Data protection declaration

Effective Date: December 28, 2023

THIS NOTICE DESCRIBES HOW ACCOUNT INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

We are committed to protecting privacy of your account information. While you receive bullion services from us, we create records of the bullion services that we provide to you. We need these records to provide you with quality pharmacy services and to comply with law. This Notice describes your rights with respect to your medical information. This Notice also describes certain duties we have regarding your medical information and how we may use and disclose your account information.

Who Will Follow This Notice

The privacy practices described in this Notice will be followed by Mocatta Bullion USA and the entities under common ownership or control of MocattaBullionUSA, (collectively referred to as “We” or “Us” in this Notice).

Your Rights Regarding Your Account Information

You have the following rights regarding account information we maintain about you:

Right to Review and Receive a Copy. You have the right to review and receive a paper or electronic copy of your account information. You may request that we send a copy of your account information to a third party. To review and request a copy your account information, you must submit your request in writing to our Privacy Officer. Under certain circumstances, we may deny your request. We may charge a reasonable cost based fee for providing you with a copy of your records.

Right to Request a Restriction on Uses and Disclosures. You have the right to ask us not to use or disclose your medical information for purposes of treatment, payment or health care operations or to individuals who are involved in your care. To request a restriction, you must submit your request in writing to our Privacy Officer. In your request, you must tell us what information you want us not to use or disclose and to whom you want the restriction to apply (for example, disclosures to a certain family member). We are not required to agree to your request and we will notify you if we don’t agree. Even if we agree to your request, we may still disclose your account information to law enforcement and state and federal agencies/departments for certain other purposes described below for which disclosure is permitted without your authorization. We may end a restriction to which we previously agreed if we inform you that we plan to do so.

Right to Request Confidential Communications. You have the right to request that we communicate with you in a specific way or at a specified location. For example, you can ask that we only contact you at a certain phone number or only send mail to a certain address. To make such request, you must submit your request in writing to our Privacy Officer. In your request, you must tell us how or where you wish to be contacted and to what address we may send bills for medications and services provided to you. We will not ask you about the reason for your request. We will agree to all reasonable requests.

Right to Request Amendment. You have the right to request that we correct your medical information if you believe it is incorrect or incomplete. You have this right for as long as the information is kept by us. To make this request, you must submit your request in writing to our Privacy Officer and explain why a correction is needed. We may deny your request if it is not in writing or does not include a reason for your request. We may also deny your request if you ask us to correct information that we did not create (unless the person or entity that created the information is no longer available to make the correction), is not part of the medical information kept by us, is not part of the account information which you may inspect and copy, or if we determine that your account information is accurate and complete. If we accept your request, we will inform you about our acceptance and make the appropriate corrections. If we deny your request, we will inform you and give you a chance to submit to us a written statement disagreeing with the denial. We will add your written statement to your record and include it whenever we disclose the part of your medical information to which your written statement relates.

Right to Request Accounting of Disclosures. You have the right to request a list of the times we have shared your account information for six years prior to the date of your request, who we shared it with, and why. We will include all the disclosures. To request this list, you must submit your request in writing to our Privacy Officer. Your request must state a time period for which you want to receive the accounting. We will provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within twelve months. We will notify you of the cost involved and you may choose to withdraw or modify your request before any costs are incurred.

Right to Receive Breach Notice. You have the right to receive notice following a breach of your medical information which results in such information being compromised.

Right to Choose Someone to Act For You. If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your account information. We will make sure the person has this authority and can act for you before we take any action.

Right to Receive Copy of This Notice. You have the right to receive a copy of this Notice. You may ask us to give you a copy of this Notice at any time. Even if you have agreed to receive this Notice electronically, you may still ask for a paper copy of this Notice at any time. You may obtain a copy of this Notice at our website, www.mocattabullionusa.com. To obtain a paper copy of this Notice, please contact our Privacy Officer at 740-396-0084.

Our Duties Regarding Your Account Information

We are required by law to:

• Maintain the privacy and security of your medical information,

• Provide you with this Notice about our legal duties and privacy practices with respect to your account information,

• Provide you with notice if a breach occurs that may have compromised the privacy or security of your medical information, • Abide by the terms of this Notice.

How We May Use and Disclose Your Account Information

We may use and disclose your account information without obtaining your authorization as described below.

Treatment. We may use and disclose your account information to provide you with bullion products and services. We may disclose your account information to marketing, sales and other account service providers who provide bullion services to you. For example, a vendor offering product of interest to you may need to know what other products you are acquiring. We also may use your account information to contact you about an event, service or appointment, to follow up on your account.

Payment. We may use and disclose your medical information so we can bill and receive payment for bullion services we provide to you or other responsible for payment party.

Businesd Operations. We may use and disclose your account information for purposes of bisiness operations, which are various activities necessary to run our business, provide quality bullion services and contact you when necessary. For example, we may use and disclose your account information to evaluate the performance of our staff and for quality improvement activities. We may use account information about you to manage the provision of bullion services to you. We may disclose your account information to consultants, vendors  and others for review and learning purposes.

Family Members and Othets Involved in Your Account. We may disclose to your family members or to any other person you identify your account information relevant to such person’s involvement in your account or payment for your account. If you are present, we may make disclose the information if either you agree to the disclosure, we provide you with an opportunity to object to the disclosure and you do not say no, or if we reasonably infer that you do not object to the disclosure. If you are not present, we may disclose your account information that is directly relevant to the person’s involvement with your account if we determine this is in your best interest.

Compliance With Law. We may disclose your account information to law enforcement and as required by Federal or state law.

Lawsuits and Legal Actions. We may disclose your account information in response to a court or administrative order, subpoena, discovery request or other lawful process, subject to applicable procedural requirements.

Law Enforcement. We may disclose your account information to law enforcement officials to report or prevent a crime and as otherwise authorized or required by law.

Specialized Government Functions. We may disclose your account information for special government functions such as military, national security and presidential protective services.

Research. We may use or disclose your account information for research purposes provided that we comply with applicable laws.

Limited Data Sets. We may use or disclose a limited data set (which is account information in which certain identifying information has been removed) for purposes of research, or operations. We require any recipient of such information to agree to safeguard such information.

Business Associates. We may share your medical information with third party business associates, which are vendors that perform various services for us. For example, we may disclose your account information to a vendor that provides billing or collection services for us. We require our business associates to safeguard your account information.

Other Uses and Disclosures of Your Account Information

Other uses and disclosures of your medical information not covered by this Notice will be made only with your written authorization. If these laws do not permit disclosure of such information without obtaining your authorization, we will comply with those laws.

How You May Revoke Your Authorization

If you provide us with an authorization to use and disclose your account information, you may revoke your authorization at any time. However, the uses and disclosures of account information before the revocation will not be affected by your action and we cannot take back any account information that has already been disclosed by us in reliance on your previously provided authorization permitting the disclosure. To revoke any previously provided authorization you must submit a written request for revocation to our Privacy Officer.

Changes to This Notice

We reserve the right to change the terms of this Notice at any time and to apply the revised Notice to all account information that we maintain about you. We will post a copy of the current Notice on our website at www.mocattabullionusa.com. The Notice will specify the effective date of the Notice. Each time you visit our website, you will see a link to the current Notice in effect. In addition, at any time you may request a copy of the Notice currently in effect.

For More Information or to Report a Complaint

If you have questions or would like more information about our privacy practices, you may contact our Privacy Officer at 740-396-0084 or by mail at the address noted below. If you believe your privacy rights have been violated, you may file a written complaint with our Privacy Officer. We will not retaliate against you for filing a complaint. To file a complaint with us, please direct your complaint to our Privacy Officer:

Privacy Officer Mocatta Bullion USA, LLC

10833 Beaver Rd NW Pataskala, Ohio 43062

Phone: 740-396-0084