647 Main St. Suite #200B Lake Geneva, WI. 53147

Wisconsin Precious metals refining services buying, selling & refining

PRIVACY POLICY

DATA PROTECTION AND PRIVACY POLICY

Wisconsin Precious Metals Refining Services (WPMRS) respects individual privacy and values the confidence of its customers, employees, vendors, business partners and others. WPMRS strives to collect, store, process and distribute Personal Information in a manner consistent with the laws of the countries in which it does business, as well as the GDPR. This Data Protection and Privacy Policy (the “Policy”) sets forth the privacy principles that WPMRS follows with respect to Personal Information transferred to WPMRS from anywhere in the world, including transfers from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway).

SCOPE

This Policy applies to all Personal Information received by WPMRS in any format including electronic, paper or verbal. WPMRS collects, stores and processes Personal Information concerning current and former employees, as well as applicants for employment through its Internet websites, its intranet site, electronic mail and manually. WPMRS will not sell or share this information with third parties in ways different than what is disclosed in this Policy. On a global basis, WPMRS will establish and maintain business procedures that are consistent with this Policy. Notwithstanding the foregoing, WPMRS has separate policies governing the processing of employee personal data and external personal data in those countries that are members of the EU. These policies are consistent with EU data protection law.

WPMRS collects, stores, and processes Personal Information from prospective customers, vendors, professional advisers and consultants, distributors, dealers, suppliers, business partners and others, such as name, contact and financial information. This information may be maintained at its offices in Lake Geneva, Wisconsin or at other WPMRS facilities, and its authorized agents, consistent with local legislation. WPMRS collects this Personal Information for, among other things, legitimate business reasons such as processing and fulfilling orders; customer service; the provision of services or products to WPMRS, product, warranty and claims administration; meeting governmental reporting and records requirements; maintenance of accurate accounts payable and receivable records; marketing; internal marketing research; safety and performance management; financial and sales data; and contact information. All Personal Information collected by WPMRS will be used for legitimate business purposes consistent with this Policy.

WPMRS may process and disclose Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which an WPMRS business is acquired by or merged with another business, or sells, liquidates, or transfers all or a portion of its assets.

WPMRS also may process or disclose Personal Information as is reasonably necessary or legally required on important public interest grounds, to respond to lawful requests by public authorities (including to meet national security or law enforcement requests), to meet governmental reporting or records requirements, or for the establishment, exercise or defense of legal claims by WPMRS or other companies within its corporate group.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that processes Personal Information provided by WPMRS to perform tasks on behalf of or at the instruction of WPMRS.

“WPMRS” means Wisconsin Precious Metals Refining Services.

“Personal Information” means any information or set of information that identifies or could be used by or on behalf of WPMRS to identify an individual. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Information.

“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, trade union membership, political opinions, or religious or philosophical beliefs, that concerns health or sex life, or that contains criminal records. In addition, WPMRS will treat as Sensitive Personal Information any Personal Information received from a third party where that third party treats and identifies the Personal Information as sensitive.

PRIVACY PRINCIPLES

WPMRS commits to subject the Personal Information covered by this policy to the following principles:

NOTICE: Where WPMRS collects Personal Information directly from individuals, it will inform them about the purposes for which it collects, stores and processes Personal Information about them, the types of non-Agent third parties to which WPMRS discloses that information, and the choices and means, if any, WPMRS offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to WPMRS, or as soon as practicable thereafter, and in any event before WPMRS uses the information for a purpose other than that for which it was originally collected.
CHOICE: WPMRS will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-Agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For Sensitive Personal Information, WPMRS will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of the information to a non-Agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

WPMRS will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

DATA INTEGRITY AND PURPOSE LIMITATION: WPMRS will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. WPMRS will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete and current.
ACCOUNTABILITY FOR ONWARD TRANSFER: WPMRS uses third-party Agents to assist us in accomplishing the purposes described in this Policy, for example to support our customers, perform technical operations, and store and transmit data. WPMRS will confirm that any third party to which it discloses Personal Information will appropriately safeguard the privacy of that Personal Information. Examples of appropriate privacy safeguards include: a contract obligating the third party to provide at least the same level of protection as is required by the relevant privacy principles, the third party being subject to EU data protection law, Privacy Shield certification by the third party, or the third party being subject to another European Commission adequacy finding (e.g., companies located in Switzerland). Where WPMRS has knowledge that a third party is using or disclosing Personal Information in a manner contrary to this Policy, WPMRS will take reasonable steps to prevent or stop the use or disclosure. WPMRS holds third parties to which it discloses Personal Information accountable for maintaining the trust our employees and customers place in the company. WPMRS may remain liable if any Agent processes Personal Information in a manner inconsistent with the regulations, unless WPMRS first demonstrates that it is not responsible for the event giving rise to the damage.
ACCESS AND CORRECTION: Upon request, WPMRS will grant individuals reasonable access to Personal Information that it holds about them. In addition, WPMRS will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete. Any employees that desire to review or update their Personal Information can do so by contacting their local Human Resources Representative.
SECURITY: WPMRS will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. WPMRS protects data in many ways. Physical security is designed to prevent unauthorized access to database equipment and hard copies of sensitive Personal Information. Electronic security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized access from remote locations. This protection includes the use of firewalls, restricted access and encryption technology. WPMRS limits access to Personal Information and data to those persons in WPMRS’s organization, or as Agents of WPMRS, that have a specific business purpose for maintaining and processing such Personal Information and data. Individuals who have been granted access to Personal Information are aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been provided training and instruction on how to do so.
RECOURSE, ENFORCEMENT, AND LIABILITY: WPMRS will conduct compliance audits of its relevant privacy practices to verify compliance with this Policy and the relevant privacy principles.

DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the WPMRS Data Protection Point of Contact via the contact information below. WPMRS will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy and as required by law.

INTERNET PRIVACY

WPMRS sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, vendors, business partners and others. WPMRS recognizes the importance of maintaining the privacy of Personal Information collected through websites that it operates. WPMRS’s purpose for operating its websites is to provide information concerning products and services to the public. In general, visitors can reach WPMRS on the Web without revealing any Personal Information. Visitors on the Web may elect to voluntarily provide Personal Information via WPMRS websites but are not required to do so. WPMRS collects information from visitors to the websites who voluntarily provide Personal Information by filling out and submitting online questionnaires concerning feedback on the website, requesting information on products or services, or seeking employment. The Personal Information voluntarily provided by website users is contact information such as the user’s name, home and/or business address, phone numbers and email address. WPMRS collects this information so it may answer questions and forward requested information. WPMRS does not sell this information.

WPMRS may also collect anonymous information concerning website users through the use of “cookies” in order to provide better customer service. “Cookies” are small files that websites place on users’ computers to identify the user and enhance the website experience.

Company personnel periodically audit WPMRS’s commercial websites to determine what cookies are used on each. The cookies used are typically not intrusive and are not typically connected to visitors’ contact or other identifiable information. Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies. Visitors can learn how to control or delete cookies used on WPMRS’s websites by visiting http://www.aboutcookies.org for detailed guidance. If visitors do suppress the website cookies, however, some areas of WPMRS websites may not function properly.

The list below describes the cookies used on www.wpmrs-refining.com.

SESSION COOKIES

We use a session cookie that lasts for the duration of your visit to our site and is used for load balancing. User data is linked to your contact information if you agree to the use of cookies for the purpose of enhancing your browsing experience and to personalize information to your interests.

PERSISTENT COOKIES FOR SITE ANALYTICS

Google Analytics – we use this to understand how the site is being used in order to improve the user experience. User data is not linked to any of your contact information.

You can find out more about Google’s position on privacy as regards its analytics service at https://support.google.com/analytics/answer/6004245?hl=en

WPMRS’s website is not directed toward children. Nevertheless, WPMRS is committed to complying with applicable laws and requirements, such as the United States’ Children’s Online Privacy Protection Act (“COPPA”).

WPMRS website users have the option to request that WPMRS not use information previously provided, correct information previously provided, or remove information previously provided to WPMRS. Those that would like to correct or suppress information they have provided to WPMRS should forward such inquiries to:

WPMRS

647 Main St. Suite 200B

Lake Geneva, WI 53147

USA