California Consumer Privacy Act Disclosures
Last Modified and Effective Date: January 20, 2024
California Privacy Notice
This notice and policy supplements information contained in privacy disclosures from Sprott Inc. and its corporate business affiliates and subsidiaries (“Sprott”). It applies solely to residents of the State of California (“consumers” or “you”). It explains your privacy rights, provides our “notice at collection,” and includes certain mandated disclosures about our treatment of California residents’ information.
Any terms defined in the California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”) have the same meaning when used in this notice and policy. This notice and policy does not reflect our collection, use, or disclosure of California residents’ personal information, or data subject rights, where an exception under the CCPA applies. You can download a pdf version of the notice and policy here.
- RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED AND DISCLOSED, AND TO REQUEST DELETION OF PERSONAL INFORMATION
- As a California resident, you have the rights listed below.
To submit a request to exercise the right to know, please submit an email request to privacy@sprott.com or call our toll-free number at 855-943-8099. To submit a request to delete personal information, please submit an email request to privacy@sprott.com or call our toll-free number at 855-943-8099. - Sprott may ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Sprott will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
- RIGHT TO ACCESS You have the right to access PI (up to two times per year) which we may collect or retain about you. If requested, we shall provide you with a copy of your PI which we collect as permitted by law. You also have the right to receive your PI in a structured and commonly used format so that it can be transferred to another entity (“data portability”).
- RIGHT TO KNOW You have the right to request that we disclose the following about your PI, as defined by law:
○ The specific PI we may collect;
○ The categories of PI we may collect;
○ The categories of sources from which we may collect your PI;
○ The business purpose(s) for collecting or sharing your PI;
○ The categories of PI we may disclose for business purposes; and
○ The categories of third parties to whom we may sell or share your PI. - RIGHT TO OPT-OUT / DO NOT SELL/DO NOT SHARE MY PERSONAL INFORMATION or state: Certain data collection on our sites such as website analytics and cookies may be a “sale” under California privacy law. To change your preferences, click here.
- RIGHT TO REQUEST THAT WE DO NOT COLLECT, SHARE, OR DISCLOSE MY SENSITIVE PERSONAL INFORMATION You have the right to limit how your SPI is disclosed or shared with third parties, as defined in the CCPA/CPRA. Sprott
- RIGHT TO DELETION In certain circumstances, you have the right to request the erasure of your PI. Upon verifying the validity of a deletion request, we will delete your PI from our records, and instruct any service providers or third parties to delete your information, when applicable.
- RIGHT TO CORRECT/RIGHT TO RECTIFICATION In certain circumstances, you have the right to request correction of any inaccurate PI. Upon verifying the validity of a verifiable consumer correction request, we will use commercially reasonable efforts to correct your PI as directed, taking into account the nature of the PI and the purposes of maintaining your PI.
- ACCESS AND OPT OUT OF AUTOMATED-DECISION-MAKING INCLUDING PROFILING
Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.
EXERCISING YOUR RIGHTS If you are a California resident, you can exercise any of your rights as described in this Policy/Notice and under applicable privacy laws by using the contact information provided in this Notice. We will not discriminate against you for exercising such rights. Except as described in this Policy/Notice or provided for under applicable privacy laws, there is no charge to exercise your legal rights.
When a business sells your personal information, you have a right to opt out of such sale. Sprott does not sell, and in the preceding 12 months did not sell, California residents’ personal information. Sprott does not have actual knowledge that it sells the personal information of minors under 16 years of age.
- PERSONAL INFORMATION HANDLING PRACTICES
When a business sells your personal information, you have a right to opt out of such sale. Sprott does not sell, and in the preceding 12 months did not sell, California residents’ personal information. Sprott does not have actual knowledge that it sells the personal information of minors under 16 years of age.
| Category of Personal Information Collected | Categories of Sources from which the Information was Collected | Business or Commercial Purpose(s) for which Information is Collected | Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose |
| Identifiers: Name, telephone number, residential address, e-mail address, IP address, driver’s license number, social security number, passport number, banking information | We may collect this type of information from: Directly from you. For example, when you contact or request information from us including via the Sprott websites, when you create a Sprott account, or through meetings and telephone conversations with you. Third Parties, including Service Providers. For example, service providers that Sprott uses and other third parties that Sprott chooses to collaborate or work with, or your financial advisors or dealers that provide information to us on your behalf. | We may use this type of information to: Establish your identity and verify the accuracy of your information, such as to confirm your identification. Provide you with our services, such as to; use the websites and execute your transactions; process, maintain and service your account(s); provide you with confirmations, tax receipts, proxy mailings, financial statements and other reports; enable service providers to perform the services offered on our websites; determine the suitability of our services for you and your eligibility for our services; market products and services that may be of interest to you. Register an account, manage user relationship, and communicate with you. Handle and record consumer rights requests, including opt-ins and opt-outs; Monitor, protect and improve Sprott security assets and resources, including devices, systems, customer data, infrastructure, and Sprott network. Prevent or detect fraud or criminal activity. Comply with laws, regulatory requirements and to respond to lawful requests, court orders and legal processes. |
We may disclose this type of information to: Service Providers, custodians of assets. Third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders). Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition. Sprott Affiliates and Subsidiaries. For example, Sprott affiliates and subsidiaries may share business processes and common data systems. |
| Any categories of Personal Information described in subdivision (e) of Section 1798.80: Name, date of birth, age, gender, telephone number, residential address, e-mail address, IP address, driver’s license number, social security number, passport number, financial information, occupation, employment history, credit history, information about third parties required by law or performance of contract (e.g. information about your spouse) |
We may collect this type of information from: Directly from you. For example, when you contact or request information from us including via the Sprott websites, when you create a Sprott account, or through meetings and telephone conversations with you. Third Parties, including Service Providers. For example, service providers that Sprott uses and other third parties that Sprott chooses to collaborate or work with, or your financial advisors or dealers that provide information to us on your behalf. | We may use this type of information to: Establish your identity and verify the accuracy of your information, such as to confirm your identification. Determine the suitability of our services for you and your eligibility for our services; Provide you with our services, such as to; use the websites and execute your transactions; process, maintain and service your account(s); provide you with confirmations, tax receipts, proxy mailings, financial statements and other reports; enable service providers to perform the services offered on our websites; determine the suitability of our services for you and your eligibility for our services; market products and services that may be of interest to you. Register an account, manage user relationship, and communicate with you. Handle and record consumer rights requests, including opt-ins and opt-outs; Monitor, protect and improve Sprott security assets and resources, including devices, systems, customer data, infrastructure, and Sprott network. Prevent or detect fraud or criminal activity. Comply with laws, regulatory requirements and to respond to lawful requests, court orders and legal processes. |
We may disclose this type of information to: Service Providers, custodians of assets. Third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders). Sprott Affiliates and Subsidiaries. For example, Sprott affiliates and subsidiaries may share business processes and common data systems. Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition. |
| Commercial information: Browsing history; investment and services history |
You. Service provider such as for Anti-Money Laundering checks. | Provide you with our services, such as to; use the websites and execute your transactions; process, maintain and service your account(s); provide you with confirmations, tax receipts, proxy mailings, financial statements and other reports; enable service providers to perform the services offered on our websites; determine the suitability of our services for you and your eligibility for our services; market products and services that may be of interest to you. Comply with laws, regulatory requirements and to respond to lawful requests, court orders and legal processes. | We may disclose this type of information to: Service Providers. Third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders). Sprott Affiliates and Subsidiaries. For example, Sprott affiliates and subsidiaries may share business processes and common data systems. Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition. |
| Internet or other electronic network activity information: IP address, domain name, browsing history, browser type, settings, and capabilities, device type and settings, operating system, network information, time of visit, duration of visit, date and time stamps of actions | We may collect this type of information from: Using cookies and automatic collection methods. Sprott and its service providers may collect information from the computer, tablet, phone, or other device that you install our mobile application on, that you use to access our websites, or that you use to open an email or click on an advertisement from Sprott. Sprott does not respond to “do not track signals.” | We may use this type of information to: Provide you with our services, such as to; use the websites. Measure user engagement with the websites, and detect viewing history. | We may disclose this type of information to: Service Providers. Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition. |
| Geolocation data: IP Address | We may collect this type of information from: Using cookies and automatic collection methods. Sprott and its service providers may collect information from the computer, tablet, phone, or other device that you install our mobile application on, that you use to access our websites, or that you use to open an email or click on an advertisement from Sprott. Sprott does not respond to “do not track signals.” |
We may use this type of information to: Provide you with our services, such as to; use the websites. To facilitate transactions or operations on your behalf. To help with auditing interactions and transactions with you, addressing security, fixing errors, our advertising or marketing, maintaining accounts and providing customer service, internal research, verifying service quality or safety, document storage and shredding, and mail distribution. To manage our organization and administration. To comply with our legal obligations, including security investigations. As required by law. | We may disclose this type of information to: Service providers such as for website analytics. Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition. Sprott Affiliates and Subsidiaries. For example, Sprott affiliates and subsidiaries may share business processes and common data systems. |
| Audio information, electronic, visual, thermal, olfactory or similar information | We may collect this type of information from: You. | We may use this type of information: If you call and leave a voice mail, we record the message | We may disclose this type of information to: Third parties and service providers such as our phone system. Third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders). For example, we may be required to report your income to taxation authorities, or disclose your personal and business information to self-regulatory organizations, such as the U.S. Securities and Exchange Commission and the Financial Industry Regulatory Authority. Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition. Sprott Affiliates and Subsidiaries. For example, Sprott affiliates and subsidiaries may share business processes and common data systems. |
| Inferences drawn from any of the information identified above to create a profile about You: Predictions of behavior, interests, preferences, and needs | We may collect this type of information from: You. Your device. | We may use this information to: Market products and services that may be of interest to you; Measure user engagement with the websites. | We may disclose this type of information to: Service Providers. Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition. |
| Sensitive Personal Information This includes: ID numbers, such as social security or passport number; account log-in or financial account information; precise geolocation (defined as accurate to within a 1850 feet radius circle); racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of email or other communications; genetic data; biometric data processed to uniquely ID an individual; or PI collected and analyzed concerning a person’s health, sexual orientation or sex life; the processing of any biometric data to identify a consumer, as well as personal information concerning a consumer's health or sexual orientation. | We may collect this type of information from: You. | We may use this type of information to: Establish your identity and verify the accuracy of your information, such as to confirm your identification. Determine the suitability of our services for you and your eligibility for our services; Provide you with our services, such as to execute your transactions; process, maintain and service your account(s); provide you with confirmations, tax receipts, proxy mailings, financial statements and other reports; Register an account, manage user relationship, and communicate with you; Monitor, protect and improve Sprott security assets and resources. Prevent or detect fraud or criminal activity. Comply with laws, regulatory requirements and to respond to lawful requests, court orders and legal processes. | We may disclose this type of information to: Service Providers. Third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders). Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition. Sprott Affiliates and Subsidiaries. For example, Sprott affiliates and subsidiaries may share business processes and common data systems. |
| Characteristics of protected class information under California or Federal Law such medical condition, marital status, sex, and age | You. | Provide you with our services. | Service Providers Third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders). Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition. Sprott Affiliates and Subsidiaries. For example, Sprott affiliates and subsidiaries may share business processes and common data systems. |
We will not retain or store Personal Information for longer than is reasonably necessary to fulfill the purposes for which it was collected or that you authorized after collection, or as otherwise required by law.
- RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF CCPA RIGHTS
You may not be discriminated against because you exercise any of your rights under the CCPA in violation of California Civil Code § 1798.125.
- AUTHORIZED AGENT
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California and the agent provides proof that you gave the agent signed permission to submit the request; and
- You directly confirm with Sprott that you provided the authorized agent with permission to submit the request.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please provide any information Sprott requests to verify your identity. The information that Sprott asks you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
- CONTACT FOR MORE INFORMATION
If you have any questions or comments about this notice and policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, please do not hesitate to contact us at:
Sprott Inc.
Royal Bank Plaza, South Tower
200 Bay Street, Suite 2600
Toronto, Ontario M5J 2J1
Canada
Telephone: 416.943.8099
Toll Free: 855.943.8099
Email address: privacy@sprott.com