Privacy Notice

01Controller and contact

The controller of personal data processed through this website and client desk is NewEarth Commodities, a division of NewEarth Nation Trust 14 (registration 414941086), with offices in the USA, South Africa, Zambia and the Democratic Republic of the Congo.

Privacy enquiries, access requests and objections: commodities@newxearth.com, +27 61 586 9195.

02Personal data we collect

• Account data: name, email address, telephone number, organisation, assigned role, account status and login timestamps.
• Identity and due diligence data: passport or national identity documents, proof of address, company registration and ownership records, beneficial-owner details, director and signatory details.
• Financial data: proof of funds, source of funds evidence, banking coordinates, escrow instructions and wallet references supplied by you.
• Commodity and transaction data: licences, origin declarations, assay reports, logistics records, refinery documentation, contracts and instructions.
• Correspondence: enquiry forms, desk messages, information requests, notes and attachments.
• Technical data: IP address, browser and device information, and security or audit log entries generated when you use the desk.

03Why we process it and our lawful bases

• To perform or prepare a contract with you: account creation, onboarding, transaction coordination and payment-release procedure.
• To comply with legal obligations: anti-money-laundering, counter-terrorist-financing, sanctions screening, record-keeping and lawful requests from authorities.
• For legitimate interests: verifying counterparties, preventing fraud and abuse, securing the platform, maintaining audit trails and defending legal claims.
• With your consent: optional communications and any disclosure beyond what the procedure or law requires. Consent may be withdrawn at any time without affecting prior processing.

04Confidential information and controlled disclosure

Buyer client information sheets (CIS), proof of funds and equivalent confidential packs are held by the desk and are not published to other parties. Counterparties receive a NewEarth confirmation of verified status, not the underlying file.

Documents are released to another party only where that party's role in the transaction requires it, where you instruct release, or where disclosure is legally required.

05Who receives personal data

• Desk staff acting under role-based permissions: administrators, compliance officers and transaction managers.
• Transaction counterparties, refineries, escrow providers, banks and introducers — limited to the information their role requires.
• Professional advisers, auditors and legal counsel where necessary.
• Service providers that host, secure or transmit data on our behalf (cloud hosting, database and file storage, transactional email delivery), under contractual confidentiality obligations.
• Regulators, law-enforcement or courts where we are legally required to disclose.

06International transfers

We operate across the USA, South Africa, Zambia and the DRC, and our infrastructure providers may process data in other jurisdictions. Where personal data is transferred across borders we rely on appropriate safeguards, including contractual protections with our processors, and limit transfers to what the transaction or a legal obligation requires.

07Security measures

• Encrypted transmission (TLS) and encrypted storage of uploaded documents in a private, non-public file store.
• Row-level database access controls so each account can only read records its role permits.
• Authenticated, time-limited links for document access; no public document URLs.
• Append-only audit logging of status changes, approvals and document actions.
• Segregation of duties on payment release, requiring separate authorised approvals.

08How long we keep data

Retention periods are set out in our Data Retention Policy. In summary, due diligence and transaction records are retained for the period required by anti-money-laundering and commercial record-keeping obligations, after which they are deleted or anonymised. Draft applications that are never submitted may be deleted by you at any time.

09Your rights

We respond to verified requests within one month where practicable. Some rights are limited where retention is legally mandated, for example anti-money-laundering records.

• Request access to the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request erasure where we no longer have a lawful basis or obligation to retain it.
• Object to or request restriction of certain processing.
• Request a portable copy of data you provided to us.
• Withdraw consent where processing is based on consent.
• Complain to us via the Complaints Procedure, or to the data protection authority in your jurisdiction.

10Cookies and analytics

The site uses only the cookies and local storage needed to keep you signed in, maintain security and remember your language preference. See the Cookie Notice for detail.

11Automated decision-making

We do not make decisions producing legal or similarly significant effects about you by automated means alone. Onboarding and payment-release decisions are made by authorised desk personnel.

12Children

The desk is a business service and is not directed at anyone under 18. We do not knowingly collect data from children.

13Changes to this notice

We may update this notice. The 'last updated' date above shows the current version, and material changes will be notified to account holders through the desk.