Privacy Policy

Fodere Critical Minerals ("Fodere", "we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect personal data when you visit our website, use our services, or engage with us in any capacity. Fodere operates from offices in London (United Kingdom), New York (United States), and Johannesburg (South Africa), and this policy applies globally across all jurisdictions in which we operate. We comply with applicable data protection laws including the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), the South African Protection of Personal Information Act (POPIA), and other relevant legislation.

The data controller responsible for your personal data is Fodere Critical Minerals, with its registered office at 5 Approach Road, London SW20 8BA, United Kingdom. For any questions regarding this policy or your personal data, please contact us at info@foderegroup.com.

We may collect and process the following categories of personal data: Contact Information: Name, email address, phone number, company name, and job title provided through our contact forms, investor enquiry forms, or direct correspondence. Account Data: Login credentials and authentication data if you register for our Client Portal or investor platform. Technical Data: IP address, browser type and version, device information, operating system, time zone setting, and browsing actions collected automatically when you visit our website. Analytics Data: Information about how you use our website, including pages visited, time spent on pages, click patterns, and referral sources, collected via Google Analytics 4 (GA4). Communications Data: Records of correspondence when you contact us, including enquiries about our products (Titanium Dioxide, Vanadium Pentoxide, Niobium, Alumina, and Rare Earth Elements), investment opportunities, or partnership proposals. Professional Data: Information relevant to business relationships, including your role in the critical minerals supply chain, trading history, and commercial interests.

We use your personal data for the following purposes: Business Operations: To respond to enquiries about our mineral processing technology, products, and services; to manage investor relations and stakeholder communications; and to facilitate commercial negotiations and offtake agreements. Client Portal: To provide access to market data, document vaults, sector analysis, and other portal features for registered investors and partners. Website Improvement: To analyse website usage patterns and improve user experience, content, and functionality. Legal Compliance: To comply with legal and regulatory obligations, including those related to mining operations, environmental reporting, corporate governance, and anti-money laundering requirements. Marketing Communications: To send relevant industry updates, news about our operations, and information about our products, where you have consented to receive such communications or where we have a legitimate interest in doing so. Security: To protect our website, systems, and users from fraud, unauthorised access, and cyber threats.

We process your personal data on the following legal bases: Consent: Where you have given clear consent for us to process your personal data for specific purposes, such as subscribing to our newsletter or submitting an enquiry. Contractual Necessity: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract. Legitimate Interests: Where processing is necessary for our legitimate business interests, such as improving our services, managing investor relations, and ensuring the security of our operations, provided these interests do not override your fundamental rights. Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject, including mining regulations, financial reporting, and anti-money laundering laws.

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyse website traffic. Essential Cookies: Required for the website to function properly, including session management and security features. Analytics Cookies: We use Google Analytics 4 (GA4) to collect anonymised data about website usage. GA4 uses first-party cookies to measure user interactions. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on. Firebase Cookies: Our website is hosted on Firebase, which may set cookies for performance monitoring and hosting optimisation. You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

We do not sell your personal data to third parties. We may share your data with: Service Providers: Trusted third-party service providers who assist us in operating our website and business, including Google (Analytics and Firebase hosting), and email service providers. These providers are contractually obligated to protect your data. Professional Advisors: Legal, financial, and accounting advisors in connection with our business operations. Regulatory Authorities: Government bodies, regulators, and law enforcement agencies where required by law or in connection with our mining and minerals processing operations. Business Partners: With your consent, we may share relevant information with potential offtake partners, joint venture participants, or investors in the context of our critical minerals business.

Given our global operations across the United Kingdom, United States, and South Africa, your personal data may be transferred internationally. Where data is transferred outside the UK or EEA, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the relevant authorities, adequacy decisions, or other legally recognised transfer mechanisms. Data processed by Google (Analytics and Firebase) may be transferred to and stored in the United States in accordance with Google’s data processing terms and applicable transfer mechanisms.

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws and regulations. Specifically: Contact form submissions and general enquiries are retained for up to 3 years from the date of last interaction. Client Portal account data is retained for the duration of the account and for 5 years thereafter. Analytics data is retained in accordance with our Google Analytics settings (currently 14 months). Financial and regulatory records are retained in accordance with applicable legal requirements, which may be up to 7 years or longer.

Depending on your jurisdiction, you may have the following rights regarding your personal data: Right of Access: Request a copy of the personal data we hold about you. Right to Rectification: Request correction of inaccurate or incomplete data. Right to Erasure: Request deletion of your personal data where there is no compelling reason for continued processing. Right to Restrict Processing: Request that we limit how we use your data. Right to Data Portability: Request transfer of your data to another organisation in a structured, commonly used format. Right to Object: Object to processing based on legitimate interests or for direct marketing purposes. Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing. To exercise any of these rights, please contact us at info@foderegroup.com. We will respond to your request within 30 days.

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit (SSL/TLS), secure authentication via Firebase Auth, access controls and role-based permissions, regular security reviews, and secure hosting infrastructure provided by Google Firebase. While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will take steps to delete it promptly.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have concerns about how your data is being processed, please contact us: Fodere Critical Minerals 5 Approach Road, London SW20 8BA, United Kingdom Email: info@foderegroup.com Phone: +44 (0) 207 859 4161