Legal Documentation

Privacy Policy

Effective Date: May 19, 2026  |  Jurisdiction: Switzerland / International  |  Version: 1.0

This Privacy Policy describes how we collect, use, store, and protect information provided by business clients, prospective customers, and website visitors in connection with our NP1 Nickel Wire (0.025mm) supply services. We are committed to safeguarding your information and maintaining transparency in all our data practices, in accordance with applicable international privacy regulations including the Swiss Federal Act on Data Protection (nFADP) and the EU General Data Protection Regulation (GDPR) where applicable.

Contents

  1. Who We Are
  2. Information We Collect
  3. How We Use Your Information
  4. Legal Basis for Processing
  5. Data Sharing & Third Parties
  6. International Data Transfers
  7. Data Retention
  8. Security Measures
  9. Your Rights
  10. Cookies & Website Analytics
  11. Business Communications
  12. Changes to This Policy
  13. Contact Us

01

Who We Are

We are a specialty materials supplier offering certified NP1-grade Nickel Wire (0.025mm diameter) to industrial, research, and commercial buyers worldwide. Our inventory is stored in Switzerland and has undergone third-party laboratory certification through an ISE-accredited Swiss laboratory. We operate as a direct-to-buyer supplier, eliminating traditional distribution layers to offer competitive pricing at institutional quality.

References in this policy to "we," "us," or "our" refer to SJEM Diversified, LLC, a limited liability company with its principal office at 930 S. 4th Street, Suite 209, Las Vegas, Nevada 89101, USA.

02

Information We Collect

We collect only the information necessary to conduct business with you and respond to your inquiries. This includes:

Business Contact Information

  • Company name, registered address, and country of operation
  • Name and title of your authorized representative or purchasing contact
  • Business email address and telephone number
  • VAT/tax identification number where required for invoicing

Transaction & Order Information: Purchase history, order volumes, product specifications requested, pricing agreements, and shipping/logistics details.

Compliance & Regulatory Information: End-use declarations, export control certifications, and documentation required under applicable trade and materials regulations.

Communication Records: Emails, inquiry forms, and records of communications related to quotations, orders, or support.

Website Usage Data: IP address, browser type, pages visited, and time spent on site, collected automatically via standard web server logs and analytics tools.

We do not collect personal consumer data, sensitive personal categories of data, or payment card information directly (payments are processed through secure third-party providers).

03

How We Use Your Information

We use collected information for the following business purposes:

04

Legal Basis for Processing

Where the GDPR or Swiss nFADP applies, we rely on the following legal bases for processing your data:

05

Data Sharing & Third Parties

We do not sell, rent, or trade your business information. We may share information with trusted third parties only where necessary:

All third parties engaged by us are bound by appropriate data protection agreements and are required to handle your data securely and only for the stated purpose.

06

International Data Transfers

Our operations are based in Switzerland, a country recognized by the European Commission as providing adequate data protection. Where data is transferred to recipients outside Switzerland or the European Economic Area, we implement appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent mechanisms to ensure your data remains protected.

07

Data Retention

We retain business records, including contact and transaction information, for a minimum of seven (7) years following the close of a business relationship, as required by Swiss and international commercial and tax law. Records related to export compliance may be retained longer where required by applicable regulations. Website analytics data is retained in aggregated, anonymized form.

When data is no longer required, it is securely deleted or anonymized.

08

Security Measures

We take data security seriously. Our measures include:

In the event of a data breach that poses risk to your rights, we will notify affected parties and relevant authorities in accordance with applicable law.

09

Your Rights

Depending on your jurisdiction, you may have the following rights regarding your business data:

To exercise any of these rights, please contact us using the details in Section 13. We will respond within 30 days. We may require verification of your identity or authorization before processing your request.

10

Cookies & Website Analytics

Our website uses minimal cookies necessary for functionality and basic analytics. We do not use advertising or behavioral tracking cookies. Types of cookies used may include:

You may disable non-essential cookies through your browser settings. Disabling cookies will not prevent you from using our website or submitting inquiries.

11

Business Communications

We may send you information about product availability, pricing updates, new certifications, or relevant market developments where you have provided consent or where we have an existing business relationship and the communications relate to our services.

You may opt out of non-essential communications at any time by replying to any email with "Unsubscribe" in the subject line or contacting us directly. Transactional communications related to active orders or compliance requirements cannot be opted out of while a business relationship is active.

12

Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our operations, legal requirements, or best practices. When we do, we will update the "Effective Date" at the top of this page. Material changes will be communicated via email to existing clients. Continued engagement with our services following notice of changes constitutes acceptance of the updated policy.

We encourage you to review this policy periodically.

13

Contact Us

For privacy-related inquiries, data subject requests, or questions about this policy, please contact us at:

Privacy & Data Inquiries

Company SJEM Diversified, LLC
Address 930 S. 4th Street, Suite 209, Las Vegas, Nevada 89101, USA
Email privacy@clevermetals.com
Response Within 30 business days

If you are located in the European Economic Area and believe your data protection rights have been violated, you have the right to lodge a complaint with your local supervisory authority, or with the Swiss Federal Data Protection and Information Commissioner (FDPIC).