Privacy Policy

1. Who we are

Keystone Trading Groupe LLC ("Keystone", "we", "us") operates the website keystonetrading.us and is the controller of the personal data described in this policy. Office: 30 Wall St Fl 8, New York, NY 10005, United States. Contact for all privacy matters: info@keystonetrading.us. Company registration details are available on request.

2. Personal data we collect

• a) Email correspondence: information you voluntarily provide when you email us, such as your name, company, job title, contact details, the details of your inquiry and any documents you choose to attach. Please do not include sensitive personal data in documents you send us.
• b) Technical data: when you visit the website, our hosting and security providers automatically process technical information such as IP address, browser and device type, pages visited, referring page and timestamps.
• c) Usage analytics: see section 6.

We do not knowingly collect special categories of personal data.

3. Purposes and legal bases (EU/UK GDPR)

• Responding to your inquiry or consultation request and taking steps at your request before entering into a contract - Art. 6(1)(b) GDPR.
• Managing business relationships with counterparties, counterparty screening (KYC/KYB, sanctions) and record keeping - Art. 6(1)(b) and Art. 6(1)(f) GDPR (our legitimate interest in operating our business and conducting compliant transactions), and Art. 6(1)(c) where a legal obligation applies.
• Website security, abuse and spam prevention, and keeping the site working - Art. 6(1)(f) GDPR (legitimate interest in a secure and functional website).
• Aggregated usage analytics and technical performance monitoring - Art. 6(1)(f) GDPR (legitimate interest in understanding and improving the website).

Any information you send us by email is provided voluntarily. We do not use your data for automated decision-making or profiling with legal effects.

4. How long we keep data

Inquiry and correspondence data: up to 24 months after our last contact with you, unless a longer period is required by law or needed to establish, exercise or defend legal claims, or you become a client or counterparty, in which case records are kept for the period required for the business relationship and applicable record-keeping obligations. Analytics and hosting logs: according to the retention periods of the respective providers.

5. Recipients and service providers

We do not sell your personal data. We share it only with service providers that process it on our behalf, and where necessary with professional advisers, authorities or courts when required by law. Our providers are:

• Lovable (Sweden) - website hosting and delivery, and website usage analytics (see section 6).
• Cloudflare, Inc. (United States) - content delivery network and security for the website; processes connection data such as IP address and may set a strictly necessary security cookie.
• AZ.pl (Poland) - email hosting for @keystonetrading.us mailboxes.
• Google LLC / Google Ireland Ltd - Google Fonts, used to display the website typography; your browser connects to Google servers, which receive your IP address.

Members of our team receive inquiries relevant to their region or role.

6. Cookies, local storage and analytics

We do not use advertising or marketing cookies and we do not sell or share data for cross-context behavioural advertising. The website uses:

• A security cookie set by Cloudflare (__cf_bm, about 30 minutes) to distinguish legitimate visitors from automated traffic. This is strictly necessary.
• A first-party session identifier (session-id, about 30 minutes, stored as a cookie and/or in your browser's local or session storage) used by our hosting provider's built-in analytics to count visits and page views and measure performance.
• Technical monitoring by our hosting provider that records page views, clicks, errors and performance metrics, and may record a sample of anonymised session interactions (session replay) to help diagnose technical problems.

You can block or delete cookies and site storage in your browser settings; the site will continue to work. Where required by local law, we will ask for your consent before using non-essential analytics.

7. International transfers

We are based in the United States and some of our providers are located outside the European Economic Area and the UK. Where personal data from the EEA or UK is transferred to countries without an adequacy decision, the transfer relies on the EU-U.S. Data Privacy Framework (where the recipient is certified), the European Commission's Standard Contractual Clauses or the UK International Data Transfer Addendum, or, where applicable, Art. 49(1)(b) GDPR when the transfer is necessary to handle your request. You may request more information about these safeguards at info@keystonetrading.us.

8. Your rights under EU/UK GDPR

You have the right to access your personal data, to rectification, to erasure, to restriction of processing, to data portability, and to object to processing based on our legitimate interests. Where processing is based on consent, you may withdraw it at any time without affecting prior processing. To exercise your rights, email info@keystonetrading.us. We will respond within one month and may need to verify your identity. You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the country of your habitual residence, place of work or place of the alleged infringement (for example the President of the Personal Data Protection Office (UODO) in Poland or the Information Commissioner's Office (ICO) in the United Kingdom).

9. California residents (CCPA/CPRA)

In the past 12 months we have collected the following categories of personal information: identifiers (name, email address, phone number, IP address); professional or employment-related information (company, job title); commercial information (details of your inquiry, commodities, volumes and timing); internet or other electronic network activity (pages visited, interactions and technical data); and, only if you send them by email, documents you choose to provide. We collect this information from you directly and from your device, for the business purposes described in section 3. We do not sell personal information and do not share it for cross-context behavioural advertising, and we do not use or disclose sensitive personal information for purposes that would give rise to a right to limit. We retain personal information as described in section 4.

California residents have the right to know what personal information we collect, use and disclose; to access it; to request deletion; to request correction of inaccurate information; to opt out of sale or sharing (which we do not do); and not to be discriminated against for exercising these rights. To exercise your rights, email info@keystonetrading.us with the subject "California privacy request". We will verify your request by matching information you provide with information we hold. You may use an authorised agent, who must provide proof of authorisation. We will respond within 45 days.

10. Security

We use appropriate technical and organisational measures, including encrypted (HTTPS) connections, restricted access to mailboxes and servers, rate limiting and spam filtering. No method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

11. Children

This website is intended for business users and is not directed at children. We do not knowingly collect personal data from anyone under 16. If you believe a child has provided us with personal data, please contact us and we will delete it.

12. Changes to this policy

We may update this policy from time to time. The current version is always available on this page with its "Last updated" date. Where changes are material, we will highlight them on this page.

13. Contact

For any questions about this policy or our handling of personal data, contact us at info@keystonetrading.us or write to Keystone Trading Groupe LLC, 30 Wall St Fl 8, New York, NY 10005, United States.