Kitco Privacy Policy

Updated: August 25, 2022

Your trust means everything to us.

And it always has. Our commitment to integrity has always been an important value for us. Part of that commitment includes being transparent with how we use your information, and how we protect your right to privacy.

This Privacy Policy explains how we process any personal information collected on the Kitco platform. It also tells you what choices you have with respect to that information. The policy has a serious tone that reflects the importance of the issue and is in line with federal regulations. If you have any questions, feel free to reach out to us anytime at privacy@kitco.com.

Table of contents:

• Introduction
• Information we collect and why we collect it
• How we share your personal information
• How we protect your personal information
• Your choices with regards to your personal information
• How to stay informed on Privacy Policy changes
• How to contact us

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 services. By visiting our sites and apps, using or applying for a Kitco account, and buying or selling any and all products with us, you are consenting to agree to our Privacy Policy.

Information we collect and why we collect it

Depending on the Kitco products or services you use, the following information is collected from you:

• All visitors to our sites or users of our apps: If you're simply browsing our sites or apps and don't have any accounts or subscriptions with us yet, we don't collect, capture, or retain any of your personal information. We only collect information about:
  • Your 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 taken through our sites or apps
  • Cookies and other information about your browsing session
  A cookie is a piece of data from a website that's stored within a web browser for the website to retrieve at a later time. Cookies are used to tell the server that a visitor has returned to a particular website. They can contain information that can be used to track other pages you've visited, but cannot read data off your hard disk or read cookie files created by other websites. You can refuse cookies by turning them off in your browser, and you don't need them turned on to use our sites, apps, or services.
  
  We use this anonymous information to remember your preferences and provide you with relevant and personalized advertising. We may also use and share the information on 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 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:
  
  We may 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, phone number, fax number)
  • Your financial information (bank account) to facilitate a transaction
  • Transaction-related details such as amount paid or received for products or services, the shipping address
  For security purposes, we collect information that helps us authenticate and verify your identity to prevent fraud or other suspicious activity. The information we collect may include:
  
  
  • Your login and password details, your security questions, and answers
  • Your residential address, year 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 provided through a mobile app or computer webcam (i.e., a selfie))
  • A digital representation of your voice (only for customers that have opted-in to this service), that's inaudible to the human ear but can be recognized by a computer
  We may collect information that helps us comply with anti-money laundering regulations:
  
  
  • Your occupation, employment history and any 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 other sources we consider appropriate.
  • We may collect 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.
• 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 and emails: For quality assurance, training, and security purposes, telephone calls are recorded. We also keep additional copies of emails and chats made or received by our employees.
• General: We may collect your name, email and phone number if you contact our customer experience team, post a review or comment on our various social media channels, post other user-generated content on one of our sites 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.
• Visitors to third party websites: Our sites and apps may contain links or references to websites operated by other companies. Please keep in mind that when you provide information to us on a third-party site or platform, the information may be separately collected by that third-party site or platform. We are not responsible for the privacy and security policies of those other websites.
  
  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.
  
  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.

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
• 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 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
• Governments, courts, regulators and law enforcement authorities, including those outside your country of residence, upon demonstration of lawful authority.

Your 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 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.

If all or part of Kitco is merged, sold or reorganized (including transfers made as part of insolvency or bankruptcy proceedings), your personal information could be shared with the successor business. Please rest assured we'll make all reasonable efforts to ensure the successor treats your information with the same respect and consideration as we do.

How we protect your personal information

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.

Your choices with regards to your personal information

Depending on the services you use and the sensitivity of your information, we may obtain your consent to share 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 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.

Choices related to your personal information

We encourage you to ensure that your information is as accurate and up to date as possible. If you have an account with us, you can access and update your information online or call our customer experience team at 1 877-775-4826 to request your personal information be updated. You aren't required to provide personal information when requested, however this may prevent us from providing certain services to you.

Choices related to cookies

Your browser or internet device may allow you to delete, disable, or block certain cookies.

Choices related to communication

• Marketing: 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.
• Informational and other: 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.

How to stay informed on Privacy Policy changes

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 website. 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 policy.

How to contact us

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

Kitco Metals Inc.
Attn: Customer Experience Department
620 Cathcart Street, Suite 900
Montreal, Quebec, H3B 1M1

privacy@kitco.com

1 877-775-4826