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Privacy Policy

Draft — last updated 2026-07-10. Pending legal review.

This document is a draft and is subject to change pending legal review. Highlighted items (e.g. [operator legal name]) are placeholders to be completed before this policy is relied upon.

1. Scope & who we are

This Privacy Policy describes how MapleGamma (the "Service"), operated by [operator legal name], handles personal information when you create an account and use the Service. The Service provides general market information and simulated (paper-trading) results for educational purposes only, and is not investment advice. We handle personal information in accordance with applicable Canadian privacy law, including PIPEDA.

2. Information we collect

  • Account information: your email address and authentication credentials (a hashed password, and/or a Google OAuth identifier, and/or passkey public-key credentials). We do not store plaintext passwords.
  • Consent records: your acceptance of the Terms, the not-investment-advice acknowledgement, your Quebec-residency attestation, and the version and time of that acceptance.
  • Email preferences: whether you have opted in to the Morning Briefing email, and changes to that preference.
  • Session & security data: session tokens and limited technical signals (such as IP address and a device identifier) used for sign-in, trial eligibility, and abuse prevention.
  • Billing data: subscription tier and status, and identifiers from our payment processor. Payment card details are handled by the payment processor and are not stored by us.

3. How we use information

We use this information to operate the Service: to authenticate you, maintain your session, determine your entitlement/plan, process subscriptions, prevent trial abuse and fraud, keep records of consent, and communicate service-related matters. We do not sell your personal information.

4. Email communications & your consent (CASL)

We send account and service-related messages (for example, security and billing notices) as needed to operate the Service. The Morning Briefing email is optional: we send it only if you expressly opt in (at sign-up or from your account page). You may withdraw your consent and unsubscribe at any time using the link in each message or from your account page; we will honour unsubscribe requests promptly. Commercial electronic messages we send will identify us and include a valid unsubscribe mechanism and contact information, consistent with Canada's Anti-Spam Legislation (CASL).

5. Cookies & similar technologies

We use a small number of strictly necessary, first-party cookies to run the Service — for example, a session cookie to keep you signed in, a device cookie for trial eligibility and abuse prevention, and short-lived cookies used during sign-in (OAuth state and consent). We do not use third-party advertising or cross-site tracking cookies.

6. Service providers / sub-processors

We share limited information with service providers who process it on our behalf to run the Service, including: our hosting and edge platform, [Cloudflare]; our payment processor, [Helcim] (billing and card processing); [Google] (optional sign-in via Google OAuth); and our email delivery provider, [email provider]. These providers are authorized to use personal information only as necessary to provide their services.

7. Where your information is processed

Our providers may store or process information on servers located in Canada, the United States, or other countries. Where information is processed outside your province or Canada, it may be subject to the laws of those jurisdictions, including lawful access by courts and authorities there.

8. Data may be delayed or inaccurate

Market data shown in the Service may be delayed, incomplete, or inaccurate and is provided for general information only. See the Terms of Use.

9. Service not available in Quebec

The Service is not directed at, or intended for use by, residents of the province of Quebec, and is not available to Quebec residents.

Avis : ce service ne s'adresse pas aux résidents du Québec et ne leur est pas destiné. L'information fournie est de nature générale et ne constitue pas un conseil en placement ni une recommandation.

10. Data retention

We retain account, consent, and billing records for as long as your account is active and thereafter as required for legal, tax, security, and record-keeping purposes, after which we delete or de-identify them.

11. Your rights & choices

Subject to applicable law, you may access, correct, or request deletion of your personal information, and withdraw consent (including unsubscribing from optional email). You can manage sign-in and email preferences, and delete your account, from your account page or by contacting us. We will respond within the time required by law.

12. Security

We use reasonable technical and organizational safeguards (including password hashing, encrypted transport, and access controls) to protect personal information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Children

The Service is not directed to individuals under the age of majority in their province of residence, and we do not knowingly collect their personal information.

14. Past performance

Past performance — whether actual or simulated — is not indicative of, and does not guarantee, future results.

15. Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the date above and, where appropriate, provide notice.

16. Contact

Questions about this Privacy Policy, or to exercise your rights, can be sent to [contact / privacy email], [operator legal name], [mailing address].