Privacy Notice

Nelum operates a compliance and documentation platform for the physical commodities trade. We are the controller of the personal data described in this notice. We operate from the United Kingdom and the United Arab Emirates.

Account and contact data: name, email address, telephone number, company, and role.

Business verification (KYB) data: company registration and incorporation documents, tax registration, proof of address, ownership and control structure, beneficial ownership details, licences, and bank confirmations.

Identity verification (KYC) data: government identity documents, a photograph of your face, and, where identity verification is performed by our provider, a liveness check.

Transaction data: posts, listings, offers, order terms, trade documents, shipment and customs records, and assay results.

Payment data: your subscription and purchase history. Card details are collected and held by Stripe, our payments partner, and never touch Nelum's systems.

Technical data: log data, IP address, device and browser information, and usage data.

We collect a photograph of each representative because counterparties in this trade meet in person and need to confirm that the individual in front of them is the registered representative of the company they claim.

Where a photograph is processed by automated face-matching or liveness detection for the purpose of uniquely identifying you, that is biometric data and is treated as a special category of personal data. We process it on the basis of your explicit consent and to meet our obligations in relation to the prevention of money laundering.

Your photograph is stored privately. It is displayed on your representative credential page — which is accessible to anyone holding the link — only where you have given separate, explicit consent to that publication. You may withdraw that consent at any time, and the photograph will be removed from the credential page. Withdrawal does not affect the underlying identity record, which we are required to retain (see section 7).

To provide the platform and perform our contract with you: account, transaction, and document data.

To comply with legal obligations: anti-money-laundering and counter-terrorist-financing checks, sanctions screening, record keeping, and reporting to authorities where required.

For our legitimate interests in operating a safe platform: fraud prevention, security, service improvement, and support. We balance these against your rights.

With your consent: publication of your photograph on your credential page, and the analytics cookies and measurement described in section 10. You may withdraw either at any time.

Counterparties: on the platform your company is initially identified by a pseudonymous reference. Your company's legal name and the details of your representative become visible to a counterparty once you enter into an order together, and through your representative credential where you have consented to publish it.

Service providers, who process data on our instructions: our hosting and database provider, our identity verification provider, our payments partner (Stripe), our email provider, and the provider of the AI model used to extract terms from documents you upload.

Google, which measures how our pages are used — and only where you have accepted analytics cookies. Section 10 sets out what Google receives, what it does not, and how to change your mind.

Authorities and professional advisers, where we are required or permitted to disclose. In some circumstances we are prohibited by law from telling you that a disclosure has been made.

We do not sell personal data.

Personal data is transferred between the United Kingdom, the European Economic Area, the United Arab Emirates, the United States, and other countries where our service providers operate. Where data leaves the UK or EEA we rely on adequacy decisions where they exist, and otherwise on standard contractual clauses together with any additional safeguards required.

Verification records and transaction records are retained for five years after the end of our business relationship with you, as required by anti-money-laundering law. In some jurisdictions a longer period applies.

Trade documents are kept for six years as an audit record of what counterparties agreed, measured from the end of the matter they relate to rather than from the day they were uploaded. Because that record belongs to both parties, one party asking us to erase their account does not remove it from the other party’s record.

This retention obligation takes precedence over a request for erasure. Where you ask us to delete data that we are required to retain, we will restrict its use to meeting that legal obligation rather than deleting it, and we will tell you that we have done so.

Account and technical data not subject to that obligation is retained only as long as needed for the purpose it was collected.

Subject to the retention obligations above, you have the right to access your personal data, to have inaccurate data corrected, to request erasure, to restrict or object to processing, to data portability, and to withdraw consent where processing is based on consent. Withdrawing consent does not affect processing carried out before withdrawal.

One category is withheld from an access response, and we say so rather than leaving a gap. Sanctions and politically-exposed-person screening results are not disclosed to the person screened. Disclosing them would tell someone precisely which details produced a match and therefore what to change before the next check, and where a screening has informed a report to the authorities, disclosure would risk an offence of tipping off. Where we withhold on this basis, the response we give you names the category we have withheld and why, so that you can challenge it.

Records of a transaction are not disclosed in full either, because they contain another party's personal data as well as yours. We disclose your own part of them.

To exercise a right, contact us via our contact page. You also have the right to complain to a supervisory authority — in the United Kingdom, the Information Commissioner's Office.

Verification documents and identity photographs are held in private storage that is not publicly accessible. Access is restricted, and access by our staff is logged. Documents you submit for business verification cannot be retrieved through the platform once submitted, including by you.

Some cookies are strictly necessary for the platform to function — signing you in and keeping you signed in — and are set without asking, because the platform cannot run without them. One further cookie records the answer you gave to the cookie banner, so that we do not ask again on every page.

Everything else is measurement, and we ask first. We measure how the site is used — which pages are opened, in what order, roughly where in the world from, and on what kind of device — using Google Analytics, provided by Google Ireland Limited. This covers both our public pages and the signed-in platform. It is switched off until you accept: analytics storage is denied by default, so a visitor who declines, or who never answers the banner, is counted without a cookie and without an identifier that persists between visits.

The two are separate choices, and you can give one without the other. “Public pages” covers which of our public pages get read; “the platform” covers which parts of the signed-in product get used. The banner offers to accept both, or to open a panel where each is listed separately. In that panel both start switched on: turn off whichever you do not want and continue, or refuse everything with the button beside Save. Whatever is switched off is not recorded and nothing is stored for it.

If you accept either, Google Analytics sets cookies on your device (named _ga and _ga_ followed by our property identifier) that let it recognise the same browser on a later visit, which is how we learn whether people come back. They last up to two years unless you clear them, and we delete them ourselves the moment you turn measurement off.

What Google receives is the page address, the page that referred you, an approximate location derived from your IP address, and your device, browser and language. We do not send Google your name, your email address, your company, or anything you post, and we do not permit Google to combine what it sees here with data from other Google services: advertising features, Google Signals and ad personalisation are all switched off on our property. Google processes this data on our instructions and, for a limited set of its own purposes, as an independent controller under its own terms; it may transfer and process it outside the United Kingdom and the European Economic Area, including in the United States, under standard contractual clauses. Google describes how it handles data from sites that use its services at How Google uses information from sites or apps that use our services, and publishes a browser add-on that blocks Google Analytics on every site at Google Analytics Opt-out Browser Add-on. Analytics records are held by Google for 14 months and then deleted.

You can change your answer at any time: “Cookie choices” at the foot of any public page, or Measurement under Account in your settings if you have an account. We will ask again in any event about six months after you answer. Withdrawing is no harder than accepting was, takes effect immediately, and does not affect measurement already recorded.

Addresses that identify a specific person are removed before measurement is recorded, and this is the part we ask you to hold us to. Every web address on this platform that names somebody — a member's profile, a company, an order, an offer, a post, an invitation link — is reduced to the KIND of page it is before anything is sent, and the part that names them is discarded in your browser and never transmitted. An invitation link is counted as a visit to the invitation page and never as a visit by the named holder it was sent to; opening a counterparty's profile is counted as a profile being opened and never as that profile. Anything after a question mark in the address is dropped whole.

So what we learn from the signed-in platform is which parts of it get used, and never who you looked at or what you traded. What you post, the terms you agree, the documents you upload, the messages you send and the counterparties you deal with are not recorded for analytics and are not sent to Google in any form.

The Back Office our own staff use is not measured at all.

We may update this notice. Material changes will be notified through the platform. Questions, or requests relating to your rights, can be directed to us via our contact page.