COOKIE POLICY

How Stratmont Global uses cookies and similar technologies on stratmontglobal.com, and how you can control them. Last updated: 23 June 2026

CONTENTS ==================================================================================== 1. About this Cookie Policy 2. What are cookies and similar technologies? 3. The categories of technology we use 4. Cookies and technologies we use 5. What we learn from these technologies 6. Our consent banner 7. How to give, change or withdraw your consent 8. Browser controls 9. Consequences of disabling cookies 10. Legal basis under ePrivacy and the GDPR 11. Third-party providers and processors 12. International transfers and retention 13. Your data-protection rights 14. Changes to this policy and how to contact us

1. About this Cookie Policy

This Cookie Policy explains how Stratmont Global ("Stratmont Global", "we", "us" or "our") uses cookies and similar technologies on our website at https://stratmontglobal.com (the "Site"), and the choices available to you.

The legal entity responsible for the Site is Oksana Kholieva, an individual trading as Stratmont Global — a business name registered in Ireland under the Registration of Business Names Act 1963 (Registered Business Name No. 786173), with a principal place of business at 40 Mill Street, Baltinglass, Co. Wicklow, W91 DK64, Ireland.

Stratmont Global is an independent advisory and intermediation business in international commodity and raw-materials markets (metals, energy and soft commodities). The Site is a brochure and contact website: it has no user accounts, no login area, no online shop, no payment processing and no newsletter. The technologies described here are therefore used to keep the Site working, to understand how it is used, and to diagnose and fix faults — not to build advertising profiles or to sell data.

This Cookie Policy should be read together with our Privacy Policy, which explains in full how we handle personal data, and our Terms & Conditions, which govern your use of the Site. Where a term used here is also defined in the Privacy Policy, it has the same meaning.

2. What are cookies and similar technologies?

Cookies are small text files that a website asks your browser to store on your device. They are widely used to make websites work, to make them work more efficiently, and to provide information to the website operator. Cookies may be set by the website you are visiting (first-party cookies) or by a third party providing a service through that website (third-party cookies). They may last only for the duration of your visit (session cookies) or remain until they expire or are deleted (persistent cookies).

Several other technologies perform similar functions to cookies, and we treat them the same way under this policy:

• Local storage and session storage — small amounts of data stored by your browser for a website. Session storage is cleared when you close the browser tab; local storage persists until it is cleared. We use a session-storage key to remember your scroll position and a stored value to remember your language preference (see the table below).

• Pixels (web beacons) — tiny, usually invisible elements embedded in a page or message that can record that a page or content has loaded.

• Software development kits (SDKs) and scripts — small pieces of code loaded into the page that provide functionality such as analytics measurement or error diagnostics, and which may read or write cookies or storage.

Throughout this policy, references to "cookies" should be read as including these similar technologies unless the context says otherwise.

3. The categories of technology we use

We group the technologies on this Site into three categories, based on what they do and the legal basis on which we may use them.

3.1 STRICTLY NECESSARY / FUNCTIONAL

These are essential to provide the Site you have asked for and to make it work correctly — for example, remembering your chosen interface language and preserving your scroll position and router state as you move between pages. They do not track you across other websites and are not used for analytics or advertising. Under the Irish ePrivacy Regulations (see Section 10), technologies that are strictly necessary to deliver a service you have requested are exempt from the consent requirement, so we use them without asking for your consent. The session-storage key tsr-scroll-restoration-v1_3 and your EN/FR/DE/RU language preference fall into this category.

3.2 ANALYTICS / PERFORMANCE

These help us understand how visitors find and use the Site — which pages and areas are viewed, where visitors arrive from, and when they visit — on an aggregated basis, so that we can improve content and performance. We use a first-party, privacy-oriented analytics tool called Flock for this purpose. Analytics technologies are not strictly necessary and are used only with your consent.

3.3 SESSION REPLAY / DIAGNOSTICS

These record, on a sampled basis, a reconstruction of how pages are used — such as clicks, scrolling and navigation — so that we can diagnose errors and improve usability. We use an rrweb-based session-recording and error-diagnostics tool for this. Recording is limited to approximately 10% of sessions plus sessions in which an error or crash occurs, and the content of text inputs is masked so that what you type into form fields is not captured. Because this is privacy-sensitive, we disclose it plainly here and use it only with your consent.

Only the strictly necessary / functional category is exempt from consent. The analytics and session-replay categories are non-essential and are activated only after you accept them — see Sections 6 to 8.

4. Cookies and technologies we use

The table below lists the cookies and similar technologies we currently use, with indicative purposes and durations. This list is indicative and may change as we update the Site or our providers; the most current information is reflected in the consent tool on the Site (see Section 6). Durations for third-party technologies are set by the relevant provider and are shown here as indicative values.

• tsr-scroll-restoration-v1_3 - Provider: Stratmont Global (first party) - Purpose: Preserves scroll position and router state so pages restore correctly as you navigate. - Type: Strictly necessary / functional (session storage; no consent required) - Duration: Session (cleared when the tab is closed)

• Language preference (EN / FR / DE / RU) - Provider: Stratmont Global (first party) - Purpose: Remembers the interface language you select so the Site displays in your chosen language. - Type: Strictly necessary / functional (browser storage; no consent required) - Duration: Persistent (until cleared)

• Flock analytics identifier(s) (loaded from /~flock.js, proxied via /~api/analytics) - Provider: Flock (first-party analytics, served via our domain) - Purpose: Measures site usage on an aggregated basis — which pages and areas are viewed, where visitors arrive from (referring source), and the time and date of visits — to help us improve the Site. - Type: Analytics / performance (consent required) - Duration: Indicative: session to 12 months, per provider settings

• rrweb session-replay / diagnostics identifier(s) (loaded via /__l5e/events.js) - Provider: Session-replay and error-diagnostics provider (rrweb-based) - Purpose: Records a sampled reconstruction of page interactions (clicks, scrolling, navigation), with text inputs masked, to diagnose errors and improve usability. - Type: Session replay / diagnostics (consent required) - Duration: Indicative: session to 30 days, per provider settings

Some technologies set more than one identifier, and exact names can vary between versions. If you would like a fuller current breakdown, please contact us using the details in Section 14.

5. What we learn from these technologies

Through these technologies, and through our web servers more generally, we may collect technical and usage information automatically. Our analytics tool (Flock) measures site usage on an aggregated basis — the pages and areas of the Site you view, the source you arrived from (referring URL), and the time and date of your visit. Our web servers and security logging may also record technical details such as your IP address, approximate location, device and browser type, and operating system. The reconstruction of on-page interactions such as clicks, scrolling and navigation is captured only by our session-replay / diagnostics tool, on the sampled basis and with text inputs masked as described in Section 3.3.

We use this information to keep the Site secure and available, to understand how it is used, and to identify and fix faults. We do not use it to make decisions that produce legal or similarly significant effects about you, and we do not carry out advertising profiling. Where this information constitutes personal data, it is handled in accordance with our Privacy Policy.

Please note that the technologies described here relate to how the Site is used. They are separate from the information you actively provide — for example through our contact form or by email or phone. As explained in our Privacy Policy, you should not submit unnecessary sensitive or confidential third-party information through the Site.

6. Our consent banner

When you first visit the Site, a cookie-consent banner is displayed. Strictly necessary / functional technologies (Section 3.1) are active because they are needed for the Site to work and are exempt from consent. Non-essential technologies — analytics (Flock) and session replay / diagnostics (rrweb-based) — are not set or activated until you choose to accept them.

The banner lets you:

• Accept non-essential cookies, so that analytics and session-replay technologies are enabled; or

• Reject non-essential cookies, so that only strictly necessary / functional technologies are used.

We treat non-action as a refusal: if you do not accept, non-essential technologies remain switched off. Your choice is remembered so that you are not asked on every page, and we will ask you again periodically or where our use of cookies materially changes.

7. How to give, change or withdraw your consent

Your consent to non-essential cookies is entirely optional and you may change or withdraw it at any time, with effect for the future. Withdrawing consent is as easy as giving it.

• Through the consent tool: you can reopen the consent settings on the Site at any time to switch the analytics and session-replay categories on or off.

• Through your browser: you can clear or block cookies and storage as described in Section 8. Clearing stored data will also reset your previous consent choice, and the banner will appear again on your next visit.

Withdrawing consent does not affect the lawfulness of any processing carried out before you withdrew it. Because the strictly necessary / functional technologies are exempt from consent, they are not affected by changing these settings.

8. Browser controls

In addition to our consent tool, most web browsers let you control cookies and similar storage through their settings — for example, to block or delete cookies, to clear local and session storage, or to be warned before a cookie is stored. The relevant controls are usually found in the browser's privacy or security settings, and detailed instructions are available from your browser provider. You can find general guidance about managing cookies at www.aboutcookies.org and www.allaboutcookies.org.

Some browsers and extensions can send automated privacy or opt-out signals on your behalf. Because we only set non-essential cookies after you give consent through our banner, no such signal is overridden: unless and until you accept, our analytics and session-replay technologies remain switched off. We keep developments in this area under review and will update this policy if our approach changes.

9. Consequences of disabling cookies

You can use the Site with non-essential cookies switched off. Because this is a brochure and contact site, refusing analytics and session-replay technologies will not prevent you from reading our pages, using the contact form, or contacting us by email or phone.

The main effects of disabling technologies are:

• Strictly necessary / functional: if you block these through your browser, some features may not work as intended — for example, the Site may not remember your chosen language (EN/FR/DE/RU) or restore your scroll position correctly between pages.

• Analytics (Flock): your visit will not be measured, which means we have less aggregated insight to improve the Site, but your experience of the Site is otherwise unaffected.

• Session replay / diagnostics: your session will not be recorded, which may make it harder for us to reproduce and fix a fault you encounter, but again your experience is otherwise unaffected.

10. Legal basis under ePrivacy and the GDPR

Our use of cookies and similar technologies is governed in Ireland by the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (S.I. No. 336 of 2011) (the "ePrivacy Regulations"), read together with the EU General Data Protection Regulation (Regulation (EU) 2016/679, the "GDPR") and the Irish Data Protection Act 2018.

• Strictly necessary / functional technologies are used under the ePrivacy exemption for storage that is strictly necessary to provide a service explicitly requested by the user. Where the related data is personal data, our legal basis is our legitimate interests in operating and securing the Site (Article 6(1)(f) GDPR).

• Analytics (Flock) and session replay / diagnostics are non-essential. We place and read these technologies only with your consent under the ePrivacy Regulations, and our GDPR legal basis for the associated processing is your consent (Article 6(1)(a) GDPR), which you may withdraw at any time as described in Section 7.

Other processing of personal data described in our Privacy Policy — such as responding to enquiries, managing business relationships, ensuring security, meeting legal and regulatory obligations, and establishing or defending legal claims — relies on the legal bases set out in that policy and is not dependent on cookies.

11. Third-party providers and processors

The Site is built and served on the Lovable web platform, and static assets are delivered through a content delivery network (Cloudflare R2). Our providers act as our data processors or sub-processors and handle data on our instructions and under appropriate contractual safeguards. They include:

• the Lovable hosting platform, which builds and serves the Site;

• the Cloudflare R2 content delivery network, which serves static assets;

• the analytics tool (Flock);

• the session-replay / diagnostics tool (rrweb-based); and

• our email provider.

These providers may set or read identifiers in connection with the services they perform for us, and their own technologies are subject to their respective terms and privacy / cookie notices. We encourage you to review those notices for further detail about how each provider operates. Stratmont Global remains responsible to you for the technologies deployed on the Site under this policy.

We do not use cookies to sell your personal data, and we do not operate third-party advertising or cross-site tracking on the Site.

12. International transfers and retention

Some of our providers may process data outside the European Economic Area (EEA). Where this happens, we ensure the transfer is protected by an EU adequacy decision or by Standard Contractual Clauses (SCCs), with supplementary measures applied where needed, in line with our Privacy Policy.

As to retention: strictly necessary / functional storage lasts only for the periods indicated in the table in Section 4 (for example, the scroll-restoration key is cleared when you close the tab). Analytics and session-replay data are retained in accordance with the relevant provider's retention settings and for no longer than necessary for the purpose for which they were collected. Further detail on retention is available on request using the contact details in Section 14.

13. Your data-protection rights

Where cookies and similar technologies involve the processing of your personal data, you have rights under the GDPR, including the rights of access, rectification, erasure, restriction of processing, data portability and objection (including to processing based on legitimate interests), and the right to withdraw consent at any time under Article 7(3) GDPR. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal (see Section 7). We seek no special-category data through the Site, and we do not carry out solely automated decision-making that produces legal or similarly significant effects about you.

To exercise your rights, please contact us at Info@stratmontglobal.com. We aim to respond within one month, although this period may be extended by up to two further months where permitted under Article 12(3) GDPR (for example, where a request is complex or where we receive a number of requests), in which case we will let you know. You also have the right to lodge a complaint with the Irish supervisory authority, the Data Protection Commission (DPC), at 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland (www.dataprotection.ie). Our Privacy Policy explains these rights in full.

14. Changes to this policy and how to contact us

We may update this Cookie Policy from time to time to reflect changes in the technologies we use, our providers, or legal requirements. When we make material changes, we will update the "Last updated" date above and, where appropriate, ask for your consent again through the banner. Please check this page periodically.

If you have any questions about this Cookie Policy or about how we use cookies and similar technologies, you can contact us:

• Email: Info@stratmontglobal.com

• Phone: +353 89 605 2254

• Business hours: Monday–Friday, 08:00–18:00 CET

This Cookie Policy is governed by the laws of Ireland, and the courts of Ireland have exclusive jurisdiction over any dispute arising from or in connection with it. For more information about how we handle personal data, please see our Privacy Policy; for the terms governing your use of the Site, see our Terms & Conditions.

Stratmont Global — Oksana Kholieva (sole trader), Registered Business Name No. 786173 40 Mill Street, Baltinglass, Co. Wicklow, W91 DK64, Ireland Info@stratmontglobal.com | +353 89 605 2254 | https://stratmontglobal.com ====================================================================================