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BLEYER LIMITED (trading as Bleyer Bullion)
PRIVACY POLICY
Effective Date: 15 April 2026
Version: 1.1

Bleyer Limited trading as Bleyer Bullion (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, share and protect personal data when you use our website, purchase products, sell bullion to us, request storage services, contact us, or otherwise deal with us.

This policy should be read together with our Terms and Conditions, Cookie Policy and AML & Identity Verification Notice.

1. WHO WE ARE
1.1 Data Controller: Bleyer Limited
1.2 Trading Name: Bleyer Bullion
1.3 Service Address for Privacy Matters:
The Barley and Vine
121 East Street
South Molton
EX36 3BU
1.4 Email: [email protected]
1.5 Telephone: 01769 618618
1.6 Website: www.bleyerbullion.co.uk
1.7 We are registered with the UK Information Commissioner’s Office (“ICO”).

2. PERSONAL DATA WE COLLECT
We may collect and process the following categories of personal data:
2.1 Identity Data
a) full name
b) title
c) date of birth (where required)
d) passport details
e) driving licence details
f) identity verification records
2.2 Contact Data
a) billing address
b) delivery address
c) email address
d) telephone numbers
2.3 Transaction Data
a) products purchased
b) storage arrangements
c) buyback transactions
d) valuations requested
e) payment references
f) delivery details
2.4 Financial Data
a) bank account details for payments or buybacks
b) partial payment references
c) anti-fraud transaction data
We do not store full payment card details.
2.5 Compliance Data
a) proof of address
b) sanctions screening outcomes
c) source of funds notes
d) source of wealth notes
e) suspicious activity notes where lawfully permitted
2.6 Technical Data
a) IP address
b) browser type
c) operating system
d) website usage data
e) cookie identifiers
2.7 Marketing Data
a) newsletter preferences
b) consent records
c) campaign interaction data
2.8 CCTV Data
Where you visit our premises, CCTV images may be captured for security and crime prevention purposes.

3. HOW WE COLLECT DATA
We collect data:
a) directly from you;
b) when you place an order;
c) when you sell items to us;
d) when you request storage or valuations;
e) through website forms;
f) via cookies and analytics tools;
g) from banks, payment processors and fraud prevention providers;
h) from sanctions or identity databases where legally permitted.

4. HOW WE USE YOUR DATA
We use personal data to:
a) process orders and payments;
b) arrange delivery or collection;
c) administer storage and vaulting services;
d) buy bullion from you;
e) perform valuations;
f) respond to enquiries;
g) verify identity;
h) prevent fraud and money laundering;
i) meet legal obligations;
j) improve our website and services;
k) send marketing where permitted;
l) protect our staff, premises and business.

5. LEGAL BASES FOR PROCESSING
We rely on one or more of the following legal bases:
a) performance of a contract;
b) compliance with legal obligations;
c) legitimate interests;
d) consent (for certain marketing/cookies);
e) establishment, exercise or defence of legal claims.

6. DISCLOSURE OF YOUR DATA
We may share data with:
a) payment processors including Elavon;
b) website and IT providers including Willcox Media;
c) email and business systems providers including Microsoft 365;
d) CRM / marketing providers including ActiveCampaign;
e) analytics and advertising providers including Google and Meta;
f) couriers and delivery agents;
g) vaulting / storage partners including Baird & Co, Loomis and relevant custodians;
h) accountants, solicitors and professional advisers;
i) law enforcement, regulators or tax authorities where required.
We only share data where reasonably necessary.

7. INTERNATIONAL DATA TRANSFERS
Some service providers may process personal data outside the UK.
Where this occurs, we seek to ensure appropriate safeguards are in place, such as adequacy regulations, contractual protections or equivalent lawful transfer mechanisms.

8. DATA SECURITY
We use reasonable technical and organisational security measures designed to protect personal data against unauthorised access, misuse, alteration or loss.
No internet transmission or storage system is guaranteed to be completely secure.

9. DATA RETENTION
9.1 We retain customer records for at least six years after we cease dealing with a customer.
9.2 We may retain data longer where required for:
a) anti-money laundering obligations;
b) tax matters;
c) dispute resolution;
d) legal claims;
e) fraud prevention;
f) regulatory compliance.

10. MARKETING
10.1 We may send marketing communications where permitted by law.
10.2 You may unsubscribe at any time using the unsubscribe link or by contacting us.
10.3 We do not currently send SMS marketing.

11. YOUR RIGHTS
Subject to applicable law, you may have rights to:
a) access your data;
b) correct inaccurate data;
c) erase data in certain circumstances;
d) restrict processing;
e) object to processing;
f) data portability;
g) withdraw consent where consent applies;
h) complain to the ICO.

12. COMPLAINTS
If you have concerns, please contact us first.
You may also complain to the Information Commissioner’s Office via www.ico.org.uk.

13. COOKIES
Please see our separate Cookie Policy.

14. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The latest version will appear on our website.

15. CONTACT US
Bleyer Limited trading as Bleyer Bullion
[email protected]
01769 618618

COOKIE POLICY
Effective Date: [Insert Date]
This Cookie Policy explains how Bleyer Limited trading as Bleyer Bullion uses cookies and similar technologies.

1. WHAT ARE COOKIES?
Cookies are small text files placed on your device when you visit a website.
They help websites function, remember preferences, measure traffic and improve services.

2. TYPES OF COOKIES WE USE
2.1 Strictly Necessary Cookies
Required for website functionality such as security, page navigation and checkout processes.
2.2 Analytics Cookies
Used to understand website traffic and behaviour. We use tools such as Google Analytics.
2.3 Advertising Cookies
Used to help measure advertising and show relevant adverts. We may use Meta/Facebook Pixel and related technologies.
2.4 Preference Cookies
Used to remember settings and user preferences.

3. CONSENT
Where required by law, non-essential cookies are used only after you provide consent through our cookie banner or consent tool.
You may withdraw consent at any time.

4. MANAGING COOKIES
You can control cookies by:
a) adjusting our cookie settings tool;
b) changing browser settings;
c) deleting stored cookies.
Blocking some cookies may affect website performance.

5. THIRD-PARTY COOKIES
Some cookies may be placed by third parties such as Google, Meta or service providers integrated with our website.
Their own privacy notices may also apply.

6. CHANGES
We may update this Cookie Policy from time to time.

AML & IDENTITY VERIFICATION NOTICE
Effective Date: [Insert Date]
Bleyer Limited trading as Bleyer Bullion is committed to lawful and responsible trading in precious metals.
Because bullion can involve high-value transactions, we may need to verify identity and source of funds.

1. WHY WE REQUEST IDENTIFICATION
We may request documents or information to:
a) comply with anti-money laundering laws;
b) prevent fraud and identity theft;
c) comply with sanctions regulations;
d) verify ownership of funds or assets;
e) protect customers and our business.

2. WHAT WE MAY REQUEST
Depending on the transaction, we may ask for:
a) passport;
b) driving licence;
c) proof of address;
d) date of birth;
e) bank account evidence;
f) explanation of source of funds;
g) source of wealth information;
h) company ownership details.

3. WHEN WE MAY ASK
Checks may be required:
a) before first purchase;
b) for higher value transactions;
c) for cash transactions;
d) for unusual transaction patterns;
e) before buybacks;
f) before release of stored bullion;
g) where law requires enhanced checks.

4. SANCTIONS AND FRAUD SCREENING
We may screen names and transactions against fraud, sanctions and politically exposed person databases where lawful.

5. FAILURE TO PROVIDE INFORMATION
If requested information is not provided, we may delay, refuse or cancel a transaction.

6. HOW YOUR DATA IS USED
Identity and compliance data is handled in accordance with our Privacy Policy.

7. REPORTING OBLIGATIONS
In certain circumstances we may be legally required to make confidential reports to relevant authorities. We may be prohibited from discussing this.

8. QUESTIONS
Please contact [email protected] if you have any questions regarding our verification requirements.