Privacy Policy

This Privacy Policy, together with the JGB Standard Terms and Conditions of Service (where applicable), constitutes the privacy policy of JGB Joint Gold Bullion Import-Export Co., Ltd. (“JGB”, “we”, “us”, or “our”).

When we refer to “JGB”, “we”, “us”, or “our” in this Privacy Policy, we refer to JGB Joint Gold Bullion Import-Export Co., Ltd. and its Affiliates, which are responsible for the collection, processing, and protection of your personal data.

We respect your privacy and are committed to protecting your personal data in accordance with the Law of the Lao People’s Democratic Republic on Personal Data Protection and internationally recognized privacy standards. This Privacy Policy explains how we collect, use, store, disclose, and safeguard your personal data when you:

visit our website at www.jgbbullion.com or any website operated by JGB,
access or use the JGB mobile application,
access any JGB application programming interface (API), and/or
use any services offered through the JGB Interface (collectively, the “Interface” and the “Services”).

JGB and its Affiliates are committed to complying with all applicable laws and regulations relating to personal data protection, including but not limited to:

Law of Lao PDR on Personal Data Protection, and
principles aligned with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

This Privacy Policy sets out the principles by which JGB collects, retains, manages, transfers, discloses, and processes your personal data.

Unless otherwise defined herein, terms used in this Privacy Policy shall have the meaning given under the Law of Lao PDR on Personal Data Protection and/or the GDPR, where applicable.

ACCEPTANCE OF PRIVACY POLICY

By clicking the “I Agree” button and by accessing or using our Services, you acknowledge and signify your acceptance of the terms of this Privacy Policy. JGB Joint Gold Bullion Sole Co., Ltd. (“JGB”) reserves the right to revise or update this Privacy Policy at any time to reflect changes in applicable laws or in our data collection, processing, and usage practices.

If changes are made to this Privacy Policy, JGB will notify you by email, by posting an update on the Interface, or by displaying a notice within the Services. You may be required to accept the updated Privacy Policy before continuing to use the Services.

If you do not agree with, or are not comfortable with, any part of this Privacy Policy, you must immediately discontinue access to — and use of — the Interface and the Services.

If you have any questions about this Privacy Policy or our privacy practices, please e-mail us at support@jgbbullion.com

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy is intended to provide you with clear information on how JGB collects, uses, processes, stores, and protects your personal data when you access or use the Interface and our Services. Our Interface and Services are not intended for children, and we do not knowingly collect personal data relating to children.

It is important that you read this Privacy Policy together with any other privacy notices, supplementary policies, or fair processing statements that we may provide on specific occasions when we collect or process personal data about you, so that you fully understand how and why your personal data is being used.

This Privacy Policy supplements any other notices or privacy policies (where applicable) and does not override them.

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate, complete, and up to date. You are responsible for informing us promptly if any of your personal data changes during the course of your relationship with JGB. Failure to provide accurate and updated information may affect your ability to use the Interface or Services.

THIRD-PARTY LINKS

Our Interface and Services may contain links to third-party websites, plug-ins, or applications. Clicking on such links or enabling those features may allow third parties to collect, access, or share data about you.

JGB does not control these third-party websites and is not responsible for their privacy practices, data protection policies, or content. When you leave our Interface or Services, we strongly encourage you to review the privacy policy of every website or service you access.

THE DATA WE COLLECT ABOUT YOU

“Personal data” means any information relating to an identified or identifiable individual. It does not include data where your identity has been removed or cannot be associated with you (anonymous data).

JGB may collect, use, store, and transfer different categories of personal data about you, which we group as follows:

Identity Data

first name, middle name, last name;
username or similar identifier;
marital status, title;
date of birth, age, nationality;
gender, job title/occupation;
Tax Identification Number;
passport number;
driver’s license information;
national identity card information;
visa details;
photograph or photographic identification.

Contact Data

billing address;
residential or delivery address;
email address;
mobile/telephone numbers.

Financial Data

bank account details;
payment card or transfer details;
transaction history;
bullion account activity (e.g., deposits, withdrawals, trades);
tax-related identifiers or financial verification information.

Transaction Data

payments to and from you;
gold purchases, sales activities;
name of sender/recipient;
transaction amounts;
timestamps and transaction reference data.

Technical Data

IP address;
login data;
browser type and version;
time zone setting and location;
browser plug-ins;
operating system and platform;
device identifiers;
other technical information.

Profile Data

your username and password;
purchases, bookings, orders, or program participation history;
preferences and interests;
feedback and survey responses

Usage Data

support or complaint information provided to JGB;
public social networking posts related to JGB;
authentication data or security questions;
user ID and access logs;
click-stream data;
cookies and tracking technologies.

Marketing and Communications Data

your preferences in receiving marketing from JGB or third parties;
your communication preferences.

Aggregated Data

JGB may collect, use, and share statistical or demographic data (“Aggregated Data”).
Aggregated Data may be derived from your personal data, but it is not considered personal data in law if it does not directly or indirectly reveal your identity.

Example:

JGB may use your Usage Data to determine the percentage of users who access a specific feature on the Interface.

If Aggregated Data is combined with personal data in a way that identifies you, JGB treats the combined data as personal data and processes it under this Privacy Policy.

Special Categories of Personal Data

JGB does not collect sensitive personal data, such as:

race or ethnicity;
religious or philosophical beliefs;
political opinions;
union membership;
sexual orientation;
health, genetic, or biometric data.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where JGB is required by law or by contract to collect certain personal data from you, and you fail to provide such data when requested:

JGB may be unable to provide the Services;
JGB may be unable to enter into or perform a contract with you;
JGB may need to cancel a Service or program you are enrolled in.

If cancellation is necessary, JGB will notify you at the relevant time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use various methods to collect personal data from and about you, including the following:

Direct Interactions

You may provide us with your Identity, Contact, and Financial Data by filling in forms or by communicating with us via post, phone, email, or through any other method. This includes personal data you provide when you:

apply for or use our Services;
create an account on our Interface or through our Services;
subscribe to our Services, updates, or publications;
request marketing materials, content, or notifications;
participate in competitions, promotions, or surveys; or
provide feedback or contact us for support or inquiries.

Automated Technologies / Interactions & Third-Party Sources

We may automatically collect certain technical and usage data as you interact with our Interface, such as:

browsing actions and patterns;
hardware model and device identifiers;
operating system version;
browser type and version;
IP address, MAC address, or other device identifiers;
activity logs and click-stream data.

We may also obtain personal data about you from various third-party and public sources, as permitted or required by applicable law, including:

public databases;
credit bureaus;
identity verification providers;
resellers and channel partners;
joint marketing partners;
social media platforms.

HOW WE USE YOUR PERSONAL DATA & LEGAL BASIS FOR PROCESSING

We will only use your personal data within the limits permitted by applicable law. In accordance with the legal bases set out under the GDPR and similar principles recognized under the Law of the Lao People’s Democratic Republic on Personal Data Protection, we will most commonly process your personal data where:

We need to perform a contract that we are about to enter into or have already entered into with you;
It is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests; or
We need to comply with a legal or regulatory obligation.

You may refer to the Glossary at the end of this Privacy Policy for more information on the types of lawful bases we rely on when processing your personal data.

We have set out below, in table format, an overview of how we plan to use your personal data and the legal basis for such processing. Where relevant, we have also indicated what our legitimate interests are.

Please note that we may process your personal data based on more than one lawful ground, depending on the specific purpose for which your data is being used.
If you require additional details regarding the exact lawful basis we rely upon in a particular situation, please contact us.

TABLE: PURPOSES OF PROCESSING & LEGAL BASIS

Purpose of Processing	Types of Personal Data	Legal Basis for Processing	Legitimate Interest (where applicable)
To register you as a new user and create your Bullion Account	Identity, Contact	Contract performance	—
To verify your identity and conduct KYC/AML/CTF checks	Identity, Contact, Financial, Transaction, Document Data	Compliance with legal obligations	Preventing fraud, financial crime, and ensuring regulatory compliance
To provide gold trading, gold spot pricing, bullion account services, vaulting, and physical delivery	Identity, Financial, Transaction, Profile	Contract performance	Efficient service delivery and ensuring system integrity
To process and record gold purchases, sales, deposits, withdrawals, and delivery transactions	Transaction, Financial, Identity	Contract performance	Maintaining accurate and secure transaction records
To manage payments, fees, refunds, and billing operations	Financial, Transaction, Identity	Contract performance; Legal obligation	Ensuring smooth financial operations
To communicate with you about service updates, transaction alerts, or account notifications	Identity, Contact, Transaction	Contract performance	Ensuring transparent and secure communication
To manage and enhance system security, fraud detection, and incident investigation	Technical, Usage, Identity	Legitimate interest; Legal obligation	Protecting JGB and users from security threats
To improve the Interface, Services, customer experience, and system functionality	Technical, Usage, Profile	Legitimate interest	Enhancing platform efficiency and user experience
To conduct data analytics (e.g., market analysis, service usage monitoring)	Usage, Technical, Aggregated Data	Legitimate interest	Business development and service optimization
To administer promotions, rewards, surveys, or loyalty programs	Identity, Contact, Profile, Usage	Contract performance; Legitimate interest	Engaging users and enhancing participation
To send marketing, promotions, and communications (if you opt in)	Identity, Contact, Marketing Preferences	Consent	Growing JGB’s services responsibly
To comply with laws, regulations, reporting duties, and requests from government or regulators	Identity, Financial, Transaction	Legal obligation	Ensuring JGB complies with AML, tax, customs & financial regulations
To maintain business records, audit trails, and risk management files	Transaction, Financial, Identity, Technical	Legal obligation; Legitimate interest	Ensuring operational accountability and audit readiness
To settle disputes, enforce rights, and manage legal claims	Identity, Contact, Transaction	Legitimate interest; Legal obligation	Protecting JGB’s legal rights and responding to claims
To prevent misuse of Services, abuse, or unauthorized access	Technical, Usage, Profile	Legitimate interest	Maintaining platform integrity and user safety
To provide customer support and resolve issues	Identity, Contact, Usage, Transaction	Contract performance	Delivering effective user assistance

MARKETING

We may use your personal data to determine which products, services, or updates we believe may be relevant or of interest to you in connection with the Interface or the provision of our Services, including Bullion Accounts, LBMA Gold products, gold-trading features, or related offerings.
Based on your communication preferences, we may send you marketing communications regarding JGB events, industry news, gold-market updates, or partner promotions; deliver targeted advertising; and provide promotional offers or content tailored to your interests.

You may update your marketing preferences at any time in accordance with this Privacy Policy.

INFORMATION SHARED WITH THIRD PARTIES

From time to time, we engage third-party companies, vendors, and individuals to perform certain functions on our behalf where necessary for the operation of our business and the provision of our Services. We also use third-party software and applications that may process information qualifying as your personal data. These third parties are granted access only to the personal data required to perform their designated functions and are strictly prohibited from using such data for any other purpose.

We will only share your personal data with third parties that have a legitimate and lawful basis for accessing it, including but not limited to the following:

Identity Verification & Compliance Partners

We share your personal data with third-party identity verification and due diligence providers in order to comply with AML Laws, CTF Laws, Anti-Bribery Laws, Sanctions Laws, and other Applicable Laws, including requirements specific to bullion trading and precious metals compliance.

Professional & Operational Service Providers

We share your personal data with service providers who deliver professional or operational support services—such as consultancy, banking, legal, design, data analytics, IT systems, insurance, accounting, marketing, and other business-critical functions—under contractual agreements that support our business operations.

Financial Institutions & Payment Partners

We share your personal data with financial institutions and banking partners that process payments or transactions authorized by you, including settlement of bullion trades, LBMA gold purchases, and related financial operations.

Corporate Transactions (Mergers & Acquisitions)

We may share your personal data with companies or legal entities involved in a potential or actual merger, acquisition, restructuring, or corporate reorganization involving JGB. In such an event, we will require the new combined entity to honor this Privacy Policy with respect to your personal data. You will be notified in advance of any material changes to the applicable policies.

Law Enforcement, Regulatory Bodies & Government Authorities

We share your personal data with law enforcement, regulators, courts, or other governmental authorities when required by subpoena, court order, regulatory request, or other applicable legal procedure; or where we believe, in good faith, that such disclosure is necessary to:

prevent physical harm or financial loss;
report suspected illegal activity (including suspicious bullion trading activity);
comply with KYC/AML/CTF regulations; or
investigate potential violations of our Terms, policies, or applicable laws.

We require all third parties to maintain strict confidentiality, protect the security of your personal data, and process such data only in accordance with this Privacy Policy, contractual obligations, and applicable laws.

OPTING OUT

You may opt out of having your personal data shared with third parties, or of allowing us to use your personal data for any purpose that is incompatible with the purposes for which it was originally collected or subsequently authorized by you. However, if you choose to opt out, please note that certain features of our Interface or Services — including those related to Bullion Account access, LBMA gold trading, or JGB’s compliance procedures — may no longer be available to you or may function with limited capability.

COOKIES

You may configure your browser settings to refuse all or some browser cookies, or to receive alerts when cookies are being set or accessed. Please be aware that disabling or refusing cookies may cause certain features of our Interface or Services to become inaccessible or may impair functionality, including features related to real-time gold spot pricing, trading dashboards, and account verification.
For more details regarding the types of cookies we use, please refer to our Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which it was collected, unless we reasonably determine that we must use it for another purpose and that such purpose is compatible with the original one or required to comply with Applicable Laws (including AML, CTF, KYC, and precious-metal trading regulations).
If you wish to receive an explanation regarding how the processing for a new purpose remains compatible with the original purpose, please contact us.

If we need to use your personal data for any purpose unrelated to the original purpose, we will notify you and explain the legal basis that permits us to do so.

Please note that, where required or permitted by law, we may process your personal data without your knowledge or consent, provided such processing complies with all relevant legal requirements.

DATA SECURITY

We implement appropriate technical and organizational security measures to protect your personal data from accidental loss, unauthorized access, misuse, alteration, or disclosure. Access to your personal data is strictly limited to authorized personnel and third parties with a legitimate business need, all of whom are bound by confidentiality obligations.

We maintain procedures for managing suspected data breaches and will notify you and any relevant regulatory authority where required by law.

DATA RETENTION

We will retain your personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, tax, accounting, audit, anti-money laundering, counter-terrorist financing, sanctions compliance, and reporting obligations applicable to JGB. We may retain your personal data for a longer period where necessary in the event of a complaint, regulatory inquiry, or if we reasonably believe that litigation relating to our relationship with you may arise.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data; the potential risk of harm from unauthorized access, use, or disclosure; the purposes for which we process the data and whether those purposes can be achieved through other means; and all applicable legal, regulatory, tax, accounting and compliance requirements, including those relevant to bullion trading, LBMA gold transactions, and KYC/AML obligations.

Contact information—such as your name, email address, and telephone number—used for marketing purposes will be retained on an ongoing basis until you choose to unsubscribe.

Content you submit or post on our Interface (including support requests, comments, documents, photographs, videos, and other uploaded material) may be retained indefinitely, even after you close your account, to support audit, regulatory compliance, fraud detection, and crime-prevention purposes.

YOUR LEGAL RIGHTS

Subject to applicable data protection laws, you may exercise the following rights regarding your personal data:

Access: Request a copy of the personal data we hold about you.
Correction: Request correction of inaccurate or incomplete personal data.
Erasure: Request deletion of your personal data where there is no lawful reason for us to continue processing it (subject to legal and regulatory retention requirements).
Objection: Object to our processing where it is based on legitimate interests or where your data is used for direct marketing.
Restriction: Request that we suspend processing of your personal data in specific circumstances (e.g., to verify accuracy or for legal claims).
Data Portability: Request transfer of your personal data to you or a third party in a structured, machine-readable format, where applicable.
Withdraw Consent: Withdraw your consent at any time where processing is based on consent; however, this may affect our ability to provide certain Services.

If you wish to exercise any of these rights, please contact us through the channels provided in this Privacy Policy.

OTHER

Legitimate Interest
Means our business interest in operating, managing, and improving our Services to provide you with a secure and efficient experience. We carefully assess and balance any potential impact on your rights before processing personal data on this basis. We do not rely on legitimate interest where such interests are overridden by your rights, unless we have your consent or are permitted by law.

Performance of Contract
Means processing your personal data where necessary to perform a contract with you or to take steps at your request before entering into a contract.

Comply with a Legal Obligation
Means processing your personal data where required to comply with applicable laws to which we are subject.

CONTACT DETAILS

If you have any questions regarding this Privacy Policy or our data protection practices, please e-mail us at Support@jgbbullion.com

You have the right to complain at any time to the Information and Data Protection Tribunal (“Tribunal”). However, we would appreciate the opportunity to address your concerns internally before you approach the Tribunal.