electronic storage system can be guaranteed to be completely secure. Users should also take appropriate steps to protect their own accounts, wallets and devices.

G. Cookies & Website Technologies

KimberLite is committed to respecting your online privacy.

Our website does not use cookies for behavioural advertising or cross-site tracking. Where essential technologies are required to operate the website securely or deliver core functionality, they are used solely for those purposes.

If KimberLite introduces cookies or similar technologies in the future, this Privacy Policy will be updated to reflect those changes.

H. Technical & Usage Information

When you visit our website, we may automatically collect limited technical information to help maintain security, improve performance and understand how visitors use our services.

This information may include:

  • IP address
  • Browser type and version
  • Device information
  • Operating system
  • General geographic location
  • Pages visited
  • Website navigation paths
  • Time spent on pages
  • Referral sources

Where possible, this information is analysed in aggregated or anonymised form and is not used to identify individual users.

I. Marketing Practices

KimberLite does not use automatically collected browsing information to build advertising profiles or deliver targeted behavioural advertising.

If you have chosen to receive marketing communications, those communications will only be sent in accordance with your preferences and applicable privacy laws.

You may unsubscribe from marketing communications at any time using the unsubscribe link provided or by contacting KimberLite directly.

J. Automated Decision-Making

KimberLite does not make decisions that produce legal or similarly significant effects based solely on automated processing of personal information.

Where automated technologies are used to support website security, fraud prevention or platform administration, appropriate human oversight remains in place.

Should automated decision-making become part of KimberLite's services in the future, this Privacy Policy will be updated to explain how those processes operate and the rights available to users.

K. Giving Your Consent

Where consent is required, KimberLite will ask you to take a clear and positive action before collecting or processing your personal information.

Examples include:

  • Completing an enquiry form
  • Subscribing to newsletters
  • Registering for updates
  • Joining future services or promotions

By providing your information in these circumstances, you confirm that you understand how it will be used in accordance with this Privacy Policy.

You may withdraw your consent at any time where processing relies upon your consent.

L. Third-Party Websites

Our website may contain links to third-party websites, applications or services for your convenience.

These websites operate independently from KimberLite and have their own privacy policies and data handling practices.

We encourage you to review the privacy policies of any third-party services before providing personal information, as KimberLite is not responsible for their privacy practices.

M. International Transfers

KimberLite operates internationally and, where necessary, personal information may be transferred to, stored or processed in countries outside the United Kingdom.

Where international transfers occur, we implement appropriate safeguards designed to protect personal information in accordance with the UK GDPR and the UK Data Protection Act 2018.

These safeguards may include contractual protections, equivalent security standards or other lawful transfer mechanisms recognised under applicable data protection legislation.

N. Your Rights

Under applicable data protection law, including the UK GDPR where it applies, you have rights relating to how your personal information is used. These include the right to:

  • Request access to your personal information
  • Request correction of inaccurate information
  • Request deletion of personal information where appropriate
  • Restrict or object to certain types of processing
  • Withdraw consent where processing relies upon your consent
  • Request a copy of your personal information in a portable format where applicable
  • Lodge a complaint with the appropriate supervisory authority

KimberLite will respond to valid requests within the time-frames required by applicable law.

O. Accuracy of Your Information

Keeping your information accurate helps us provide secure and reliable services.

If your personal details change, please let us know so we can keep our records up to date.

P. Children's Privacy

KimberLite's products and services are not intended for individuals under the age of 18.

We do not knowingly collect personal information from children. If we become aware that personal information has been collected from an individual under the age of 18 without appropriate authorisation, we will take reasonable steps to remove that information where legally possible.

Q. How Long We Keep Information

We retain personal information only for as long as it is reasonably necessary to:

  • Provide our products and services
  • Fulfil contractual obligations
  • Meet legal and regulatory requirements
  • Resolve disputes
  • Protect KimberLite's legal rights
  • Maintain appropriate business records

When personal information is no longer required, it will be securely deleted or anonymised where appropriate.

R. Typical Retention Periods

Retention periods vary depending on the type of information collected and the legal obligations that apply.

Examples include:

  • Customer enquiries — retained for as long as necessary to respond and maintain appropriate business records
  • Marketing subscriptions — retained until you unsubscribe or withdraw your consent
  • Transaction records — retained for the period required by applicable financial, accounting and regulatory obligations
  • Identity verification records — retained where required to satisfy applicable KYC and AML legislation
  • Website security records — retained only for as long as necessary to protect the security and integrity of our systems

Where retention periods expire and information is no longer required, it will be securely deleted or anonymised where appropriate.

S. Questions or Complaints

If you have questions about this Privacy Policy or believe your personal information has not been handled appropriately, we encourage you to contact KimberLite first so we can work with you to resolve the matter promptly.

If you remain dissatisfied, you may also have the right to lodge a complaint with the Information Commissioner's Office (ICO) or another relevant supervisory authority.

T. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal obligations or business operations.

The most recent version will always be published on the KimberLite website. We encourage you to review this page periodically so you remain informed about how your personal information is handled.

U. Contact KimberLite
Privacy Enquiries

If you have questions about this Privacy Policy, want to exercise your privacy rights or need more information about how KimberLite handles your personal information, please contact our Privacy Team.

Email: info@kimbertoken.io

We are committed to responding to privacy enquiries as promptly as possible and in accordance with applicable data protection laws.