WEBSITE PRIVACY NOTICE

Last Update: September 2024

Eldorado Gold Corporation ("Eldorado Gold") is committed to protecting your personal data. This website privacy notice (the "Privacy Notice") describes how Eldorado Gold collects, uses, shares, and protects information collected about you on its websites (individually a "Site" and collectively, the "Sites").

Any personal data you provide, or we collect from the use of Eldorado Gold Sites will only be used in accordance with this Privacy Notice.

This Privacy Notice covers the following:

  • What is personal data?
  • What are the purposes for the collection, use and disclosure of your personal data?
  • With whom do we share your personal data?
  • Is your data transferred outside your province or country?
  • How does Eldorado Gold obtain your consent?
  • How long does Eldorado Gold retain your data?
  • Use of technology on the Site
  • How does Eldorado Gold protect your personal data?
  • Data Subject or Individuals’ Rights
  • Contacting Eldorado Gold about your privacy

What is personal data?

Personal data means data about an identifiable or identified natural person. For example, personal data includes such things as your home address and telephone number, your date of birth, your personal email address, and your credit card or other financial information.

What are the purposes for the collection, use and disclosure of your personal data?

Eldorado Gold processes personal data only on grounds that are allowed under applicable legislation:

  • Consent
  • Performance of a contract
  • Legal obligation
  • Legitimate interests of Eldorado Gold

We do not collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of genetic data, biometric data in order to uniquely identify a person or data concerning health or sex life and sexual orientation. We ask that you not communicate or provide these elements of data to us through our Sites. We will not use your personal data for decisions based solely on automated processing if the decision produces legal effects concerning you or significantly affects you, unless you give your explicit consent for this processing.

If you have given Eldorado Gold your consent, you may, at any time, unsubscribe or withdraw your consent by contacting Eldorado Gold as set out below, subject to our legal obligations and any applicable retention policies. In some cases, withdrawal of your consent may result in Eldorado being unable to provide you with a particular service through our Sites. If so, Eldorado will advise you of the consequences of your withdrawal of consent at the time.

Consent

Eldorado Gold collects, uses and discloses your personal data only for identified purposes with your knowledge and consent. Eldorado identifies these purposes to you at the time it collects this information. Some of the purposes for which Eldorado may collect, use and disclose your personal data on its Sites are:

  • To respond to inquiries and requests for one-time or ongoing communications from Eldorado Gold through the “Contact Us” form on our Sites;
  • To respond to shareholder and investor enquiries;
  • To respond to and process applications for employment with Eldorado Gold; and
  • To provide you with marketing materials (such as newsletters or links to Eldorado Gold social media posts) if you have indicated an interest in receiving such marketing materials.

If you choose not to provide Eldorado with your personal data, the Site will not collect any personal data about you.

Legal Obligation

Eldorado Gold may disclose your personal data without your permission to the extent that it is required or permitted to do so by applicable law for the following purposes:

  • To comply with applicable securities laws regarding communications with potential and actual investors;
  • In connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend Eldorado Gold’s legal rights.

Performance of Contract

Eldorado Gold collects, uses and discloses your personal data in the event you have sought contracting opportunities, or educational opportunities, or solicited business with Eldorado Gold, for the following purposes:

  • To evaluate the contractual opportunity and if applicable, negotiate and execute a contract with you (these activities include, but are not limited to, circulation of supplier due diligence questionnaires or a request to participate in a supplier due diligence online evaluation process and circulation of a confidentiality agreement);
  • To comply with commitments made to local authorities regarding hiring, Eldorado Gold may provide information relating to inquiries and hiring from local areas in which Eldorado Gold operates, to evidence compliance with commitments made by Eldorado Gold;
  • To comply with commitments made with local authorities regarding local sourcing, engagement with local organizations and groups, or provide educational opportunities (either individually or to groups).

Individuals seeking employment or contractor opportunities with Eldorado Gold will receive a specific candidate data privacy notice.

Legitimate interests of Eldorado Group

Eldorado Gold collects, uses and discloses your personal data to support its legitimate interests to monitor and enhance the security of our Sites and other systems to which it may connect.

With whom do we share your personal data?

Eldorado Gold may share your personal data with third parties to assist Eldorado Gold to administer activities on the Site, such as website maintenance, or to our auditors or other professional advisors. Eldorado may also use service providers to assist in aggregating personal data. If you have provided Eldorado Gold with your personal data, that personal data will not be sold (except it may be transferred on the sale of the stock or assets of Eldorado). Where we transfer personal data to third parties for the process of administering our Sites or services, we protect that data through contractual means.

Is your data disclosed outside of your province or country?

Your personal data may be transferred to another province or country. In this case, your personal data is also subject to the laws of that province or country. Before we disclose your personal data, we will take protective measures. We consider all the factors that may impact your privacy and assess whether the data will be adequately protected. We also enter into a contract or agreement that includes appropriate security measures for the information disclosed.

For data transfers of personal data outside Québec, the relevant legislation requires Eldorado Gold to conduct an assessment to ensure the personal data receives an adequate level of protection. The legislation requires that the contract governing such transfers must take into account the results of the assessment.

How does Eldorado Gold obtain your consent?

Eldorado obtains consent to collect, use and disclose your personal data for the reasonable and necessary purposes set out above. When you provide Eldorado Gold with your information, such as for signing up to receive our newsletters or emails about business developments, you are consenting to the collection, use and disclosure of your personal data for these purposes, in accordance with the principles outlined in this Notice.

How long does Eldorado Gold retain your personal data?

Eldorado Gold will not store your personal data longer than necessary to fulfil the purpose for which it was collected or to satisfy any applicable legal requirements.

Use of Technology on the Site

The Site uses cookie technology to make your use of the Site more convenient. A cookie is a text file which enables the Site to store information about your activities on the Site, or the length of your stay. Any personal data that is collected by the cookies will be used only on an aggregate basis, which means that Eldorado Gold takes the identifiers off the information and uses it for statistical purposes to assist Eldorado Gold in enhancing your online experience, or to evaluate the success of promotions that Eldorado Gold may carry on through the Site. The Site does not collect your personal or financial data from your computer, nor does it place persistent cookies on your computer. The Site will not put cookies on your hard drive. Most web browsers are set to accept cookies by default, however, you should have an option to disable cookies associated with the Site. If you choose to do so, this may affect the functionality of the Site and your ability to access certain features of the Site.

How does Eldorado Gold protect your personal data?

Eldorado Gold is committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate technical and organizational measures to safeguard and secure the personal data we process. They include:

  1. physical measures, such as locked premises;
  2. technological measures, such as firewalls;
  3. organizational measures, such as the adoption of an information security policy.

Only staff members who need to process your personal information to perform their duties may access it. These individuals only have access to the information necessary to perform their duties. We have established the roles and responsibilities of staff members throughout the processing cycle of your personal data.

Eldorado Gold Sites endeavour to use appropriate reasonable security arrangements to prevent any unauthorized access, collection, use, disclosure, copying, modification or disposal of your personal data in accordance with applicable law. Eldorado Gold exercises care in the secure transmission of your personal data, however, no transmission of personal data over the Internet is completely secure. Eldorado Gold cannot guarantee that personal data disclosed through the Internet cannot be intercepted by third parties. However, Eldorado Gold has taken the steps that are reasonably available to Eldorado Gold to protect any personal data that you have provided to Eldorado Gold, including, in its disposal or destruction in due course.

Please remember that you control what personal data you provide while using Eldorado Gold Sites.

If, despite all our efforts, a data breach does occur, Eldorado Gold shall take all necessary steps to limit the impacts of the breach and do everything in its power to limit the damage. In case of a data breach which is likely to result in a high risk, and depending on the circumstances, we will take reasonable actions to inform you about remedial actions to prevent further damage. It is our responsibility to inform the relevant supervisory authority or authorities without undue delay.

Data Subject or Individuals’ Rights

Withdrawing your Consent

You may request to withdraw your consent to the use, disclosure and retention of your personal data. The processing of this request depends on the situation and the purpose sought. As the case may be:

  1. you can withdraw your consent, but we will no longer be able to provide you with a service that depends on it;
  2. you cannot withdraw your consent because the processing of your personal information is necessary or mandatory.

In all cases, we may need to retain certain personal data to comply with our legal obligations.

Accessing and correcting your personal data

You may request details of personal data which we hold about you. If you would like a copy of the personal data held on you, please write to the contact address below. If you believe that any personal data, we are holding on you is incorrect or incomplete, please contact us as soon as possible, at the address below. We will promptly correct any personal data found to be incorrect.

Contacting us about your privacy

If you have any questions about this Privacy Notice, you may contact our Chief Compliance Officer. In Québec, the Chief Compliance Officer is responsible for the protection of personal information held by the company.

You may contact the Chief Compliance Officer in the following way:

Québec:

Head of Compliance 
Eldorado Gold Québec 
300 3e Avenue Est 
Val-d’Or QC 
J9P OJ6 Canada

British Columbia: 

Chief Compliance Officer 
11th Floor, 550 Burrard Street 
Vancouver, BC 
V6C 2B5

You can also email: [email protected]

From time to time, we may change this Privacy Notice when it is appropriate to do so. We recommend that you review this Privacy Notice from time to time so that you are aware of any changes.

Contacting your Supervisory Authority

If you are dissatisfied with Eldorado Gold’s handling of any privacy complaints, you have the right to lodge a complaint with your respective supervisory authority.

Québec

Commission d'accès à l'information 
Suite 2.36 525 René-Lévesque Blvd. East

Quebec City, Quebec 
G1R 5S9 Telephone: 418 528-7741 
Fax: 418-529-3102 
Toll Free: 1-888-528-7741 
Email: [email protected]

British Columbia

Office of the Information and Privacy Commissioner for British Columbia 
PO Box 9038 Stn. Prov. Govt. 
Victoria B.C. V8W 9A4 
Telephone: (250) 387-5629 
Email: [email protected]