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Privacy Policy

Effective September 7, 2026 · Version 2026-09-07

Effective Date: September 7, 2026

The Speculator Intelligence Inc. (“The Speculator,” “we,” “us,” or “our”) respects your privacy and is committed to responsibly managing personal information collected through The Speculator, including thespeculator.ca and any related websites, applications, tools, accounts, communications and services that we operate (collectively, the “Platform”).

This Privacy Policy explains:

  • what personal information we may collect;
  • why we collect it;
  • how we use it;
  • when it may be disclosed;
  • how it is protected and retained;
  • the choices and rights available to users; and
  • how to contact us about privacy matters.

By accessing or using the Platform, you acknowledge the practices described in this Privacy Policy.

Where consent is required by applicable law, we will obtain consent appropriate to the circumstances.

1. WHO WE ARE

The Platform is operated by:

The Speculator Intelligence Inc.

Ontario, Canada

Privacy inquiries may be directed to:

admin@thespeculator.ca

The Speculator Intelligence Inc. is responsible for personal information under its control and has designated responsibility for overseeing its privacy practices.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information that we collect, use or disclose in connection with the Platform.

“Personal information” generally means information about an identifiable individual, subject to the definitions and exclusions established by applicable privacy law.

This Privacy Policy does not govern information about corporations or other organizations where that information does not constitute personal information under applicable law.

It also does not govern the independent privacy practices of third-party websites, issuers, regulatory authorities, market-data providers, news organizations or other services that may be linked to or referenced through the Platform.

3. INFORMATION WE MAY COLLECT

Depending on how you interact with The Speculator, we may collect the following categories of information.

A. Account Information

If you create an account, we may collect information such as:

  • your email address;
  • account identifier;
  • authentication information;
  • account creation date;
  • login information;
  • account status; and
  • information required to maintain or secure your account.

Passwords may be processed and stored through our authentication service provider using appropriate security mechanisms.

We do not intend to store passwords in readable plain-text form.

B. User Preferences and Platform Activity

When you use Platform features, we may collect information associated with your account or session, including:

  • watchlists;
  • saved companies;
  • saved securities;
  • filters;
  • research preferences;
  • selected commodities;
  • saved searches;
  • alerts or notification preferences;
  • feature preferences; and
  • other settings or information you intentionally save through the Platform.

This information may be used to provide and personalize Platform functionality.

C. Technical and Device Information

When you access the Platform, certain technical information may be collected automatically.

This may include:

  • Internet Protocol (IP) address;
  • browser type;
  • operating system;
  • device type;
  • approximate geographic region derived from technical information;
  • referring webpage;
  • pages viewed;
  • date and time of access;
  • session information;
  • authentication events;
  • application events;
  • error logs;
  • security logs; and
  • other technical information associated with use of the Platform.

We may use this information to operate, secure, diagnose and improve the Platform.

D. Analytics Information

We may use analytics technologies to understand how users interact with the Platform.

Analytics information may include:

  • pages viewed;
  • features used;
  • session duration;
  • navigation paths;
  • approximate location;
  • device and browser information;
  • referral sources;
  • general interaction information; and
  • aggregated usage statistics.

We use analytics information to understand Platform usage, identify technical problems, improve features and make product decisions.

Where third-party analytics providers are used, those providers may process information in accordance with their own terms and privacy practices.

E. Cookies and Similar Technologies

The Platform may use cookies, local storage and similar technologies.

These technologies may be used to:

  • maintain user sessions;
  • keep users signed in;
  • remember preferences;
  • provide authentication;
  • maintain Platform security;
  • prevent fraud or abuse;
  • measure Platform usage;
  • understand navigation and performance; and
  • improve Platform functionality.

Some cookies or similar technologies may be essential to the operation of the Platform.

Others may relate to analytics or optional functionality.

Your browser may permit you to block or delete cookies. However, disabling essential cookies or storage technologies may prevent certain Platform features from functioning properly.

F. Communications

If you contact The Speculator, we may collect:

  • your email address;
  • your name, if provided;
  • the contents of your message;
  • attachments or information you voluntarily provide;
  • support requests;
  • error reports;
  • correction submissions; and
  • records of our correspondence with you.

We use this information to respond to inquiries, provide support, investigate reported issues and improve the Platform.

G. Information

You Voluntarily Provide

You may choose to provide information to us when:

  • submitting feedback;
  • reporting an error;
  • requesting a correction;
  • contacting support;
  • participating in a survey;
  • joining a waitlist;
  • requesting access to a feature; or
  • communicating with us for another purpose.

You should avoid submitting sensitive personal information unless it is reasonably necessary for the purpose of your communication.

4. INFORMATION WE DO NOT INTEND TO COLLECT

The Speculator is not designed to require users to provide highly sensitive financial or identity information merely to conduct investment research.

For the current free Platform, we do not intend to require information such as:

  • banking credentials;
  • brokerage passwords;
  • securities account passwords;
  • credit card numbers;
  • Social Insurance Numbers;
  • passport numbers; or
  • government-issued identity documents unless a future feature legitimately requires such information and appropriate notice and safeguards are implemented.

If paid services are introduced, payment information may be processed through a third-party payment provider rather than being directly stored by The Speculator.

This Privacy Policy will be updated where appropriate if our collection practices materially change.

5. HOW WE USE PERSONAL INFORMATION

We may use personal information for purposes including:

Providing the Platform To:

  • create and maintain accounts;
  • authenticate users;
  • provide watchlists and saved features;
  • maintain user preferences;
  • deliver requested Platform functionality; and
  • provide support.

Operating and Improving The Speculator

To:

  • understand how the Platform is used;
  • identify popular or underused features;
  • diagnose technical problems;
  • improve user experience;
  • develop new functionality;
  • test Platform changes;
  • monitor system performance; and
  • conduct internal analytics.

Security and Abuse Prevention

To:

  • authenticate users;
  • detect suspicious activity;
  • protect accounts;
  • prevent unauthorized access;
  • investigate misuse;
  • enforce our Terms of Use;
  • prevent fraud;
  • protect our infrastructure; and
  • maintain Platform security and integrity.

Communications

To:

  • respond to questions;
  • provide support;
  • communicate important account information;
  • send security notices;
  • notify users of material Platform changes;
  • respond to privacy requests; and
  • provide communications requested by users.

Legal and Compliance Purposes

To:

  • comply with applicable laws;
  • respond to lawful requests;
  • investigate legal claims;
  • protect our legal rights;
  • enforce agreements;
  • maintain required records; and
  • meet regulatory or legal obligations.

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

6. CONSENT

We seek consent for the collection, use and disclosure of personal information where required by applicable law. Consent may be express or implied depending on:

  • the sensitivity of the information;
  • the purposes for which it is collected;
  • the user's reasonable expectations; and
  • applicable legal requirements.

For example, if you provide your email address to create an account, we may use that email address as reasonably necessary to provide, authenticate, secure and administer that account.

Where appropriate, you may withdraw consent to certain uses of personal information by contacting us.

Withdrawal of consent may affect our ability to provide features that depend on the relevant information.

Withdrawal of consent does not affect uses or disclosures already lawfully made.

7. WHEN WE MAY DISCLOSE PERSONAL INFORMATION

We do not sell personal information.

We may disclose or make personal information available in the circumstances described below.

Service Providers

We may use third-party companies to help operate the Platform.

These may include providers of:

  • cloud hosting;
  • database infrastructure;
  • account authentication;
  • website hosting;
  • application infrastructure;
  • email delivery;
  • analytics;
  • cybersecurity;
  • monitoring;
  • error tracking;
  • customer support;
  • data storage; and
  • other technical services.

These providers may process personal information on our behalf where reasonably necessary to provide their services.

We seek to use service providers under arrangements appropriate to the nature of the information and services involved.

Legal Requirements

We may disclose information where we reasonably believe disclosure is required or permitted by law, including in response to:

  • court orders;
  • warrants;
  • subpoenas;
  • regulatory requirements;
  • lawful governmental requests; or
  • other legal processes.

Protection of Rights and Security

We may disclose information where reasonably necessary to:

  • investigate fraud;
  • investigate security incidents;
  • prevent abuse;
  • protect users;
  • protect The Speculator;
  • enforce our Terms of Use; or
  • establish, exercise or defend legal claims.

Business Transactions If The Speculator Intelligence Inc. becomes involved in a proposed or completed:

  • financing;
  • merger;
  • acquisition;
  • restructuring;
  • sale of assets;
  • corporate reorganization; or
  • similar transaction, personal information may be disclosed or transferred where permitted by applicable law and subject to appropriate confidentiality and privacy protections.

With Your Direction or Consent

We may disclose information where you direct us to do so or otherwise consent to the disclosure.

8. THIRD-PARTY SERVICE PROVIDERS AND INTERNATIONAL PROCESSING

The Speculator may use technology and service providers located in Canada, the United States or other jurisdictions.

As a result, personal information may be processed or stored outside your province or outside Canada.

When information is processed in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, governments, law-enforcement authorities or regulatory bodies in accordance with applicable law.

The Speculator remains responsible for personal information under its control as required by applicable privacy law and uses appropriate contractual, organizational or technical measures where appropriate for third-party processing.

For information about particular service providers involved in processing your information, you may contact:

admin@thespeculator.ca

9. GOOGLE ANALYTICS AND OTHER ANALYTICS SERVICES

Where enabled, The Speculator may use third-party analytics services, including technologies such as Google Analytics, to understand general Platform usage and performance. These technologies may collect information such as:

  • device information;
  • browser information;
  • approximate location;
  • pages visited;
  • referral information;
  • interactions with Platform features; and
  • session or usage information.

We use this information primarily to understand aggregate usage patterns and improve the Platform.

Where analytics technologies use cookies or similar identifiers, users may be able to manage those technologies through browser settings, cookie controls or tools made available by the relevant provider.

If our analytics practices materially change, this Privacy Policy may be updated accordingly.

10. PERSONAL INFORMATION AND INVESTMENT RESEARCH

Information regarding the companies, securities, projects, officers, directors and other persons displayed through The Speculator may originate from public corporate, regulatory, financial or professional sources.

Not all information appearing on company research pages constitutes personal information collected from Platform users.

Publicly available corporate and professional information may be collected, organized or presented as part of The Speculator's research functions, subject to applicable law.

User account information and user research activity are treated separately from public company research information.

11. WATCHLIST PRIVACY

A user's watchlist, saved companies, filters and similar research preferences are intended to support that user's Platform experience. We do not treat the presence of a company on a user's watchlist as evidence that the user:

  • owns that security;
  • intends to purchase that security;
  • recommends that security;
  • has a particular financial position; or
  • holds any particular investment belief.

We may analyze watchlist and feature usage in aggregated or de-identified form to understand Platform usage and improve functionality.

12. AGGREGATED AND DE-IDENTIFIED INFORMATION

We may create aggregated or de-identified information from Platform usage.

For example, we may analyze:

  • the number of users using a feature;
  • commonly viewed commodities;
  • commonly used filters;
  • general traffic levels; or
  • overall Platform performance.

Where information has been appropriately aggregated or de-identified so that it no longer identifies an individual, it may no longer constitute personal information under applicable law.

We may use aggregated or de-identified information for legitimate business purposes, including analytics, research and product development.

13. DATA RETENTION

We retain personal information only for as long as reasonably necessary to:

  • provide the Platform;
  • maintain accounts;
  • fulfill the purposes described in this Privacy Policy;
  • satisfy legal or regulatory obligations;
  • resolve disputes;
  • enforce agreements;
  • maintain security;
  • prevent abuse; or
  • meet legitimate operational requirements.

Retention periods may vary depending on the type of information.

For example, account information may generally be retained while an account remains active and for a reasonable period after account closure where necessary for legal, security, backup or operational purposes.

Information that is no longer reasonably required will be deleted, destroyed or de-identified in accordance with our practices and applicable law.

Information may remain temporarily in backup systems after deletion from active systems.

14. SECURITY SAFEGUARDS

We use administrative, technical and organizational safeguards appropriate to the nature and sensitivity of the information under our control.

Depending on the system and information involved, safeguards may include:

  • access controls;
  • authentication controls;
  • restricted administrative access;
  • encrypted network connections;
  • security logging;
  • database security;
  • infrastructure security;
  • provider security controls;
  • account protections;
  • backups; and
  • monitoring for unauthorized activity. be completely secure.

However, no internet-based service, database or information system can be guaranteed to be completely secure.

Users are responsible for protecting their own login credentials and should not share passwords or account access with unauthorized persons.

If you believe your account or personal information may have been compromised, contact:

admin@thespeculator.ca

15. PRIVACY AND SECURITY BREACHES

We maintain procedures intended to identify and respond to privacy and security incidents. Where a breach of security safeguards involving personal information occurs, we will assess the circumstances and take actions required by applicable law. Where legally required, this may include notifying affected individuals and reporting the breach to the appropriate privacy regulator.

16. ACCESSING YOUR PERSONAL INFORMATION

Subject to applicable law, you may request information concerning personal information we hold about you.

You may also request access to that information.

Requests may be sent to:

admin@thespeculator.ca

We may need to verify your identity before responding.

Certain information may be withheld where permitted or required by law, including information that would reveal another person's personal information, legally privileged information or information subject to another lawful exception.

17. CORRECTING YOUR PERSONAL INFORMATION

You may ask us to correct personal information about you that you believe is inaccurate or incomplete.

Where appropriate and reasonably possible, we will correct the information.

Account information that can be changed directly through Platform settings should ordinarily be updated through those settings. For other requests, contact: admin@thespeculator.ca

18. ACCOUNT AND DATA DELETION REQUESTS

You may request deletion of your account and personal information associated with it by using any available account-deletion functionality or contacting:

admin@thespeculator.ca

Following a valid deletion request, we will delete or de-identify applicable personal information where reasonably possible and legally appropriate.

Certain information may be retained where necessary for:

  • legal obligations;
  • fraud prevention;
  • security;
  • dispute resolution;
  • enforcement of agreements;
  • backup integrity; or
  • other purposes permitted or required by law.

Deletion of an account may permanently remove access to saved watchlists, preferences and other account-associated features.

19. WITHDRAWING CONSENT

Where processing is based upon your consent, you may withdraw that consent, subject to reasonable notice and any legal or contractual restrictions.

Withdrawal may result in the loss of access to features that require the relevant information.

For example, if you request deletion of information necessary to maintain an account, we may be unable to continue providing that account.

Requests may be submitted to:

admin@thespeculator.ca

20. MARKETING COMMUNICATIONS

The Speculator may offer newsletters, product announcements or other communications in the future.

Where required by applicable law, we will obtain appropriate consent before sending commercial electronic messages.

Marketing communications will include an appropriate method for unsubscribing where required.

Operational messages concerning matters such as:

  • account security;
  • privacy;
  • requested support;
  • material service changes; or
  • account administration may still be sent where necessary or legally permitted.

21. CHILDREN AND MINORS

The Speculator is a financial research platform and is not directed primarily toward children.

Users who create an independent account must meet any minimum age requirements described in our Terms of Use and applicable law.

We do not knowingly seek to collect unnecessary personal information from children.

If you believe that a child has provided personal information to us in circumstances where it should not have been collected, please contact: admin@thespeculator.ca

22. THIRD-PARTY LINKS AND WEBSITES

The Speculator may link to:

  • issuer websites;
  • stock exchanges;
  • securities regulators;
  • news organizations;
  • government websites;
  • technical reports;
  • financial statements;
  • corporate filings; and
  • other third-party resources.

Once you leave The Speculator, the privacy practices of the third party apply.

We are not responsible for the privacy, security or data-handling practices of third-party websites or services that we do not control.

Users should review the privacy policies of those services where appropriate.

23. AUTOMATED SYSTEMS AND ARTIFICIAL INTELLIGENCE

The Speculator uses automated systems and may use artificial intelligence to process public corporate, financial, geological, regulatory and related information.

These systems are primarily intended to support the research functions of the Platform.

We may also use automation to assist with:

  • fraud prevention;
  • security;
  • technical operations;
  • search functionality;
  • data organization; and
  • product improvement.

We do not intend to use a user's private account data to make individualized determinations concerning that user's creditworthiness, employability, insurance eligibility or other similarly significant personal decisions.

If our use of automated systems involving personal information materially changes, we may update this Privacy Policy and provide additional information where required by law.

24. DO NOT SUBMIT CONFIDENTIAL ISSUER INFORMATION

The Speculator primarily operates using publicly available information. Users should not submit material non-public information, confidential issuer information, insider information, trade secrets or other information that they are not authorized to disclose through feedback forms, correction requests, support communications or other Platform features. If you report an error or provide a correction regarding a public company, we encourage you to provide a link or reference to publicly available supporting documentation.

25. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

  • changes to the Platform;
  • new features;
  • new service providers;
  • changes in data practices;
  • changes in applicable law;
  • new regulatory requirements; or
  • other operational developments.

The Effective Date appearing at the beginning of this Privacy Policy identifies the current version.

If we make material changes affecting how personal information is collected, used or disclosed, we may provide additional notice through the Platform, by email or through another appropriate method. Where additional consent is required by law, we will seek that consent.

26. PRIVACY QUESTIONS AND COMPLAINTS

If you have a question, concern or complaint regarding our privacy practices, you may contact:

Privacy Officer

The Speculator Intelligence Inc.

Ontario, Canada

Email: admin@thespeculator.ca

We will review privacy concerns and seek to respond within a reasonable period. If you are not satisfied with our response, you may have the right to raise your concern with the Office of the Privacy Commissioner of Canada or another applicable privacy regulator.

27. CONTACT INFORMATION

For privacy requests, including requests concerning:

  • access;
  • correction;
  • deletion;
  • consent;
  • account information;
  • cookies;
  • data processing;
  • security concerns; or
  • complaints, please contact:

The Speculator Intelligence Inc.

Privacy Officer

Ontario, Canada

admin@thespeculator.ca