Kitco Privacy Policy

Effective Date: October 31, 2024
Last Update: October 31, 2024

Introduction

Kitco Metals Inc. ("Kitco" or "we") is committed to respecting and protecting your privacy and Personal Information when it comes to our online websites, social networking sites ("Sites"), mobile applications ("Apps") and any information, products, software, applications or services available on the Sites (the “Services”). This Privacy Policy (“Privacy Policy”) explains how we process any information that could reasonably be linked, directly or indirectly, with you or your household, including any information that is subject to applicable data protection laws (“Personal Information”), collected online or offline about you, including on the Kitco platform. It also tells you what choices you have with respect to that Personal Information. Kitco is the controller (i.e., responsible party) for the Personal Information practices described in this Privacy Policy. If you have any questions, feel free to reach out to us anytime at privacy@kitco.com.

You can access specific topics within this Privacy Policy by clicking on the relevant links below:

1. Information We Collect about You
2. Sources of Personal Information
3. Use and Processing of Your Personal Information
4. Disclosures of Your Personal Information
5. Cookies and Similar Technologies
6. Opt-Out Preference Signals
7. Security Measures
8. Data Retention
9. Children's Privacy
10. International Transfers of Your Personal Information
11. Links to Other Websites
12. Your Choices Relating to Your Personal Information
13. Your Rights Relating to Your Personal Information
14. Changes to this Privacy Policy
15. Contact Us

1 INFORMATION WE COLLECT ABOUT YOU

Depending on the Kitco products or Services you use, the following information is collected from or about you, or may have been collected in the past 12 months:

• Contact Information/Identifiers, including name, email address, postal address for mailing and shipping, phone or fax number, username, business contact information, or other similar identifiers and account log-in information.
• Government Identifiers, including government-issued identification document numbers and other information on the document (which, in certain instances, may be considered sensitive Personal Information).
• Employment and Background Information, including occupation and employment history.
• Information pertaining to Funds or Precious Metals, such as documents related to your source of funds or source of precious metals.
• Information Specific to the Services, in certain instances, such as invoices, business and commercial communications, order status and history.
• Demographic Information, including age and gender, some of which may include characteristics of protected classifications under applicable law.
• Device Information and Other Unique Identifiers, device identifier, internet protocol (IP) address, information about the type of device you use, or similar unique identifiers.
• Internet or Other Network Activity, including browsing or search history, your device operating system and browser type, your browser language, and information regarding your interactions with our Sites or referring websites, mobile applications, emails, or advertisements.
• Geolocation Data, including information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.
• Payment Information, including credit or debit card number, bank account number, or other financial information.
• Biometric Data, such as when you agree to provide photographs for verification purposes.
• Inferences, which are drawn from or created based on any of the information identified in this section.
• Sensitive Personal Information (where permitted and in accordance with applicable law), of the information listed above, governmental identification, precise geolocation, biometric data, username and password, security question and security answer and/or financial information are also sensitive Personal Information.

The provision of the sensitive Personal Information listed above is voluntary. To the extent that you provide Kitco with your biometric data, any biometric data will be permanently deleted when the initial purpose for which it was collected or obtained has been satisfied or within three years after your last interaction with Kitco, whichever occurs first, unless otherwise required by law.

If you do not provide us with certain Personal Information, we may not be able to fulfill the requested purpose of collection, such as to respond to your queries or request for customer service or to provide the full functionality of our Sites or Apps to you. However, unless otherwise specified, not providing your Personal Information will not result in legal or other consequences to you.

2 SOURCES OF PERSONAL INFORMATION

We collect your Personal Information in the following ways, pursuant to applicable law:

• Directly from You, such as when you use our Services, create an account and profile with us, sign up with us to receive marketing communications, or otherwise reach out to us.
• Other Sources, including publicly available sources, vendors, affiliates, and through tracking technologies. To learn more about our use of cookies and similar tracking technologies, please review the “Cookies and Similar Technologies” section below. We may also collect Personal Information about you when you don't have a direct relationship with us. This may happen, for instance, when someone applies to open an account with us for a legal entity where you are a beneficial owner or a legal representative.

3 USE AND PROCESSING OF YOUR PERSONAL INFORMATION

We use your Personal Information for the following business purposes associated with our general business operations, including:

• All visitors to our Sites or users of our Apps: We may collect your device information and other unique identifiers, and internet or other network activity to help us improve our Sites and Apps.
• To provide our Services: We may process your contact information and similar Personal Information to provide you with access to the Services on the Sites and Apps.
• Communications/alerts/newsletters subscribers: When you opt-in for our newsletters, marketing materials, or to a rate-watch tool on our Sites or Apps, we may collect information so we can respond to you with any information you requested.
• Customers who apply for or open an account, or initiate a precious metals transaction with us: When you apply to open an account with us, we may collect your contact information, payment information, and information specific to the Services to process your transaction.
• To prevent fraud, money laundering, and other illegal activity: We use Personal Information, including contact information, device information, biometric data, and other unique identifiers, and similar information, to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of Kitco and our users, customers, employees, or others.
• To improve our Sites and Apps: We may collect your contact information, internet and other network activity, and similar Personal Information about you to analyze, administer, maintain, evaluate, and improve our Sites and Services, and to develop new products and Services.
• To conduct marketing: We may use Personal Information for marketing and promotional purposes to show you advertisements for products and/or Services tailored to your interests on social media and other websites.
• To manage our business operations: We may use your Personal Information to manage our business operations, perform our obligations and exercise our rights under any agreement that you or your organization has with us.
• For other purposes: We may process your Personal Information for other purposes with your consent, or as otherwise permitted or required by applicable law.
• To meet our legal and regulatory obligations: We use Personal Information to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
• Montreal Counter visitors: Our Montreal Counter operates video surveillance for security and operational purposes to help us improve our customer experience.
• Call recordings, copies of chats, text messages, emails, mails, and interactions with the Sites: For quality assurance, training, and security purposes, telephone calls, chat communications, and certain interactions with the Sites are recorded. We also keep additional copies of emails, chats, text messages and mails made or received by our employees.
• Potential employees: If you are a prospective employee of ours, you may be asked to share information with us if you apply for employment using our Sites. In order to use the Career feature, you will be required to create a unique profile and supply a username and a password. In addition, to complete the application process, you will be asked to provide information about your previous employment, education and qualifications, as well as your contact information.

If you submit Personal Information relating to another person to us, we trust you have the necessary consent from such individuals and have authority to disclose their Personal Information to us, as well as their consent to our collection, use and disclosure of their Personal Information, for the purposes outlined in this Privacy Policy.

4 DISCLOSURES OF YOUR PERSONAL INFORMATION

We may disclose, or have disclosed in the prior 12 months, your Personal Information to selected third parties, including:

• Affiliated Companies: We may disclose your Personal Information to affiliates, business partners, joint marketers, suppliers, sub-contractors and agents for the performance of any contract we enter into with them or you.
• Advertisers: We may disclose your Personal Information to advertisers and advertising networks solely to select and serve relevant advertisements to you.
• Service Providers: We may disclose Personal Information to analytics and search engine providers that assist us in the improvement and optimization of our Sites and Apps. We may also disclose your Personal Information to risk management service providers that assist us in prevention and detection of fraud and in compliance of regulatory obligations.
• Collection Agencies and Other Authorized Parties: We may disclose your Personal Information to collection agencies and other authorized parties that assist us in retrieving debts and locating hard to find customers who have holdings, or to allow us to pursue available remedies or limit the damages that we may sustain.
• Other Parties: We may disclose your Personal Information to governments, courts, regulators, judicial authorities, and law enforcement authorities, including those outside your country of residence, or in relation to a legal activity, upon demonstration of lawful authority. We may also disclose such Personal Information if we believe disclosure is necessary to prevent physical, financial, or other harm, injury, or loss.
• Corporate Transaction: We may disclose your Personal Information in connection with a proposed or actual corporate merger, acquisition, consolidation, sale of assets, bankruptcy, insolvency or other corporate change. Such recipient will be bound by terms and conditions reasonably similar to those set out in this Privacy Policy. Please rest assured we'll make all reasonable efforts to ensure the successor treats your Personal Information with the same respect and consideration as we do.
• Deidentified Personal Information: We may disclose or use aggregated or deidentified data for any lawful purpose. Deidentified information is generally not considered to be Personal Information under applicable laws.
• Additional Disclosures: From time to time, we may disclose your Personal Information to our attorneys, banks, auditors, securities brokers and other professional service providers and advisors in connection with the purposes described above.
• Other Disclosures with Your Consent: We may disclose your Personal Information with your consent to other unaffiliated third parties who are not described elsewhere in this Privacy Policy.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes.

5 COOKIES AND SIMILAR TECHNOLOGIES

Any time you visit our Sites, our web servers automatically collect information about you, including, in some instances, Personal Information, through cookies, web beacons, and other similar tracking technologies (collectively “cookies”). Cookies are small text files that are placed on your computer or mobile device when you visit a website. Cookies help the Sites remember information about your visit, which can make it easier to visit the Sites again and make the Sites more useful to you. Some cookies are deleted once you close your browser (session cookies), while other cookies are retained even after you close your browser so that you can be recognized when you return to a website (persistent cookies). More information about cookies and how they work is available at www.allaboutcookies.org. Generally, your email address and all other Personal Information is collected only when you voluntarily provide that data.

Cookies on our Sites are generally divided into the following categories:

Cookie Type	Description
Essential Cookies	These are cookies that our Sites need in order to function and that enable you to browse and use the Sites and their features. Without these essential cookies, the Sites will not perform as smoothly for you as we would like them to, and we may not be able to provide the Sites or certain Services or features you request. Examples of where these cookies are used include: to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes.
Analytics Cookies	Analytics cookies provide us with information regarding how visitors navigate and interact with our Sites. Such cookies allow us to understand, for example, more about how many visitors we have to our Sites, how many times they visit us and how many times a user viewed specific pages within our Sites.
Advertising Cookies	Advertising cookies may be placed by us or third parties to enable third-party ad networks to recognize a unique cookie on your computer or mobile device. The information that is collected and disclosed by these types of cookies may also be linked to the device identifier of the device you are using to allow us to keep track of all the websites you have visited that are associated with the ad network. This information may be used for the purpose of targeting advertisements on our Sites and third-party sites based on those interests.

We may use the information collected through cookies and related tracking technologies for the following purposes:

• To make our Sites easier to use and generally improve their performance.
• To gather metrics about how you interact with our Sites.
• For security reasons.
• To provide personalized content. For example, we may store user preferences, your default language, device and browser information, and your profile information, which includes the level of your usage of the Sites so we can identify you across devices and personalize the content you see.
• To advertise to you via behavioral/targeted advertising and allow others to do the same.

Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent this. If you disable cookies, your ability to use some features of the Sites may be limited. For mobile devices, you may be able to manage certain cookies using your built-in mobile device settings and controls. Any choices concerning cookies are browser and/or device specific. If you clear your cookies from your browser on any of your devices, your choices will need to be reset. You should check how to do this on your device(s) and operating systems.

Some of these cookies may be placed by third-party service providers to help determine the effectiveness of our advertising campaigns or email communications. The use of cookies by third-party service providers is within their control and not ours. We do not control their websites or their policies and practices regarding your Personal Information, and you should be aware that different rules might apply to the collection, use or disclosure of your Personal Information by third parties in connection with their advertisements or promotions and other sites you encounter on the Internet. This Privacy Policy does not cover any use of Personal Information that a third-party service provider may directly collect from you, and we do not undertake to confirm, investigate, or police their practices.

Along those lines, Kitco uses YouTube API services to connect the contents of Kitco's YouTube Channel(s) with our Sites and Apps. You can learn more about YouTube's privacy policies at policies.google.com/privacy.

6 OPT-OUT PREFERENCE SIGNALS

Our systems generally recognize commercially reasonable opt-out preference signals (e.g., Global Privacy Controls). Recognition of this signal will only occur with respect to the device and/or browser that communicates the signal such that you may need to update your preferences on every device or browser you use to access our Services.

7 SECURITY MEASURES

Your safety and security is of utmost importance to us. As such, we enforce the highest security measures when it comes to protecting your Personal Information against theft, loss, and corruption, as well as defending against the misuse and alteration of any customer data stored on our servers.

To keep your credit card information secure, we only use the Payment Card Industry (PCI) Compliant version of the Transport Layer Security (TLS) protocol for transferring credit card information across the internet, and all Kitco employees and agents are aware of this security policy. Your Personal Information is accessible only to selected employees and agents who need this information to carry out contractual obligations with you.

However, when you log into your account through a public or other unsecured connection, or if you choose to share your login information with others, we can't guarantee the security of your account. It's best practice to keep your passwords private, so you should avoid sharing this information with others. We do not guarantee that your Personal Information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such Personal Information. In the event of an incident that we are required by law to inform you of, we may notify you electronically, in writing, or by telephone, if permitted to do so by law. We encourage you to use caution when using the Internet. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us as specified in the "Contact Us" section below.

8 DATA RETENTION

The time periods for which we retain your Personal Information depend on the purposes for which we use it and applicable law for the type of data and use. Kitco will keep your Personal Information for as long as you are a registered subscriber or user of our Services or for as long as we have a valid business purpose to do so and, thereafter, for no longer than is required or permitted by law. The Personal Information we collect may be stored and processed in servers in Canada, the United States and/or other jurisdictions where Kitco, or our service providers, have facilities.

9 CHILDREN'S PRIVACY

Kitco does not knowingly collect Personal Information from children under the age of 14 (or other relevant age of majority) without first obtaining parental consent in accordance with applicable laws. Users under the age of 14 should not submit any Personal Information to us. If you believe we have collected Personal Information from your child in error or have questions or concerns about our practices relating to children, please notify us using the details in the "Contact Us" section below. We will take prompt steps to remove the Personal Information from our systems.

10 INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

Kitco is headquartered in Canada and we have operations, entities, and Services throughout the world. Your Personal Information may be transferred to a third-party service provider for processing and storage, and may also be stored and processed in countries where we have facilities or service providers. By using our Services, you consent to your Personal Information being transferred to countries outside of Canada, which may have different data protection rules. If your Personal Information is transferred outside of Canada, the governments, courts, law enforcement or regulatory agencies of that jurisdiction may be able to obtain disclosure of your Personal Information through the laws of that jurisdiction. We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.

11 LINKS TO OTHER WEBSITES

Our Sites may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Kitco. Linked websites may have their own privacy policies or notices, which we recommend you review if you visit those websites. This Privacy Policy only applies to Personal Information collected on these Sites. We have no control over third-party websites and are not responsible or liable for the content, privacy practices, or use of any websites that are not affiliated with Kitco.

12 YOUR CHOICES RELATING TO YOUR PERSONAL INFORMATION

Depending on the Services you use and the sensitivity of your information, we may obtain your consent to disclose information in different ways. Express consent may be obtained verbally, online, or in writing, and implied consent may be obtained through your use of our Sites or Apps, or when you approach us to obtain information on Kitco's products and Services.

Generally, we seek consent to collect, use and disclose Personal Information at the same time we collect the information. In some circumstances, we may identify a new purpose and seek your consent to use and disclose Personal Information after it's been collected.

Consent can also be given through an authorized representative, such as a legal guardian or a person with Power of Attorney. This may be necessary if we cannot obtain express consent from a minor (i.e., someone who is under the age of 18), or a person who is seriously ill, or mentally incapacitated.

We will send necessary communication to you and other users of our Services that contains important information, as well as other communication you request from us. You may not opt out from receiving these communications or adjust the media format through which you receive them.

We may occasionally send you marketing content about our Sites, Services, or products, as well as the products and services of unaffiliated third parties through email, text, pop-ups, push notifications and messaging applications. You can opt out of these marketing communications at any time. If you have an account with us, you can also adjust your communication preferences in your account settings or by calling our customer experience team at 1 877-775-4826. For messages sent via push notifications, you can manage your preferences on your device.

13 YOUR RIGHTS RELATING TO YOUR PERSONAL INFORMATION

You may have certain rights regarding your Personal Information. The rights available to you depend on our reason for processing your Personal Information and the requirements of applicable law (i.e., your rights will vary depending on whether you are located in, for example, California). Specifically, you may have the following rights:

• Right to access: You may have the right to obtain confirmation as to whether Personal Information concerning you is being processed, and, where that is the case, to request access to the Personal Information. This access to information includes the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipients of Personal Information, among other categories of information. However, this is not an absolute right, and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the Personal Information free of charge. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
• Right to data portability: You may have the right to request that we transfer the Personal Information we have collected about you to another organization, or directly to you, in a structured, commonly used, and machine-readable format, under certain conditions.
• Right to correction: You may have the right to request that we correct any Personal Information about you that is inaccurate. Depending on the purpose of the processing, you also have the right to request that we complete the Personal Information we hold about you where you believe it is incomplete, including by means of providing a supplementary statement.
• Right to deletion: You may have the right to request that we erase your Personal Information, under certain conditions.
• Right to know what Personal Information is sold or shared and to whom, and right to prohibit the sale or sharing of Personal Information: We do not and have not in the preceding 12 months, sold your Personal Information, nor do we sell the Personal Information of minors under the age of 16 for money. However, we have shared (in this context, “share” means the use of your Personal Information for cross-contextual behavioral advertising) your Personal Information, which may be treated as a “sale” under applicable law. You may opt-out of the sharing of your Personal Information by updating your cookie preferences, as described above.
• Right to opt-out of targeted advertising: As noted above, we engage in targeted advertising through the use of cookies. You may opt-out of targeted advertising by updating your preferences in the cookie preference center or by contacting us, as stated below.
• Right to opt-out of profiling: You may have the right to opt out of the processing of your Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. At this time, we do not engage in profiling for purposes that may be opted out of.
• Right to limit the use and disclosure of sensitive Personal Information: We will only use sensitive Personal Information as needed for the purposes for which it was collected. If this changes, we will notify you, and you may have the right to restrict such additional uses.
• Right to withdraw consent: Where we rely on your consent to process your Personal Information, such as when we process sensitive Personal Information or record certain interactions between you and Kitco, you have the right to withdraw that consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
• Right of non-discrimination/retaliation: We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy, nor do we retaliate against individuals who exercise these rights.

Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law.

Depending on where you are located, a person authorized to act on your behalf may make a verifiable request related to your Personal Information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.

In any circumstances, your request must: (i) provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

To exercise your rights, please contact us as stated in the “Contact Us” section of this Privacy Policy.

14 CHANGES TO THIS PRIVACY POLICY

To ensure this Privacy Policy stays up to date, we may make changes from time to time without notifying you directly. You'll always be able to see any changes made on our Sites. The revised Privacy Policy will be date stamped with 'Last Updated' at the top and will become effective when posted to our Sites. Using our Sites, Apps, products and Services, and/or providing consent to the updated Privacy Policy following such updates constitutes your acceptance of the revised Privacy Policy.

15 CONTACT US

If you have any questions or concerns about this Privacy Policy, you can contact us at:

By Mail:	Attn: Data Protection Officer 620 Cathcart Street, Suite 900 Kitco Metals Inc. Montreal, Quebec, H3B 1M1
By E-Mail:	privacy@kitco.com
By Phone:	1 877-775-4826