Privacy Policy

WEBSITE TERMS OF USE

INTRODUCTION

These terms and conditions set forth the terms and conditions under which you may use the website RMBULLION.COM owned and operated by Ramez Mecattaf S.A.L.

This Website aims to facilitate the purchase of tangible physical bullion. All Products offered are sold as physical items for ownership, delivery, or collection. The Website does not operate as a trading platform and does not provide brokerage, custody, or investment management services or advice

These terms and conditions are deemed an integral part of our contract with You whenever You purchase any of the Products from Us on our website RMBULLION.COM or use any of our services. They also apply whether you use our services via our website RMBULLION.COM, our helpline, in our offices or any other means whatsoever.

These terms and conditions incorporate by reference our Privacy Policy, AML/KYC Policy, and any other policies expressly referred to on our Website.

By using or accessing the Website, You hereby represent and warrant that You have read these Terms, acknowledge and understand their content, agree to, and accept all the terms and conditions set forth in these Terms, whether or not You register to the Website or proceed with the purchase of any of the Products.

Conducting business with us is subject to our policies. If you use our Website or services in any way that breaches our policies, we reserve the right to exercise any legal remedies available by law or by contract to mitigate, stop and get indemnified for such breaches.

DEFINITIONS

The following terms shall have the meaning ascribed to them herein after, throughout the Terms:

CONTRACT FORMATION AND BINDING COMMITMENT

Each Order that you make constitutes a binding offer by You to buy from Us the Products and/or services stated in the Order, subject to the Terms. By approving such Terms, You represent that You have thoroughly read those terms and conditions and acknowledge and approve them in their entirety.

Formation of the Contract. You acknowledge that the Products by nature have volatile prices that varycontinuously. Any Order placed through the Website, helpline, or in-store are firm and binding. You are committed to your Order at the time it is placed. From the moment the Order is submitted, a contractual relationship is formed between You and Us for the purchase of the Products in the quantities and prices expressly referred to in the Order. Hence, You become liable for the full cost of the Products and any related services You have purchased.

Performance Pre-Requirements. While the Contract is deemed formed upon submission of the Order, We reserve our right to terminate this Contract without any liability whatsoever and prior to completing the delivery of the Products, in the event pre-requirements set out by law or contractually are not met by You (the “Pre-Requirements”).

The Pre-Requirements include the following:

Identity Verification: Receipt by Us of a valid copy of Your Identification Card or Passport that allows Us to collect and verify your identity.

KYC/ Compliance Clearance: Receipt of KYC, anti-money laundering (AML), and compliance checks forms duly filled in and clearance from Us in accordance with local and international regulatory requirements and internal compliance policies.

Payment Confirmation: Receipt of either the Deposit payment or of the Products purchase price in full.

We reserve the right, at our discretion, to refuse, cancel, or limit any order where required for legal, compliance, regulatory reasons, risk management, pricing error, or fraud-prevention reasons. In such cases, if payment has already been received, it will be refunded in accordance with our refund policy.

SUBCONTRACTORS

We use subcontractors to help us provide some of our services. We may at any time subcontract any part or all of our business or services without any need for Your notification or consent. We may also at any time change our subcontractors, including those who directly provide any services to You (such as carriers who make deliveries). We shall not be liable for the acts or omissions of third-party service providers except where such parties act under our direct control or where liability cannot be excluded under mandatory applicable law.

INVESTMENT ADVICE

All information on this Website is provided for general information purposes only. We are not authorized and cannot give investment advice. We also cannot provide advice on any potential tax implications relating to the Contract and the Products. You are solely responsible for evaluating your purchase decisions. By approving the Terms, you represent that you have sought the needed investment, legal and financial advice in relation to the purchase of the Products.

NO SPECULATION OR TRADING

The Website is not intended for speculative activity, short-term trading, or market timing. No leverage, margin, derivatives, futures, options, paper contracts or other financial products are offered. Any price references displayed are incidental to the sale of physical Products and do not constitute market quotations, forecasts or recommendations.

PRICES

Under the Contract, the Price for the Products and services is the price as stated in the Order confirmed upon checkout.

The Price displayed on the Website does not reflect only international spot prices for such commodity; the Price includes as well (i) bullion metal premium; (ii) fabrication and minting costs; (iii) logistics and transportation costs; (iv) handling and packaging costs; and (v) insurance and administrative charges. The Price excludes delivery charges and the payment getaway fees.

ORDERS

To buy Products for delivery or collection, you must place the Order through our Website, specifying the item(s), quantities, the Price, the delivery address and any required transaction details.

Each Order you place constitutes a binding offer to purchase and forms the Contract with Us at the time of placement in accordance with these Terms.

Fulfillment of the Orders is subject to the Pre-Requirements and conditions referred to herein. We may request additional information or documentation to comply with applicable laws and regulations and the Terms, before releasing, delivering, or making Products available for collection.

DELIVERY

If You opted for the delivery option, The Products will be delivered to the delivery address as stated in the order using a carrier selected by Us. We reserve the right to choose the delivery method and carrier appropriate for high-value shipments.

You are responsible for ensuring that the delivery address and contact details provided in the Order are accurate and complete. We shall not be responsible for delivery failures or delays resulting from incorrect or incomplete information supplied by you.

We shall not be liable for delays in delivery or failure to deliver caused by events beyond our reasonable control, including without limitation stock shortages, adverse weather conditions, traffic delays, transport disruptions, mechanical breakdowns, supplier delays, regulatory or compliance holds, security incidents, or other force majeure events.

Any delivery dates or timeframes provided are estimates only and the time of delivery is not of essence to the Contract. Transfer of risk of the Products shall pass to You upon delivery to the delivery address referred to in the Order and confirmation of delivery by the carrier to that address.

You should not accept or sign for any delivery where the package appears damaged, resealed, opened, or tampered with. In such case, you must refuse delivery and instruct the carrier to return the package to us.

A one-time delivery attempt will be made. Our carrier will request identification documentation to verify that the identity of the person receiving the Products corresponds to You. If delivery is unsuccessful, you will be required to collect the Products from our premises. We accept no liability for packages delivered to multi-occupancy buildings, shared premises, or work addresses, or where postal redirection or third-party receipt arrangements are in place, once the delivery has been signed for or otherwise confirmed as delivered by the carrier. We accept no liability for loss or damage once the package has been delivered to the delivery address mentioned in the Order and delivery has been confirmed by the carrier.

If delivery cannot be completed due to your unavailability or refusal to accept delivery you are required to collect the Products from our premises,

INVESTIGATION OF NON-DELIVERY

We reserve the right, but not the obligation, to investigate cases of non-delivery or disrupted delivery. Whether and how we conduct any investigation shall be at our reasonable discretion.

We may decide to investigate in particular where we suspect fraud, misrepresentation, delivery irregularities, security risks, or compliance concerns. We may commission others, including investigators and professional advisers, to assist with any investigation.

You agree to cooperate fully with any such investigation and to provide promptly any information, documentation, statements, or confirmations reasonably requested by us or our appointed representatives.

We may share relevant information relating to the order, delivery, and customer identity with carriers, insurers, investigators, and competent authorities where reasonably required for investigation, security, or compliance purposes.

Nothing in this clause creates an obligation on us to compensate you unless our liability is established in accordance with these Terms.

COLLECTION SERVICE

Whenever delivery service is not or no longer available or you do not opt for such delivery service, You must collect the item(s) within 5 working days from the date we notify you that they are available for collection, unless agreed otherwise

At the time of collection, you must present Your Identification Card or Passport. Such identification must match any information previously provided to us as part of the Order and must remain valid. We may carry out additional identity, security, and compliance checks at collection.

If any identification verification is not satisfied, we shall be entitled to refuse handing over and release of the Products.

Collection by a third party is permitted only where we have approved this in advance in writing. Any authorized representative must present valid original identification and written authorization acceptable to us. We reserve the right to refuse release if authorization or identification is not satisfactory.

Transfer of risk of the Products passes to you immediately upon physical handover and acknowledgment of receipt at the collection point.

If the Products are not collected within the specified collection period, we reserve the right to charge reasonable storage, insurance, and handling fees and, after giving reasonable notice, to cancel the Order and resell the Products. Any resulting price difference, market loss, or associated costs may be recovered from you in accordance with these Terms.

PAYMENT AND DOWN PAYMENTS

The Price as mentioned on the Order will be invoiced to You and should be settled as per the payment terms determined by us and set out in the Order confirmation.

All invoiced sums shall be paid in full in the currency of the invoice without deduction or set of (statutory or otherwise) and in cleared funds.

If we have reasonable grounds to believe that you will fail to comply with the present payment terms, we shall be entitled to postpone or to refuse delivery of the Order.

Where a down payment or partial payment is accepted:

The down payment constitutes a binding and irrevocable commitment to purchase.

The Product may be reserved, allocated, or sourced specifically for you.

You are bound to pay the remaining balance in full within the agreed timeframe and accept delivery or pick up.

Failure to complete payment or accept delivery within the required timeframe

OUR PRODUCT INFORMATION

Our Product information reflects weight, purity, and specifications provided by recognized mints or refiners. Images are illustrative only. Packaging and appearance may vary without affecting metal content or purity. All Products sold through this Website are physical bullion products. No financial instruments, investment products, or speculative services are offered. Except as expressly stated, no warranties are given as to fitness for purpose or suitability, to the maximum extent permitted by law.

LIABILITY

These Terms set out the full extent of our obligations and liabilities in respect of the supply of products and the performance of any related services. Unless expressly stated in these Terms and Conditions, no warranties, representations, conditions, or other terms shall be binding on us.

To the fullest extent permitted by applicable law, all warranties, conditions, or terms implied by statute, law, or otherwise are excluded, including any implied warranties of merchantability, fitness for a particular purpose, satisfactory quality, or conformity with description.

Our maximum aggregate liability for all claims arising under or in connection with any Contract, whether in contract, warranty, condition, tort (including negligence), strict liability, statute, or otherwise shall be limited to the total amount actually paid by You to Us for the purchased Products or service giving rise to the claim.

To the fullest extent permitted by applicable law, no liability is accepted for indirect, incidental, or consequential losses, including losses arising from market price movements and losses arising from cybersecurity events, system failures, risks and consequences of cyberattacks, unauthorized access, data breaches, or electronic communication disruptions.

RISK NOTICE

We sell Products and metal, based on the global metal market’s prices, which are volatile and outside of our control. Precious metal prices may fluctuate due to global supply and demand, economic conditions, and geopolitical factors.

CANCELLATION RIGHTS AND REFUND POLICY

You acknowledge and agree that this Contract is not subject to the Consumer Protection Law No. 659/2005. By acknowledging that the Products are a precious metal commodity, you understand that their prices fluctuate continuously as per international financial markets and any cancellation or refund can cause significant losses on Us.

Hence, all Orders including partially paid Orders, are deemed final, non-cancelable, and non-refundable, once placed.

Cancellation or refund rights shall only apply if We fail to deliver the Products in compliance with the Order placed.

TERMINATION OF CONTRACT BY US

Before terminating the Contract, We will -where reasonably practicable- consider whether any default, breach or potential issue may be remedied. If it is capable of remedy, we may attempt to contact you and allow a reasonable period to remedy the breach.

We reserve the right to terminate the Contract, or any particular Order, transaction, or service, if in our reasonable opinion:

the breach or default cannot be remedied;

the breach or default is not remedied within three (3) working days following notification; or

performance is prevented or materially impaired by factors beyond our control, including regulatory, compliance, market, or operational constraints.

We may terminate the Contract or suspend performance immediately, without prior notice, where we reasonably suspect or determine any of the following:

fraud or suspected fraud;

breach of sanctions or export control rules;

anti-money laundering (AML) or counter-terrorist financing (CFT) concerns;

failure of identity verification or KYC requirements;

provision of false, misleading, or incomplete information; or

payment irregularities or suspicious transaction patterns.

Upon termination, we may cancel outstanding Orders, suspend delivery, liquidate or hedge related market positions, and recover from you any losses incurred as a result of the termination or your default, including price differences, hedging costs, transaction costs, storage fees, administrative charges, and recovery expenses, to the extent permitted by applicable law.

Any amounts payable by you upon termination due to your default represent a compensation of the Company’s losses and costs arising from market exposure and transaction handling.

CONSEQUENCES OF TERMINATION

If You or We terminate the Contract or any part of it, either by mutual agreement or written notification made by Us,

You shall remain financially responsible for any loss caused to Us by such termination the fluctuations of the metal price. Th shall be calculated as the difference between the applicable global market spot price at the time your order was placed and the applicable global market spot price at the time termination is accepted or processed by us, multiplied by the precious metal content of the relevant item(s).

CHANGES OF YOUR DETAILS

You are responsible for keeping your personal information accurate and up to date. Failure to notify us of changes may result in suspension of services, cancellation of pending transactions, or termination of our contractual relationship.

OUR INSURANCE

We are not obliged to obtain or maintain insurance specifically to cover risks under any contract, order, transport, or transaction unless we have expressly agreed to do so with you in writing, and you have agreed in writing to pay the applicable charges for arranging and maintaining such insurance.

We may, at our discretion, maintain insurance policies to cover risks relating to our business generally, including all our contracts and all our customers, products, storage locations, or operations. Such policies are maintained for our own benefit and shall not be deemed customer specific insurance or create any direct right to your benefit.

Where we hold insurance that may respond to a loss, we reserve the right to determine, at our sole discretion, whether or not to make a claim under such policy and whether or not to apply any insurance proceeds toward liabilities arising under the Contract. We may satisfy liabilities -if any- through insurance or through other funding sources at our discretion.

You remain responsible for arranging any insurance coverage you consider appropriate for the Products purchased after risk has passed to you in accordance with these Terms.

RELIANCE ON YOUR ORDER

It is your responsibility to ensure that the Order is complete and accurate. Whilst we will carry out ID verification and check that the Order contains the information we need, we do not pick up errors or omissions. You cannot rely on us to detect your errors or omissions.

DATA PROTECTION

We process personal data in accordance with applicable data protection laws and our Privacy Policy.

We process your personal data where necessary for Contract performance, compliance with legal and regulatory obligations (including KYC/AML and sanctions checks), fraud prevention, security, and our legitimate business interests, and, where required, based on your consent.

By submitting the Order, you acknowledge and agree that We may use Your personal data to carry out identity verification, anti-fraud checks, compliance screening, and risk assessments. For these purposes, we may share your personal information with credit reference agencies or fraud prevention agency, and competent authorities. Such organizations may retain a record of that information in accordance with their legal obligations.

Your email address is essential in order for us to be able to supply you with important information such as order confirmations and changes to the service. By registering with us you accept that your email address may be used to supply you with such information.

You are responsible for providing accurate email address details and ensuring receipt of electronic communications. We are not responsible for consequences arising from incorrect contact information or failure to access messages properly sent by us.

Nothing in this clause limits your rights under applicable data protection laws as described in our Privacy Policy.

USERNAME AND PASSWORD SECURITY

It is your responsibility to ensure the confidentiality of your account username and password, and to inform us immediately if you have any reason to believe that your password has become known to anyone else. We cannot accept any responsibility for unauthorized use of your account on the Website.

NO GUARANTEE OR COMPENSATION SCHEMES

The Contract constitutes a purchase of Products; it is a purchase of commodities and cannot be considered at any time as being a financial transaction, a deposit, an investment or any other types of financial instruments. Accordingly, purchases made from Us are not protected by any deposit insurance, investor protection, or compensation scheme.

By accepting the Terms, You represent that you understand the market volatility and commercial risks related to the Products and commit not to seek compensation or recourse against Us for any loss you may incur from such purchase.

GOVERNING LAW

The Order, the Contracts, these Terms, the Privacy Policy and all other policies and dealings relating thereto are governed by the applicable laws of Lebanon. Any disputes relating thereto shall be subject to the exclusive jurisdiction of the competent courts of Beirut, Lebanon.

REGULATORY, COMPLIANCE, E-KYC, AND AML

In accordance with Lebanese laws and Banque du Liban regulations, customers may be required to provide identification documents, proof of address, and other information for KYC, AML, CFT, and compliance purposes.

Additional information may be requested from to time by Us before or after completion of the purchase. Orders may be delayed, suspended, or cancelled without any liability on Us, if compliance requirements are not satisfied.

AMENDMENTS

We reserve the right to amend or update these Terms from time to time. Any such amendments shall take effect from the time they are published on our Website.

Amendments shall not affect Orders or Contracts that have already been confirmed at the time the amended Terms take effect, which shall continue to be governed by the version in force at the time of Order is placed, unless otherwise required by applicable law.

Your continued use of the Website or placement of new Orders after the updated Terms have been published, constitutes your acceptance of such amended Terms.

PRIVACY POLICY

This general personal data protection policy (the “Policy”) covers Ramez Mecattaf SAL (“RM” or the “Company”) and its website www.rm-bullion.com (the “Website”) regarding types of information that RM may collect, directly from you or from the Website, and the treatment of such personal information. As part of our daily business operations, including the online sale of precious metals (gold and silver) and compliance with applicable Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, we need to collect personal data from our clients and prospective clients in order to provide them with our services and/or products.

This Policy applies to the processing activities performed by the Company to the personal data of its clients/potential clients and Website visitors. Therefore, this Policy does not apply to websites operated by any other organizations and/or any other third parties.

This Policy will also provide you with instructions on how to proceed if you do not wish to share personal information with RM when visiting its Website.

For purposes of this Policy, personal information is information about you that is personally identifiable including but not limited to: name, age, personal identification information, address, e-mail address or phone number and any information required to verify your identity and complete a purchase transaction in accordance with applicable laws and regulations.

If someone under the legal age to enter into purchase transactions under Lebanese Laws provides the Company with personal information by obtaining access in violation of the Website access restrictions and its terms of use, RM ask that his/her parent(s) or guardian(s) contact the Customer Service Department by e-mail, at: . Under such circumstances, RM will undertake all appropriate measures to securely dispose and/or delete such data without any undue delay and inform parent(s) or guardian(s) accordingly.

Upon receiving this request, RM will promptly remove such information from the Company’s records, unless retention is required by applicable legal or regulatory obligations. The RM Website is only intended for persons of legal age to enter into transactions.

RM’s Website may contain links to external websites and through the existence of these publicly available links, the Company does not endorse or take any responsibility regarding their privacy practice or policies. Therefore, you are encouraged to consult the privacy policies and data protection policies of such third parties, so as to be informed about their practices regarding the processing of your personal data.

This applies as well on any other information voluntarily provided by you.

We are dedicated to protecting your confidentiality and privacy of your personal data and handling your personal data in accordance with the provisions of the Lebanese Banking Secrecy Law of 3/9/1956, Law no.81/2018 (Electronic Transaction & Personal Data), and BDL Basic Circular no. 146, providing for the protection of natural persons with regard to the processing of personal data and for the free movement of such data and/or any other applicable legislation (hereinafter referred collectively as the “Data Protection Legislation”).

For the purposes of applicable data protection legislation, RM acts as the “Data Controller” in relation to the personal data collected and processed under this Policy.

Information, Collection and Use

RM does not collect personal information when visiting its Website, unless this information is provided upon registration (completion of an online purchase order and customer verification eKYC process). However, it should be noted that the information collected by RM when visiting its Website is collected in an aggregated form, i.e. no personal identification of the concerned individual is possible.

Moreover, we may collect personal information about you from third parties when we seek to verify your identity (as this is described below), as part of our regulatory requirements, including AML and KYC requirements imposed by applicable Lebanese Laws and BDL Regulations. Such third parties may include, without limitation, identity verification agencies, credit referencing agencies and similar bodies (i.e. Thomson Reuters Database, Department of Registrar’s website, etc.).

Additionally, this information actively provided by individuals through inter alia, the completion of the Company’s online purchase form and identity verification process is required, to enable us to process and complete the purchase, verify your identity, and to comply with the relevant rules and regulations. The information that we may collect from you includes the following:

It is further clarified that all relevant information and documentation that is collected when you successfully complete a purchase transaction or undergo the customer verification process are stored in our internal record-keeping systems. This allows among others, the maintenance of transaction records, compliance monitoring, customer support administration, and proper documentation of sales, and provision of customer support, where required.

We ensure that your personal data is processed lawfully, fairly and in a transparent manner for the certain purposes and lawful bases, that are disclosed to you this Policy.

The information under the categories of Technical Data, Location Data and Online Activity Information is collected for statistical purpose and used to help diagnose problems with the server. This information is not used in a manner that directly identifies you, except as otherwise described in this Privacy Policy.

The information included in the rest of the categories of personal data in the table herein above is collected by RM when you initiate or complete a purchase transaction. Such information is required to provide our services and products, in order for us to be able to complete the transaction, comply with regulatory obligations, maintain transaction records, and provide customer support.

Therefore, RM is required to verify your identity, in order to accept you as a client and complete transactions, and such information is needed in order to be in a position to effectively process your purchase. It is required by the Law no. 44/2015 (Fighting Money Laundering and Terrorist Financing) and BDL Circulars, that the Company collects the necessary data for verifying your identity and verifying the source of funds (when applicable).

We may therefore, process your personal data for the purposes described above for one (1) or more lawful bases of processing, depending on the specific purpose for which we are using your data.

The applicable lawful bases (hereinafter referred to as the “Lawful Bases”) are the following:

processing is necessary for the performance of the Contract with you;

processing is necessary for compliance which RM is subject to as per applicable laws and regulations;

you have provided us with your consent to the processing of your personal data for specific purpose;

If RM requests you to provide it with certain personal data and you fail to do so, RM may not be in a position to provide a service and/or sell any Products and/or to enter into a contract with you, in which case RM will inform you accordingly.

All personal information provided by You to RM through the Website is purely voluntary in nature. You acknowledge that such information is collected only when you visit our Website and/or proceed with the completion of our online purchase or identity verification process. If you do not want your information to be collected, please do not submit such information to the Website. If you have already submitted personal information to the Company and wish to have them removed from the records, please contact RM at the contact details below. However, you acknowledge that this right is not absolute. More information regarding the right to be forgotten, can be found below and also you can contact us directly at the contact details herein below.

When contacting us, requesting us to delete such information (or in any other case where you have a request to exercise any of your rights, as these are set out herein), we may ask you for information such as: namehome address, date of birth, telephone, business and mobile numbers, as well as any other identifying information which may be required by RM occasionally. Please note that upon contacting RM, you are not considered by the Company as anonymous anymore.

Information about your transactions as a client with RM are collected, including information about your use of the Company’s Website, the dates and times you have accessed the Website, the version of the terms of use and this Policy which you have accepted every time you log in and any other information freely provided, which RM may choose to collect occasionally. This information is collected for the purpose of providing you with the requested services or products.

RM may automatically receive and record information on its server logs from your browser, including your IP address, cookie information, and the page that has been requested.

RM uses information for the following general purposes: fulfill clients’ requests, improve the Company’s products of services, communicating with customers, for contest registrations and sweepstakes, for the submission of publications and/or advertisements, to provide information to third parties affiliated to RM and to contact the clients. We undertake that such processing of your personal data will fall under one of the above-mentioned lawful bases. We will not provide your information to nonaffiliated third parties without your prior consent. More information regarding whom we may share your personal data with, can be found below.

We may also process your personal data to tell you about products, services and offers that may be of interest to you or your business. The personal data that we process for this purpose consists of information you provide to us and data we collect and/or infer when you use our services. This information helps us to improve our services, customize browsing experience and enables us to inform you of additional products, services or promotions relevant to clients. We can only use your personal data to promote our products and services to you if we have your explicit consent to do so or, in certain cases, if we consider that it is in our legitimate interest to do so.

By entering personal information into the Website, you acknowledge that you are of legal age to enter into binding transactions in the jurisdiction from where you access the Website. This Policy was posted on the Website and is effective as of its posting. For any questions or comments regarding this Policy, please contact RM by email, at:

Automated Decision-Making and Profiling

RM uses automated processing tools as part of its identity verification (eKYC), Anti-Money Laundering (AML), sanctions screening, fraud prevention, and transaction risk assessment procedures.

Accordingly, RM may conduct automated checks to verify your identity, screen your details against sanctions lists, and assess transaction-related risk indicators.

Based on the results, RM will determine whether a transaction can proceed, requires additional information or documentation, or must be declined.

Information, Sharing and Disclosure

RM implements appropriate technical and organizational measures to secure and encrypt confidential information where appropriate.

RM does not rent, sell, or share personal information about its clients with other people or organizations except as provided herein, or under the following circumstances: to establish or exercise the Company’s legal rights or to defend against legal claims, in compliance with Banking Secrecy Law of 1956; We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of RM’ terms of use, or as otherwise required by the law.

RM is entitled to share and/or otherwise disclose your personal data to a third party, in compliance with the Banking Secrecy Law of 1956:

to the extent that it is required to do so by under and/or pursuant to any applicable legislation, rules and/or regulations;

where there is a duty to the public to disclose; or

at your request or with your consent to the parties described below. Therefore, RM may disclose your personal data, in the following circumstances:

Where required by Law;

Where requested by BDL or any other regulatory authority having control or jurisdiction over the Company;

to government bodies and law enforcement agencies where required by law and in response to other legal and regulatory requests;

to relevant authorities to investigate or prevent fraud, money laundering or other illegal activity;

where necessary in order for the RM to defend or exercise its legal rights to any court or tribunal or arbitrator or Ombudsman or governmental authority;

to such an extent as reasonably required to complete purchase transaction and provide the products or services you have requested;

to payment service providers and banks processing your transactions;

to auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes; provided that in each case the relevant professional shall be informed about the confidential nature of such information and commit to the confidentiality herein obligations as well;

only to the extent required, to other service providers for statistical purposes in order to improve the Company’s marketing, in such a case the data will be provided in an aggregate form;

to anyone authorized by you; and

to an affiliate or introducing broker of RM or any other company in the same group of the RM.

The Client acknowledges and accepts that the disclosure of personal data may be necessary to maintain the business relationship with third parties and to comply with applicable legal, regulatory, and operational requirements related to financial services. The Company shall take all reasonable measures to ensure that any third-party recipients of Client data uphold adequate standards of data protection in line with Law No. 81/2018, BDL Circulars, and any applicable regulations.

Such disclosure shall be limited strictly to the purposes stated above and shall remain valid for a period of ten (10) years, subject to renewal based on continuing legal grounds or the Client’s explicit consent, unless otherwise required by law. The Company shall retain personal data where necessary for the fulfilment of statutory obligations, including but not limited to anti-money laundering and counter-terrorism financing requirements.

The Client may, at any time, withdraw their consent to the processing of personal data and request its erasure by contacting at . However, the Company shall retain the right to preserve specific data for the duration required by applicable law and regulatory authorities.

The Company shall not be held liable for any loss or damage resulting from lawful disclosures carried out in good faith and in adherence to this Policy, provided that adequate safeguards were applied and subject to the conditions and exceptions set forth under the Lebanese Banking Secrecy Law of 1956.

Cookies

RM may use web beacons to access RM cookies inside and outside the Company’s network of websites and in connection with the Website’s Services. The Company may set and access RM cookies on your computer. Cookies are pieces of information that may track visitors’ source, click source, search keywords, and other information relating to how users access and navigate the Company’s Website. Some web-based services require those cookies. Please note that we do not sell or distribute information collected through cookies to any third party. Any information that the website may store in cookies, is used exclusively for internal purpose.

More information on cookies and how we collect and use them can be found on our “Cookies Policy” available on our Website.

Changes to This Policy

RM may update this Policy from time to time in order to ensure that it remains aligned with applicable requirements and any changes to our data management practices. Upon updating this Policy, we will ensure to notify you of such changes, where required. Moreover, a copy of the latest version of this Policy will always be available on our Website. The Company may provide its clients with notices, including those regarding changes to this Policy, by: e-mail, regular mail or postings on the Website.

Security

RM takes all appropriate measures to ensure a level of security appropriate to protect any personal data provided to us or otherwise collected by RM (where applicable) from third party sources, from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed.

Your personal data may be stored electronically or in paper form.

RM implements appropriate technical and organizational measures such as data encryption, access management procedure, clean desk policy, business continuity and disaster recovery, IT systems risk assessment, physical and logical access segregation, process in case of personal data breach policy etc. Additionally, RM limits access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process the Client’s personal data on the Company’s instructions and they are subject to a duty of confidentiality.

Online transactions are not done on the Website, they are processed through secure third-party payment gateways, for example:

Payments for the purchase of precious metals are processed through secure third-party payment gateways using the payment credentials provided by the customer at the time of checkout.

Where applicable, refunds (if approved in accordance with RM’s policies) are processed through the same authorized payment channels used for the original transaction, subject to verification of the customer’s identity and transaction details.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, RM shall notify the competent authority and, where required by applicable law, inform the affected data subjects.

What happens if I choose not to continue dealing with RM?

If you do choose to end your relationship with us, we are required to retain your Data on our records for ten (10) years, from the date of your last transaction or written request to terminate the relationship.

Further to the above, when your personal data is no longer necessary for the purpose for which it was collected, we will remove any details that will identify you or we will securely destroy the records. However, it is acknowledged that such personal data may be retained for a longer period of time where required by compliance regulations. Particularly, we are subject to certain anti-money laundering laws which require us to retain personal data for a period of five (5) years following the completion of a transaction or the end of our relationship with you, or for a longer period (which may extend up to ten (10) years where required by BDL or other competent authorities, including copies of the documents used to perform customer due diligence, supporting evidence and records of transactions with you and your relationship with us.

Your Rights

Right of access – you have a right to request us to confirm whether we are processing your personal data and to obtain a copy of the personal data that we hold about you.

Right of rectification – you have a right to request from us to correct the personal data that we hold about you if its inaccurate or incomplete. The Company will update your personal data in accordance with your instructions.

Deletion of personal data (Right to be forgotten) – you have the right, in certain circumstances, to request that we erase your personal data from our records. Where such circumstances apply and no legal exceptions exist (e.g. where we are obliged to store your personal data inwh compliance with a legal obligation under Lebanese law), the Company acting as data controller, will erase your personal data from its records.

Right to restriction of processing – you have a right to request from us where certain conditions apply, to restrict the processing of your personal data. Such conditions include cases where the processing is unlawful, and you oppose erasure and request the restriction of their use instead. However, restriction of processing does not prevent RM from storing your personal data.

Right to data portability – you have a right to receive your personal data you have provided us in a structured, commonly used and machine-readable format and, where technically feasible, to request transmission to another data controller to the extent applicable.

Right to Object/Opt-Out – you have a right to object on grounds relating to your particular situation, to certain types of processing such as direct marketing or processing based on legitimate interests (or those of a third party). However, it is well understood that under certain cases, we may demonstrate compelling legitimate grounds to process your information and data which override your rights and freedoms.

Where the processing of your personal data is based on your consent, you are entitled to withdraw such consent. However, any withdrawal of consent shall not affect the lawfulness of processing based on consent, before it was withdrawn by you.

If you exercise certain rights, we may not be able to continue providing certain services and/or products and completing transactions and we shall not be liable in this respect.

Our commitment to you

Your privacy is paramount to us, as is the privacy of every other visitor. The entire team at RM is fully committed to safeguarding any information we collect, use and hold about you.

Further to section 3 above, you further acknowledge the following:

Confirm that all personal information provided by you during the purchase, and/or identity verification process is accurate and lawful.

Agree that your personal contact details, including name and other personal information required to complete a transaction and comply with legal obligations, may be disclosed to third parties strictly as described in this Policy, including payment service providers, regulatory authorities, auditors, and service providers assisting RM in its operations.

Acknowledge that any third party entities to whom we may disclose and/or transfer your personal data may be located in countries where data protection Laws may not provide an equivalent level of protection to Lebanese Law.

Agree that your personal information may be disclosed to third parties for marketing purposes and in order to best administer your relationship with RM.

Where you have consented to marketing communications, such communications may relate to RM’s products and services.

Acknowledge that any agreement between the two parties shall be governed by and construed with the Lebanese Laws and the Lebanese Courts will have the exclusive jurisdiction in case of any dispute.

Agree that you have carefully read and understood this Policy and consent to the collection and processing of your personal data in accordance with its terms.

In order to comply with applicable legal and regulatory obligations and to complete transactions, you may be required to provide personal data necessary for the execution of such transactions and related compliance procedures.

RM processes personal data lawfully and transparently in accordance with applicable data protection laws. Where processing is based on consent, you may withdraw such consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal. In order to be in a state of compliance with the applicable laws and in order to be in a position to proceed with a business relationship with you, you must provide your personal data to us which are necessary for the required commencement and execution of a business relationship and the performance of our contractual obligations. RM is committed to protecting your privacy and handling your data in an open and transparent manner, and as such we process your personal data in accordance with the local data protection laws. Provided that you have given us your specific consent for processing, then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.

Governing Law

Any use of our website will be governed by the Laws of Lebanon, and by accessing our website you agree to be bound by all the terms and conditions that are published on the Website.

Limitation of Liability

We do not provide any warranty as to the accuracy, adequacy or completeness of the information and materials contained in our website. We also expressly reject any liability for any errors and/ or omissions in such information.

RM does not provide any warranty of any kind, whether implied expressed or statutory, including but not limited to the warranties of non-infringement of third-party rights, title merchantability, fitness for a particular purpose and freedom from computer virus, in connection with the information and materials available on our Website.

Hyperlinks to other websites are followed at your own risk. We do not control, investigate, verify, monitor, or endorse the content, accuracy, or opinions expressed on third-party websites. Accordingly, you should consult the privacy policies applicable to the website(s), in order to be properly informed about their data processing activities.

RM shall not be liable for any damages, losses or expenses arising in connection with our website or its use or inability to use by any person, including errors, omissions, interruptions, faults, delays in operation or transmission, computer viruses, communication failures, line or system failures, interference, fraudulent impersonation, unauthorized access, or erroneous recording or transmission of messages, even if RM or its representatives have been informed of the possibility of such damages, losses or costs.

We shall not be held liable for any damage that may occur to the hardware or software of any visitor arising as a result of the use of our Website and/or in connection with other websites, hyperlinks, or internet resources.

Do you have any questions?

If you have any questions or concerns that have not been addressed in this Policy, please contact us using the details provided above.

The RM Website implements appropriate technical and organizational security measures, including encryption and access controls, to protect against unauthorized access, malicious activity, and cybersecurity threats.