Privacy Policy

Last Updated: August 13, 2026

INTRODUCTION

Legacy Partners Colorado LLC d/b/a Kirk Elliott Precious Metals (“we” or “us”) values our visitors’ privacy. This privacy policy summarizes what information we might collect from a registered user or other visitor (“you”), and what we will and will not do with it. By using our website (“Website”) and services (“Services”), you accept and consent to the terms of the privacy policy in effect at the time of your visit.

Please note that this privacy policy does not govern the collection and use of information by companies that Kirk Elliott Precious Metals does not control, nor by individuals not employed or managed by Kirk Elliott Precious Metals. If you visit a website that we mention or link to, be sure to review its privacy policy before providing the site with information.

Use of this website and KEPM services are subject to KEPM Terms & Conditions.

WHAT WE DO WITH YOUR PERSONALLY IDENTIFIABLE INFORMATION

It is always up to you whether to disclose personally identifiable information to us, although if you elect not to do so, we reserve the right not to register you as a user or provide you with any products or services. “Personally identifiable information” means information that can be used to identify you as an individual, such as:

  • your name, company, email address, phone number, billing address, and shipping address;

  • your KEPM user ID and password;

  • any account-preference information you provide us;

  • your computer’s domain name and IP address, indicating where your computer is located on the Internet;

  • session data for your login session, so that our computer can ‘talk’ to yours while you are logged in; and

  • The data set forth in the KEPM Terms & Conditions necessary for KEPM to provide the requested services.

If you do provide personally identifiable information to us, either directly or through a reseller or other business partner, we will:

  • not sell or rent it to a third party without your permission;

  • use your email to provide you with information we believe you need to know or may find useful, such as news about our services and products; and

  • take commercially reasonable precautions to protect the information from loss, misuse and unauthorized access, disclosure, alteration and destruction;

We will not use or disclose the information except:

  • with our third-party vendors as necessary to provide services or products you have ordered, such as by providing it to a carrier to deliver products you have ordered;

  • in other ways described in this privacy policy or to which you have otherwise consented;

  • anonymized and/or in the aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, statistical compilations);

  • as required by law, including in response to a subpoena or search warrant;

  • to outside auditors who have agreed to keep the information confidential;

  • as necessary to enforce the KEPM Terms and Conditions;

  • in the event of a merger, consolidation, acquisition, or sale of substantially all of KEPM’s assets;

  • as necessary to protect the rights, safety, or property of KEPM, its users, or others; this may include (for example) exchanging information with other organizations for fraud protection and/or risk reduction.

OTHER INFORMATION WE COLLECT

We may collect other information that cannot be readily used to identify you, individually or in the aggregate, for technical administration of our Website; research and development; customer and account administration; and to help us focus our marketing efforts more precisely.

SMS COMMUNICATIONS

If you provide your mobile phone number and opt in to receive SMS communications from Kirk Elliott Precious Metals, we may send you text messages related to your account, transactions, service updates, or other information you have requested. In consenting to receive SMS data from Kirk Elliott Precious Metals, you agree to receive such data from us via SMS.

Mobile opt-in data and SMS consent will not be shared, sold, rented, or disclosed to third parties for marketing purposes. Message frequency may vary. Message and data rates may apply. You may opt out at any time by replying STOP, and reply HELP for support.

COOKIES

Kirk Elliott Precious Metals uses “cookies” to store personal data on your computer. We may also link information stored on your computer in cookies with personal data about specific individuals stored on our servers. If you set up your Web browser (for example, Chrome, Edge, or Firefox) so that cookies are not allowed, you might not be able to use some or all of the features of our Website.

TRACKERS

Some browsers have a Do Not Track (“DNT”) feature that lets you tell websites that you do not want to have your online activities tracked. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity via Cookies or other tracking technologies. Our Website honors DNT signals to best of its ability. For information regarding DNT and how to enable this setting, if available, on your devices please see https://allaboutdnt.com.

KEPM treats Global Privacy Control signals as opt-out of sale and opt out of targeted or cross-context behavioral advertising requests under applicable state laws.

EXTERNAL DATA STORAGE SITES

We may store your data on servers provided by third-party hosting vendors with whom we have contracted. These third-party hosting vendors are restricted from using your data for any purpose except to facilitate our services. We require our third-party hosting vendors to treat your data with at least the same level of security as We do.

NOTICE TO CALIFORNIA RESIDENTS

This section applies solely to individual residents of the State of California and describes how we collect, use, disclose, and otherwise process their personal information (as defined in the California Consumer Privacy Act of 2018, as amended, Cal. Civ. Code § 1798.100 et seq. (“CCPA”), and its implementing regulations, Cal. Code Regs. tit. 11, § 7000 et seq.). For the purposes of this section, personal information does not include deidentified, aggregated, or anonymized information that is maintained in a form that is not capable of being associated with or linked to you or a particular household and publicly available information from government records.

Sources of Personal Information

We collect personal information directly from you when you provide it to us and automatically using cookies and other technologies.

Purposes for Collecting Personal Information

We collect, use, and disclose personal information about you for the business and commercial purposes further described in the “What We Do With Your Personally Identifiable Information” section of this Privacy Policy.

Collection, Disclosure, and Sale or Share of Personal Information

As described in the “What We Do With Your Personally Identifiable Information” section of this Privacy Policy, we disclose personal information with our affiliates, advisors, and service providers and contractors that help us operate the Site and our business. We may also disclose personal information with a variety of third parties, including if we are subject to certain corporate transactions or reorganizations; to comply with law or to protect our rights or the rights and safety of others; or for purposes otherwise disclosed or for which you have consented.

For the purposes of this section, when we use the term “third party” we mean entities that are not service providers or contractors providing services on our behalf and that are not entities with whom you interact with directly.

In the last 12 months, we have collected each of the categories of personal information noted below and disclosed it, for a business purpose, to the categories of recipients in the table. We do not sell or share your personal information as “sell” and “share” are defined under CCPA. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

Category of Personal InformationCategories of Recipients to Whom Personal Information Is Disclosed for Business Purposes
Identifiers, such as name, email address, online identifiers and other information.Service Providers and Contractors, such as Analytics Vendors, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
Internet/Network Activity Information, such as browsing history, search history, IP address, Device Information, and log and analytics data.Service Providers and Contractors, such as Analytics Vendors, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
Geolocation Data, such as location information from your device or estimated based on your IP address.Service Providers and Contractors, such as Analytics Vendors, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
Personal Information, such as name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.Service Providers and Contractors, such as Analytics Vendors, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies

We only use and disclose Sensitive Personal Information for permitted purposes set forth under Cal. Code Regs. tit. 11, § 7027(m), as set forth in the KEPM Terms & Conditions.

Data Retention

Company retains your personal information for as long as necessary to fulfill the purposes for which such personal information was collected and in compliance with applicable laws. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the Site services and operate the business; (ii) the type of personal information collected; and (iii) whether we are subject to a legal, contractual, or other obligation to retain the personal information (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to your personal information that we or our service providers or contractors have collected (subject to certain limitations at law):

Right to Know

The right to request the following information relating to the personal information we have collected about you and disclosed about you:

  • The categories of personal information we have collected about you;

  • The categories of sources from which the personal information was collected;

  • The business or commercial purposes for collecting, selling, or sharing the personal information;

  • The categories of third parties with whom the business shares personal information;

  • The categories of personal information sold, and for each category identified, the categories of third parties to whom it sold that particular category of personal information; and

  • The categories of personal information that the business disclosed for a business purpose, and for each category identified, the categories of third parties to whom it disclosed that particular category of personal information.

Right to Opt Out of Sale or SharingThe right to direct us not to sell or share personal information we have collected about you to third parties, including for ad targeting/cross contextual advertising.
Right to Limit Use and Disclosure of Sensitive Personal InformationThe right to request that we limit our use or disclosure of Sensitive Personal Information (as defined by California law) about you to certain uses authorized by the CCPA.
Right to Know Specific Pieces of InformationThe right to obtain a copy of the specific pieces of personal information we have collected about you in a structured, machine-readable format that may be transmitted to another entity without hindrance, to the extent technically feasible.
Right to CorrectThe right to request that we correct your inaccurate personal information maintained by us.
Right to Request DeletionThe right to request the deletion or erasure of personal information we have collected from you, subject to certain exceptions.
California’s Shine the Light LawCalifornia Civil Code Section 1798.83, known as the “Shine the Light” law, permits our Website visitors who are California residents to request and obtain from us a list of their personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not share any personal information with third parties for their direct marketing purposes.

Nondiscrimination

We do not discriminate against you for exercising any of the rights noted above. We are permitted to deny or limit your request in accordance with applicable laws.

How to Exercise Your California Privacy Rights

To exercise the rights described above, please submit a request to us by either:

  • Calling us at (720) 605-3900.

  • Emailing us at legal@kepm.com with the Subject Line “KEPM Privacy Request”.

Your request must:

  • Provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person; and

  • Describe your request with sufficient detail for us to properly understand, evaluate, and respond to it.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm that the requested personal information relates to you. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. Please provide your name and email address in the original request, as well as an explanation of the right you wish to exercise. We will use the information provided in a request solely to verify your identity or authority to make the request and to review and comply with the request. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.

If you wish to submit a verifiable consumer request on behalf of another individual, we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf. For requests to know, access, correct or delete personal information, we may ask you to provide sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf, verified your own identity directly with us pursuant to the instructions set forth in this Privacy Policy, and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.

NOTICE TO RESIDENTS OF OTHER US STATES

This section applies to residents to the extent the comprehensive consumer privacy law of your state applies to Company and to the personal information we collect through the Site.

Depending on your state of residence, you may have the right to: (i) confirm whether we process your personal information and access that personal information; (ii) correct inaccuracies in your personal information; (iii) delete personal information provided by you or obtained about you; (iv) obtain a copy of personal information you previously provided to us in a portable and, to the extent technically feasible, readily usable format; and (v) opt out of the processing of your personal information for purposes of targeted advertising, the sale of personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

We do not sell your personal information, and we do process your personal information for purposes of targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. We knowingly collect or process sensitive data through KEPM services as set forth in the KEPM Terms & Conditions.

To exercise any of these rights, please submit a request using one of the methods described in the “How to Exercise Your California Privacy Rights” section above. We will respond within the time required by applicable law (generally 45 days of receipt of your request, subject to any extension the applicable law permits). We need to verify your identity before acting on your request, and we may decline a request as permitted by applicable law. We will not discriminate against you for exercising any of these rights.

If we decline to take action on your request, you may appeal our decision by emailing us at legal@kepm.com with the subject line “KEPM Privacy Request Appeal.” Within 60 days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response, including a written explanation of the reasons for our decision. If your appeal is denied, you may contact the Attorney General of your state to submit a complaint.

INFORMATION COLLECTED FROM CHILDREN

You must be at least 18 years old to use Kirk Elliott Precious Metals’ Website and services. Kirk Elliott Precious Metals does not knowingly collect information from children under 18.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this privacy policy as we deem necessary or appropriate because of legal compliance requirements or changes in our business practices. If you have provided us with an email address, we will endeavor to notify you, by email to that address, of any material change to how we will use personally identifiable information.

QUESTIONS OR COMMENTS

If you have questions or comments about Kirk Elliott Precious Metals’ privacy policy, send an email to legal@kepm.com or contact us via any of the ways described in the Contact Us page at www.kepm.com.

Thank you for choosing us!