PRIVACY POLICY

Modtra Systems

Effective Date: January 01, 2026

At Modtra Systems (“Modtra Systems” “Modtra”, “we”, “us”, or “our”), we respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.modtrasystems.com (the “Site”), contact us, or use our services as a professional mandate and intermediary in global commodities trading.

Please read this Privacy Policy carefully. By accessing or using our Site or services, you agree to the practices described in this policy.

1. Information We Collect

We may collect the following types of information:

• Personal Information you provide directly: name, email address, phone number, company name, job title, business address, and any other details you submit via contact forms, inquiry forms, emails, or calls.

• Business and Trading Information: Details about your commodities trading interests, requirements, preferred products (e.g., Gold, Copper, Aluminium, Sulphur, Urea 46), volume expectations, and other transaction-related information you voluntarily provide. Where a formal engagement occurs, such information may be further protected under a separate Non-Disclosure Agreement (NDA).

• Automatically Collected Information: IP address, browser type, device information, operating system, referring URLs, pages visited, and usage data through cookies and similar technologies.

• Communication Records: Records of emails, messages, or calls with our team.

We do not collect sensitive personal data (such as racial or ethnic origin, health data, or financial account details) unless voluntarily provided and necessary for our services.

2. How We Use Your Information

We use your information for the following legitimate business purposes:

• To respond to your inquiries and provide information about our mandate and intermediary services.

• To facilitate introductions between buyers and sellers in commodities trading.

• To improve our website, services, and user experience.

• To communicate with you about updates, offers, or important notices.

• To comply with legal obligations, prevent fraud, and enforce our terms.

• For internal business purposes such as analytics and record-keeping.

3. Sharing of Information

We may share your information in the following limited circumstances:

• With potential trading counterparties (buyers or sellers) only when you explicitly request or consent to an introduction.

• With trusted service providers (e.g., hosting providers, email services, or third-party verification services) who assist us and are bound by confidentiality.

• When required by law, regulation, court order, or government authority (including AML/KYC requirements).

• In the event of a business transfer (merger, acquisition, or sale of assets).

We do not sell your personal information to third parties for marketing purposes.

4. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience, analyze website traffic, and remember your preferences. You can manage cookie preferences through your browser settings. Note that disabling cookies may affect site functionality.

5. Data Security

We implement reasonable administrative, technical, and physical security measures to protect your personal information. However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

6. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy or as required by applicable law.

7. Your Rights

Depending on your location, you may have rights to:

• Access, correct, or delete your personal data.

• Object to or restrict processing.

• Withdraw consent where applicable.

To exercise these rights, please contact us using the details below. We will respond within a reasonable timeframe.

8. International Data Transfers

Your data may be transferred to and processed in countries outside your jurisdiction (including South Korea and other operational locations). We take appropriate safeguards to protect your information during such transfers.

9. Children’s Privacy

Our Site and services are not directed at children under the age of 18. We do not knowingly collect personal data from children.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on our Site with an updated effective date.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Modtra Systems

Email: sales@modtrasystems.com