سياسة الخصوصية

PRIVACY POLICY

Effective Date: February 9, 2026

1. Introduction and Scope of Authority

Mellon's Company LLC (the "Company"), a wholly-owned subsidiary of Luxmal Group LLC, is committed to maintaining the highest standards of data integrity and privacy. This policy governs the processing of personal data collected through our website and during the provision of our strategic consultancy and "Investment Formulas." By using our services, you acknowledge the data practices described herein.

2. Comprehensive Data Collection

We collect information that identifies, relates to, or could reasonably be linked to an individual or household ("Personal Data").

Identification & Professional Data: Full name, corporate title, employer, and business entity documentation.
Contact Information: Professional email addresses, secure phone lines, and registered business addresses.
Due Diligence & Compliance Data: As a Delaware entity, we collect data required under the Bank Secrecy Act (BSA) and USA PATRIOT Act, including government-issued identification and proof of wealth/funds for AML/KYC verification.
Technical & Usage Data: IP addresses, browser fingerprinting, and interaction metadata collected via secure session cookies.

3. Legal Basis and Purpose of Processing

Pursuant to international regulations (including GDPR Art. 6), we process data under the following legal bases:

Contractual Necessity: To execute consultancy agreements and investment frameworks.
Legal Obligation: To satisfy federal and international regulatory reporting (AML/KYC).
Legitimate Interests: To protect the Group’s intellectual property and prevent fraudulent activities.
Consent: Where you have explicitly opted-in to receive corporate communications from the Luxmal Group.

4. Strategic Intra-Group Data Sharing

Mellon's Company LLC operates within the Luxmal Group LLC centralized data ecosystem.

Joint Controllership: Your data may be shared with our parent company and global affiliates to ensure cross-border regulatory compliance and unified strategic execution.
Protection Standards: All intra-group transfers are protected by Inter-company Data Transfer Agreements and strict confidentiality protocols, ensuring that your data receives the same level of protection across the entire Group structure.

5. International Data Transfers and Delaware Jurisdiction

Your information is primarily processed at our headquarters in Wilmington, Delaware, USA.

Cross-Border Consent: If you are accessing this site from the European Economic Area (EEA) or other jurisdictions with strict data localization laws, you acknowledge that the USA may have different data protection standards. We utilize Standard Contractual Clauses (SCCs) to bridge these jurisdictional requirements.

6. Data Retention and Deletion Protocols

We adhere to a "Storage Limitation" principle. Data is retained:

For the duration of the professional relationship.
For a minimum of five (5) years following the termination of a relationship to comply with Delaware and Federal AML record-keeping statutes.
Until the expiration of the statute of limitations for potential legal claims.

7. Global Privacy Rights (GDPR/CCPA/CPRA)

Depending on your residency, you may exercise the following rights:

Right to Know/Access: Request disclosure of what personal information we collect and how it is used.
Right to Rectification: Mandate the correction of inaccurate professional data.
Right to Opt-Out: Object to the processing of data for marketing purposes.
Right to Non-Discrimination: We will not deny services or change the quality of our consultancy based on the exercise of your privacy rights.

8. Advanced Data Security

We employ institutional-grade security measures, including AES-256 encryption for data at rest and TLS/SSL protocols for data in transit. Access to sensitive due diligence data is restricted to authorized Compliance Officers within Mellon's Company LLC and Luxmal Group LLC on a "need-to-know" basis.

9. Contact and Data Privacy Liaison

For all inquiries, formal requests, or to exercise your privacy rights, please contact our Compliance Department:

Mellon's Company LLC

1013 Center Road, Suite 403A

Wilmington, DE 19805, USA

Email: mellons@usa.com

Attn: Data Privacy Liaison