PRIVACY POLICY

PRIVACY POLICY & DISCLAIMER

General
BMB Base Metals Brokerage GmbH is a BaFin registered Tied Agent (No.150029) of Toyota Tsusho Metals Ltd., which is authorised and regulated by the UK Financial Conduct Authority (Reg.No. 189983).. Mention of specific commodities should not be taken as a recommendation to buy or sell these commodities. Commodity derivative trading is risky and you should understand those risks before trading. Neither any information presented, nor any opinion expressed on this website, constitutes a solicitation to buy or sell futures or options or futures contracts, or OTC products.

Limitation of liability for internal content

The content of our website has been compiled with meticulous care and to the best of our knowledge. However, we cannot assume any liability for the up-to-dateness, completeness or accuracy of any of the pages.

Pursuant to section 7, para. 1 of the TMG (Telemediengesetz – Tele Media Act by German law), we as service providers are liable for our own content on these pages in accordance with general laws. However, pursuant to sections 8 to 10 of the TMG, we as service providers are not under obligation to monitor external information provided or stored on our website. Once we have become aware of a specific infringement of the law, we will immediately remove the content in question. Any liability concerning this matter can only be assumed from the point in time at which the infringement becomes known to us.

Limitation of liability for external links

Our website contains links to the websites of third parties (“external links”). As the content of these websites is not under our control, we cannot assume any liability for such external content. In all cases, the provider of information of the linked websites is liable for the content and accuracy of the information provided. At the point in time when the links were placed, no infringements of the law were recognisable to us. As soon as an infringement of the law becomes known to us, we will immediately remove the link in question.

Copyright

The content and works published on this website are governed by the copyright laws of Germany. Any duplication, processing, distribution or any form of utilisation beyond the scope of copyright law shall require the prior written consent of the author or authors in question.

Data protection

A visit to our website can result in the storage on our server of information about the access (date, time, page accessed). This does not represent any analysis of personal data (e.g., name, address or e-mail address). If personal data are collected, this only occurs – to the extent possible – with the prior consent of the user of the website. Any forwarding of the data to third parties without the express consent of the user shall not take place.

Privacy Policy

We are very delighted that you have shown interest in our enterprise.

Data protection is of a particularly high priority for the management of

the BMB Base Metals Brokerage GmbH . The use of the Internet pages of the

BMB Base Metals Brokerage GmbH is possible without any indication of

personal data; however, if a data subject wants to use special enterprise

services via our website, processing of personal data could become

necessary. If the processing of personal data is necessary and there is no

statutory basis for such processing, we generally obtain consent from the

data subject.

The processing of personal data, such as the name, address, e-mail

address, or telephone number of a data subject shall always be in line

with the General Data Protection Regulation (GDPR), and in accordance with

the country-specific data protection regulations applicable to the BMB

Base Metals Brokerage GmbH. By means of this data protection declaration,

our enterprise would like to inform the general public of the nature,

scope, and purpose of the personal data we collect, use and process.

Furthermore, data subjects are informed, by means of this data protection

declaration, of the rights to which they are entitled.

As the controller, the BMB Base Metals Brokerage GmbH has implemented

numerous technical and organizational measures to ensure the most complete

protection of personal data processed through this website. However,

Internet-based data transmissions may in principle have security gaps, so

absolute protection may not be guaranteed. For this reason, every data

subject is free to transfer personal data to us via alternative means,

e.g. by telephone.

1. Definitions

The data protection declaration of the BMB Base Metals Brokerage GmbH

is based on the terms used by the European legislator for the adoption of

the General Data Protection Regulation (GDPR). Our data protection

declaration should be legible and understandable for the general public,

as well as our customers and business partners. To ensure this, we would

like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following

terms:

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation

(GDPR), other data protection laws applicable in Member states of the

European Union and other provisions related to data protection is:

BMB Base Metals Brokerage GmbH

Neuer Wall 36

20354 Hamburg

Germany

Phone: +494038686-0

Email: datenschutz@bmbrokerage.de

Website: www.metalbrokers.de

3. Collection of general data and information

The website of the BMB Base Metals Brokerage GmbH collects a series of

general data and information when a data subject or automated system calls

up the website. This general data and information are stored in the server

log files. Collected may be (1) the browser types and versions used, (2)

the operating system used by the accessing system, (3) the website from

which an accessing system reaches our website (so-called referrers), (4)

the sub-websites, (5) the date and time of access to the Internet site,

(6) an Internet protocol address (IP address), (7) the Internet service

provider of the accessing system, and (8) any other similar data and

information that may be used in the event of attacks on our information

technology systems.

When using these general data and information, the BMB Base Metals

Brokerage GmbH does not draw any conclusions about the data subject.

Rather, this information is needed to (1) deliver the content of our

website correctly, (2) optimize the content of our website as well as its

advertisement, (3) ensure the long-term viability of our information

technology systems and website technology, and (4) provide law enforcement

authorities with the information necessary for criminal prosecution in

case of a cyber-attack. Therefore, the BMB Base Metals Brokerage GmbH

analyzes anonymously collected data and information statistically, with

the aim of increasing the data protection and data security of our

enterprise, and to ensure an optimal level of protection for the personal

data we process. The anonymous data of the server log files are stored

separately from all personal data provided by a data subject.

4. Registration on our website

The data subject has the possibility to register on the website of the

controller with the indication of personal data. Which personal data are

transmitted to the controller is determined by the respective input mask

used for the registration. The personal data entered by the data subject

are collected and stored exclusively for internal use by the controller,

and for his own purposes. The controller may request transfer to one or

more processors (e.g. a parcel service) that also uses personal data for

an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—

assigned by the Internet service provider (ISP) and used by the data

subject—date, and time of the registration are also stored. The storage of

this data takes place against the background that this is the only way to

prevent the misuse of our services, and, if necessary, to make it possible

to investigate committed offenses. Insofar, the storage of this data is

necessary to secure the controller. This data is not passed on to third

parties unless there is a statutory obligation to pass on the data, or if

the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of

personal data, is intended to enable the controller to offer the data

subject contents or services that may only be offered to registered users

due to the nature of the matter in question. Registered persons are free

to change the personal data specified during the registration at any time,

or to have them completely deleted from the data stock of the

controller.

The data controller shall, at any time, provide information upon

request to each data subject as to what personal data are stored about the

data subject. In addition, the data controller shall correct or erase

personal data at the request or indication of the data subject, insofar as

there are no statutory storage obligations. The entirety of the

controller’s employees are available to the data subject in this respect

as contact persons.

5. Subscription to our newsletters

On the website of the BMB Base Metals Brokerage GmbH, users are given

the opportunity to subscribe to our enterprise’s newsletter. The input

mask used for this purpose determines what personal data are transmitted,

as well as when the newsletter is ordered from the controller.

The BMB Base Metals Brokerage GmbH informs its customers and business

partners regularly by means of a newsletter about enterprise offers. The

enterprise’s newsletter may only be received by the data subject if (1)

the data subject has a valid e-mail address and (2) the data subject

registers for the newsletter shipping. A confirmation e-mail will be sent

to the e-mail address registered by a data subject for the first time for

newsletter shipping, for legal reasons, in the double opt-in procedure.

This confirmation e-mail is used to prove whether the owner of the e-mail

address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP

address of the computer system assigned by the Internet service provider

(ISP) and used by the data subject at the time of the registration, as

well as the date and time of the registration. The collection of this data

is necessary in order to understand the (possible) misuse of the e-mail

address of a data subject at a later date, and it therefore serves the aim

of the legal protection of the controller.

The personal data collected as part of a registration for the

newsletter will only be used to send our newsletter. In addition,

subscribers to the newsletter may be informed by e-mail, as long as this

is necessary for the operation of the newsletter service or a registration

in question, as this could be the case in the event of modifications to

the newsletter offer, or in the event of a change in technical

circumstances. There will be no transfer of personal data collected by the

newsletter service to third parties. The subscription to our newsletter

may be terminated by the data subject at any time. The consent to the

storage of personal data, which the data subject has given for shipping

the newsletter, may be revoked at any time. For the purpose of revocation

of consent, a corresponding link is found in each newsletter. It is also

possible to unsubscribe from the newsletter at any time directly on the

website of the controller, or to communicate this to the controller in a

different way.

6. Newsletter-Tracking

The newsletter of the BMB Base Metals Brokerage GmbH contains so-called

tracking pixels. A tracking pixel is a miniature graphic embedded in such

e-mails, which are sent in HTML format to enable log file recording and

analysis. This allows a statistical analysis of the success or failure of

online marketing campaigns. Based on the embedded tracking pixel, the MBH

Metalbrokers Hamburg GmbH may see if and when an e-mail was opened by a

data subject, and which links in the e-mail were called up by data

subjects.

Such personal data collected in the tracking pixels contained in the

newsletters are stored and analyzed by the controller in order to optimize

the shipping of the newsletter, as well as to adapt the content of future

newsletters even better to the interests of the data subject. These

personal data will not be passed on to third parties. Data subjects are at

any time entitled to revoke the respective separate declaration of consent

issued by means of the double-opt-in procedure. After a revocation, these

personal data will be deleted by the controller. The BMB Base Metals Brokerage GmbH automatically regards a withdrawal from the receipt of the

newsletter as a revocation.

7. Contact possibility via the website

The website of the BMB Base Metals Brokerage GmbH contains information

that enables a quick electronic contact to our enterprise, as well as

direct communication with us, which also includes a general address of the

so-called electronic mail (e-mail address). If a data subject contacts the

controller by e-mail or via a contact form, the personal data transmitted

by the data subject are automatically stored. Such personal data

transmitted on a voluntary basis by a data subject to the data controller

are stored for the purpose of processing or contacting the data subject.

There is no transfer of this personal data to third parties.

8. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the

data subject only for the period necessary to achieve the purpose of

storage, or as far as this is granted by the European legislator or other

legislators in laws or regulations to which the controller is subject

to.

If the storage purpose is not applicable, or if a storage period

prescribed by the European legislator or another competent legislator

expires, the personal data are routinely blocked or erased in accordance

with legal requirements.

9. Rights of the data subject

10. Data protection for applications and the application

procedures

The data controller shall collect and process the personal data of

applicants for the purpose of the processing of the application procedure.

The processing may also be carried out electronically. This is the case,

in particular, if an applicant submits corresponding application documents

by e-mail or by means of a web form on the website to the controller. If

the data controller concludes an employment contract with an applicant,

the submitted data will be stored for the purpose of processing the

employment relationship in compliance with legal requirements. If no

employment contract is concluded with the applicant by the controller, the

application documents shall be automatically erased two months after

notification of the refusal decision, provided that no other legitimate

interests of the controller are opposed to the erasure. Other legitimate

interest in this relation is, e.g. a burden of proof in a procedure under

the General Equal Treatment Act (AGG).

11. Data protection provisions about the application and use of

Google Analytics (with anonymization function)

On this website, the controller has integrated the component of Google

Analytics (with the anonymizer function). Google Analytics is a web

analytics service. Web analytics is the collection, gathering, and

analysis of data about the behavior of visitors to websites. A web

analysis service collects, inter alia, data about the website from which a

person has come (the so-called referrer), which sub-pages were visited, or

how often and for what duration a sub-page was viewed. Web analytics are

mainly used for the optimization of a website and in order to carry out a

cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600

Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the

application “_gat. _anonymizeIp”. By means of this application the IP

address of the Internet connection of the data subject is abridged by

Google and anonymised when accessing our websites from a Member State of

the European Union or another Contracting State to the Agreement on the

European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic

on our website. Google uses the collected data and information, inter

alia, to evaluate the use of our website and to provide online reports,

which show the activities on our websites, and to provide other services

concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system

of the data subject. The definition of cookies is explained above. With

the setting of the cookie, Google is enabled to analyze the use of our

website. With each call-up to one of the individual pages of this Internet

site, which is operated by the controller and into which a Google

Analytics component was integrated, the Internet browser on the

information technology system of the data subject will automatically

submit data through the Google Analytics component for the purpose of

online advertising and the settlement of commissions to Google. During the

course of this technical procedure, the enterprise Google gains knowledge

of personal information, such as the IP address of the data subject, which

serves Google, inter alia, to understand the origin of visitors and

clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access

time, the location from which the access was made, and the frequency of

visits of our website by the data subject. With each visit to our Internet

site, such personal data, including the IP address of the Internet access

used by the data subject, will be transmitted to Google in the United

States of America. These personal data are stored by Google in the United

States of America. Google may pass these personal data collected through

the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies

through our website at any time by means of a corresponding adjustment of

the web browser used and thus permanently deny the setting of cookies.

Such an adjustment to the Internet browser used would also prevent Google

Analytics from setting a cookie on the information technology system of

the data subject. In addition, cookies already in use by Google Analytics

may be deleted at any time via a web browser or other software

programs.

In addition, the data subject has the possibility of objecting to a

collection of data that are generated by Google Analytics, which is

related to the use of this website, as well as the processing of this data

by Google and the chance to preclude any such. For this purpose, the data

subject must download a browser add-on under the link

https://tools.google.com/dlpage/gaoptout and install it. This browser

add-on tells Google Analytics through a JavaScript, that any data and

information about the visits of Internet pages may not be transmitted to

Google Analytics. The installation of the browser add-ons is considered an

objection by Google. If the information technology system of the data

subject is later deleted, formatted, or newly installed, then the data

subject must reinstall the browser add-ons to disable Google Analytics. If

the browser add-on was uninstalled by the data subject or any other person

who is attributable to their sphere of competence, or is disabled, it is

possible to execute the reinstallation or reactivation of the browser

add-ons.

Further information and the applicable data protection provisions of

Google may be retrieved under

https://www.google.com/intl/en/policies/privacy/ and under

http://www.google.com/analytics/terms/us.html. Google Analytics is further

explained under the following Link https://www.google.com/analytics/.

12. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing

operations for which we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a

contract to which the data subject is party, as is the case, for example,

when processing operations are necessary for the supply of goods or to

provide any other service, the processing is based on Article 6(1) lit. b

GDPR. The same applies to such processing operations which are necessary

for carrying out pre-contractual measures, for example in the case of

inquiries concerning our products or services. Is our company subject to a

legal obligation by which processing of personal data is required, such as

for the fulfillment of tax obligations, the processing is based on Art. 6

(1) lit. c GDPR.
In rare cases, the processing of personal data may be necessary to protect

the vital interests of the data subject or of another natural person. This

would be the case, for example, if a visitor were injured in our company

and his name, age, health insurance data or other vital information would

have to be passed on to a doctor, hospital or other third party. Then the

processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1) lit. f GDPR.

This legal basis is used for processing operations which are not covered

by any of the abovementioned legal grounds, if processing is necessary for

the purposes of the legitimate interests pursued by our company or by a

third party, except where such interests are overridden by the interests

or fundamental rights and freedoms of the data subject which require

protection of personal data. Such processing operations are particularly

permissible because they have been specifically mentioned by the European

legislator. He considered that a legitimate interest could be assumed if

the data subject is a client of the controller (Recital 47 Sentence 2

GDPR).

13. The legitimate interests pursued by the controller or by a

third party

Where the processing of personal data is based on Article 6(1) lit. f

GDPR our legitimate interest is to carry out our business in favor of the

well-being of all our employees and the shareholders.

14. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data

is the respective statutory retention period. After expiration of that

period, the corresponding data is routinely deleted, as long as it is no

longer necessary for the fulfillment of the contract or the initiation of

a contract.

15. Provision of personal data as statutory or contractual

requirement; Requirement necessary to enter into a contract; Obligation of

the data subject to provide the personal data; possible consequences of

failure to provide such data

We clarify that the provision of personal data is partly required by

law (e.g. tax regulations) or can also result from contractual provisions

(e.g. information on the contractual partner).

Sometimes it may be necessary to conclude a contract that the data subject

provides us with personal data, which must subsequently be processed by

us. The data subject is, for example, obliged to provide us with personal

data when our company signs a contract with him or her. The non-provision

of the personal data would have the consequence that the contract with the

data subject could not be concluded.

Before personal data is provided by the data subject, the data subject

must contact any employee. The employee clarifies to the data subject

whether the provision of the personal data is required by law or contract

or is necessary for the conclusion of the contract, whether there is an

obligation to provide the personal data and the consequences of non-

provision of the personal data.

16. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or

profiling.

We would like to expressly point out that the transmission of data via

the Internet (e.g., by e-mail) can offer security vulnerabilities. It is

therefore impossible to safeguard the data completely against access by

third parties. We cannot assume any liability for damages arising as a

result of such security vulnerabilities.

The use by third parties of all published contact details for the

purpose of advertising is expressly excluded. We reserve the right to take

legal steps in the case of the unsolicited sending of advertising

information; e.g., by means of spam mail.

BMB Base Metals Brokerage GmbH