FRC Licensed Fund Manager  ·  Registration No. TZ 309/04
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Privacy Policy

Effective Date: April 10, 2026  ·  Golomt Asset Management LLC

Golomt Asset Management LLC ("GAM", "we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in accordance with the Law of Mongolia on Personal Data Protection, the EU General Data Protection Regulation (GDPR), and applicable Japanese privacy laws (Act on the Protection of Personal Information — APPI). Please read this policy carefully.

Contents
  1. Who We Are
  2. Information We Collect
  3. How We Use Your Information
  4. Legal Basis for Processing
  5. Cookies and Tracking Technologies
  6. Your Rights
  7. Security
  8. Third-Party Links
  9. Changes to This Policy
  10. Contact Us
Section 01

Who We Are

Golomt Asset Management LLC is a regulated investment fund management company licensed by the Mongolian Financial Regulatory Commission (FRC License No. TZ 309/04), registered and operating in Ulaanbaatar, Mongolia.

Registered Address: Suite #701, 7th Floor, Meru Tower, 1st Khoroo, Sukhbaatar District, Ulaanbaatar, Mongolia
Email: [email protected]
Phone: +976-8505-2456

Section 02

Information We Collect

We collect the following categories of personal information:

CategoryExamplesSource
Identity DataFull name, passport number, national ID, date of birth, nationalityInvestor application forms
Contact DataEmail address, phone number, postal addressEnquiry forms, applications
Financial DataBank account details, source of funds, total assets, investment experienceInvestor application, KYC process
Compliance DataKYC documents, AML screening results, PEP status, FATCA declarationsRegulatory onboarding process
Technical DataIP address, browser type, device information, pages visited, time on siteAutomatically via cookies and Google Analytics
Communication DataEnquiry content, correspondence recordsContact and enquiry forms

We do not knowingly collect personal data from individuals under the age of 18.

Section 03

How We Use Your Information

We use your personal information for the following purposes:

Section 04

Legal Basis for Processing

For visitors from the European Union or Japan, we process your personal data under the following legal bases:

PurposeLegal Basis (GDPR / APPI)
Investor onboarding and KYC/AMLLegal obligation (Art. 6(1)(c) GDPR)
Fund management and reportingContract performance (Art. 6(1)(b) GDPR)
Responding to enquiriesLegitimate interests (Art. 6(1)(f) GDPR)
Analytics and website improvementConsent (Art. 6(1)(a) GDPR) via cookie banner
Marketing communicationsConsent or legitimate interests
Section 05

Cookies and Tracking Technologies

Our website uses cookies and similar technologies. A cookie is a small text file stored on your device. We use:

You can withdraw your consent to analytics cookies at any time by clicking "Cookie Settings" in the footer or rejecting them via our cookie consent banner. You can also control cookies through your browser settings.

For more information, see Google's Privacy Policy and Google Analytics opt-out.

Section 06

Your Rights

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

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

Section 07

Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These include encrypted communications (HTTPS), access controls, and confidentiality agreements with all staff and service providers.

However, no method of transmission over the internet is completely secure. While we strive to protect your information, we cannot guarantee its absolute security.

Section 08

Third-Party Links

Our website contains links to third-party websites, including Golomt Bank (golomtbank.com) and LinkedIn. This Privacy Policy does not apply to those websites. We encourage you to read the privacy policies of any third-party sites you visit.

Section 09

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify registered investors of material changes by email. The "Effective Date" at the top of this page indicates when the policy was last revised. We encourage you to review this page periodically.

Section 10

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

This Privacy Policy was last updated on April 10, 2026.
Golomt Asset Management LLC · FRC License No. TZ 309/04