Privacy policy

Proprietary Restriction:
This document is property of Zeme Eco Fuels and Alloys Ltd, any disclosure, reproduction or transmission to unauthorized parties is prohibited.

Zeme Eco Fuels and Alloys Ltd is a company registered under the laws of Cyprus with registration number HE357072 (hereinafter the “Company” or “We”).

This policy sets out the basis and explains how we will treat and/or process any personal data and/or information we collect from you, or which you provide to us, in the course of cooperating with us and/or contacting us for any reason. By reaching the Company, each interested party hereby gives its consent to such collection, processing, storage and use of personal information by the Company as explained below or as otherwise stated at the point of collection. This Privacy Policy also demonstrates your rights in relation to your data and indicates whom you can contact for additional information or queries

Nothing in this Privacy Policy Declaration shall limit your statutory rights in relation to your personal data. By providing personal data to the Company, you consent that the Company will be processing your data in accordance with this Privacy Policy. This Privacy Policy:

  • provides an overview of how the Company collects and processes your personal data and tells you about your rights under the local data protection law and the EU General Data Protection Regulation (EU) 2016/679 (‘GDPR’),
  • is directed to natural persons who are either current or potential associates and/or members of the Company, or are authorized representatives/agents or beneficial owners of legal entities or of natural persons who are current or potential associates and/or members (herein referred to as the interested parties),
  • is directed to natural persons who have and/or maintain such a business relationship with the Company,
  • contains information about when we share your personal data with other third parties (for example, our service providers).

In this Privacy Policy, your data is called “personal data” and/or “personal information”.

The term ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’ or ‘interested party’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal data includes special categories of personal data and pseudonymised personal data but excludes anonymous data or data that has had the identity of an individual permanently removed.

The term ‘special categories of personal data’ or ‘sensitive data’ refers to information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

The term ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

References to ‘you’ or ‘your’, relate to the relevant individual who is the subject of the personal data.

When we refer to “our website” or “this website” in this policy, we mean the specific webpage of

The Company in the context of exercising its scopes, for which it was founded, collects the necessary personal information required to safeguard the interested parties’ data and/or assets and/or privacy and to provide the interested parties with the services they require, as well help the Company to construct the interested parties’ profile based on their requirements and preferences in order to achieve its scopes effectively.

In this respect, the Company gathers information from the interested parties, which it receives them via its website or via other means. The Company might also collect and process personal data from service providers (such as AML/KYC provider etc.) which it lawfully obtains and is permitted to process. In certain circumstances, the Company may gather personal information from banks and/or credit agencies, and/or clearing agencies and/or other sources.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes [first name, maiden name, last name, username or similar identifier, title, date of birth and gender].
  • Contact Data includes [billing address, delivery address, email address and telephone numbers].
  • Financial Data includes [bank account and payment card details].
  • Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
  • Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Company’s website].
  • Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
  • Usage Data includes [information about how you use our website, products and services].
  • Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.

Where interested parties are required to provide us with personal data of other data subjects (such as family members) as required for the purposes of our engagement, we take steps to ensure that the interested parties have complied with the privacy laws and regulations relevant to that personal data.

We understand the importance of protecting children’s privacy. Our website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children. We may collect personal data in relation to children only provided that we have first obtained their parents’ or legal guardian’s consent or unless otherwise permitted under law. For the purposes of this Privacy Policy, “children” are individuals who are under the age of eighteen (18).

We may also collect or obtain personal data from you because we observe or infer that data about you from the way you interact with us. For example, to improve your experience when you use this Website and ensure that it is functioning effectively, we (or our service providers) may use cookies (small bits of data stored in a user’s browser) which may collect personal data.

The Company will protect your privacy and use, store, process and handle of your personal data in an open and transparent manner and in accordance with GDPR and local data protection law.
• We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Provided that you have given us your specific consent for processing (other than for the reasons set out herein) then the lawfulness of such processing is based on that consent. You have the right to withdraw consent to such processing at any time by contacting by clicking on the “Unsubscribe” function in any marketing communications, including emails, that we send to you. Any processing of personal data prior to the receipt of your revocation will not be affected.
Purposes for which we will use your personal data.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)   (a) Identity
(b) Contact
(c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time].
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a product/service purchase, warranty registration, product/service experience or other transactions].
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please refer to our Cookies Policy
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

In order for the Company to proceed with a customer relationship with an interested party, the interested party must provide all personal data which are necessary for the required commencement and execution of a membership relationship. The Company is obligated to collect such personal data, in order to verify interested parties’ identity before entering in a relationship with them or the legal entity for which an interested party is the authorized representative / agent or beneficial owner, so that it complies with its statutory and legal obligation as mentioned above.

If an interested party does not and/or refuses to provide the Company with the required data, then the Company will not be allowed to commence and/or to continue its membership relationship either with the interested party, or as an individual and/ or as the authorized representative/agent and/or the beneficial owner of a legal entity.

We use a range of physical, electronic and managerial measures to ensure that your personal data is kept secure, accurate and up to date. These measures include:

  • education and training of the relevant staff regarding privacy obligations when handling personal data;
  • administrative and technical controls to restrict access to personal data on a ‘need to know’ basis; and
  • technological security measures, including fire walls, encryption and anti-virus software.

The Company may share your information with its affiliates and/or with member companies which are within the same group with the Company, as well as with its partners and associates, in the event such information is reasonably required in order to provide the products or services to its interested parties or in order to offer additional similar products and services that meet interested parties’ needs, and which are delivered in a manner that is useful and relevant only where interested parties have authorized the Company to do so. Such affiliates, group members, partners and associates, enter into contractual agreements with the Company by which they observe confidentiality and data protection according to the GDPR and local data protection law.

The Company may also be legally required to disclose interested parties’ personal data, to supervisory and other regulatory and public authorities, so it complies with its statutory and legal obligations.

The Company does not sell, license, lease, rent or share, or otherwise disclose interested parties’ personal information to third parties, except as described below:

  1. Where required by law or a court order by a competent court; in case such disclosure is required to be made by law or any regulatory authority, it will be made on a ‘need-to-know’ basis, unless otherwise instructed by the regulatory authority;
  2. Where requested by any regulatory authority having control or jurisdiction over the Company and/or the interested party and/or their associates and/or in whose territory the Company has interested parties;
  3. To relevant authorities to investigate or prevent fraud, money laundering or other illegal activity;
  4. To credit reference and fraud prevention agencies, third authentication service providers, banks and other financial institutions for credit checking, fraud prevention, anti-money laundering purposes, identification or due diligence checks and/or monitoring of the interested parties. To do so they may check the details the interested parties have supplied against any particulars on any database (public or otherwise) to which they have access. They may also use interested parties’ details in the future to assist other companies for verification purposes. A record of the search will be retained by the Company;
  5. To the Company’s professional advisors provided that in each case the relevant professional shall be informed about the confidential nature of such information and commit to the confidentiality herein obligations as well;
  6. To other service providers who create, maintain or process databases (whether electronic or not), offer record keeping services, email transmission services, messaging services or similar services which aim to assist the Company collect, storage, process and use interested party information or get in touch with the interested party;
  7. To third parties engaging with the Company to help carry out certain internal functions such as account processing, fulfilment, or other data collection activities relevant to the Company’s scopes;
  8. To credit reporting or collection agencies as reasonably required in order to provide the services to Company and/or its interested parties;
  9. To other service providers for statistical purposes in order to improve the Company’s marketing, in such a case the data will be provided in an aggregate form;
  10. Where necessary in order for the Company to defend or exercise its legal rights to any court or tribunal or arbitrator or Ombudsman or governmental authority;
  11. At the interested parties’ request or with the interested parties’ consent;
  12. Interested party Information is disclosed in relation to US taxpayers to the Inland Revenue in the Republic of Cyprus, which will in turn report this information to the Internal Revenue Service (IRS) of the U.S. according to the Foreign Account Tax Compliance Act (FATCA) of the USA and the relevant intergovernmental agreement between the Republic of Cyprus and the U.S.

Use of the shared information is strictly limited to the performance of the above and is not permitted for any other purpose. All third parties with which the Company shares personal information are required to protect such personal information in accordance with all relevant legislation and in a manner like the way the Company protects the same. The Company will not share personal information with third parties which it considers will not provide its interested parties the required level of protection.

As a general rule, the interested parties’ data is processed within the European Union/European Economic Area (EU/EEA), and no data is transferred to and/or processed in countries outside the EU/EEA.

Telephone conversations and electronic communications between the interested party and the Company might be recorded and kept by the Company for a period of up to five years and recordings will be the sole property of the Company. The interested parties accept such recordings as conclusive evidence of conversations so recorded. Such recordings shall be provided to the interested parties upon request.

From time to time the Company may seek to contact interested parties, whether by phone or by email and may process interested parties’ personal data for the purpose of informing them of any updates and/or news and/or any information related to the Company.

Any interested party wishing to opt in for such information and/or marketing activities may contact the Company at

The Company is not responsible for the privacy policies or the content of sites to which the Company website links and has no control of the use and/or the protection of information which is provided to the interested parties and/or which is collected by those sites. Whenever an interested party elects to link to a co-branded web site or to a linked web site, the interested party may be asked to provide registration or other personal information. Please note that such information is recorded by a third party and will be governed by the privacy policy of that third party and not the present privacy policy declaration

When the interested party is becoming a member of the Company, he will be joining the Company’s mailing list in order to receive Company news, product updates, and analysis & research updates provided that a consent has been provided by the interested party. If the interested party wishes to unsubscribe from the mailing list, they must inform the Company in writing via sending an email to or click the ‘unsubscribe’ link on the mailing list whenever that is possible.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Interested parties/You have the following rights in terms of their/your personal data that the Company holds about them/you:

  1. Receive access to their personal data.This enables them to e.g. receive a copy of their personal data and to check that the Company is lawfully processing such. A request by the interested party may be sent to
  2. Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Interested parties may also have the right to object where the Company is processing their personal data, for direct marketing purposes. This also includes profiling since it is related to direct marketing.

If the interested party objects to processing for direct marketing purposes, then the Company shall stop the processing of the interested party’s personal data for such purposes.

  1. Request to receive a copyof their personal data in a format that is structured and commonly used and transmit such data to other organizations. Interested parties also have the right to have their personal data transmitted directly by the Company to other organizations that they will name [data portability]. We are not responsible for the security of the personal data or its processing once received by the third party. Please be advised that we may not provide you with certain data if providing it would interfere with another’s rights.
  2. Withdraw the consent that they gave to the Companyabout the processing of their personal data at any time. Any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn or revoked by the interested party.
  3. Request the restriction of processing of your personal data. You have the right to restrict processing if:
  • the said data is not accurate,
  • it has been used unlawfully but you do not wish for us to delete it,
  • it is not relevant any more, but you want us to keep it for use in possible legal claims, or
  • you have already asked us to stop using your personal data but you are waiting for us to confirm if we have legitimate grounds to use your data.

In the event that you choose to exercise this right, and provided that such request may not be overridden on legitimate grounds, we shall retain your data but restrict processing.

  1. Request rectification of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. When we keep personal data submitted to us, we do not assume responsibility for verifying the ongoing accuracy of the content of personal data. If you would like to update any personal data you have submitted to us, please email us at
  2. Request erasure of your personal information. You have the right to request the erasure of your personal data [known as the ‘right to be forgotten’] where there is no good reason for us to continue to process it. Additionally, you also have the right to ask us to erase your data where you have exercised your right to object to processing (see Object to processing above).

To exercise any of your rights, or if you have any other questions about our use of your personal data, please send an email to

We endeavour to address all of your requests promptly.

If you have any questions or complaints about this Privacy Policy or the way we process your personal data, or would like to exercise any of your rights set out above please send an email with the details of your complaint to

You also have a right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus. For further information on your rights and how to complain to the Data Protection Commissioner please contact us.

The Company uses cookies to secure interested parties’ trading activities and to enhance the performance of the Company’s web site. Cookies used by the Company do not contain personal information or other sensitive information.

The Company may share web site usage statistics with reputable advertising companies and with its affiliated marketing companies. It is noted that the information collected by such advertising companies is not personally identifiable. To administer and improve the Company’s website, the Company may use third parties to track and analyse usage and statistical volume information. The third party may use cookies to track behaviour and may set cookies on behalf of the Company. These cookies do not contain any personally identifiable information.

The Company may update this Privacy Policy from time to time.  We will notify you appropriately when we make changes to this Privacy Policy and we will amend the revision date at the top of this page. We encourage you to review this Privacy Policy periodically to be informed about how we are processing and protecting your personal data. Any changes to this Privacy Policy will become effective when we publish the revised Privacy Policy on our website, save as otherwise expressly agreed between us.