Legal
Privacy policy
Effective October 22, 2026
This privacy policy explains how Hamerdon Metals LLC, a Delaware limited liability company based in Arlington, Virginia (“Hamerdon,” “we,” “us” or “our”), collects, uses, discloses and protects personal information in connection with hamerdon.com (the “site”), enquiries submitted through the site, and our business dealings with suppliers, customers and their representatives. It also describes the privacy rights available to you and how to use them.
This policy does not cover information about Hamerdon job applicants or employees, which is handled under separate notices.
Summary
- We collect the details you enter in our enquiry form, information you send us while doing business with us, and basic technical information such as your IP address.
- We use it to respond to you, to buy and supply tungsten, to meet legal and compliance obligations, to keep the site secure and, for business contacts, to send occasional business updates you can unsubscribe from at any time.
- We do not sell personal information and do not share it for targeted advertising.
- You can ask to access, correct or delete your information, among other rights, by emailing [email protected].
1. Information we collect
Information you give us
- Enquiry form: enquiry type (supplying or sourcing), full name, company, work email, phone number (optional), material, approximate quantity, material location, material description, and the options you select (records available, recycler onboarding, DFARS requirement).
- Correspondence: the content of emails, calls and other messages you exchange with us.
- Supplier qualification and onboarding: business registration details, business contact details, tax documentation (such as Form W-9, which includes a taxpayer identification number; for a sole proprietor this may be a Social Security number), payment and bank account details for paying invoices, and material origin, purchase and chain-of-custody records.
- Customer dealings: business contact details, purchase specifications, delivery details, contract and compliance requirements, and billing information.
Information collected automatically
When you visit the site, our servers and our network provider automatically receive technical information your browser sends: IP address, browser and device type (user agent), the pages and files requested, the referring page, and the date and time of the request. We may derive an approximate location (such as country or region) from an IP address. We do not collect precise geolocation. When you submit an enquiry, we store the IP address and browser type with it to help prevent spam and abuse.
Information from other sources
- Colleagues at your company who give us your details as a contact.
- Public sources, such as business registries, company websites and industry directories.
- Government restricted-party and sanctions lists used for compliance screening.
- Service providers who help us operate the site and our business.
We do not ask for, and ask that you do not send, sensitive information such as health information, racial or ethnic origin, religious beliefs or biometric data. Please do not include confidential business information in the enquiry form; if confidential information needs to be exchanged, we will arrange an appropriate agreement first.
2. How we use information
- To respond to enquiries and to evaluate material offered to us or requested from us.
- To do business: qualifying and onboarding suppliers, purchasing and selling material, arranging logistics, sampling and analysis, invoicing and payment.
- To prepare lot documentation, including origin, chain-of-custody and analysis records that support customers’ compliance review under laws such as 10 U.S.C. 4872 and DFARS 252.225-7052.
- To meet legal obligations: tax reporting, recordkeeping, restricted-party and sanctions screening, export control compliance, and responding to lawful requests from authorities.
- To send business communications to business contacts, as described in Business emails.
- To operate and improve the site, including understanding how it is used in aggregate.
- To protect the site, our business and others against spam, fraud, security incidents and misuse, and to establish, exercise or defend legal claims.
We use taxpayer identification numbers and bank account details only for tax reporting, verifying suppliers and making payments. We do not use any information to infer characteristics about you, and we do not use it for automated decisions that produce legal or similarly significant effects.
3. Cookies, analytics and online tracking
Current practice. The site does not currently set cookies, and it does not use analytics, advertising or social media tracking tools. The enquiry form is submitted directly to our own server.
Service providers that receive technical data. The site is delivered through Cloudflare, which processes all requests to protect the site and route traffic, and may collect network performance and error reports from your browser. Pages load the Public Sans typeface from Google Fonts, so Google receives your IP address and browser information when the font is requested. See the Cloudflare privacy policy and Google privacy policy.
Analytics. We may add website analytics to understand, in aggregate, how visitors use the site (for example, which pages are visited and how visitors arrive). If we do, we will update this policy to name the provider and describe any cookies or similar technologies used. We will not use analytics data for targeted advertising or sell it.
Opt-out preference signals. We treat a Global Privacy Control (GPC) signal from your browser as a request to opt out of the sale or sharing of your personal information and of targeted advertising. Because we do not sell or share personal information or engage in targeted advertising, no further action is needed on our part, but we will continue to honor the signal if our practices change.
Do Not Track. There is no common industry standard for responding to browser “Do Not Track” signals, so the site does not respond to them differently. We do not track visitors across third-party websites over time, and we do not allow third parties to do so on our site.
4. Business emails
If you contact us or do business with us as a representative of a company, we may send you occasional emails about Hamerdon’s tungsten purchasing, supply and related compliance developments. Every such email includes an unsubscribe link, and you can also opt out by emailing [email protected]. We process opt-out requests promptly, and in any case within 10 business days. We keep a record of your opt-out so that we do not email you again. Opting out of business updates does not stop messages about an enquiry, transaction or relationship you have with us.
5. How we disclose information
We disclose personal information only as follows:
- Service providers that process information on our behalf and under contract, such as our network and security provider (Cloudflare), our email and productivity provider (Google Workspace), and providers of IT, analytics, email delivery, accounting, payment, laboratory analysis, logistics and professional services.
- Business counterparties as part of a transaction. Origin and chain-of-custody documentation that accompanies a lot may identify the supplying company and, where needed, a contact at that company. We provide it to the customers, processors and auditors involved in that material’s supply chain. We will discuss this with suppliers during onboarding.
- Professional advisors such as lawyers, accountants, auditors and insurers.
- Government and legal. Where required by law, regulation, contract flow-down clauses or legal process, including to regulators, law enforcement, courts and U.S. government contracting and audit authorities, and where we believe disclosure is needed to protect rights, property or safety.
- Corporate transactions. In connection with a merger, financing, acquisition, reorganization or sale of all or part of our business, subject to appropriate confidentiality protections.
- With your consent or at your direction.
6. No sale or sharing
We do not sell personal information, and we do not share personal information for cross-context behavioral (targeted) advertising, as those terms are defined under state privacy laws. We have not done so in the past 12 months. We do not knowingly sell or share the personal information of anyone under 16. We do not disclose personal information to third parties for their own direct marketing purposes.
7. How long we keep information
We keep personal information only as long as reasonably necessary for the purposes described in this policy, using the following criteria:
- Enquiries that do not lead to a business relationship: up to three years after our last contact, so that we have context if you contact us again, and then deleted.
- Supplier and customer records, including onboarding, tax, transaction, lot, origin and chain-of-custody records: for the duration of the relationship and at least seven years afterward, or longer where tax law, government contracting rules, a contract or a customer’s compliance documentation requires.
- Server and security logs: for a limited period, after which they are deleted automatically as logs rotate, unless needed to investigate a security incident or misuse.
- Email preferences: business update subscriptions are kept until you unsubscribe; opt-out records are kept so that we can honor your choice.
We may keep information longer where necessary to comply with a legal obligation, resolve a dispute or enforce an agreement.
8. Security
We use reasonable administrative, technical and physical safeguards appropriate to the information we hold. The site is served over encrypted HTTPS connections, enquiry records are stored on systems with restricted access, and access to personal information is limited to people who need it for their work. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a security breach affects your personal information, we will notify you and any required authorities as required by applicable law.
9. Your privacy rights
Many U.S. states, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, give residents rights over their personal information. Some of these laws do not apply to information about people acting in a business role, and some apply only to companies above certain size thresholds. To keep things simple, we offer the following rights to every individual in the United States, subject to the exceptions and limitations the law allows:
- Know and access: confirm whether we process your personal information, and receive the categories and specific pieces of personal information we hold about you, the sources, the purposes, and the categories of recipients.
- Portability: receive a copy of the personal information you provided to us in a commonly used, machine-readable format.
- Correction: ask us to correct inaccurate personal information.
- Deletion: ask us to delete personal information we hold about you.
- List of recipients: where your state law provides it, receive a list of the specific third parties to which we have disclosed personal information.
- Opt out of the sale of personal information, sharing for targeted advertising, and profiling in furtherance of decisions with legal or similarly significant effects. We do not do any of these things, but you may still submit an opt-out request, and we will honor it if our practices change.
- Limit use of sensitive personal information. We use sensitive personal information (such as a taxpayer identification number) only for purposes permitted without an opt-out, such as tax compliance and making payments.
- Non-discrimination: we will not discriminate or retaliate against you for exercising any of these rights.
We may decline part or all of a request where the law allows, for example where we must keep information to meet a legal obligation, complete a transaction, detect security incidents, or establish or defend legal claims. If we decline, we will tell you why.
10. How to make a request
Submit a request by emailing [email protected] with the subject line “Privacy request.” Tell us which right you want to use, your name, your company if applicable, and the email address you used with us.
Verification. To protect your information, we will verify your request by matching details you provide with information we hold, usually by contacting you at the email address we have on file. We may ask for more information if needed, and we will use it only for verification. You do not need an account with us to make a request.
Authorized agents. You may use an authorized agent to submit a request on your behalf. We may ask the agent for signed written permission from you, or a valid power of attorney, and may ask you to verify your identity directly.
Timing. We will acknowledge your request within 10 business days and respond within 45 days of receipt. If we need more time, we may extend this once by up to 45 additional days, and we will tell you why. Requests are free of charge, though the law allows us to decline or charge a reasonable fee for requests that are manifestly unfounded, excessive or repetitive.
Appeals. If we decline your request, you may appeal by replying to our decision, or by emailing [email protected] with the subject line “Privacy appeal,” within a reasonable time. We will respond in writing within 45 days, or within the period your state’s law requires, and explain our decision. If your appeal is denied, you may contact the Attorney General of your state (and, in California, the California Privacy Protection Agency).
11. Additional information for California residents
This section supplements the rest of this policy and is provided under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). It also serves as our notice at collection: the categories of personal information we collect, the purposes for which we use them, and how long we keep them are described below and in section 2 and section 7.
In the past 12 months, we have collected the following categories of personal information, from the sources described in section 1:
| Category | Examples | Business purposes | Disclosed for a business purpose to |
|---|---|---|---|
| Identifiers | Name, email address, phone number, IP address | Responding to enquiries, doing business, security, business communications | Service providers, business counterparties, advisors, authorities where required |
| Personal information under Cal. Civ. Code 1798.80(e) | Name, contact details, bank account details for payment | Doing business, payments | Service providers (payment, accounting), advisors |
| Commercial information | Material offered or requested, quantities, transaction records | Responding to enquiries, doing business, lot documentation | Service providers, business counterparties, advisors, authorities where required |
| Internet or other electronic network activity | Browser type, pages requested, referring page, date and time | Operating and securing the site, aggregate site analysis | Service providers (network, security, analytics) |
| Approximate geolocation | Country or region derived from IP address; material location you provide | Security, logistics, evaluating material | Service providers, business counterparties |
| Professional or employment-related information | Company, role, business relationship | Responding to enquiries, doing business, business communications | Service providers, business counterparties, advisors |
| Sensitive personal information | Taxpayer identification number (for sole proprietors, possibly a Social Security number), provided during supplier onboarding | Tax reporting, supplier verification, payments | Service providers (accounting, payment), advisors, tax authorities |
We do not collect biometric information, precise geolocation, health information or information about protected characteristics, and we do not draw inferences to create a profile about you.
We do not sell or share personal information, and we use sensitive personal information only for the purposes permitted by California Code of Regulations, title 11, section 7027(m). For that reason we do not offer “Do Not Sell or Share” or “Limit the Use of My Sensitive Personal Information” links. To exercise your CCPA rights, see section 10.
Shine the Light. California Civil Code section 1798.83 allows California residents to ask for information about disclosures of personal information to third parties for their direct marketing purposes. We do not make such disclosures.
12. Nevada residents
Nevada law allows residents to opt out of the sale of certain covered information. We do not sell covered information as defined by Nevada law. You may still submit an opt-out request to [email protected], and we will honor it if our practices change.
13. Children
The site is intended for businesses and is not directed to children. We do not knowingly collect personal information from anyone under 18. If you believe a child has given us personal information, contact us and we will delete it.
14. Where information is processed
Hamerdon is based in the United States, and we store and process information in the United States. The site is intended for visitors in the United States. If you contact us from elsewhere, your information will be transferred to and processed in the United States, where data protection laws may differ from those in your country.
15. Other websites
The site may link to websites we do not control, such as government and regulatory sources. Their privacy practices are governed by their own policies.
16. Changes to this policy
We may update this policy from time to time, and we review it at least once a year. The effective date at the top shows when it was last changed. If we make a material change, such as starting to use a new category of personal information or a new type of tracking technology, we will post a notice on the site before the change takes effect and, where required, ask for your consent.
17. Contact us
Questions or concerns about this policy or our privacy practices can be sent to:
Hamerdon Metals LLC
Arlington, Virginia
Email: [email protected]
If you have a disability and need this policy in a different format, email us and we will provide it.