Privacy Policy
philoro USA, Inc.
Effective Date: March 24, 2026
This Privacy Policy describes how philoro USA, Inc. (”philoro”, ”we”, ”us”, or ”our”) collects, uses, discloses, and protects Personal Information collected through our website and in connection with inquiries initiated through the website. The website is informational only. It is not a web shop and does not provide online purchasing, checkout, account registration, or online order fulfillment for precious metals.
Before submitting Personal Information to us or using the Sites, please review this Privacy Policy carefully.
Certain philoro services or subsidiaries may use different privacy policies to provide notice to you about how your Personal Information is used and disclosed. To the extent that philoro services or subsidiaries post or reference a different privacy policy, that different privacy policy, not this Privacy Policy, will apply to your Personal Information collected in the context of those services or by that subsidiary.
1. Scope of this policy
This Privacy Policy applies to Personal Information collected through the philoro website, through communications that begin with website inquiries, including phone calls, emails, and contact form submissions, through third party sources, including ad networks, through other online or offline services, tools, events and any other context in which we link to or otherwise provide you with a copy of this Privacy Policy. Any purchase or sale of precious metals is handled separately through direct communication and may be subject to additional transaction terms, customer onboarding, know-your-customer, anti-money laundering, sanctions screening, payment, delivery, and recordkeeping procedures.
2. Personal information we collect
“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as the examples provided within categories of Personal Information identified in this Section 2 below. We may collect the following categories of Personal Information, depending on how you interact with us:
Identifiers: such as your name, business name, email address, telephone number, mailing address, account names and associated passwords, social media profiles, investor or customer type, and the content of your messages, requests, or other communications.
Protected Characteristics: those provided with special protection under applicable law, such as your age, race, citizenship, and gender.
Profile Information: such as information about your preferences and characteristics (including inferences drawn from other personal information), in order to understand your preferences and tailor our services and communications to you.
Transaction and compliance-related information: if discussions progress beyond an initial inquiry, we may collect information needed to evaluate or process a prospective transaction, including identity-verification information, beneficial ownership information, tax or payment-related details, and information required for legal or compliance reviews.
Website and device information: IP address, browser type, device identifiers, operating system, language preferences, pages viewed, links clicked, referring URLs, dates and times of visits, geolocation data should you consent to share your location, and similar technical usage data or internet activity.
Cookies and analytics information: information collected through cookies and similar technologies used for site functionality, security, traffic measurement, and analytics.
Some of the information we collect may be considered Sensitive Personal Information under privacy laws, such as your account log-in information. We use your Sensitive Personal Information only for legitimate business purposes, including to (i) perform services or provide goods reasonably expected by an average person; (ii) detect security incidents; (iii) resist malicious, deceptive, or illegal actions; (iv) ensure the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) perform or provide internal business services; or (vii) verify or maintain the quality or safety of a service or device.
3. How we use personal information
We may use Personal Information to: respond to inquiries; communicate about our products, services, and availability; verify your identity and information; maintaining and servicing your account and preferences; discuss potential transactions; provide customer support; operate, maintain, and improve the website; monitor usage and performance; protect the website and our business; comply with legal, regulatory, and compliance obligations; prevent fraud, money laundering, sanctions violations, or other unlawful activity; maintain business records;, where permitted by law, send marketing or promotional communications; and for other purposes consistent with the context of the collection of your information, or as otherwise disclosed to you prior to the use of your information.
4. Cookies and similar technologies
5. Sources of personal information
We may collect Personal Information directly from you, automatically from your browser or device when you use the website, and from third parties where appropriate, such as website hosting providers, analytics providers, compliance or screening providers, publicly available sources, business partners, payment providers, logistics providers, social media platforms (if you interact with us through your social media account(s)), third parties to whom you direct us to collect your Personal Information, or other service providers involved in a prospective or completed transaction. We will treat Personal Information collected from third-party sources in accordance with this Privacy Policy.
6. How we disclose personal information
We may disclose Personal Information to the following categories of recipients, as reasonably necessary for the purposes described in this Privacy Policy:
Service providers: hosting providers, website developers, IT and security providers, communications platforms, customer relationship management tools, analytics providers, and other vendors that help us operate our business and website. Our policy is to inform our Service Providers not to use or disclose your Personal Information for any purpose other than for providing services to us.
Our Corporate Family: companies philoro USA, Inc. owns and controls, companies that own and control philoro USA, Inc., or companies that are otherwise related to philoro USA, Inc., sister companies with shared ownership.
Compliance and transaction support providers: identity-verification providers, sanctions-screening or anti-fraud providers, payment processors, insurers, vaulting providers, carriers, logistics companies, and other parties involved in evaluating, documenting, or completing a transaction.
Affiliates and professional advisers: our affiliates, auditors, accountants, consultants, and legal advisers.
Governmental, regulatory, or legal recipients: courts, regulators, law enforcement, or other parties where disclosure is required or permitted by law, subpoena, court order, or to protect rights, safety, or property. We may share your Personal Information with law enforcement agencies or other government agencies (i) when we, in good faith, believe you or others are acting unlawfully, (ii) when we believe it is necessary or appropriate to satisfy any law, regulation or other governmental request, (iii) to operate our business and Sites properly, (iv) to protect or defend our rights or the rights or well-being of our users, even without a subpoena, warrant or court order, or (v) we believe disclosure is necessary to protect the health and safety of our personnel, clients, guests, and the general public.
Corporate transaction participants: parties involved in an actual or proposed merger, sale, financing, reorganization, or similar business transaction.
7. Marketing communications
If you contact us or otherwise request information, we may send you communication relating to your inquiry. Where permitted by law, we may also send you information about our products or services. You may opt out of marketing emails at any time by using the unsubscribe link in the message or by contacting us using the information below.
8. Data retention
We retain Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to respond to inquiries, maintain business and compliance records, complete or evaluate transactions, resolve disputes, enforce agreements, and comply with legal, tax, accounting, recordkeeping, anti-money laundering, sanctions, and other regulatory obligations. Retention periods may vary depending on the type of information and the nature of the relationship or transaction.
We have implemented reasonable safeguards designed to protect your information from loss, misuse, alteration, or destruction. We also take reasonable steps designed to ensure that third parties who work with us agree to protect the Personal Information.
Without limiting any other terms that apply to our Sites and this Privacy Policy, you understand that we cannot guarantee that your Personal Information will be private or secure. Except to the extent provided by law, we are not responsible or liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the Sites and our services. Please be careful whenever sending Personal Information to us via e-mail. E-mail is not a secure means of transferring information.
9. Data security
We use reasonable administrative, technical, and physical safeguards designed to protect Personal Information. However, no method of transmission over the internet and no method of electronic storage is completely secure, and we cannot guarantee absolute security.
10. U.S. State privacy rights
Depending on where you live and subject to applicable law, you may have rights regarding your Personal Information, such as the right to request access to or confirmation of the Personal Information we hold about you, request correction of inaccurate information, request deletion, request a portable copy, opt out of certain targeted advertising, profiling, or sales-related processing where applicable, limit the use of sensitive Personal Information where applicable, and appeal a denial of certain requests where applicable.
If you choose to exercise any of these rights, philoro will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of philoro’s Sites or services. Some rights are subject to exceptions and may not apply in every circumstance or jurisdiction.
To submit a privacy rights request, please contact us at usa@philoro.com or (833) 744-5676. We may need to verify your identity before responding.
We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. If you have an Account with us, we will use our existing Account authentication practices to verify your identity. If you do not have an Account with us, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.
You may be able to use an authorized agent to submit a rights request on your behalf. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.
Certain laws may give you a right to appeal any denials of your request to exercise your rights. If we deny your request and you would like to submit an appeal, please contact us at usa@philoro.com.
11. How we respond to do not track signals
12. How we respond to the global privacy control
13. Marketing opt-out
If you would like to opt out of receiving promotional or marketing e-mail from us, you may use the “unsubscribe” mechanism included in each marketing message. You may let us know by sending us an email to usa@philoro.com with REMOVE in the subject line, and stating the e-mail address you wish to be removed from our mailing list. If you have an Account, you may be able to manage your subscriptions through your Account. However, your option not to receive promotional and marketing e-mail shall not preclude us from corresponding with you, by e-mail or otherwise, regarding your existing relationship with us. Your opt-out request will also not apply to correspondence that has already been initiated.
14. Legal basis for processing
15. Children’s privacy
The website is not directed to children, and we do not knowingly collect Personal Information online from anyone under 18 years of age. If we learn that we have collected Personal Information from a child under 18 without appropriate authorization, we will take reasonable steps to delete it. If you believe a child under 13 has provided us with Personal Information, please contact us at usa@philoro.com or by phone at (833) 744-5676.
16. Third-Party links
The website may contain links to third-party websites or services. We are not responsible for the privacy, security, or data practices of third parties, and this Privacy Policy does not apply to them. Please review the privacy policies of any third-party sites you visit.
17. International transfers
Our service providers may store or process Personal Information in the United States or in other countries where they operate. By interacting with the website or providing information to us, you understand that your information may be transferred to and processed in countries that may have different data protection laws than your jurisdiction.
18. Changes to this privacy policy
We may update this Privacy Policy from time to time. When we do, we will revise the Effective Date above and post the updated version on the website. Your continued use of the website after the updated Privacy Policy becomes effective constitutes your acknowledgment of the revised Privacy Policy, to the extent permitted by law. We encourage you to periodically review this page for the latest information on our privacy practices.
19. Contact us
If you have questions about this Privacy Policy or our privacy practices, please contact philoro USA, Inc. by email at usa@philoro.com or by phone at (833) 744-5676.