Privacy Policy

This Privacy Policy applies to Aurum ("Aurum", "we", "our", "us"), the private wealth management platform accessible at findaurum.com. Aurum is operated by Aurum Capital Partners LLC (Reg. No. 400467400), registered in Georgia at 1 Gabashvili St. Tbilisi, Georgia.

For all privacy-related enquiries, contact: info@findaurum.com, marked PRIVACY, or call +995 551 81 5959.

2.1 Information you provide directly

When you complete our client brief form or contact us, we collect:

• Full name and email address
• Current tax residency jurisdiction
• Approximate liquid wealth band (where voluntarily provided)
• Primary financial objective and preferred residency route
• Timeframe and engagement type preferences
• Any additional information you provide in correspondence

2.2 Information collected automatically

When you visit findaurum.com, we may collect:

• IP address and approximate geographic location
• Browser type, operating system, and device identifiers
• Pages visited, time on page, and navigation path
• Referring URL and search terms

This information is collected via cookies and similar tracking technologies. See Section 7 for full details.

2.3 Information we do not collect

We do not collect:

• Payment card or bank account information through this website
• National insurance numbers, passport numbers, or government-issued identity documents through this website
• Medical or health information
• Children's data — this site is directed at sophisticated adult investors only

We use the information we collect for the following purposes:

• To respond to your enquiry and prepare for your discovery call
• To assess whether Aurum's services are appropriate for your situation
• To provide residency structuring, vault allocation, and wealth management services where an engagement is agreed
• To send you information about our services where you have consented or where we have a legitimate interest
• To comply with our legal and regulatory obligations, including AML/KYC requirements under Georgian National Bank standards
• To operate and improve this website

Our legal basis for processing under applicable data protection law:

• Contract: where processing is necessary to provide services you have requested
• Legitimate interests: where we have a compelling reason to process your data that is not outweighed by your rights (e.g. responding to enquiries, fraud prevention)
• Legal obligation: where we are required to process data to comply with law
• Consent: where you have actively opted in to a specific use

We do not sell your personal data. We do not share it with third parties for their own marketing purposes.

We may share your data with the following categories of recipients, strictly for the purposes described in Section 3:

• T3RRA Ltd — our technology infrastructure partner, for the purpose of vault issuance and L3RS-1 protocol compliance
• TBC Bank JSC and JSC Bank of Georgia — for private banking onboarding where an engagement is agreed and you have consented
• Georgian legal counsel — for SPV formation, property title registration, and tax documentation
• International legal counsel — for platform structure review
• IT service providers — for website hosting, email, and CRM systems, under data processing agreements
• Regulatory and law enforcement authorities — where required by law

All third-party processors are required to handle your data in accordance with applicable law and our instructions.

Aurum operates from Georgia and the United Kingdom. Information you provide may be transferred to and processed in Georgia — a FATF-compliant, EU-DCFTA jurisdiction. Georgia is not currently designated as adequate under UK GDPR or EU GDPR. Where such transfers occur, we implement appropriate safeguards including standard contractual clauses or rely on a recognised legal basis for transfer.

If you are based in the European Economic Area or the United Kingdom, you may contact us to obtain details of the specific transfer safeguards applicable to your data.

Depending on your jurisdiction, you may have the following rights in respect of your personal data:

• Access: request a copy of the personal data we hold about you
• Rectification: request correction of inaccurate or incomplete data
• Erasure: request deletion of your data where there is no compelling reason for us to retain it
• Restriction: request that we restrict processing of your data in certain circumstances
• Portability: receive your data in a structured, machine-readable format
• Objection: object to processing based on legitimate interests
• Withdrawal of consent: withdraw consent at any time where processing is consent-based

To exercise any of these rights, contact us at info@findaurum.com marked PRIVACY. We will respond within 30 days. Where requests are complex or numerous, we may extend this period by a further 60 days with notice.

You also have the right to lodge a complaint with the supervisory authority in your jurisdiction. In the United Kingdom, this is the Information Commissioner's Office (ico.org.uk). In the EU, contact the supervisory authority in your member state.

findaurum.com uses cookies and similar technologies. Detailed information on our cookie use is set out in our Cookie Policy.

In summary:

• Strictly necessary cookies: required for the site to function. Cannot be disabled.
• Analytics cookies: help us understand how visitors use the site. Used only with your consent.
• Preference cookies: remember your settings. Used only with your consent.

You can manage your cookie preferences through our consent banner or your browser settings. Withdrawing consent for non-essential cookies will not affect the site's core functionality.

We retain your personal data only for as long as necessary for the purposes for which it was collected, or as required by law.

• Enquiry data (from the client brief form): up to 24 months from last contact where no engagement commences
• Client engagement data: for the duration of the engagement and a minimum of 7 years thereafter, to comply with AML/KYC, tax, and financial record-keeping obligations
• Website analytics data: up to 26 months

On expiry of the applicable retention period, data is securely deleted or anonymised.

We implement technical and organisational measures appropriate to the risk associated with processing your personal data. These include encrypted transmission (TLS), access controls, and regular security review. No transmission over the internet is completely secure. We cannot guarantee the security of data transmitted to our site, but we take all reasonable precautions.

We may update this Privacy Policy from time to time. Material changes will be notified via the website or by email where we hold your contact details. The effective date at the top of this document will be updated accordingly. Continued use of findaurum.com after the effective date of an updated Policy constitutes acceptance of the changes.

For all privacy enquiries: info@findaurum.com, marked PRIVACY, or call +995 551 81 5959.

Aurum Capital Partners LLC
Reg. No. 400467400
1 Gabashvili St. Tbilisi, Georgia
findaurum.com

This Privacy Policy was last updated in March 2026.