Kitco Privacy Policy

Updated: April 20, 2021

Introduction

Kitco Metals Inc. ("Kitco") is committed to respecting your privacy and protecting your personal information in connection to our online websites, social networking sites (collectively referred to as "sites"), mobile applications ("apps") and services.

By visiting our sites and apps, using or applying for a Kitco account, or initiating a transaction with us, you are consenting to agree to our Privacy Policy.

This policy sets out:

• What information we collect about you and why we collect it;
• How we share your personal information;
• How we protect your personal information;
• Your choices with regards to your personal;
• How to be informed about our Privacy Policy changes;
• How to contact us.

What information we collect about you and why we collect it

Depending on the products or services that you choose, we have listed below the types of information that we may collect from you and why:

All visitors to our sites or users of our apps: If you are browsing our sites or apps and you do not have any accounts or subscriptions with us, we do not collect, capture, or retain your personally identifiable information. We only collect the following: information about your physical location, your Internet Protocol (IP) address, the type of mobile device you use, your device operating system and browser type, the unique identifier of your device, your browser's language, the address of referring websites, the path you take through our sites or apps, cookies and other information about your browsing session.

• A cookie is a small file of letters and numbers that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the site uses to track the pages you've visited. A cookie cannot read data off your hard disk or read cookie files created by other sites. You can refuse cookies by turning them off in your browser. You do not need to have cookies turned on to use our sites, apps, or services.
• We use this anonymous information to remember your preferences and to provide advertising that is more relevant to you. We may also use and share information about your browsing session for analytics purposes to improve our products and services.

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 your name, email address and phone number in order to respond to you with the information you requested.

Customers who apply for or open an account, or initiate a precious metals transaction with us:

• We will collect information that allows us to carry out our obligations relating to your contracts and transactions with us:
  • Your contact information (full legal name, email address, phone number, fax number);
  • Your financial information to facilitate a transaction (e.g., your bank account information);
  • Transaction-related details such as amount paid or received for products or services and the shipping address.
• Information that helps us authenticate you, verify your identity, and prevent fraud:
  • Your login and password details, your security questions and answers, as well as your voiceprint;
  • Your residential address, date of birth and IP address;
  • Documents that assist us in verifying your identity (e.g., proof of residential address, an original, scanned or photographed image of your government-issued photo identification document, or an image of your face that you provide through a mobile app or computer webcam (i.e., a selfie)).
• Information that helps us comply with anti-money laundering regulations:
  • Your occupation, employment history and documents related to your source of funds or source of precious metals.
• We may collect personal information about you through third party service providers, publicly available records, or any other source that we deem appropriate.
• We may collect personal information about you when you do not 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.

Retail store visitors: We operate video surveillance in store for security and operational purposes, for example, to help us improve our customers' shopping experiences.

Call recordings, copies of chats and emails: We record telephone calls and keep copies of emails and chats made or received by our employees and agents for quality assurance, training and security purposes.

General: We may collect your name, email and phone number if you contact our customer service department, post a review or comment on one of our social media pages, post other user-generated content on one of our websites or mobile services, or participate in a contest, promotion or survey.

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 corporate site. 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, you warrant that you have obtained the necessary consent from such individual 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 set forth in this Privacy Policy.

How we share your personal information

We may disclose and share your personal information with selected third parties including:

• affiliates, business partners, joint marketers, suppliers, sub-contractors and agents for the performance of any contract we enter into with them or you;
• advertisers and advertising networks solely to select and serve relevant advertisements to you and others;
• analytics and search engine providers that assist us in the improvement and optimization of our sites and apps;
• risk management service providers that assist us in prevention and detection of fraud and in compliance of regulatory obligations;
• collection agencies that assist us in retrieving debts and locating hard to find customers who have holdings;
• governments, courts, regulators and law enforcement authorities, including those outside your country of residence, upon demonstration of lawful authority;
• to allow us to pursue available remedies or limit the damages that we may sustain.

We may transfer your personal information to a third-party service provider for processing and storage. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our services you consent to the transfer of information to countries outside of Canada, which may have different data protection rules. In the event that 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.

In the event that all or a part of our business is merged, sold or reorganized (including transfers made as a part of insolvency or bankruptcy proceedings), personal information about you could be shared with the successor business. We will make reasonable efforts to help ensure that any successor treats your information in accordance with this Privacy Policy.

How we protect your personal information

We adhere to the highest security measures to ensure your personal information is protected against theft, loss, and corruption, and against the misuse and alteration of any customer data stored on our servers. We only use PCI Compliant version of the Transport Layer Security (TLS) protocol for transferring credit card information across the internet. All our employees and agents are aware of our security policies. Your personal information is made available only to selected employees and agents who require the information to carry out contractual obligations with you. However, when you access your account via a public or unsecured computer terminal or if you choose to share your login credentials ("Electronic Identification Information"), we cannot guarantee the security of your account. It is your obligation to ensure that your electronic identification information is kept secret.

Our sites and apps may contain links or refer you to other websites. Those other websites may be operated by other companies affiliated with us or by third party companies not affiliated with us. We are not responsible for the privacy and security policies of those other websites.

Your choices with regards to your personal information

Depending on the services you use and the sensitivity of the information, we may obtain your consent in different ways. Express consent may be obtained verbally, online, or in writing. Implied consent may be obtained through your use of our sites or apps, or when you approach us to obtain information on our products and services. Generally, we will seek consent to collect, use and disclose personal information at the same time as when we collect the information. In some circumstances, we may identify a new purpose and seek consent to use and disclose personal information after it has been collected. You can also give consent through an authorized representative, such as a legal guardian or a person with a Power of Attorney. This may be necessary, for example, if we cannot obtain express consent from an individual who is a minor (i.e., someone who is under the age of 18), seriously ill, or mentally incapacitated.

With regards to the information we collect:

Choices related to your personal information

• If you have an account with us, you may access and update your personal information through your online account. You may also request to update your personal information by calling our customer service department at 1-877-775-4826. It is your sole responsibility to ensure that your personal information is accurate and up to date.
• You may decline to provide personal information when we request it; however, your decision may prevent us from providing certain services or all of the services to you.

Choices relating to cookies

• You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you to delete, disable, or block certain cookies.

Choices relating to communication

• Marketing: We may send you marketing content about our sites, services, products, as well as the products and services of unaffiliated third parties through various communication channels, for example, email, text, pop-ups, push notifications and messaging applications.  You may opt out of these marketing communications by following the instructions in the communications you receive. If you have an account with us, you may also adjust your communication preferences in your account settings. For messages sent via push notifications, you may manage your preferences in your device. You may also request changes to your communication preferences by calling our customer service department at 1-877-775-4826.
• Informational and other: We will send communications to you that are required or necessary to send to users of our services, notifications that contain important information, and other communications that you request from us. You may not opt out of receiving these communications or adjust the media and format through which you receive these notices.

How to be informed about our Privacy Policy changes

We may change our Privacy Policy from time to time and without prior notice to you. The date of the last update is provided at the beginning of this Privacy Policy. Any changes will become effective upon being posted on our sites. Use of 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.

How to contact us

If you have any questions about this policy, you can contact us at:

Kitco Metals Inc.

Attention: Customer Service Department

620 Cathcart Street, Suite 900
Montreal, Quebec, H3B 1M1
privacy@kitco.com
1-877-775-4826