Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") governs how Africa Metals & Minerals Commodities Limited ("AMMC," "we," "us," or "the Company") collects, uses, stores, protects, and discloses information obtained from Buyers, Sellers (Suppliers), Agents, and visitors ("Users") of the AMMC platform at africametalsminerals.com.

AMMC operates as a principal-led, closed-loop trade infrastructure where AMMC is the sole buyer of record from Sellers and the sole seller of record to Buyers. No direct relationship exists between Buyers and Sellers. This Policy reflects that structure and the corresponding data handling obligations.

2. Information We Collect

We collect information necessary to facilitate trade, ensure regulatory compliance, and protect the integrity of AMMC's closed-loop infrastructure:

2.1 Information Provided by Users

• Personal identification: full name, email address, phone number, nationality, date of birth
• Business credentials: company legal name, registration number, country of incorporation, business address, representative details
• KYC/AML documentation: government-issued identification, proof of address, company registration documents, beneficial ownership declarations
• Trade credentials: supplier certifications, mining licenses, export permits, certificates of analysis, provenance records
• Shipping and logistics: delivery addresses, port preferences, Incoterms selections, customs documentation
• Agent-specific data: referral codes, referral chain records, commission banking details

2.2 Information Generated Through Platform Use

• Transaction records: order history, bid participation, bulk request submissions, escrow activity, settlement records
• Verification records: inspection reports, test results, quality assessments, media verification logs
• Communication records: messages exchanged through the platform, trade desk correspondence, dispute submissions
• Device and usage data: IP address, browser type, operating system, pages visited, session duration, geolocation data

3. How We Use Information

We process collected information strictly for the following purposes:

• Processing, fulfilling, and settling commodity orders, bulk requests, and bids within AMMC's closed-loop infrastructure
• Conducting KYC/AML verification, sanctions screening, and ongoing compliance monitoring for all user categories
• Performing independent product verification, testing, and quality assurance through AMMC or its appointed inspection partners
• Calculating shipping logistics, customs duties, and delivery estimates
• Administering escrow accounts, payment processing, and trade settlements where AMMC is the contracting counterparty
• Managing agent referral chains, commission calculations, and payout processing
• Providing customer and trade desk support, including dispute resolution
• Detecting and preventing fraud, payment disputes, unauthorized chargebacks, money laundering, and sanctioned trade
• Improving platform functionality, security infrastructure, and user experience
• Complying with applicable legal, regulatory, and tax obligations

4. Payment & Transaction Data

AMMC does not store payment card details. All card processing is handled by PCI DSS-compliant third-party payment providers.

• Transaction metadata including amounts, currencies, payment method, payment status, and timestamps are maintained by AMMC for audit, compliance, chargeback defence, and dispute resolution purposes
• Escrow transaction data, milestone records, and settlement confirmations are retained for the duration required by applicable financial regulations and AMMC's internal compliance framework
• Payment data may be used to defend against unauthorized chargebacks, payment reversals, or bank disputes initiated in breach of AMMC's Terms of Service

5. Data Sharing & Disclosure

We do not sell, trade, or rent your personal information. Consistent with AMMC's principal model where no direct Buyer-Seller relationship exists, data sharing is strictly limited:

5.1 Limited Operational Sharing

• With logistics and shipping providers: only the minimum information required for delivery coordination (consignee details, delivery address, commodity description, weight)
• With payment processors: only information necessary for transaction execution and chargeback defence
• With accredited inspection and testing partners: only information necessary for product verification and quality assurance
• With AMMC's legal counsel: in the event of disputes, litigation, or regulatory proceedings

5.2 Information Not Shared

• Buyer identities, order details, or commercial terms are never disclosed to Sellers. Sellers' sole counterparty is AMMC
• Seller identities, sourcing details, supply chain information, or pricing terms are never disclosed to Buyers. Buyers' sole counterparty is AMMC
• Agent referral chains, commission structures, and override arrangements are not disclosed to Buyers or Sellers
• AMMC's internal pricing models, margin structures, settlement schedules, and operational data are strictly confidential and are not disclosed to any User under any circumstances

5.3 Regulatory & Legal Disclosure

• We may disclose User information when required by law, regulation, court order, or governmental request from a competent authority
• We may disclose information to enforce our Terms of Service, protect AMMC's legal rights, or defend against legal claims
• In no event shall any regulatory or legal disclosure include AMMC's proprietary commercial data, trade methodologies, supplier networks, or internal operational documentation unless specifically and individually compelled by a court of competent jurisdiction

6. AMMC Company Documentation & Proprietary Information

AMMC's internal company documentation, including but not limited to the following, is strictly confidential and proprietary and shall not be released, disclosed, shared, or made available to any User, third party, or external entity under any circumstances whatsoever:

• Corporate formation documents, shareholder agreements, board resolutions, and governance records
• Internal financial statements, profit and loss records, balance sheets, and management accounts
• Supplier contracts, purchase agreements, pricing arrangements, and settlement terms with Sellers
• Buyer contracts, sales agreements, margin structures, and commercial arrangements with Buyers
• Agent agreements, commission structures, override arrangements, and referral network architecture
• Internal compliance procedures, risk assessment frameworks, and due diligence methodologies
• Trade flow data, sourcing strategies, logistics arrangements, and operational playbooks
• Technology infrastructure details, platform architecture, security protocols, and system configurations
• Employee records, internal communications, strategic plans, and business development materials

No User, counterparty, agent, or third party has any right to request, demand, compel, or obtain access to any AMMC company documentation, regardless of the nature of the commercial relationship, the value of transactions conducted, or any claim or dispute arising from platform use. This restriction applies during and after the term of any User's engagement with the platform and survives termination of these Terms indefinitely.

Any attempt to access, solicit, reverse-engineer, or compel disclosure of AMMC's proprietary documentation through legal action, regulatory complaint, or other means shall be considered a material breach and may result in immediate account termination, forfeiture of pending payments, and pursuit of all available legal remedies by AMMC.

7. Cookies & Tracking Technologies

We use cookies and similar technologies to maintain session state, authenticate Users, manage cart functionality, remember preferences, and analyse platform usage patterns. Essential cookies are required for platform functionality. Analytics cookies help us improve service quality. You can control non-essential cookie settings through your browser preferences, though disabling essential cookies may impair platform functionality.

8. Data Retention

• Personal and business data is retained for as long as your account is active and for a minimum of seven (7) years thereafter to comply with Nigerian commercial record-keeping requirements, international trade compliance standards, and tax obligations
• Transaction records, escrow documentation, settlement records, and trade correspondence are retained for a minimum of ten (10) years from the date of the last transaction
• KYC/AML records are retained in accordance with applicable anti-money laundering regulations, which may require retention beyond account closure
• Verification and inspection records are retained for the duration required to support warranty claims, dispute resolution, and regulatory inquiries
• Data may be retained longer where required by law, ongoing disputes, or legitimate business interests including chargeback defence

9. User Rights

Subject to applicable law and the limitations set out in this Policy, you may exercise the following rights:

• Access: Request confirmation of whether we process your personal data and obtain a copy thereof
• Correction: Request correction of inaccurate or incomplete personal information
• Deletion: Request deletion of your personal data, subject to legal retention obligations, ongoing disputes, and AMMC's legitimate interests
• Portability: Request your personal data in a structured, machine-readable format where technically feasible
• Objection: Object to specific processing activities where processing is based on legitimate interests

Important limitations:The exercise of data rights does not extend to AMMC's company documentation, proprietary data, trade records where AMMC is a party, or any information that AMMC is required to retain for regulatory compliance, dispute resolution, or chargeback defence. Deletion requests will not be honoured where they would impair AMMC's ability to defend against claims, comply with legal obligations, or enforce its Terms of Service.

To exercise your rights, contact us at Support@africametalsminerals.com. We will respond within thirty (30) days and may require identity verification before processing your request.

10. Data Security

We implement industry-standard technical and organisational measures to protect your data, including encryption in transit (TLS) and at rest, role-based access controls, multi-factor authentication for administrative access, regular security audits, intrusion detection systems, and secure cloud infrastructure hosted within reputable data centres. However, no method of electronic transmission or storage is 100% secure, and AMMC cannot guarantee absolute security. Users are responsible for maintaining the confidentiality of their account credentials.

11. International Data Transfers

As an international trade platform, your data may be processed and stored in jurisdictions outside your country of residence, including Nigeria, the United Kingdom, and other locations where AMMC's infrastructure or service providers operate. By using the platform, you consent to such transfers. AMMC implements appropriate safeguards including contractual protections with service providers to ensure your data receives equivalent protection regardless of jurisdiction.

12. Updates to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the platform and by updating the "Last updated" date above. Continued use of the platform after changes constitutes acceptance of the revised Policy. We encourage Users to review this Policy periodically.

13. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of the courts of the Federal Capital Territory, Abuja, Nigeria.

14. Contact Information

For privacy-related enquiries, data rights requests, or concerns about how we handle your information: