Privacy notice

This notice explains how Power Elements collects and uses personal data through this website, its forms and its portals: what we collect, why, who sees it, how long we keep it, and the rights you have. It is written to meet the UK and EU General Data Protection Regulation, Rwanda’s Law No. 058/2021 relating to the protection of personal data and privacy, and the US state privacy laws that apply to us. Where they differ, we follow the stricter rule.

Who is responsible

Power Elements, Inc., 5465 Legacy Drive, Suite 650, Plano, Texas 75024, United States, is responsible for the personal data collected through this site. If you deal with one of our Rwandan companies, PowerS Ltd, PowerM Ltd or PowerX Ltd, that company is also responsible for the data it holds about you.

Our Chief Financial Officer is accountable to the board for data protection, supported by a data protection lead. You can reach them at privacy@powerelements.com.

What we collect

• Visiting the site. No personal data for analytics: we count visits without cookies or identifiers. Our servers keep short technical logs, including IP addresses, to keep the site secure.
• Sales enquiries, supplier and SCTP registrations. Your name, work email, organisation, role and country, and what you tell us about your business, the material you need or supply and its end use, or your mine or deposit.
• Trade Room onboarding. Details of your company, its owners and the people authorised to act for it; copies of identity and company documents; end-use declarations; and the results of sanctions, politically-exposed-person and adverse-media screening.
• Investor Relations portal. Your account details, the requests you make and a log of the documents you open.
• Job applications. Your contact details, your CV and anything else you choose to send.
• Speak up reports. What you report and, if you choose to give them, your name and contact details. You can report anonymously where the law permits.
• Contacting us. Your name, contact details and message.

We do not ask for sensitive data such as health information. If you include it in a CV or a report, we use it only where the law allows and only for the purpose you sent it for.

Why we use it, and our legal basis

• To answer enquiries and take a business relationship forward: steps you ask us to take before a contract, and our legitimate interest in running our business.
• To check counterparties, suppliers and investors before we deal with them, including sanctions and export-control screening: our legal obligations, and our legitimate interest in knowing who we deal with.
• To run the Trade Room and the Investor Relations portal and keep them secure: our agreement with you, and our legitimate interest in security.
• To consider job applications: steps you ask us to take before an employment contract, and our legitimate interest in finding people for future roles. You can ask us to delete your CV at any time.
• To receive and investigate Speak up reports: our legal obligations, and our legitimate interest in preventing and dealing with wrongdoing.
• To keep records and deal with legal claims: our legal obligations, and our legitimate interest in protecting our rights.

We do not make decisions about you based solely on automated processing. Screening is automated, but a named person reviews every result and makes the decision.

Who we share it with

Within the Power Elements group, the companies that need it to deal with you. Outside the group, only:

• service providers who host the site, deliver email, monitor errors and carry out identity and sanctions screening for us, under written contracts that limit them to our instructions;
• professional advisers, auditors and insurers;
• regulators, courts and other authorities, where the law requires it or to protect our rights;
• a buyer of all or part of our business, under the same protections.

We do not sell personal data, and we do not share it for advertising.

International transfers

We operate in the United States, Rwanda and the United Kingdom, so your data may be handled outside the country where you are. We transfer it only where the law permits, using the safeguards it requires, such as adequacy decisions, approved contractual clauses and, for data from Rwanda, the authorisation of the National Cyber Security Authority where required.

How long we keep it

We keep personal data only for as long as we need it for the purpose we collected it for, or for as long as the law requires. Counterparty and supplier due-diligence records are kept for at least five years after the relationship ends.

At the end of each period we delete the data or make it anonymous.

How we protect it

We encrypt data in transit and the documents you upload, limit access to the people who need it and keep a record of who has accessed it. If a breach puts your data at risk, we tell you and the relevant authority as the law requires.

Your rights

Depending on where you live, you can ask us to:

• tell you what personal data we hold about you and give you a copy;
• correct it;
• delete it;
• restrict or object to how we use it, including use based on our legitimate interests;
• give it to you, or to another organisation, in a portable format;
• stop using it where we rely on your consent.

Rwanda’s law also lets you designate an heir to your personal data. If you live in a US state with a consumer privacy law, you have the rights that law gives you, and we will not treat you differently for using them.

To use any of these rights, email privacy@powerelements.com. We reply within one month, or sooner where the law requires, and may ask you to confirm your identity first.

You can also complain to a data protection authority: the Information Commissioner’s Office in the UK, the authority in your EU country, or the National Cyber Security Authority in Rwanda. We would welcome the chance to put things right first.

Children

This site is not meant for anyone under 18, and we do not knowingly collect their data.

Cookies

Public pages set no cookies. Signed-in areas use only the cookies needed to keep you signed in. See Cookies and analytics.

Changes to this notice

We update this notice when our practices change. Each version is dated and kept.