Privacy Policy

Current pre-launch scope

TipGoldVault is currently operating a pre-launch website and waitlist only.

The current website and waitlist do not provide a customer account or permit you to purchase, sell, store or take delivery of bullion. Joining the waitlist does not create ownership of any gold or silver.

This Privacy Policy is limited to the personal information handled in connection with the current website, waitlist, referrals, website analytics, advertising and related pre-launch communications.

TipGoldVault’s contemplated future paid service is expected to involve additional activities and service providers. Before materially broader categories of personal information are collected for that service, we expect to update our privacy disclosures and provide the agreements and notices applicable to the paid service.

Eligibility

The waitlist is currently intended only for individuals who:

• are 19 years of age or older;
• reside in Canada; and
• do not reside in Quebec.

The website and waitlist are not directed to minors.

Personal information we collect

We collect personal information in several ways.

Information you provide directly

When you join the waitlist, we currently request:

• your first name; and
• your email address.

We may also collect information you voluntarily provide when you contact us, ask a question, make a privacy request, report a problem or otherwise communicate with us.

The current waitlist does not collect payment, banking or identity-verification information.

Waitlist and referral information

In connection with the waitlist, we may process information such as:

• your waitlist registration and status;
• referral, attribution and referral-status information;
• information reasonably necessary to validate registrations and referrals and prevent misuse;
• consent status where an optional consent is offered; and
• unsubscribe and suppression status.

A displayed waitlist position or referral event is not necessarily final and may be subject to validation under the Website & Waitlist Terms of Use.

If a referral-credit programme is introduced, we may use information reasonably necessary to determine referral eligibility and administer the programme. Before materially broader customer or transaction information is collected or used for the future paid service, we expect to update this Privacy Policy and provide the applicable customer privacy disclosures.

Information collected when you use the website

Depending on your device, browser, settings and privacy choices, we and our service providers may collect technical and usage information such as:

• IP address;
• browser type and version;
• device type and device information;
• operating system;
• network information;
• approximate location derived from technical information, where applicable;
• referring URL or source;
• pages viewed;
• links and website features used;
• timestamps;
• cookie or similar technology identifiers;
• analytics identifiers;
• advertising identifiers;
• campaign and attribution information; and
• other technical information reasonably generated when a browser communicates with a website.

Our website analytics may measure page views and interactions with forms, calculators, demonstrations and other website features.

Marketing and communications information

Where applicable, we may maintain information about:

• whether you have consented to receive commercial electronic messages;
• email delivery, opens, clicks and other campaign engagement information made available by our providers;
• waitlist and campaign list or segment membership;
• communications sent to you;
• unsubscribe or withdrawal requests;
• suppression status; and
• information reasonably necessary to respect your communication choices.

We may use service providers to support waitlist administration, email delivery and marketing communications.

Cookies and similar technologies

We use or may use cookies, browser storage, pixels, tags and similar technologies.

We divide these technologies into three categories:

• Necessary technologies support functions that are reasonably required to operate or secure the website, remember privacy choices, process a requested waitlist action or provide similar core functionality.
• Analytics technologies help us understand how visitors use the website, measure website interactions, identify errors and improve performance and content.
• Advertising technologies help us measure advertising, attribute campaigns, build or match audiences where permitted, retarget advertising, optimise campaigns and understand advertising effectiveness.

Analytics technologies remain disabled until you enable Analytics.

Advertising technologies remain disabled until you enable Advertising.

You may leave optional technologies disabled without preventing the basic website from operating. You can later change your decision through the Cookie Settings control.

We periodically review the configuration so that our disclosures and technical behaviour remain aligned.

Google Analytics

Where you enable Analytics, we use Google Analytics to understand website usage and interactions. Google Analytics may process technical, browser, device, page-view, interaction and analytics-identifier information.

Google provides additional information about how it processes information from websites and apps that use its services.

Advertising technologies

Where you enable Advertising, we may use advertising technologies to measure advertising effectiveness, attribution and campaign performance.

Depending on the technology and configuration, advertising providers may receive technical, browser, device, network, page, interaction and advertising information.

Where identifiers are used for permitted advertising matching, they may be transformed before transmission. Transformation does not necessarily make information anonymous where it remains capable of being associated with an individual or account.

We do not send payment, banking or identity-verification information through the current waitlist for advertising purposes.

Advertising audience matching

We do not currently use known waitlist contact information for advertising-platform audience matching.

If this changes, we will update our privacy disclosures and obtain any consent required by applicable law before using personal information for that purpose.

Why we use personal information

Subject to applicable law, we may collect, use and disclose personal information for purposes including:

• operating, maintaining and securing the website;
• processing and administering waitlist registrations;
• providing the waitlist and referral experience requested by a participant;
• validating registrations, queue information and referrals;
• administering and validating referral credits where the referral-credit programme is made available;
• preventing bots, duplicate registrations, fraud, manipulation and other abuse;
• communicating about waitlist administration;
• responding to questions and support requests;
• sending commercial electronic messages where we have an appropriate legal basis;
• administering communication preferences and unsubscribes;
• measuring website use and performance where permitted;
• improving website design, content and features;
• troubleshooting technical problems;
• measuring and improving advertising effectiveness where permitted;
• advertising audience functions where separately authorised and permitted by law;
• investigating suspected violations of our Terms or unlawful conduct;
• protecting TipGoldVault, our users, service providers and others;
• complying with legal, regulatory, court or governmental requirements;
• establishing, exercising or defending legal rights;
• enforcing our Website & Waitlist Terms of Use; and
• evaluating or completing a proposed or completed financing, reorganisation, merger, acquisition, sale or other corporate transaction where permitted by applicable law.

We will not use personal information for a materially new purpose that requires additional consent without obtaining that consent where required by law.

Consent and other lawful authority

We obtain consent where required by applicable privacy law.

The appropriate form of consent depends on the context, sensitivity of the information, reasonable expectations and the nature of the collection, use or disclosure.

Certain information is reasonably necessary to provide a function you request. For example, we need an email address to administer an email-based waitlist. If you withdraw consent to a use that is necessary to provide the waitlist, we may no longer be able to maintain your waitlist participation.

These choices remain distinct. In particular:

• marketing consent is separate from acceptance of the Website & Waitlist Terms and is presented separately at the point of collection;
• Analytics and Advertising technology choices are optional;
• refusing an optional Analytics or Advertising technology choice does not by itself prevent you from joining the waitlist.

There are also circumstances in which applicable law permits or requires us to collect, use or disclose personal information without consent.

Waitlist administration and commercial electronic messages

Joining the waitlist requests communications reasonably necessary to administer the waitlist, such as registration confirmation, a requested referral link or status information, material operational changes and security-related notices.

That administrative relationship is not intended to operate as blanket consent to marketing.

Where an electronic message is a commercial electronic message for purposes of Canada’s anti-spam legislation, we will rely on an applicable consent, exception or other lawful basis and will provide required sender identification and unsubscribe functionality.

If you separately consent to TipGoldVault marketing, you may withdraw that consent at any time by using the unsubscribe mechanism in a marketing email or by contacting us.

We may retain limited suppression information after an unsubscribe so that we can continue to honour it.

Service providers and disclosures

We may use third parties to perform functions on our behalf. Depending on the function and your choices, those parties may process personal information.

Current or relevant categories include providers supporting:

• website hosting and cloud infrastructure;
• waitlist and referral management;
• email delivery;
• customer-relationship and marketing systems;
• website analytics;
• advertising and attribution;
• security and fraud prevention; and
• professional legal, accounting and advisory services.

Service providers may change over time. We seek to limit personal information provided to a service provider to what is reasonably appropriate for the service or permitted purpose.

Certain advertising providers may process information under their own terms and privacy practices for purposes described in this Policy.

We do not sell personal information.

We do not rent or sell our waitlist list to unrelated marketers.

We may otherwise disclose personal information:

• at your direction or with your consent;
• to service providers and contractors;
• where permitted in connection with a business transaction;
• to professional advisers subject to appropriate obligations;
• where reasonably necessary to investigate fraud, security incidents, abuse or unlawful activity;
• to comply with applicable law, legal process, court orders or governmental requests;
• to protect legal rights, safety or property; or
• in another circumstance permitted or required by law.

Cross-border processing

TipGoldVault is based in Canada, but some of our service providers may process or store personal information outside Canada, including in the United States.

As a result, personal information may be subject to the laws of another jurisdiction and may be accessible to courts, law-enforcement agencies, regulators or governmental authorities in that jurisdiction where lawful under the applicable local law.

We remain responsible for personal information under our control as required by applicable Canadian privacy law and use contractual, organisational and other measures that we consider appropriate for the circumstances.

Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected or another purpose permitted by law, taking into account legitimate legal and business requirements.

For waitlist information, this may include the period during which:

• you remain on the waitlist;
• we reasonably expect to communicate with you about the requested waitlist or launch;
• a referral, referral-credit or programme record remains relevant;
• information is reasonably required to prevent fraud or abuse;
• a legal claim, investigation or legal hold is relevant; or
• applicable law requires or permits retention.

If you ask us to delete your waitlist information, we will assess and act on the request in accordance with applicable law. We may retain limited information where reasonably necessary for legal, security, evidentiary or suppression purposes.

For example, after an unsubscribe we may retain a minimal suppression record so that we do not inadvertently add the address back to marketing.

Information may also remain for a limited period in backups or archival systems before being overwritten or securely deleted in the ordinary course.

When personal information is no longer reasonably required for an authorised purpose and there is no legal or business need to retain it, we will destroy or de-identify it as required by applicable law.

Security

We use administrative, technical and physical safeguards that we consider reasonable and appropriate having regard to the nature of the personal information and the circumstances.

These measures may include access controls, provider-management practices, authentication, monitoring, secure system configuration and other measures appropriate to the service involved.

No Internet transmission, website, electronic storage system or security measure is completely secure. We therefore cannot guarantee absolute security.

If a privacy or security incident occurs, we will investigate and take steps appropriate to the circumstances, including notification to affected individuals or regulators where required by applicable law.

Your privacy choices and rights

Depending on applicable law and the circumstances, you may have rights to:

• request access to personal information about you under our control;
• request correction of inaccurate or incomplete information;
• withdraw consent, subject to legal or contractual restrictions and reasonable notice;
• ask us to delete information that is no longer required;
• ask questions about our collection, use or disclosure of personal information;
• raise a concern or complaint about our privacy practices;
• change optional cookie and tracking choices; and
• unsubscribe from marketing communications.

Some requests are subject to legal exceptions. For example, we may be unable to provide access to information protected by legal privilege, information that would reveal another person’s personal information where it cannot reasonably be severed, or information that applicable law permits or requires us to withhold.

A request to delete information is also not an absolute right to deletion in every circumstance. We may retain information where law permits or requires it, including for legal claims, fraud prevention, security or suppression.

To exercise a privacy right, contact our Privacy Officer using the details below. We may take reasonable steps to verify your identity before completing a request.

We will respond within the time required by applicable law.

Children and minors

The waitlist is intended for people aged 19 or older.

We do not knowingly intend to collect waitlist registrations from minors. If you believe a person under 19 has submitted personal information to the waitlist, contact our Privacy Officer so that we can review the matter and take appropriate action.

Third-party sites and services

The website may contain links to websites, social-media services or other third-party services that we do not control.

Their privacy practices are governed by their own policies and terms. This Privacy Policy does not govern independent third-party websites merely because our website links to them.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time as our website, technology, providers, legal obligations or pre-launch activities change.

The “Last Updated” date will identify the most recent version.

If a change materially alters how we collect, use or disclose personal information in a way requiring additional notice or consent, we will provide that notice or obtain that consent where required by applicable law.

Before TipGoldVault launches a materially broader paid bullion service and begins collecting materially expanded categories of customer information, we expect to update our privacy disclosures and applicable customer documentation.

Privacy Officer

Questions, complaints and privacy requests may be directed to: