PRIVACY POLICY & DATA PROTECTION NOTICE

EFFECTIVE DATE: 2026-07-01 | LAST UPDATED: 2026-07-01

1. INTRODUCTION

Fort Kobbe Management, Corp. is committed to protecting personal information entrusted to it by clients, prospective clients, suppliers, and website visitors. This Privacy Policy explains how information is collected, used, protected, retained, disclosed, and disposed of in connection with private vault storage, logistics, precious metals storage, and related services.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

2. COMPANY IDENTITY

Fort Kobbe Management, Corp., trading as Fort Kobbe International Vaults, operates private vaulting and related logistics services from Panama. Nothing in this Privacy Policy expands the scope of services offered or creates contractual obligations.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

3. SCOPE

This Policy applies to the website, enquiries, client onboarding, business communications, supplier relationships, and other legitimate business interactions.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

4. DEFINITIONS

Definitions include Personal Information, Processing, Client, Website Visitor, KYC, AML, Service Provider, Regulatory Authority, and Applicable Law.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

5. PRIVACY PRINCIPLES

Fort Kobbe follows principles of lawfulness, fairness, transparency, data minimization, purpose limitation, proportionality, confidentiality, integrity, and accountability.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

6. INFORMATION WE COLLECT

We may collect contact details, enquiry information, technical website information, identity documentation supplied during onboarding, compliance information, contractual documentation, payment-related administrative information, communications, and security records where reasonably necessary.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties

7. INFORMATION WE DO COLLECT

We do not intentionally collect unnecessary personal information, nor do we sell personal information. We do not knowingly collect information from children.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

8. SOURCES

Information may be obtained directly from individuals, authorised representatives, legal advisers, corporate service providers, publicly available records, compliance databases where legally permitted, or government authorities.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

9. LEGAL BASES

Processing is based upon consent where appropriate, contractual necessity, legal obligations, legitimate interests, fraud prevention, regulatory compliance, and protection of legal rights.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

10. WEBSITE USE

The website may collect IP addresses, browser information, security logs, cookies, and analytics solely for legitimate operational, security, and performance purposes.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

11. CLIENT ONBOARDING

KYC and customer due diligence information is collected only where required for onboarding, compliance, or contractual performance. Collection is limited to information reasonably necessary.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

12. AML

Information may be processed to comply with anti-money laundering, counter-terrorist financing, sanctions screening, fraud prevention, and other legal obligations.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

13. PRECIOUS METALS & LOGISTICS

Where clients utilise logistics or storage services involving precious metals or other assets, only information reasonably necessary to administer those services, satisfy customs or regulatory requirements, or comply with contractual obligations will be processed. This Privacy Policy does not alter the legal relationship governing any underlying transaction.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

14. CCTV & PHYSICAL SECURITY

For security purposes, Fort Kobbe facilities may employ CCTV, controlled access systems, visitor logs, and related security measures. Such information is retained only as reasonably necessary for security, regulatory, investigative, or legal purposes.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

15. COOKIES

Cookies may be used to improve website functionality, security, analytics, and user experience. Users may manage cookies through browser settings.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

16. ARTIFICIAL INTELLIGENCE

Fort Kobbe does not sell personal information for AI model training. AI technologies used internally, where any, are subject to confidentiality obligations, human oversight, and security controls.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

17. DISCLOSURE

Information may be disclosed only to authorised service providers, professional advisers, auditors, insurers, regulators, law enforcement, or courts where legally required or otherwise authorised.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

18. INTERNATIONAL TRANSFERS

Where personal information is transferred internationally, Fort Kobbe will take reasonable measures intended to provide appropriate safeguards consistent with applicable legal requirements.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company

19. SECURITY

Administrative, technical, organisational, and physical safeguards are maintained to protect information against unauthorised access, loss, alteration, misuse, or disclosure.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

20. RETENTION

Information is retained only for as long as reasonably necessary to satisfy legal obligations, regulatory requirements, contractual commitments, dispute resolution, recordkeeping, or legitimate business needs.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

21. INDIVIDUAL RIGHTS

Subject to applicable law, individuals may request access, correction, deletion, restriction, objection, portability, or withdrawal of consent where appropriate.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

22. GDPR

For individuals located within the European Economic Area or United Kingdom where applicable, Fort Kobbe seeks to respect rights recognised under applicable data protection legislation, subject to lawful limitations.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

23. CALIFORNIA NOTICE

Fort Kobbe does not sell personal information. Any rights available under applicable California law will be honoured where legally required.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

24. CHILDREN

Services are not directed to children and personal information from minors is not knowingly collected.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

25. THIRD-PARTY WEBSITES

External websites operate under their own privacy policies. Fort Kobbe accepts no responsibility for third-party privacy practices.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

26. CHANGES

This Policy may be updated periodically. Material revisions will be reflected by updating the Effective Date.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

27. CONTACT

Fort Kobbe Management, Corp.
Fort Kobbe International Vaults
Panama Pacifico, Republic of Panama
Email: info@fkmpa.com

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

Fort Kobbe applies a risk-based and proportional approach to privacy governance. Information is processed only for legitimate purposes connected with business operations, regulatory compliance, contractual performance, security, or protection of legal rights. Nothing in this Policy should be interpreted as creating duties, fiduciary relationships, or services beyond those expressly offered by the company.

28. APPENDIX A. - FREQUENTLY ASKED QUESTIONS

Do you sell my personal information?

No.

Do you use client information to train AI models?

No.

Why do you request identification documents?

Only where required for KYC, AML, contractual, or legal purposes.

Can I request access to my personal information?

Where applicable law grants such rights, yes, subject to legal limitations.

How long do you keep information?

Only as long as reasonably necessary under legal, contractual, and regulatory requirements.

Do you share information with governments?

Only where legally required or otherwise authorised.

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