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Privacy Policy

Last updated: June 30, 2026

Data Controller

The data controller responsible for Your Personal Data is Fieldunit Technologies Kft., a Hungarian limited liability company (korlátolt felelősségű társaság).

  • Registered office: 8640 Fonyód, Hungary
  • Company registration number (cégjegyzékszám): 14-09-322092
  • Tax number (adószám): 33025311-2-14
  • Registering court (nyilvántartó bíróság): Kaposvári Törvényszék Cégbírósága
  • Privacy contact: privacy@strategicrawmaterial.com

This disclosure is provided pursuant to Article 13(1)(a) of Regulation (EU) 2016/679 ("GDPR") and Section 4 of Act CVIII of 2001 on certain aspects of electronic commerce services ("Ekertv.").

Interpretation and Definitions

Interpretation

Words whose initial letter is capitalised have meanings defined under the following conditions. These definitions apply whether the term appears in singular or plural form.

Definitions

For the purposes of this Privacy Policy:

  • Account — a unique account created for You to access our Service or parts of our Service.
  • Company — Fieldunit Technologies Kft. ("the Company", "We", "Us" or "Our").
  • Cookies — small files placed on Your device by a website, containing details of Your browsing history on that website.
  • Device — any device that can access the Service, such as a computer, phone, or tablet.
  • Personal Data — any information relating to an identified or identifiable individual.
  • Service — the website operated by the Company.
  • Usage Data — data collected automatically, either generated by use of the Service or from the Service infrastructure itself.
  • Website — Fieldunit Technologies, accessible at https://strategicrawmaterial.com.
  • You — the individual accessing or using the Service, or the legal entity on behalf of which such individual is accessing the Service.

Collecting and Using Your Personal Data

the Company collects several types of information in connection with the operation of the Service. This section describes what We collect, how We use it, and the choices You have regarding Your Personal Data.

Types of Data Collected

Personal Data

While using the Service, We may ask You to provide certain personally identifiable information that can be used to contact or identify You. This may include:

  • Full name and company name
  • Email address
  • Postal or business address
  • Phone number
  • Account credentials

Usage Data

Usage Data is collected automatically when You use the Service. It may include information such as Your Device's IP address, browser type and version, the pages of the Service You visit, the time and date of Your visit, time spent on those pages, unique device identifiers, and other diagnostic data.

Tracking Technologies and Cookies

We use only strictly-necessary Cookies — small files placed on Your device to enable core Service functionality such as authentication, session management, and security. These Cookies are required for the Service to operate and cannot be switched off; You can instruct Your browser to refuse them, but doing so may make parts of the Service unusable.

The public website also uses Google Analytics 4 to measure traffic and usage. These analytics Cookies are set only after You have given Your prior consent, and they are never set inside the authenticated Service. The legal basis for this processing is Your consent (GDPR Art. 6(1)(a)), as required by the ePrivacy Directive (2002/58/EC, as amended) and its Hungarian implementation. You may withdraw Your consent at any time, with no effect on the lawfulness of processing carried out before withdrawal (GDPR Art. 7(3)), using the "Cookie settings" link in the site footer.

Use of Your Personal Data

the Company may use Personal Data for the following purposes:

  • To provide and maintain the Service, including monitoring usage and ensuring platform integrity.
  • To manage Your Account and provide access to Service functionality available to registered users.
  • To perform a contract, including the development and fulfilment of purchase or other commercial agreements entered into through the Service.
  • To contact You by email, phone, or push notification regarding updates, security notices, or other service-related communications.
  • For marketing purposes to provide news and special offers about goods or services similar to those You have enquired about, unless You opt out.
  • For business transfers in the event of a merger, acquisition, or sale of assets, where Personal Data may be transferred to the successor entity.

Under Article 6 of the GDPR, We only process Your Personal Data where at least one of the following legal bases applies:

  • Performance of a contract (Art. 6(1)(b)) — to create and manage Your Account and to execute deals You enter into through the Service.
  • Compliance with a legal obligation (Art. 6(1)(c)) — to meet Our invoicing, accounting, anti-money-laundering, and sanctions-screening obligations.
  • Legitimate interests (Art. 6(1)(f)) — to maintain platform integrity, prevent fraud, and market Our own similar goods or services to existing customers, balanced against Your rights and expectations.
  • Consent (Art. 6(1)(a)) — for any non-essential Cookie or similar tracking technology, should one be introduced. See Tracking Technologies and Cookies.

Recipients and Processors

We share Personal Data with the following categories of recipients, each acting as a processor or independent controller for its own function:

  • Payment processing — a payment service provider, to process settlement and verification-fee payments.
  • Transactional email — a transactional email provider, to deliver account and notification emails.
  • Identity and signature verification — an identity-verification provider, to perform KYC/KYB checks and identity attestations.
  • Chain-of-custody verification — a provenance-verification provider, to verify material provenance for post-match deals.
  • Cloud hosting — a cloud infrastructure provider that hosts the Service and Our databases within the European Economic Area.

Each recipient is bound by a data processing agreement consistent with Article 28 GDPR. The identity of any individual recipient will be provided on request to privacy@strategicrawmaterial.com.

Retention of Your Personal Data

the Company retains Personal Data according to the following anchors:

  • Account data — for the lifetime of Your Account, plus the applicable statutory limitation period thereafter.
  • Commission and invoice records — for the statutory accounting-retention period under Hungarian Act C of 2000 on Accounting (§169), currently eight years.
  • Audit-ledger entries — for as long as the corresponding trade record is held, since the ledger is the system of record for deal integrity.

Transfer of Your Personal Data

Your Personal Data is primarily stored and processed within the European Economic Area. Where a recipient described in Recipients and Processors is located outside the EEA, We only transfer Your Personal Data to that recipient where the transfer is covered by an adequacy decision of the European Commission under Article 45 GDPR, or is subject to Standard Contractual Clauses under Article 46 GDPR.

the Company takes all steps reasonably necessary to ensure Your data is treated securely and in accordance with this Privacy Policy wherever it is processed.

Delete Your Personal Data

You have the right to request deletion of the Personal Data that We have collected about You. You may update, amend, or delete Your information at any time by signing in to Your Account and visiting the account settings section. You may also contact Us to request access to, correction of, or deletion of any personal information You have provided to Us.

Please note that We may need to retain certain information when We have a legal obligation to do so or a lawful basis for doing so. To submit a deletion request, contact Us at privacy@strategicrawmaterial.com.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your data is transferred and becomes subject to a different Privacy Policy.

Legal Requirements

the Company may disclose Your Personal Data in the good-faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing in connection with the Service, or protect the personal safety of users or the public.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities such as a court or government agency.

Security of Your Personal Data

The security of Your Personal Data is important to Us. the Company uses commercially reasonable technical and organisational measures to protect Your Personal Data. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Your GDPR Rights

If You are located in the European Economic Area, You have the following rights under Articles 15–22 of the GDPR in relation to Your Personal Data:

  • Right of access — to obtain confirmation of, and access to, the Personal Data We hold about You.
  • Right to rectification — to have inaccurate or incomplete Personal Data corrected.
  • Right to erasure — to have Your Personal Data deleted, subject to the retention needs described in Retention of Your Personal Data.
  • Right to restriction of processing — to limit how We use Your Personal Data in certain circumstances.
  • Right to data portability — to receive Your Personal Data in a structured, commonly used, machine-readable format.
  • Right to object — to object to processing based on legitimate interests, including the right to object to direct marketing at any time.
  • Right to withdraw consent — where processing is based on consent, at any time and without affecting the lawfulness of processing before withdrawal.
  • Right to lodge a complaint — with Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) (https://naih.hu), the Hungarian data protection supervisory authority, or with the supervisory authority of Your own EU Member State of residence.

To exercise any of these rights, contact Us at privacy@strategicrawmaterial.com.

Automated Decision-Making

The Service uses an auction evaluation and clearing engine to score and rank bids against listing and request terms. The outputs of this engine are reviewable by Our operators, who may re-run or override a clearing outcome.

No decision that produces legal effects concerning You, or similarly significantly affects You, is made by solely automated means within the meaning of Article 22 GDPR.

Children's Privacy

The Service is a business-to-business marketplace and is not directed at, or intended for use by, anyone under the age of 18, consistent with the age representation in the Acknowledgment section of the Terms and Conditions. the Company does not knowingly collect Personal Data from anyone under 18. If You become aware that a minor has provided Us with Personal Data, please contact Us at privacy@strategicrawmaterial.com.

The Service may contain links to third-party websites that are not operated by Us. If You click a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. the Company has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on the Service, prior to the change becoming effective, and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. This Privacy Policy was last updated on June 30, 2026.

Contact Us

If You have any questions about this Privacy Policy, You can contact us by email: privacy@strategicrawmaterial.com.

Registered office: 8640 Fonyód, Hungary

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