Lumia Gold and Minerals Ltd respects your privacy and is committed to protecting the personal information you provide when you visit our website, contact us, submit an inquiry, request our services, download resources, or engage with us in relation to gold sourcing, precious-metals trading, buyer or seller representation, due diligence, export advisory, logistics coordination, assay and refinery support, transaction structuring, or related commercial services.
This Privacy Policy explains how we collect, use, store, disclose, and protect personal information.
By using this website or providing personal information to us, you acknowledge that you have read this Privacy Policy.
1. Who We Are
Lumia Gold and Minerals Ltd is a Kenya-based precious-metals and gold trading company providing commercial and transaction-support services to buyers, sellers, mining companies, exporters, investors, refineries, and other qualified counterparties.
For purposes of this Privacy Policy, references to:
“Lumia,” “we,” “us,” or “our”
mean Lumia Gold and Minerals Ltd.
References to:
“you,” “your,” “user,” “client,” or “visitor”
mean any person who visits our website, submits information to us, or interacts with our services.
2. Scope of This Privacy Policy
This Privacy Policy applies to personal information collected through:
- Our website
- Contact forms
- Gold inquiry forms
- Buyer inquiry forms
- Seller inquiry forms
- Due diligence forms
- Export advisory inquiries
- Investment advisory inquiries
- Newsletter subscriptions
- Download forms
- Email communications
- Telephone or WhatsApp communications
- Business meetings
- Commercial onboarding
- KYC and due-diligence processes
This Policy does not necessarily apply to third-party websites or services linked from our website.
3. Personal Information We May Collect
The type of information we collect depends on how you interact with Lumia.
We may collect the following categories of information.
Contact Information
This may include:
- Full name
- Company name
- Job title
- Email address
- Telephone number
- WhatsApp number
- Country
- City
- Business address
4. Company and Business Information
For commercial inquiries or due diligence, we may collect:
- Company legal name
- Company registration number
- Country of incorporation
- Registered address
- Business address
- Company website
- Nature of business
- Directors
- Authorized representatives
- Shareholder or beneficial ownership information where relevant
- Corporate documents
- Relevant licences or permits
5. Gold Transaction Information
If you contact us regarding a gold transaction, we may collect information such as:
- Product required or offered
- Gold doré, refined gold, nuggets, or other product
- Quantity
- Purity
- Country of origin
- Current location
- Destination
- Refinery information
- Proposed transaction value
- Preferred delivery terms
- Payment structure
- Export information
- Assay information
- Commercial documents
6. Buyer Information
Where you submit a buying inquiry, we may collect:
- Buyer company information
- Purchasing capacity
- Trial quantity
- Monthly requirement
- Destination
- Refinery details
- Buyer KYC information
- Authorized representative information
- Transaction requirements
7. Seller and Supplier Information
Where you submit a supply opportunity, we may collect:
- Supplier identity
- Company registration
- Mining or dealing information
- Gold origin
- Product information
- Available quantity
- Production or supply capacity
- Assay information
- Export capability
- Supporting commercial documentation
8. KYC and Due Diligence Information
For certain transactions, Lumia may request additional information to assess identity, legitimacy, compliance, or transaction risk.
This may include:
- Identification documents
- Company incorporation documents
- Director information
- Beneficial ownership information
- Proof of business address
- Relevant licences
- Corporate banking details
- Source-of-funds information
- Source-of-gold information
- Transaction documents
- Compliance declarations
We only request such information where reasonably relevant to a legitimate commercial, compliance, or due-diligence purpose.
9. Website and Technical Information
When you visit our website, certain information may be collected automatically.
This can include:
- IP address
- Browser type
- Device type
- Operating system
- Pages visited
- Referring website
- Date and time of access
- Approximate geographic location
- Website interaction data
- Cookie identifiers
This information helps us understand website performance, security, and visitor activity.
10. Cookies and Similar Technologies
Our website may use cookies and similar technologies.
Cookies can be used for:
- Website functionality
- Security
- Remembering user preferences
- Traffic analysis
- Performance measurement
- Understanding how visitors use our website
Where required by applicable law, we will request appropriate consent before placing non-essential cookies.
You can also manage cookies through your browser settings.
11. How We Use Personal Information
We may use personal information for legitimate business purposes, including:
Responding to Inquiries
To respond when you contact us regarding:
- Gold sourcing
- Product availability
- Buyer representation
- Seller representation
- Due diligence
- Export advisory
- Logistics
- Assay
- Refinery support
- Investment opportunities
Evaluating Commercial Opportunities
We may use information to determine whether a proposed buyer, seller, supplier, or transaction is suitable for further consideration.
Conducting KYC and Due Diligence
We may review information to:
- Verify identity
- Understand corporate ownership
- Assess transaction legitimacy
- Review supply-chain information
- Identify potential compliance risks
- Evaluate counterparties
Facilitating Transactions
Where you engage Lumia, information may be used to help coordinate:
- Buyer-seller introductions
- Assay
- Documentation
- Export processes
- Logistics
- Refinery communication
- Transaction milestones
Maintaining Business Records
We may retain commercial communications and records for:
- Contract management
- Transaction history
- Accounting
- Compliance
- Dispute management
- Business administration
Improving Our Website
Technical information may be used to:
- Improve website design
- Understand visitor behavior
- Fix technical issues
- Improve navigation
- Measure content performance
Marketing Communications
Where permitted, we may use contact information to send:
- Industry insights
- Company updates
- Gold-market educational content
- Service information
- Relevant commercial opportunities
Where consent is required, we will seek it.
You may unsubscribe from marketing communications at any time.
12. Legal Bases for Processing
Depending on applicable law and circumstances, Lumia may process personal data on one or more of the following bases:
Consent
Where you voluntarily provide information or consent to marketing communications.
Contract
Where processing is necessary to take steps at your request before entering into a contract or to perform a contract.
Legitimate Business Interests
Where processing is reasonably necessary for purposes such as:
- Responding to business inquiries
- Conducting due diligence
- Preventing fraud
- Protecting our business
- Maintaining commercial records
Legal Obligation
Where processing is necessary to comply with applicable legal, tax, regulatory, compliance, or law-enforcement obligations.
13. KYC, AML and Compliance Processing
Because Lumia operates within the gold and precious-metals industry, certain transactions may require enhanced compliance review.
Where appropriate, information may be processed for:
- Know Your Customer / Counterparty procedures
- Anti-money laundering controls
- Beneficial ownership review
- Sanctions screening
- Fraud prevention
- Responsible sourcing
- Supply-chain assessment
- Legal and regulatory compliance
We may decline to proceed with a transaction where required information cannot reasonably be obtained or where significant compliance concerns arise.
14. Who We May Share Information With
We do not sell personal information.
However, where necessary for legitimate business purposes, information may be shared with appropriate third parties.
These can include:
Professional Advisers
Such as:
- Lawyers
- Accountants
- Compliance professionals
- Consultants
Assay Laboratories and Refineries
Where required to support testing, product verification, refining, or settlement.
Logistics and Security Providers
Where information is necessary to coordinate transportation or delivery.
Insurance Providers
Where cargo or transaction insurance is being arranged.
Customs and Clearing Professionals
Where relevant to export or import procedures.
Government and Regulatory Authorities
Where disclosure is required by law or reasonably necessary for legitimate regulatory processes.
Commercial Counterparties
Buyer or seller information may be shared where reasonably necessary to progress a transaction, subject to appropriate confidentiality and due-diligence considerations.
15. International Data Transfers
Lumia may work with clients and service providers outside Kenya.
This means personal information may be transferred to or accessed from other countries.
Where such transfers occur, we take reasonable steps to ensure that information is handled with appropriate safeguards and in accordance with applicable data-protection requirements.
16. How We Protect Personal Information
We take reasonable administrative, organizational, and technical measures designed to protect personal information against:
- Unauthorized access
- Loss
- Misuse
- Alteration
- Disclosure
- Destruction
Measures may include:
- Access controls
- Secure systems
- Password protection
- Restricted document access
- Secure communication methods
- Staff confidentiality practices
- Data minimization
However, no online system can be guaranteed to be completely secure.
17. Confidential Transaction Information
Gold and precious-metals transactions can involve sensitive commercial information.
We recognize the importance of protecting information such as:
- Buyer identity
- Seller identity
- Gold location
- Product details
- Quantities
- Commercial pricing
- Assay reports
- Logistics information
- Banking information
- Corporate documents
Such information is shared only where reasonably necessary for legitimate transaction, compliance, or legal purposes.
18. Data Retention
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected.
Retention periods may depend on:
- Commercial relationship
- Transaction status
- Contractual obligations
- Legal requirements
- Tax requirements
- Compliance requirements
- Dispute or legal claims
When information is no longer required, we may delete, anonymize, or securely archive it as appropriate.
19. Your Privacy Rights
Depending on the law applicable to you, you may have rights relating to your personal information.
These may include the right to:
- Request access to your personal information
- Request correction of inaccurate information
- Request deletion in certain circumstances
- Object to certain processing
- Request restriction of processing
- Withdraw consent
- Request information about how your data is used
- Request transfer of certain information where applicable
These rights can be subject to legal exceptions.
20. How to Exercise Your Rights
If you would like to exercise a privacy right, contact Lumia Gold and Minerals using the contact details shown on our website.
Please provide enough information for us to identify the relevant records and understand your request.
We may need to verify your identity before responding.
21. Marketing Opt-Out
If you receive marketing communications from Lumia, you can request to stop receiving them at any time.
You may:
- Use the unsubscribe option provided in the communication, where available
- Contact us directly
- Request removal from marketing lists
We may still contact you regarding existing transactions, legal notices, or important service-related matters.
22. Third-Party Links
Our website may contain links to third-party websites, including:
- Government authorities
- Refineries
- Logistics providers
- Industry organizations
- Social-media platforms
- Other information sources
We are not responsible for the privacy practices or content of third-party websites.
You should review their privacy policies independently.
23. Google Analytics and Similar Services
We may use analytics tools to understand how visitors use our website.
These tools may collect information such as:
- Pages visited
- Session duration
- Device type
- Traffic source
- General location
Where required, these technologies will be managed through appropriate cookie-consent settings.
24. Contact Forms
Information submitted through website forms may be sent to Lumia by email, stored in our website systems, or processed through third-party website infrastructure.
Do not submit highly sensitive information through an ordinary website form unless specifically requested.
For formal due diligence or confidential documents, we may provide another secure communication method.
25. Downloads and Resource Access
Where downloadable resources are offered, we may request limited information such as:
- Name
- Company
- Country
This may be used to provide the requested resource and, where permitted, provide relevant follow-up information.
Users should be able to opt out of marketing communications.
26. Children’s Privacy
Our website and commercial services are intended for adults and business users.
We do not knowingly seek personal information from children for gold trading, investment, export, or other commercial transactions.
27. Automated Decision-Making
Lumia does not ordinarily rely solely on automated decision-making to determine whether to approve or reject a commercial gold transaction.
Compliance tools may assist with screening or risk identification, but material commercial decisions may involve human review.
28. Fraud Prevention
We may process and retain information where reasonably necessary to:
- Prevent fraud
- Investigate suspicious activity
- Protect clients
- Protect Lumia
- Protect legitimate suppliers and buyers
- Cooperate with lawful investigations
Where appropriate, fraudulent or suspicious conduct may be reported to relevant authorities.
29. Data Accuracy
Clients are responsible for providing accurate and up-to-date information.
If your:
- Company name
- Address
- Contact details
- Directors
- Authorized representative
- Transaction information
changes, please notify us where it remains relevant to an active relationship.
30. Information About Other People
If you provide personal information about another person—for example a director, shareholder, buyer representative, or business partner—you should ensure that you have an appropriate legal basis or authority to provide that information.
31. Business-to-Business Communications
Many of Lumia’s activities involve business-to-business communications.
We may retain professional contact details and correspondence for legitimate commercial relationship management, subject to applicable law.
32. Data Breach Response
If a security incident occurs that materially affects personal information, Lumia will take reasonable steps to:
- Investigate the incident
- Contain the issue
- Assess potential impact
- Take corrective action
- Notify affected persons or authorities where legally required
33. Kenya Data Protection Considerations
As a Kenya-based company, Lumia recognizes the importance of complying with applicable Kenyan data-protection requirements, including principles relating to:
- Lawfulness
- Fairness
- Transparency
- Purpose limitation
- Data minimization
- Accuracy
- Security
- Retention
- Data-subject rights
Where applicable, personal information will be handled in accordance with relevant Kenyan data-protection law.
34. International Visitors
Our website may be accessed by users outside Kenya.
Where laws such as the European Union General Data Protection Regulation or other international privacy rules apply to a particular relationship, we will seek to handle personal information in accordance with applicable obligations.
This Privacy Policy does not represent that every international privacy law automatically applies to every Lumia transaction.
35. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect:
- Changes to our services
- New website features
- Regulatory developments
- Changes in technology
- Updated business practices
The updated version will be published on this page with a revised Last Updated date.
We encourage users to review this Policy periodically.
36. Contact Us
If you have questions about this Privacy Policy or how Lumia Gold and Minerals handles personal information, please contact us through our official website contact channels.
Lumia Gold and Minerals Ltd
Nairobi, Kenya
Website: www.lumiagoldminerals.com
Email: info@lumiagoldminerals.com
For privacy-related inquiries, I recommend creating:
privacy@lumiagoldminerals.com
or
compliance@lumiagoldminerals.com
Privacy Request
[ Contact Our Privacy & Compliance Team → ]
Our Privacy Commitment
At Lumia Gold and Minerals, privacy forms part of professional business conduct.
Our clients may entrust us with commercially sensitive information involving companies, buyers, sellers, products, transactions, logistics, and due-diligence records.
We therefore seek to apply a simple principle:
Collect what is reasonably necessary. Use it for legitimate purposes. Protect it appropriately. Share it only where justified.
Lumia Gold & Minerals Ltd — Privacy, Confidentiality and Professional Integrity.
This Privacy Policy is intended to provide general transparency regarding Lumia Gold and Minerals’ privacy practices. It should be reviewed by appropriately qualified legal or data-protection professionals before publication to ensure it reflects the company’s actual data practices, website technologies, service providers, and applicable legal obligations.