KOBOLD METALS PRIVACY POLICY

Last Modified: February 5, 2025

KoBold Metals Company and our affiliated companies (“KoBold”, “we”, “us”) are committed to protecting and respecting privacy rights. This Policy (along with our Sites Terms of Use) explains how we may collect, use and share information that could be used to identify an individual (“Personal Data”) in the context of our offline business interactions and our website(s).  It also includes details on how you can reach us with any questions or concerns regarding your Personal Data.  Please also reference our Sites Terms of Use for additional information about interacting with KoBold and our affiliates via our Sites.

 

When Are We Collecting Personal Data and What Personal Data Might We Collect?

We generally collect Personal Data for two primary purposes: (1) licensing compliance and community outreach for areas where we have active or prospective mining operations and joint ventures, and (2) in connection with our newsletters, general public outreach and similar marketing efforts or facilitating our business relationship with you.

For our compliance and community outreach efforts, the Personal Data may include:

  • Your name, email address, address, and other contact information;
  • Business information, such as your company name, job title, your relationship with us, country of business;
  • Information about property(-ies) where you may hold an ownership or other interest;
  • Demographic or other information that may be available from public sources about you; and
  • Information you may share with us in connection with any communications we may have.

For our marketing efforts, the Personal Data may include:

  • Your name, email address, address, and other contact information;
  • Information you provide through our form fills;
  • Business information, such as your company name, job title, your relationship with us, country of business; and
  • Device information, such as the number and frequency of your visits to the website, how you found our website, the internet browsers used by you, and your IP addresses.

 

How Do We Collect Personal Data?

We collect Personal Data: (1) when you sign up for any of our mailing lists or other offerings; (2) submit any form to contact us to obtain more information about KoBold; (3) when shared via any email or other correspondence we may have with you; and (4) through the use of a cookie or other similar technology on our website(s).

We also may collect Personal Data from public records, governmental registries made available to the public and other public sources and/or third party sources that collect contact information (e.g. phone number sites, public registries, email registries).

If you disclose any Personal Data,  you represent that such Personal Data is your own and that you have the authority to do so and to permit us to use the information in accordance with this Policy.

 

For What Purposes Might We Use or Collect Personal Data?

For our compliance and community outreach efforts, we may process and use Personal Data for one or more of the following purposes:

  • Complying with requirements under law and industry standards as it relates to outreach to potential stakeholders or community members after we have staked a claim or applied for a license;
  • Engaging in community outreach in areas where we either have staked a claim or applied or a license or are considered such activity; and
  • Confirm information we have regarding property ownership, mineral rights ownership and similar interests.

For our marketing efforts, we may process and use Personal Data for one or more of the following purposes:

  • Providing copies of content or materials to you when you sign up for an email or similar distribution list;
  • Maintaining basic cookies to allow operation of our websites and email distribution lists regarding these lists and your interaction with our websites;
  • Communicate with you regarding your sign-up status for these lists; and

We also may also process and use Personal Data for one or more of the following additional purposes:

  • To provide and improve our communication and outreach efforts, tailor your experience on our website, and create reporting on our site usage activity we may share internally or with our investors and joint venture partners;
  • To facilitate our corporate operations, as necessary, such as corporate reorganizations, mergers, acquisitions and similar corporate activities;
  • To detect illegal activity or defend against legal claims;
  • To enforce our terms and conditions and other legal rights;
  • To communicate with you regarding any deletion or update requests for your Personal Data;
  • To work with our third party marketing suppliers (e.g. MailChimp, CookieYes, GravityForms, Gmail) and system analytics providers (e.g. MailChimp, Google Analytics) to help administrate your account and our contact with you;
  • To comply with applicable laws and regulations or requests from public and government authorities and/or to conduct internal investigations, information security tests and trainings and audits;
  • To prevent fraud and ensure the security of our systems; and
  • As otherwise required to comply with applicable laws and legal process.

We will not sell access to your Personal Data as a direct commercial product or service, or as part of a separate commercial product or service, whether as part of an aggregated identity or image database or otherwise.

 

Do We Use Cookies?

To help operate our websites, apps and other sites we do utilize cookies (small text-based files that are saved on your device when you visit that help the site remember certain information about your activity on the site and certain preferences relating to the site).   Most cookies are set up to be retained, preventing the need to re-save or re-enter the data each time you use the site.  We use cookies to better monitor your use of our sites and simplify and tailor your use of our sites to your preferences.   Cookies may contain Personal Data in certain circumstances, but we use those cookies only for these purposes.

The cookies we use may include the following:

If you would prefer for cookies not to be used, please use the cookies opt-out tool provided when you reach the applicable site.  Or, please reach out to us at privacy@koboldmetals.com with any specific questions.  Please note that we do our best to honor any Internet cookie rejection settings you may use on your device or browser, but cookie rejection settings may cause you to be unable to access all of the features or functionalities of a given site. 

 

How Might We Share Personal Data?

In connection with the purposes described in this Policy, we may share your Personal Data with our affiliates and our third-party service providers.  These third-party providers may include consultants, legal service providers, technology providers (e.g. hosting service providers, software service providers, IT, and related infrastructure providers) where appropriate for these third parties to assist us with such purposes (or to generally support our general business operations or business functions).

In case of a merger, acquisition, and/or other reorganizations and restructurings of our business (including prospective transactions), we may share your Personal Data with, or transfer your Personal Data to, (potential) buyers, acquirers, or business partners, as necessary to facilitate and/or effectuate such (potential) merger, acquisition and/or other reorganizations and restructurings.

If you would like to know more about our service providers where your Personal Data could be involved, we are happy to discuss specific questions.  Please reach out to us at privacy@koboldmetals.com.  By communicating with us, you are confirming your legitimate interest in such communications and our processing and handling of your Personal Data as a result, including sharing your Personal Data with third party providers, as discussed in this section.  Where required under applicable law, we will also honor any request to have your Personal Data excluded from a given service provider and/or deleted.  However, please note that any request to not have Personal Data shared with a service provider may make it difficult or impossible for us to communicate with you.  So, we reserve the right to remove you from any impacted lists or communications accordingly if you make any such request.

 

How Do We Store and Protect Your Personal Data?

KoBold has implemented reasonable technical security measures to help protect Personal Data against loss and to safeguard Personal Data against access by unauthorized persons. These measures include safeguards for physical, electronic, and procedural access and storage.  If Personal Data is involved, we have protocols in place to review the security of these vendors for similar requirements and, where applicable, ensure any required contractual safeguards are in place as well. Please note that no data transmission or storage system can be guaranteed to be 100% secure, and we cannot control (or be responsible for) the privacy, information, or other practices of any third parties beyond the protocols discussed in this section.  However, information security is a key goal for KoBold and our affiliates, and we commit to make reasonable efforts to protect Personal Data accordingly, as discussed in this Policy.

KoBold and our affiliates have operations in several countries around the world.  We also engage service providers, including cloud-based storage providers, who may operate in those countries as well as other countries.  As a result, your Personal Data may be stored and processed in any country where we have operations or in which we engage service providers and/or where those service providers may store data as part of their services.  You understand that your information may be transferred to countries outside of your country of residence, and those countries may have data protection rules, rights and remedies that are different from those of your country.  Also, in certain circumstances, courts, government authorities, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data, and you understand and agree that we may cooperate with any such requests without requiring any additional consent or notice from or to you.

If you believe a security incident has occurred or you have any other reason to believe that your Personal Data or any related interactions with us are no longer secure, please immediately notify us at privacy@koboldmetals.com.

 

Do We Retain Personal Data?

We retain Personal Data we collect from you where: (1) we have an ongoing legitimate business need or legal obligation to do so (e.g. to provide you with communications you have requested, to continue community outreach where we have continuing operations, to comply with laws and industry standards regarding outreach to land and mineral rights owners), or (2) where required by applicable law or legal process.

 

Are There Restrictions on Access By Minors Or Children?

Access and use of any KoBold website(s) is limited to individuals who are 18 years of age or older.   We do not knowingly collect Personal Data from any individual under the age of 18.  No one under the age of 18 is authorized to share Personal Data with KoBold, nor may anyone share Personal Data regarding anyone under the age of 18 with KoBold, whether via any KoBold website or otherwise.  If you are aware Personal Data of anyone under the age of 18 has been shared with KoBold or any of our affiliates, please immediately notify us at privacy@koboldmetals.com.

 

Does This Policy Address Third-Party Links or Related Services?

Our websites and other communications may include access to or use of third party services, whether via website links or otherwise.  We cannot be responsible or liable for any such third parties or their information security or other practices.  Also, we are not responsible for the information collection, use, disclosure, or security policies of any offerings from any third party should you choose to use their products, services or other solutions (e.g. social media platforms, operating platforms, wireless networks, storage platforms, etc. such as Facebook, Apple, Verizon, Orange, AT&T, Google, Microsoft, etc.).  Any use and any information you may share with these providers is at your own risk, whether via our websites or other communication channels or otherwise.  The inclusion of a link on any KoBold website or in any KoBold communication does not imply endorsement of the linked site or service by us.

 

How Are Updates To This Policy Handled?

We may update this Policy from time to time.  We will communicate any updates by posting an updated version of this Policy with an updated date (along with any other communications required under applicable law).  We encourage you to periodically review this site for any such updates.  If you no longer wish to allow use of your Personal Data under the updated Policy, you are responsible for submitting a deletion request in accordance with the instructions below.

 

How Can You Contact Us With Questions or Requests About How We Handle Personal Data?

If you have questions about this Policy as it relates to your Personal data, please contact us at privacy@koboldmetals.com or KoBold Metals, 2021 Shattuck Avenue, Suite 210 Berkeley, CA 94704, ATTN: Privacy Lead.  Similarly, if you would like to unsubscribe from any future emails or other communications, you may use the unsubscribe link in the communication (if one is provided) or contact us at the email address or mailing address above.  We will respond to your inquiry as soon as we are able.

If you would like to request to access, correct or update any of your Personal Data, or request that we delete your Personal Data, please contact us at privacy@koboldmetals.com with the subject “Personal Data Modification” or “Personal Data Deletion” (as applicable).  We will respond to your request as soon as we are able, using reasonable efforts to comply with your request (and in any event in accordance with all requirements under applicable law).   In your request, please make clear the details of your request, including what Personal Data you would like to have deleted or changed.  For your protection, we may require follow up information and/or identity verification protocols to ensure the request is coming from the legitimate owner of the Personal Data.  Please note that some partial deletion requests may not be possible, and we reserve the right to delete your Personal Data in full in that situation.

Please only submit requests and inquiries regarding your own personal data (or that of an individual for whom you are their parent (for minors), executor or similar legal guardian.

By submitting any information to use via the email and other addresses listed in these Terms, you are agreeing that KoBold and our applicable providers may utilize your Personal Data to reach out to you to understand and respond to your communications, in accordance with this Policy and our Terms of Use.