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Privacy Policy

This Privacy Policy explains how Cuprea Resource Funds Ltd, a company registered in Cyprus (reg. no. HE 496223, registered office Agiou Amvrosiou 2, 8049 Paphos, Cyprus) (“we,” “us,” “our”), collects, uses, discloses, and protects personal information in connection with the Nomad Geologist research platform (the “Platform”). By accessing or using the Platform, you agree to the practices described here.

1. Who We Are

Cuprea Resource Funds Ltd is the data controller for personal information processed through the Platform, including the retail Investor Pass subscription. Contact: nomadgeo@proton.me. Postal: Agiou Amvrosiou 2, 8049 Paphos, Cyprus.

2. Information We Collect

We collect:

  • Account information — your name, email address, organization (if provided), and login credentials.
  • Subscription and billing information — your subscription tier, invoices, and payment records. Where payments are handled off-platform (e.g. by invoice or a third-party processor), we do not store full payment-card details. Payments for the Investor Pass are processed by Paddle, our merchant of record, which collects your payment details, billing address, and tax location under its own privacy policy; we receive from Paddle your email address, subscription status, and transaction references.
  • Communications — messages you send us via the contact form or email, and our correspondence with you.
  • Usage data — information about how you access and use the Platform, such as pages viewed, log-in times, IP address, browser and device information, collected through server logs and standard web technologies.
  • Cookies and similar technologies — strictly necessary cookies for authentication and session management, and, where applicable, functional or analytics cookies (see Section 8).

3. How We Use Your Information

We use personal information to:

  • provide, operate, and secure the Platform and your account;
  • authenticate members and enforce access tiers;
  • process subscriptions, send invoices, and manage billing;
  • send you research notifications, service messages, and responses to your inquiries;
  • maintain records of disclaimer acknowledgements and other compliance-related actions;
  • monitor, prevent, and address fraud, abuse, unauthorized access, and security issues;
  • apply visible and invisible identifying marks (derived from your account, e.g. your email address and access date) to content served to subscriber accounts, solely to protect our intellectual property and investigate unauthorized redistribution;
  • comply with legal obligations and enforce our agreements.

Where the EU General Data Protection Regulation (GDPR) or UK GDPR applies, we process personal information on the following legal bases: performance of a contract (to provide the Platform and your subscription); legitimate interests (to secure and improve the Platform, prevent abuse, and communicate with members), provided these are not overridden by your rights; consent (where required, e.g. for certain cookies or marketing); and legal obligation (to comply with applicable law).

5. How We Share Information

We do not sell your personal information. We share it only with:

  • Service providers who help us operate the Platform (e.g. hosting, email delivery, payment/invoicing, file storage), bound by confidentiality and data-protection obligations;
  • Legal and regulatory authorities, where required by law, court order, or to protect our rights, safety, or property;
  • A successor entity, in connection with a merger, acquisition, or sale of assets, subject to this Policy.

6. International Data Transfers

We are based in Cyprus (European Union). Our service providers may process data in the United States and other countries outside the European Economic Area. Where personal information is transferred out of the EEA, UK, or Switzerland, we rely on appropriate safeguards (such as the European Commission’s Standard Contractual Clauses) where required.

7. Data Retention

We retain personal information for as long as your account is active and as needed to provide the Platform, and thereafter as required to comply with legal obligations, resolve disputes, and enforce our agreements. Acknowledgement and access logs may be retained for compliance and record-keeping purposes.

8. Cookies

We use strictly necessary cookies to keep you logged in and to secure the Platform; these cannot be disabled without breaking core functionality. Where we use any non-essential (e.g. analytics) cookies, we will do so consistent with applicable law and, where required, your consent. You can control cookies through your browser settings.

9. Your Rights

Depending on your location, you may have rights to: access the personal information we hold about you; correct inaccurate data; delete your data; restrict or object to certain processing; data portability; and, where processing is based on consent, to withdraw consent. Residents of the EEA/UK have these rights under the GDPR/UK GDPR; residents of certain U.S. states (e.g. California) may have analogous rights. To exercise any right, contact us at nomadgeo@proton.me. We will respond as required by applicable law. You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus, or with your local data-protection authority.

10. Security

We implement reasonable technical and organizational measures to protect personal information, including encrypted connections and access controls. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Children

The Platform is intended for professional and sophisticated investors and is not directed to individuals under 18. We do not knowingly collect personal information from children.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be notified through the Platform or by email. Your continued use after an update constitutes acceptance of the revised Policy.

13. Contact

Questions or requests regarding this Policy or your personal information: nomadgeo@proton.me, or Cuprea Resource Funds Ltd, Agiou Amvrosiou 2, 8049 Paphos, Cyprus.

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