Sierra Gorda

Privacy Policy

This Privacy Policy describes the personal information that KGHM and its affiliates (“KGHM”, “us” or “we”) collects related to the www.sgmoly.com Website (the “Website”), how we manage that information and the circumstances under which we may disclose that information. This Privacy Policy is subject to change. You should periodically check the Website for updates to this Privacy Policy. Your continued use of the Website following any changes constitutes your acceptance of these changes.

What is personal information?

Personal information means information about an identifiable individual, as more particularly described under applicable Canadian privacy legislation. The only personal information which we collect about you when you use our website is what you tell us about yourself, for example, by completing an online form when you request printed copies of public disclosure documents, or information you provide to us through the “Contact Us” section or when you send us an e-mail. We collect, use and disclose your personal information with your consent or as permitted or required by law. Your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you provide personal information about another person to us, we assume you have the consent of that individual to enable us to collect, use or disclose their information as described in this policy. If you choose to provide personal information to KGHM, we assume that you consent to the collection, use and disclosure of your personal information as outlined below.

Personal Information We Collect

Personal information we collect in relation to the Website may include:

  • information, inquiries or comments you provide to us when you contact us, including name, address, email address, telephone number and other contact information that you provide in order to receive updates or our newsletter from us; and
  • such other information we may collect with your consent or as permitted or required by law.

Use of Personal Information

We generally use personal information we collect in relation to the Website for the following purposes:

  • replying to your requests, inquiries and comments;
  • meeting legal requirements; and
  • for other purposes that are disclosed at the time of collection, with your consent or as permitted or required by law.

We may also use personal information obtained from you through the Website, such as contact information (name and email address), to provide you with company information, such as e-mail notifications, literature requests, and newsletter subscriptions or other information which we think might be of interest to you. You may opt out of this use of your personal information by using the unsubscribe/opt out function provided at the bottom of each e-mail.

Disclosure of Your Personal Information

We do not disclose the personal information you provide to us without your consent but we may disclose personal information in the following circumstances:

  • Service Providers. KGHM may transfer personal information to service providers (including affiliates of KGHM acting in this capacity) that perform services on our behalf, for example internal audit, management, billing, website hosting or similar services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Policy. Some of these service providers or affiliates may be located outside of Canada, including in the United States and your personal information may be collected, used, disclosed, stored and processed in the United States or elsewhere outside of Canada for the purposes described in this Privacy Policy and be subject to legal requirements in Canada, the United States and other foreign countries applicable to our affiliates, agents and service providers, for example lawful requirements to disclose personal information to government authorities in those countries.
  • Business Transactions. Personal information may be used by KGHM and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of KGHM or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of KGHM or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.
  • Legal and Regulatory Requirements. KGHM may disclose your personal information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable KGHM or its agents and service providers, and including lawful requirements to disclose personal information to government authorities in those countries).

Non-Personally Identifiable Information

This Section refers to information that does not, by itself, identify a specific individual. We gather certain information about the use of our Website by our visitors. This information is then compiled and analyzed in a way that does not identify our visitors personally. Our server does not currently attach cookies to your computer’s memory when you visit our website As most websites do, however, we do track usage patterns on our website on an anonymous basis. Your identity cannot reasonably be ascertained from this information. Each time you visit our website, our server records your IP Address, Internet Service Provider, the date and time of your visit, the pages you visit and the documents downloaded, the searches you performed, and the referring URL’s you came from. We use this non-personal information to optimize our website service.

Links to Other Web Sites

This site may contain links or references to other Web sites. Please be aware that we do not control other Web sites and that, in any case, this Privacy Policy does not apply to those Web sites. We encourage you to read the privacy policy of every Web site you visit.

Security

We take reasonable steps using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include safeguards to protect personal information from loss, theft, misuse, and unauthorized access, use, copying, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Access and Correction

KGHM may establish and maintain a file of the personal information subject to this Privacy Policy for the purposes described above. Authorized employees, agents and mandataries of KGHM and our service providers who require access to personal information in order to fulfil their job requirements will have access to this file which will be kept at our offices or on our servers or those of our service providers. To the extent provided by applicable law, you may request access to personal information in our custody or control, and the correction of such information, by writing to us at info@kghm.com, attention: Privacy Officer. We may take reasonable steps to verify a person’s identity before granting access or making corrections.

Updates

If we decide to change this Privacy Policy, we will post those changes on this page, and update the Privacy Policy modification date below. We will not materially change this Privacy Policy in a way that makes it less protective of the personal information we have previously collected from you without notice to you.

Last updated on: October 1, 2012