1. Introduction

Midas Letter Inc. (operating as “ML Platforms Inc.” for MidasLetter.ca and “Midas Letter USA LLC” for MidasLetter.us) (collectively, “we,” “us,” “our,” or “Company”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our websites located at MidasLetter.ca and MidasLetter.us (collectively, the “Websites”), including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Services”).

This Privacy Policy is designed to help you understand:

• What personal information we collect
• How we use and share your information
• Your privacy rights and choices
• How to contact us with privacy questions

2. Applicability and Scope

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our Websites or Services.

This Privacy Policy applies to California residents and incorporates the requirements of the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). California residents have specific rights regarding their personal information, which are described in Section 6 of this policy.

While this policy primarily addresses CCPA/CPRA compliance for California residents, we are committed to respecting the privacy of all users of our Websites and Services, regardless of location.

3. Categories of Personal Information We Collect

Over the past 12 months, we have collected the following categories of personal information from consumers:

A. Identifiers

• Real name
• Alias or username
• Email address
• Telephone number(s)
• Residential address
• Mailing address
• Unique identifiers for customer service and account management
• IP address
• Device identifiers and cookie identifiers

B. Commercial Information

• Purchase history and records
• Products or services purchased or considered
• Subscription information
• Payment transaction details
• Financial information related to our Services

C. Biometric Information

• We do not currently collect biometric information for identification purposes.

D. Internet or Other Electronic Network Activity

• Browsing history on our Websites
• Search history on our Websites
• Interaction with website content and features
• Website usage data and analytics
• Clickstream data
• Information about your interaction with our advertisements
• Social media activity related to our Services
• Performance data

E. Geolocation Data

• Approximate location based on IP address
• Country and state/province of access
• City-level location information

F. Sensory Information

• We do not routinely collect audio, electronic, visual, or similar information.

G. Professional or Employment-Related Information

• Job title and employment history
• Professional affiliations

H. Education Information

• Educational background
• Professional credentials
• Educational history and credentials
• Student status

I. Inferences Drawn from Personal Information

• Profiles reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
• Marketing preferences and interests
• Investment preferences and risk profiles
• Communication preferences

J. Protected Classification Information

• Age or date of birth
• Gender
• Marital status
• Race, ethnicity, or national origin (only when voluntarily provided)
• Religious or philosophical beliefs (only when voluntarily provided)
• Sexual orientation (only when voluntarily provided)

We collect this information only when voluntarily provided by you, and we do not intentionally collect sensitive personal information unless it is necessary for the specific services you request.

4. Sources of Personal Information

We collect personal information from the following sources:

A. Information You Provide Directly

• Registration forms and account creation
• Contact forms and inquiry submissions
• Subscription and newsletter sign-ups
• Payment and billing information
• Customer support communications
• Surveys, contests, and feedback forms
• Social media profile information you share with us
• Comments, posts, or other content you create or upload
• Job applications and professional inquiries

B. Automatic Collection Technologies

• Cookies and similar tracking technologies
• Web beacons and pixel tags
• Server logs and analytics tools
• Browser type and operating system information
• Referring and exit page information
• Click-through data
• Google Analytics and similar analytics platforms
• Advertising network data

C. Third-Party Sources

• Marketing partners and data brokers
• Social media platforms
• Financial institutions
• Public records
• Other websites and services you link to our Services from
• Third-party analytics providers
• Advertising networks and technology partners
• Business partners and service providers

D. Inferred Information

• Data derived from your online behavior and interactions
• Inferences about your interests and preferences
• Aggregated and anonymized data

5. Purposes for Collecting Personal Information

We collect and use personal information for the following purposes:

A. Service Delivery and Performance

• Providing, maintaining, and improving our Websites and Services
• Processing transactions and sending related information
• Creating and managing your account
• Delivering content, products, and services you request
• Responding to your inquiries and requests
• Providing technical support and customer service

B. Marketing and Communications

• Sending promotional emails, newsletters, and marketing communications
• Customizing and personalizing your experience
• Creating targeted marketing campaigns

C. Business Operations

• Conducting market research and analytics
• Performing analytics on user demographics and behavior
• Analyzing trends and usage patterns
• Measuring marketing effectiveness
• General business administration
• Auditing and accounting purposes
• Protecting the rights, property, and safety of our Company, our users, and the public

D. Legal and Regulatory Compliance

• Compliance with legal obligations
• Defending against legal claims
• Enforcing our terms and conditions
• Complying with laws, regulations, and legal processes
• Responding to government and law enforcement requests
• Maintaining records for legal requirements
• Establishing, exercising, or defending legal claims
• Fraud prevention and security measures

E. Advertising and Analytics

• Developing and displaying targeted advertisements
• Creating audience segments for advertising purposes
• Conducting analytics and performance analysis
• Understanding user preferences and interests
• Optimizing website functionality and user experience

6. California Consumer Privacy Rights

California residents have the following rights under the CCPA and CPRA:

A. Right to Know

You have the right to request that we disclose to you:

• The categories and specific pieces of personal information we have collected about you
• The categories of sources from which we collected your personal information
• Our purposes for collecting your personal information
• The categories of third parties with whom we share your personal information
• The categories of personal information that we have sold or disclosed for business purposes

B. Right to Delete

Subject to certain exceptions, you have the right to request the deletion of personal information we have collected from you. However, we may retain certain information as permitted by law, including:

• Information necessary to complete the transaction for which it was collected
• Information necessary to provide Services you have requested
• Information necessary to comply with legal obligations
• Information we use for security and fraud prevention purposes

C. Right to Opt-Out of Sales and Sharing

You have the right to opt-out of:

• The “sale” of your personal information to third parties
• The “sharing” of your personal information for cross-context behavioral advertising
• The use of your personal information for targeted advertising

Important Disclosure: We do not currently sell or share personal information for cross-context behavioral advertising purposes. However, we may use analytics and advertising technologies that could be deemed to constitute “sales” or “sharing” under the CCPA/CPRA. If you wish to opt-out, please see Section 7 for instructions.

D. Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing.

E. Right to Limit Use

You have the right to request that we limit our use of your personal information to purposes necessary to:

• Perform the services or provide the goods reasonably expected by an average consumer
• Detect and prevent fraud
• Comply with legal obligations
• Allow internal uses reasonably aligned with your reasonable expectations
• Detect and resolve security incidents

F. Right to Access

You have the right to access specific pieces of personal information we have collected about you in a portable and readily useable format.

G. Protection Against Discrimination

We will not discriminate against you for exercising your privacy rights. We will not:

• Deny you goods or services
• Charge different prices or rates
• Provide different quality of service
• Suggest that you will receive different prices, rates, or quality of service

Any financial incentive programs we offer are reasonably related to the value of the data we collect.

H. Right to Non-Discrimination for Privacy Choices

You have the right not to be discriminated against by us for exercising any of your CCPA/CPRA rights, provided that we may offer financial incentives that are reasonably related to the value of personal information disclosed.

7. Exercising Your California Privacy Rights

A. Submitting a Request

To exercise any of your California privacy rights, please submit a request by:

• Email: privacy@midasletter.ca or privacy@midasletter.us
• Mailing Address:
  ML Platforms Inc. / Midas Letter USA LLC
  Privacy Department
  675 Cochrane Drive,
  East Tower 6th Floor
  Markham, Ontario
  L3R 0B8

Authorized Agent: If you are an authorized agent acting on behalf of a California resident, you may submit a request on their behalf. We will require verification of your authority to act on their behalf.

B. Verification Process

To verify your identity and process your request, we will request information sufficient to reasonably verify you are the California resident about whom we collected personal information. This may include:

• Matching information you provide with information we have in our records
• Asking you to sign a declaration under penalty of perjury
• In certain cases, requesting government-issued identification

If we cannot verify your identity with reasonable certainty, we may deny your request.

C. Response Timeline

We will respond to verifiable consumer requests within 45 calendar days of receipt. If we need additional time, we will inform you of the reason and the extension period (up to 45 additional days).

D. Response Format

• For “right to know” requests: We will provide information in a portable and readily useable format that allows you to transmit the information to another entity without hindrance.
• For “right to delete” requests: We will delete personal information from our records and direct our service providers to do the same, unless an exception applies.
• For “right to correct” requests: We will take reasonable steps to correct inaccurate information.

E. Frequency Limitations

We are not required to honor a consumer request to know, delete, or correct personal information more than twice in a 12-month period.

8. Disclosure of Personal Information to Third Parties

Over the past 12 months, we have disclosed the following categories of personal information to the categories of third parties indicated:

A. Service Providers and Business Partners

We disclose identifiers, commercial information, internet activity, and other information to:

• Payment processors and financial institutions
• Email and marketing service providers
• Analytics and data analytics providers
• Hosting providers and cloud service providers
• IT and security service providers
• Customer relationship management (CRM) systems
• Advertising networks and marketing platforms
• Social media platforms
• Legal and professional service providers

B. Advertising Partners and Networks

We disclose identifiers, commercial information, internet activity, geolocation data, and inferences to:

• Advertising networks and exchanges
• Social media advertising platforms
• Marketing and retargeting services
• Audience measurement and analytics providers

C. Business Transfers

In the event of a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding, your personal information may be transferred as part of that transaction. We will provide notice before your personal information becomes subject to a different privacy policy.

D. Legal Compliance and Protection

We may disclose personal information when required by law or when we believe in good faith that disclosure is necessary to:

• Comply with applicable laws, regulations, or legal processes
• Enforce our Terms of Service and other agreements
• Protect the security or integrity of our Services
• Protect the rights, privacy, safety, and property of our Company, users, or the public
• Prevent or investigate possible wrongdoing

E. Non-Sale Disclosures for Business Purposes

We have disclosed the following categories of personal information for business purposes (not for sale or sharing):

• Identifiers
• Commercial information
• Internet or electronic network activity
• Geolocation data
• Professional or employment-related information
• Inferences

We have not sold or shared any personal information in the past 12 months.

9. Retention of Personal Information

We retain personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods vary depending on the context of the processing and our legal obligations. Generally:

• Account information is retained while your account is active and for a reasonable period afterward
• Transaction information is retained for accounting and legal purposes as required by law
• Marketing information is retained until you unsubscribe
• Communications and support records are retained for a reasonable period to provide support services
• Analytical data may be retained and aggregated for business intelligence purposes
• Information subject to legal holds is retained for the duration of applicable legal proceedings

When information is no longer necessary for its original purpose, we will delete or anonymize it, except where retention is required by law or for legitimate business purposes.

10. Data Security

We implement comprehensive administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive data in transit and at rest
• Secure server infrastructure and firewalls
• Regular security assessments and penetration testing
• Access controls and authentication mechanisms
• Employee training on data privacy and security
• Incident response procedures
• Third-party security audits and certifications

However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal information using reasonable security measures, we cannot guarantee absolute security. You use our Services at your own risk.

11. Cookies and Similar Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to:

• Remember your preferences and settings
• Understand how you use our Services
• Deliver targeted advertisements
• Analyze performance and usage trends
• Prevent fraud and enhance security
• Improve user experience

A. Types of Cookies

• Essential Cookies: Necessary for basic functionality
• Performance Cookies: Analytics and website optimization
• Marketing Cookies: Advertising and audience segmentation
• Social Media Cookies: Integration with social media platforms

B. Cookie Management

Most web browsers allow you to control cookies through browser settings. You can:

• Delete cookies stored on your device
• Block all cookies or block third-party cookies
• Receive notice when a cookie is set

Please note that disabling cookies may affect the functionality of our Services.

C. Do Not Track

Some browsers include a “Do Not Track” feature. Our Services do not currently respond to Do Not Track signals.

12. Opt-Out Mechanisms

A. Email Communications

To opt-out of promotional emails and marketing communications, you can:

• Click the “unsubscribe” link in any email we send you
• Email us at privacy@midasletter.ca or privacy@midasletter.us
• Update your communication preferences in your account settings

B. Opt-Out of Sales or Sharing

To submit a request to opt-out of the sale or sharing of your personal information, please:

• Click the “Do Not Sell or Share My Personal Information” link on our Websites
• Submit a request through our privacy request form
• Contact us at the email or mailing address provided in Section 7

C. Targeted Advertising

To opt-out of targeted advertising, you can:

• Adjust your advertising preferences in your account settings
• Use the NAI Opt-Out tool at www.networkadvertising.org
• Use the DAA Opt-Out tool at www.aboutads.info
• Enable the Global Privacy Control signal in your browser or device
• Contact our Privacy Department

Please note that even if you opt-out, you will still receive advertisements; they simply will not be targeted based on your interests and behavior.

13. Third-Party Links and Services

Our Websites may contain links to third-party websites, applications, and services that are not operated by us. This Privacy Policy does not apply to third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services before providing your personal information or using their services.

14. Children’s Privacy

Our Websites and Services are not intended for children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly.

For California residents under 18 (but at least 13 years old), we provide additional privacy protections and restrict our use of their personal information.

15. International Data Transfers

If you are located outside of California or the United States, please note that our Websites and Services are governed by United States law. By using our Services and providing your personal information, you consent to the transfer of your personal information to, and processing in, the United States, which may not provide the same level of privacy protection as your jurisdiction.

16. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our Websites with a revised “Last Updated” date. Your continued use of our Websites and Services following the posting of changes constitutes your acceptance of those changes.

We will update this policy at least once every 12 months.

17. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy, your personal information, or our privacy practices, please contact us:

Midas Letter Inc. / ML Platforms Inc.

• Email: privacy@midasletter.ca
• Website: MidasLetter.ca

Midas Letter USA LLC

• Email: privacy@midasletter.us
• Website: MidasLetter.us

Mailing Address:
ML Platforms Inc. / Midas Letter USA LLC
Privacy Department
675 Cochrane Drive,
East Tower 6th Floor
Markham, Ontario
L3R 0B8

Response Time: We will respond to privacy inquiries within 30 business days.

18. California Attorney General

If you have concerns about our privacy practices or believe we have violated your privacy rights, you may also contact the California Attorney General:

California Attorney General
P.O. Box 944255
Sacramento, CA 94244-2550
Phone: (916) 322-3360
Website: www.oag.ca.gov

19. Additional Information for California Residents

A. Data Minimization

We are committed to collecting, using, retaining, and sharing personal information in a manner that is reasonably necessary and proportionate to achieve the purposes for which the information was collected or processed.

B. Right to Opt-Out of Automated Decision-Making

To the extent we use automated decision-making technologies that significantly affect your rights, you have the right to opt-out of such processing and request human review. Please contact us for details.

C. Sensitive Personal Information

We limit our collection and use of sensitive personal information (including Social Security numbers, financial account information, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, genetic data, health data, and sex life or sexual orientation information) to purposes necessary to provide the services you request or as otherwise permitted by law.

D. Consumer Acknowledgment

By using our Websites and Services, you acknowledge that you have read and understand this Privacy Policy.

This Privacy Policy was designed to be CCPA and CPRA compliant as of December 17, 2025, in accordance with California Consumer Privacy Act and California Privacy Rights Act requirements.