Legal Info

Privacy Policy

How we collect, use, and protect your information.

Last Updated: March 2026

Introduction

This privacy policy explains how Emerald Holding ("we", "us", or "our") collects, uses, stores, and protects your personal data when you visit our website at https://www.emeraldholding.com (the "Website"). We are committed to protecting your privacy and ensuring that your personal data is handled responsibly and in compliance with applicable data protection laws.

1. Important Information and Who We Are

Emerald Holding is a Saudi-based industrial investment group that owns, manages, and develops a portfolio of specialized companies operating across metals processing, advanced chemicals, energy, and investment management. Emerald Holding is the controller and responsible for your personal data collected through this Website.

Emerald Holding is part of a group of companies (the "Group") that includes Emerald Metals, Emerald Chemicals, Emerald Energy, and Emerald Fund. When we mention "we", "us", or "our" in this privacy policy, we are referring to Emerald Holding as the entity responsible for processing your data through this Website.

If you have any questions about this privacy policy or wish to exercise your data protection rights, please contact us using the details provided in Section 9 below.

This Website is not intended for children, and we do not knowingly collect data relating to children.

2. Types of Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified. We may collect, use, store, and transfer the following categories of personal data about you:

• Identity Data: includes your first name, last name, title, and any professional affiliation or job title you provide to us.

• Contact Data: includes your email address, telephone number, postal address, and any other contact details you provide through forms on our Website.

• Technical Data: includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device identifiers, and other technology on the devices you use to access this Website.

• Usage Data: includes information about how you interact with and use our Website, including pages visited, time spent on pages, navigation paths, and referring URLs.

• Marketing and Communications Data: includes your preferences in receiving communications from us and your communication preferences.

We also collect, use, and share aggregated data such as statistical or demographic data. Aggregated data is not considered personal data as it does not directly or indirectly reveal your identity.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you, including:

• Your direct interactions. You may provide us with your Identity and Contact Data by filling in forms on our Website, sending us correspondence, or subscribing to receive information about our activities and investment opportunities.

• Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this data by using cookies, server logs, and other similar technologies.

• Third parties or publicly available sources. We may receive Technical Data from analytics providers (such as Google), and Identity and Contact Data from publicly available sources.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of a contract: where we need to perform a contract we are about to enter into or have entered into with you.

• Legitimate interests: where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include operating and improving our Website, promoting our business activities, and communicating with prospective partners and stakeholders.

• Legal obligation: where we need to comply with a legal or regulatory obligation.

• Consent: where we have obtained your active agreement to use your personal data for a specified purpose, such as sending you marketing communications.

Purposes for Which We Will Use Your Personal Data

To respond to enquiries you submit through our Website (Identity, Contact) -> Legitimate interests (to respond to prospective partners and stakeholders)

To administer and protect our Website (including troubleshooting, data analysis, testing, and system maintenance) (Technical, Usage) -> Legitimate interests (for running our business, provision of IT services, network security)

To deliver relevant Website content and measure the effectiveness of our communications (Identity, Contact, Usage, Technical, Marketing and Communications) -> Legitimate interests (to study how visitors use our Website and to develop our business strategy)

To use data analytics to improve our Website, services, and user experience (Technical, Usage) -> Legitimate interests (to keep our Website updated and relevant)

To send you information about Emerald Holding and its subsidiaries where you have consented to receive such communications (Identity, Contact, Marketing and Communications) -> Consent

Marketing Communications

You will receive marketing communications from us only if you have expressly opted in to receive such communications. We will obtain your express consent before we share your personal data with any third party for their own marketing purposes.

You can opt out of receiving marketing communications at any time by contacting us at the details provided in Section 9 or by following the unsubscribe link in any marketing email we send to you.

5. Disclosures of Your Personal Data

We may share your personal data with the following parties where necessary for the purposes set out in Section 4 above:

• Other companies within the Emerald Holding Group (Emerald Metals, Emerald Chemicals, Emerald Energy, and Emerald Fund) who provide IT, system administration, and other shared services.

• Service providers who provide IT and system administration, website hosting, analytics, and related services.

• Professional advisers, including lawyers, auditors, and consultants who provide advisory services.

• Regulatory authorities and other governmental bodies who require reporting of processing activities in certain circumstances.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Emerald Holding is headquartered in the Kingdom of Saudi Arabia. Your personal data may be transferred to, stored, and processed in countries outside your country of residence, including the Kingdom of Saudi Arabia and other jurisdictions where our Group companies and service providers operate.

Whenever we transfer your personal data internationally, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, including the use of standard contractual clauses or other legally recognized transfer mechanisms. Please contact us if you would like further information on the specific safeguards applied to the transfer of your personal data.

7. Data Security

We have implemented appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We limit access to your personal data to those employees, agents, contractors, and other third parties who have a legitimate business need to access it. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

9. Contact Details

If you have any questions about this privacy policy, about the use of your personal data, or if you wish to exercise your data protection rights, please contact us:

Entity: Emerald Holding

Website: https://www.emeraldholding.com

Email: info@emeraldholding.com

Address: Kingdom of Saudi Arabia

10. Changes to This Privacy Policy

We keep this privacy policy under regular review. This version was last updated in March 2026. We may update this policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. Any material changes will be posted on this Website. We encourage you to review this privacy policy periodically.

11. Third-Party Links

This Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

12. Cookies

Our Website uses cookies and similar technologies to distinguish you from other users. This helps us provide you with a good experience when you browse our Website and also allows us to improve it. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device. Cookies contain information that is transferred to your device.

We use the following types of cookies:

• Strictly necessary cookies: these are cookies that are required for the operation of our Website.

• Analytical or performance cookies: these allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us improve the way our Website works.

• Functionality cookies: these are used to recognize you when you return to our Website, enabling us to personalize our content for you.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.