GFG Privacy Policy

GFG (as defined below) considers privacy to be fundamental to our relationship with investors. We are committed to maintaining the confidentiality, integrity and security of investors’ personal data. We appreciate that we have access to information about our investors that is not generally available to the public and understand GFG’s obligation to protect the privacy of that information.

As used in this Notice, “GFG” means: (a) Global Frontier Group Limited, a Barbados company; (b) Northwest Metals Group LLC, a Delaware limited liability company; and (c) any other entity controlled by GFG.

This Privacy Notice (the “Notice”) details how the relevant shareholders, members or affiliates of GFG (“we” or “us”) (including the managing members of limited liability companies and the directors of corporations, in each case controlled by GFG, in which existing, former and prospective investors (“Investors”) invest) process personal data received about Investors (the Investor referred to herein as “you”) in relation to the investment or potential investment in GFG, how we collect, share, and process such personal data and your rights and obligations in relation to your personal data during the course of your investment. For information about personal data collected about individuals outside this context, please see our website terms of use.

This Notice also describes the measures we have taken in order to protect the confidentiality, integrity and security of personal data regarding Investors, our purposes for collecting such information, Investors’ rights regarding their personal data and the way to contact GFG to exercise those rights. It also describes the limited extent to which we may share that information with affiliates and non-affiliated third parties of GFG.

This Notice and the policies described herein are subject to change at any time.

Data Controller 

GFG is the data controller in relation to personal data relating to Investors. Relevant information on GFG and applicable affiliates is available in GFG’s legal documents and subscription agreements. These documents are accessible to existing Investors or can be made available by emailing info@globalfrontiergroup.com. These documents are available to new Investors via a secure data room available by emailing info@globalfrontiergroup.com. Our contact details for all data privacy inquiries and questions are provided at the end of this Notice.

Collection of Information

As an Investor, you will provide your personal data to us by completing subscription forms and associated documentation and by communicating with us by phone, e-mail or otherwise. In all cases, we may collect and process the following personal data about you:

(a) Contact and/or personal data such as first name, last name, telephone number, email address, residential address, and business address;

(b) Government-issued identifiers such as Passport number, driver’s license number, tax ID numbers;

(c) Other information we collect from subscription agreements and/or other forms of communications with you, such as social security numbers, net worth and sources of income;

(d)  Bank details and wire instructions;

(e) Screening against various lists, criminal searches and newspaper coverage;

(f) KYC and/or AML documentation including proof of identity and proof of address (for example, utility bills, bank statements, driver’s license, passport or other photo ID);

(g) With regard to each of your visits to the [data room] we automatically collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

(h)Information in relation to your net worth, history of investments, investment preferences and/or tax position.

Use of Information
  1. We use your personal data such as (a) first name, last name, telephone number, email address, residential address, and business address, (b) government-issued identifiers such as passport number, driver’s license number, and tax ID number, (c) information in relation to your net worth, history of investments, and/or tax position for purposes of account administration, management of your subscription, maintaining the register of shareholders and distributions, wire instructions, internal audit validations, communications, events, investor relations and more generally the performance of services requested by and operations in accordance with the instructions of the Investor. The use of such data is necessary for our legitimate interests to ensure effective administration of your investment and for the entry into and performance of a contract.
  1. We use your contact information such as (a) first name, last name, telephone number, email address, residential address, and business address, (b) date of birth, place of birth, citizenship, tax residency, utility bills or other identification records, (c) government-issued identifiers such as passport number, driver’s license number, tax ID number or other identifiers, (d) criminal searches, legal searches, news coverage, social media searches, and (e) KYC and/or AML documentation including proof of identity and proof of address in order to perform AML/KYC checks, screening against sanctions lists, background checks and compliance with all relevant legal, regulatory and administrative obligations and responsibilities of GFG and/or any shareholder of GFG and/or any counterparty of GFG (including providers of debt or equity finance and vendors) including pursuant to any applicable law, FATCA or similar regimes, transactions reporting, complying with requests from, and requirements of, local or foreign regulatory or law enforcement authorities, tax identification and reporting, any other automatic exchange of information regimes. The use of such information is necessary for compliance with legal and regulatory obligations including sanctions laws/AML and KYC laws and or any other laws applicable to the data controller.
  1. We use contact information such as (a) first name, last name, telephone number, email address, residential address, and business address, (b) government-issued identifiers such as passport number, driver’s license number, tax ID number, and (c) KYC and/or AML documentation including proof of identity and proof of address for risk management and fraud prevention purposes including for the evaluation of the Investor’s financial needs, monitoring the Investor’s financial situation including for assessing its creditworthiness and solvency, to manage litigation and for our accounting purposes. The use of such information is necessary for our legitimate interests to run an efficient and successful business.
  1. We use your contact information such as first name, last name, username, telephone number, email address, date/time and content of the call to monitor electronic communications for quality and business analysis.  The use of such information is necessary for our legitimate interests to run an efficient and successful business.
  1. We use your contact information such as first name, last name, telephone number and email address for the purpose of receiving materials and information about the business and fundraising activities of GFG. You can opt out of receiving such communications at any time by contacting us at info@globalfrontiergroup.com. The use of such information is necessary for our legitimate interests to run an efficient and successful business and involves consent where required.
  1. We use your contact information such as first name, last name, telephone number, email address and wire instructions or other bank details, payment amounts and percentage share ownership for the purpose of processing payments. This use is necessary for entry into and performance of a contract for our legitimate interests to ensure effective administration of our business.
Retention of Information

Investors’ personal data will be retained only for as long as the information is needed to fulfill the purposes for which it is collected and processed. GFG reserves the right to retain and use Investors’ personal data for as long as necessary to comply with our legal and regulatory obligations and business requirements and/or to resolve any ongoing disputes and enforce our agreements. For the avoidance of doubt, data will not be destroyed before any regulatory retention period expires, or during a pending investigation, whether legal or regulatory.

Disclosure of Information 

We do not disclose personal data regarding Investors except in accordance with our Notice described herein and as permitted or required by applicable law.  We may disclose personal data regarding an Investor to non-affiliated third parties under one or more of the following circumstances: (a)  as authorized by subscription agreements or organizational documents for GFG or as otherwise authorized by the Investor; (b) to the following service providers: Eticas International (Barbados) Limited as GFG’s corporate secretary; Peter Evelyn & Co  as GFG’s Barbados counsel; Thompson Henry & Associates as GFG’s statutory auditor; (c) in connection with: (i) the administration, processing and servicing of an Investor’s investment in GFG and with GFG’s general business operations; and (ii) to satisfy any anti-money laundering related customer identification procedures required by any laws or regulations applicable to such entities; (d) in connection with the making, management or disposition of any GFG investment; (e) as otherwise necessary to effect, administer or enforce Investor or GFG transactions; or (f) as required or permitted by applicable law (for example, in connection with regulatory or law enforcement inquiries).

All of your personal data will be accessible within GFG for the purpose of reviewing new Investors including conducting KYC and AML checks, screening against sanctions lists, fund administration, investor relations, compliance and legal functions, and facilitating fundraising activities for new investments. We may share personal data regarding an Investor with our affiliates, consultants and employees for legitimate business purposes, for example, in order to service Investor accounts.

Protection of Information

We maintain physical, electronic and procedural safeguards that comply with applicable standards to protect personal data regarding Investors. We use reasonable best efforts to require that any person or institution to which we disclose personal data regarding an Investor will protect the confidentiality of that Investor information and use the information only for the purposes for which we disclose the information to them. In addition, we restrict access to nonpublic personal data regarding Investors to those consultants and employees who need to know that information in the course of their job responsibilities.

Data Subject Rights

The General Data Protection Regulation (the “GDPR”) and other national privacy laws provide data subjects with certain rights regarding their personal data. To the extent that the GDPR applies to Investors whose personal data is collected and processed by GFG, these Investors have certain rights as detailed below.  Please note that we will require you to verify your identity before responding to any requests to exercise such rights by providing proof of identity and address in a form satisfactory to us. We must respond to a request by you to exercise those rights without undue delay and at least within one (1) month (although this may be extended by a further two (2) months in certain circumstances). To exercise any of your rights, please contact info@globalfrontiergroup.com.

(a) Data Rights. In certain circumstances, you have the right to access and receive a copy of the information we hold about you, to rectify any personal data held about you that is inaccurate and to request the deletion, portability or suspension of or access to personal data held about you. Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you. You can exercise your rights by contacting us at info@globalfrontiergroup.com.

(b) Withdrawal of Consent. Where you have provided your consent to us sharing or processing your personal data, you can withdraw your consent at any time by emailing info@globalfrontiergroup.com.

(c) Complaints. In the event that you wish to make a complaint about how we collect, share, or process your personal data, please contact us in the first instance at info@globalfrontiergroup.com and we will endeavor to deal with your request as soon as possible.  This is without prejudice to your right to launch a claim with the supervisory authority.

Contacting GFG

This Notice may be amended from time to time, at our discretion. Investors may contact GFG for updates or in order to exercise their rights under this Notice by emailing info@globalfrontiergroup.com.

GFG Website Terms of Use

Terms of Use / Legal Disclosures

Please read this page carefully before using this website, www.globalfrontiergroup.com, together with all of its sub-websites, materials, hyper-links, and related documents (collectively, the “Website”) and the materials that may be accessible through this Website. By using this Website, you are agreeing to be legally bound by the following terms. Global Frontier Group Limited (together with its affiliates, “GFG”) reserves the right to amend these Terms of Use (“Terms”) at any time and without notice. Your continued use of this Website constitutes your agreement to such changes.

Limited License

GFG provides this Website for your informational purposes only.

Subject to these Terms, GFG grants you a non-exclusive, non-transferable, limited right to display this Website and download the material displayed on this Website (the “Materials”) solely to view general information regarding GFG’s business and to access certain information regarding your interest in GFG.

You agree not to reproduce, modify, make collections or compilations of, distribute, or publicly display the Website or the Materials. You must not transfer the Materials to any other person or entity. You must retain, on all copies of the Materials downloaded, any and all copyright and other proprietary notices contained in the Materials. You agree to abide by all additional restrictions displayed on the Website from time to time. Any unauthorized use of the Website or the Materials and/or any other information listed on the Website is prohibited. Except as expressly provided herein, GFG does not grant you any express or implied license or permission under any patents, trademarks, copyrights or trade secret information.

You agree to access the Materials and this Website manually, by request, and not automatically, through the use of a “bot” or similar program, or by other means. You agree not to take any action, alone or with others, that would interfere with the operation of this Website, to alter this Website in any way, or to impede others’ access to and freedom to enjoy and use this Website as made available by GFG.

Regulatory Matters

The information provided on this Website is not provided to and may not be used by any person or entity in any jurisdiction where the provision or use thereof would be contrary to applicable laws, rules or regulations of any governmental authority or regulatory or self-regulatory organization or where GFG is not authorized to provide such information or services.

Ownership and Intellectual Property

“GFG” is the trade name for Global Frontier Group Limited and its affiliates. All content included on this Website, such as graphics, logos, articles and other materials, is the property of GFG or others and may be protected by copyright and other laws. Nothing on this Website shall be interpreted as granting any license or right to use any image, trade name, trademark, logo or service mark on the Website. Copying or downloading material from this Website does not transfer title to any material on this Website to you. You are prohibited from using any of GFG’s marks for any commercial and/or infringing purpose, including but not limited to use as metatags on other pages or sites on the World Wide Web, without the written permission of GFG. Anything transmitted to this Website by you becomes GFG’s property and may be used by GFG for any lawful purpose. GFG reserves any and all rights with respect to copyright and trademark ownership of all Materials on this Website, and will enforce such rights to the full extent of the law.

Proprietary Rights

All right, title and interest in this Website and any content contained herein is the exclusive property of GFG, except as otherwise stated. Unless otherwise specified, this Website is for your personal and non-commercial use only and you may print, copy and download any information or portion of this Website for your personal use only. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, frame, create derivative works from, transfer, or otherwise use in any other way for commercial or public purposes in whole or in part any information obtained from this Website, except for the purposes expressly provided herein, without GFG’s prior written approval. If you copy or download any information from this Website, you agree that you will not remove or obscure any copyright, trademark or other notices or legends contained in any such information.

Disclaimer of Warranties

The information on this Website is provided on an “as is” basis. GFG does not warrant the information provided herein or your use of this Website generally, either expressly or impliedly, for any particular purpose and expressly disclaims any implied warranties, including but not limited to, warranties of title, non-infringement, merchantability or fitness for a particular purpose. GFG will not be responsible for any loss or damage that could result from interception by third parties of any information made available to you via this Website. Although the information provided to you on this Website is obtained or compiled from sources we believe to be reliable, GFG cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose. GFG disclaims any duty to update this Website.

None of GFG or any of its directors, officers, partners, members, employees, agents, affiliates, subsidiaries or third party vendors (collectively, the “Released Parties”) will be liable or have any responsibility of any kind for any loss or damage that you incur in the event of any failure or interruption of this Website, or resulting from the act or omission of any other party involved in making this Website or the data contained herein available to you, or from any other cause relating to your access to, inability to access, or use of the Website or the Materials, whether or not the circumstances giving rise to such cause may have been within the control of the Released Parties. In no event will the Released Parties be liable to you, whether in contract or tort, for any direct, special, indirect, consequential or incidental damages or any other damages of any kind even if the Released Parties have been advised of the possibility thereof. This limitation on liability includes, but is not limited to, the transmission of any viruses which may infect a user’s equipment, failure of mechanical or electronic equipment or communication lines, telephone or other interconnect problems (for example, you cannot access your internet service provider), unauthorized access, theft, operator errors, strikes or other labor problems or any force majeure.

GFG cannot and does not guarantee continuous, uninterrupted or secure access to the Website.

LIMITATIONS OF DAMAGES

NONE OF THE RELEASED PARTIES ARE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, CONSEQUENTIAL LOSS, LIABILITY, COST, CLAIM, EXPENSE OR DAMAGES OF ANY KIND (INCLUDING, WITHOUT LIMITATION, ANY LOST PROFITS, BUSINESS INTERRUPTION, LOSS OF INFORMATION OR PROGRAMS OR OTHER DATA ON YOUR INFORMATION HANDLING SYSTEM) WHETHER IN CONTRACT OR IN TORT (INCLUDING NEGLIGENCE), THAT ARE RELATED TO THE ACCURACY, INACCURACY, USE OF, OR THE INABILITY TO USE, THE CONTENT, MATERIALS AND FUNCTIONS, OR IN CONNECTION WITH ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS OR LINE OR SYSTEM FAILURE, OF THIS WEBSITE OR ANY LINKED WEBSITE, EVEN IF GFG IS EXPRESSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

No Offers or Reliance

No material on this Website shall be used or considered as an offer to sell or a solicitation of any offer to buy the securities of GFG or any other issuer. Offers can only be made where lawful under, and in compliance with, applicable law.

GFG makes no representations that transactions and other matters discussed on this Website are available or appropriate for all jurisdictions or by all investors. Those who access this Website do so at their own initiative and are responsible for compliance with local laws or regulations.

While GFG uses reasonable efforts to obtain information from reliable sources, GFG makes no representations or warranties as to the accuracy, reliability or completeness of any information or document at this Website obtained outside of GFG. Opinions and any other contents on this Website are subject to change without notice.

GFG is not utilizing this Website to provide investment or other advice, and no information or material at this Website is to be deemed a recommendation to buy or sell any securities or is to be relied upon for the purpose of making or communicating investment or other decisions. Any transactions listed on this Website are included as representative transactions and are not necessarily reflective of overall performance. Nothing contained on this Website constitutes financial, legal, tax or other advice.

Forward Looking Statements

PAST PERFORMANCE IS NO GUARANTEE OF FUTURE RESULTS. Certain information contained herein may be based upon forward-looking statements. Forward-looking statements are inherently uncertain and factors affecting the markets in general or industries or issuers in particular may cause events or results to vary from those described herein. Accordingly, you should not rely on or draw conclusions from forward looking statements.

External Links to This Website

GFG shall have no liability for third party content or websites linking to or framing this Website. All links to this Website must be approved in writing by GFG. GFG reserves the right to revoke any such consent to link at any time.

Information Provided By You

Do not send any confidential or proprietary information to GFG via the Website. No information or materials that you provide to GFG via this Website will be considered or treated as confidential or proprietary. By providing any such information or materials to GFG, you grant to GFG an unrestricted, irrevocable, worldwide, royalty-free, non-exclusive license to use, reproduce, modify, publicly display, publicly perform, transmit and distribute such information and materials, and you further agree that GFG is free to use any ideas, concepts or know-how that you or individuals acting on your behalf provide to GFG. You agree not to use the Website to distribute, email or post any advertising, promotion or solicitation without GFG’s prior approval. You agree not to use the Website to upload, display or distribute any materials that are defamatory, threatening, obscene, harassing, or otherwise unlawful, or that incorporate the copyrighted, confidential or proprietary material of any other person or entity.

Changes

GFG reserves the right, at its sole discretion, to grant or revoke authority to use this Website or to change, add, suspend or remove the information described in the Website or the Materials at any time without prior notice to you and without any liability to you.

GFG may also impose limits on certain features or restrict your access to parts or all of this Website without notice or liability. GFG may terminate the authorization, rights and license given above and, upon such termination, you shall immediately cease using and destroy all Materials.

International Users and Choice of Law

This Website is not intended for use by any person or entity that is a citizen or resident of or located in any jurisdiction where such distribution, publication, availability or use would be contrary to applicable law or regulation or which would subject GFG or its affiliates to any registration requirement within such jurisdiction.

GFG makes no representation that the information available on this Website is appropriate or available for use in any jurisdiction. Prior to accessing the Website, users are required to ensure themselves whether the information available on this Website can be accessed and utilized in their respective jurisdictions and observe any relevant restrictions thereto. The user shall be solely responsible for compliance with all applicable laws and shall satisfy that they are not subject to any regulatory requirements which restrict or prohibit them from accessing or using the Website.

The securities of GFG have not been registered under any securities law of any foreign jurisdiction and this Website is only for the information of any person in any jurisdiction where it may be lawful to offer such securities. GFG will not undertake any requisite registration within any prohibited jurisdiction.

This Website is governed by the laws of Barbados, without giving effect to its conflict of laws provisions. You agree that the courts of Barbados shall have exclusive jurisdiction over any and all disputes arising from your use of the Website and/or the Materials.

These Terms constitute the entire agreement between GFG and you with respect to your use of this Website. You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to your use of this Website must be commenced within one (1) year after the claim or cause of action arises. If for any reason a court of competent jurisdiction finds any provision of these Terms or portion thereof to be unenforceable, that provision shall be enforced to the maximum extent permissible so as to affect the intent of the provision, and the remainder of these Terms shall continue in full force and effect.

Anti-Corruption

GFG is committed to providing the highest quality services to its investors. To achieve this, anyone working for or on behalf of GFG (including staff members, vendors, agents, suppliers or service providers) is expected to maintain the highest ethical standards, to conduct themselves with integrity and in a manner that excludes consideration of personal advantage and the interests of other clients. GFG does not tolerate bribery or corruption in any form.

Notice

Applicable rules and regulations require us to obtain, verify, and record information to identify each entity or individual that enters into a business or investment relationship with us. We may ask for your address, identification number, corporate documents or other identifying information to help us verify your identity. We may use a third party source to confirm the information you provide us.

In the ordinary course of business, GFG collects, uses, and shares personal information pertaining to its partners, employees, investors, and others. Obtaining this information is important to our ability to conduct our operations and to deliver the highest level of service, but we also recognize that you expect us to treat this information appropriately.

Privacy Policy

Our Privacy Policy describes the types of personal information we may collect about you, the purposes for which we may use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. Please see GFG’s Privacy Policy above. GFG reserves the right to amend this policy at any time and without notice. Your continued use of this Website constitutes your agreement to such changes.

Cookies

When you visit our Website, our web servers collect the details of your operating system, browser version, domain name and IP address and the details of the website you linked from to the Website. Our web servers may seek to place a “cookie” (a small data file) on your computer’s hard drive, which allows the server to recognize your computer when you visit again. If you prefer not to accept cookies, you can set your browser to reject them or to alert you before one is placed.  Please see GFG’s Cookies Policy below.

Security of Collected Information

We use all reasonable efforts to maintain physical, electronic, and administrative safeguards to protect your personal information from unauthorized or inappropriate access, but we note that the Internet is not a secure medium.

Although GFG endeavors to take steps to provide a secure environment for users accessing the Website, due to the nature of the Internet, GFG cannot guarantee confidentiality or security of any personal and other information being provided. GFG makes no warranty whatsoever to you, express or implied, regarding the security of the Website, including with respect to the ability of unauthorized persons to intercept or access information transmitted by you through the Internet.

GFG welcomes your e-mail correspondence. However, it is possible that information transmitted to GFG may be read or obtained by other parties. Messages sent over the Internet cannot be guaranteed to be completely secure or error-free as they are subject to possible interception, corruption, delay, loss or possible alteration. GFG is not responsible for them and will not be liable to you or anyone else for any damages or otherwise in connection with any messages sent by you to GFG or any message sent by GFG to you over the Internet. If you send e-mail (encrypted or not) to GFG over the Internet, you are accepting the associated risks, including lack of confidentiality.

Further, despite all possible security measures that GFG may take to keep this Website free from hacking and other interference, this Website like any other website is not free from such risks. GFG disclaims all liability on account of any loss or damage that any user may suffer or incur on account of any alteration or manipulation of any data or information accessed or downloaded from this Website.

While GFG endeavors to take every reasonable precaution to ensure accuracy, security and confidentiality of information available through/on the Website, GFG cannot be held responsible for any consequence of any action(s) carried out by any authorized or unauthorized user.

Access to Collected Information

You have certain rights under applicable laws to access your personal information held by us. You can contact us as described below to request a review or update of that information.

Electronic Correspondence

GFG may retain both outgoing and incoming electronic correspondence. GFG may be required to produce records of electronic correspondence to regulatory authorities or others with legal rights to the information. Transmission of electronic correspondence cannot be guaranteed to be secure, timely or error-free.

Contacting Us

If you have any questions about the foregoing, please contact us at info@globalfrontiergroup.com

We’d love to hear from you!

If you have any questions or would like to know more about GFG or our portfolio companies, please contact us.

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