Legal information.

01Who we are and how to contact us

This website is operated by INFRA Gold Trading Company ([Registered entity name], [jurisdiction], [registered address]), a member of the INFRA Holding Group ("INFRA Gold", "we", "us"). INFRA Gold is responsible, as controller, for the personal data described in this policy.

We treat the information entrusted to us with the same discipline we apply to every ounce we trade. For any question about this policy or about your personal data, please write to contact@icm-usa.com with the subject "Privacy".

02What personal data we collect

We collect only what we need to answer you and, if a business relationship follows, to meet our legal obligations:

Contact data you provide through our forms or by e-mail — name, company, position, e-mail address, telephone number and country.

Commercial information about your project or requirements — mine or project name, type of material, estimated volumes, preferred form, delivery terms and any documents you choose to share with us.

Due-diligence information, only when a relationship is being considered — corporate and beneficial-ownership records, identification of authorised signatories, and the results of sanctions, politically-exposed-person and adverse-media screening.

Technical data — IP address, browser type and the basic server logs needed to operate and protect the website. We do not use advertising or profiling technologies.

03How and why we use your data

To respond to your enquiry and assess whether we can work together.

To prepare, negotiate and perform purchase, offtake and resale agreements, and to coordinate assay, logistics, refining and settlement.

To carry out the know-your-customer, anti-money-laundering, sanctions and responsible-sourcing checks required by law and by our compliance framework.

To keep the website secure, prevent fraud and misuse of our forms, and comply with lawful requests from competent authorities.

We never sell personal data, and we do not use it for automated decisions that produce legal effects concerning you.

04Legal basis for processing

Depending on the purpose, we process personal data because it is necessary to take steps at your request before entering into a contract or to perform a contract; to comply with our legal obligations, in particular anti-money-laundering, sanctions and record-keeping rules; or to pursue our legitimate interest in running and protecting our business, always balanced against your rights and freedoms. Where the law requires your consent, we will ask for it, and you may withdraw it at any time.

05Sharing with group companies and providers

Personal data may be shared with other companies of the INFRA Holding Group when they take part in the same project or provide shared services such as compliance review, technology or administration, under the same standard of protection.

We also rely on carefully selected service providers — hosting, communications, screening databases, logistics, assay and refining partners, and professional advisers — who act on our instructions and are bound by confidentiality and data-protection obligations. We disclose information to public authorities only where the law requires it.

06International transfers

Our business is international, so your data may be processed outside the country where you live. Whenever data leaves a jurisdiction that restricts such transfers, we rely on adequacy decisions, standard contractual clauses or other safeguards recognised by the applicable law.

07Retention periods

Enquiries that do not lead to a business relationship are kept for up to 24 months and then securely deleted.

Records of clients, suppliers and transactions, including due-diligence files, are kept for at least five years after the relationship ends or the transaction is completed, or for longer where the law so requires.

08Your rights and how to exercise them

Subject to the applicable law, you may request access to your personal data, its rectification or erasure, the restriction of or objection to its processing, and its portability. Write to contact@icm-usa.com; we will reply within the legal time limits and may ask you to confirm your identity. You also have the right to lodge a complaint with the competent data-protection authority.

Some information cannot be erased while we are legally required to retain it — due-diligence records, for example.

09Cookies

This website uses only the technical storage strictly necessary for it to function. We do not use analytics, advertising or third-party tracking cookies. Should this change, we will update this policy and request your consent where required.

10Changes to this policy

We may update this policy to reflect changes in the law or in our activities. The date shown above identifies the current version, and any material change will be highlighted on this page.

01Acceptance of these terms

These terms govern your access to and use of this website, operated by INFRA Gold Trading Company, a member of the INFRA Holding Group. By using the website you accept them; if you do not agree, please refrain from using it.

02Use of the website

This website presents our activities and allows mining producers, refiners and buyers to contact our trading desk. You agree to use it lawfully and in good faith, to provide accurate information in our forms, and not to interfere with its security or operation, introduce malicious code, or extract data from it by automated means.

03No offer or investment advice

All information on this website is provided for general purposes only. It does not constitute an offer, solicitation or recommendation to buy or sell gold or any other commodity, security, token or investment product, nor does it constitute investment, legal, tax or financial advice.

Every purchase, offtake or resale is subject to a written contract, satisfactory due diligence, availability and applicable law. Submitting a form creates no obligation for either party. Descriptions of processes, documents and lot records are illustrative and may vary from one transaction to another.

04Intellectual property

The INFRA name, the INFRA Gold emblem, and the content and design of this website belong to INFRA Gold Trading Company or to other companies of the INFRA Holding Group, or are used under licence. You may view and print pages for your own information; any other reproduction, distribution or use requires our prior written consent.

05Third-party links

This website links to other INFRA Group platforms and may link to third-party websites. Each is governed by its own terms and policies, and we are not responsible for the content or practices of websites we do not operate.

06Limitation of liability

We take reasonable care to keep this website accurate and available, but it is provided "as is" and without warranties of any kind. To the fullest extent permitted by law, we accept no liability for any loss arising from the use of, or inability to use, the website, or from reliance on its content. Nothing in these terms excludes liability that cannot be excluded by law.

07Governing law and jurisdiction

These terms are governed by the laws of [jurisdiction]. Any dispute arising from them shall be submitted to the competent courts of [jurisdiction], without prejudice to any mandatory consumer-protection rules that may apply to you.

08Changes to these terms

We may amend these terms at any time. The version published on this page, identified by its date, is the one that applies to your use of the website.

01Our compliance commitment

Physical gold is only as valuable as the trust behind it — trust in its origin and in every hand it passes through. INFRA Gold Trading Company operates a risk-based compliance programme, overseen within the INFRA Holding Group compliance function, that covers know-your-customer, anti-money-laundering, sanctions and responsible-sourcing controls.

Our framework is designed with reference to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the FATF Recommendations and recognised practices of the international bullion market. We do not deal with counterparties, or in material, that fail these controls.

02Know Your Customer (KYC)

Before any agreement is signed, we identify and verify every producer, refiner and buyer: legal existence, registered address, directors and authorised signatories, and ultimate beneficial owners. For producers, we also review mining titles, concessions, permits and the authority to sell the production.

This information is refreshed periodically and whenever a relationship or its risk profile changes. Enhanced due diligence applies to higher-risk situations, including politically exposed persons and complex ownership structures.

03Anti-money laundering & counter-terrorist financing

We do not accept cash, anonymous counterparties, or payments from or to unrelated third parties. Funds must move through regulated financial institutions, in the name of the contracting parties.

Transactions are monitored against the expected profile of each relationship. Unusual volumes, prices, routes or payment instructions are escalated to compliance and, where required, reported to the competent authorities. Our people receive regular anti-money-laundering training.

04Sanctions screening

Every counterparty, its beneficial owners and the relevant carriers and jurisdictions are screened against the sanctions lists applicable to our operations — including those of the United Nations, the United States (OFAC), the European Union and the United Kingdom — at onboarding and on an ongoing basis. We do not deal with sanctioned persons or in prohibited jurisdictions.

05Responsible sourcing

Every lot must be traceable to an identified mine with verified title. We assess each supply chain for red flags — conflict financing, serious human-rights abuses, child or forced labour, illegal mining or environmental crime — and suspend or terminate any relationship in which these risks cannot be effectively mitigated.

Assay, transport, insurance and refining are entrusted to specialised, reputable providers, and each step is recorded in the lot file. Mines tokenized through INFRACOINN arrive with their documentation already reviewed; tokenization supports traceability, but it never replaces our own due diligence.

06Reporting concerns

Anyone — employees, counterparties, local communities or members of the public — may raise a concern about our activities or our supply chains, in confidence and without fear of retaliation. Write to contact@icm-usa.com with the subject "Compliance", or use the INFRA Group compliance platform linked above. Every report is reviewed by the compliance function.

07Record keeping

Due-diligence files, contracts, lot records and transaction documents are stored securely for at least five years after the end of each relationship or transaction, or longer where the law so requires, and are made available to competent authorities and auditors upon request.