Canadian Privacy Notice

True Grade Authentication Inc.

This CANADIAN Privacy Notice describes the practices True Grade Authentication Inc. with respect to the personal information of residents of the  Provinces we collect in connection with our websites, mobile applications, or from any other interaction (such as emails, newsletters, or forms) where we display or link to this Privacy Notice (collectively referred to as our “Services”). By accessing or otherwise using our Services, you consent to the terms of this Privacy Notice.

I. Information We Collect:  We collect personal information that varies depending on how you interact with us.  Below we describe the types of personal information we may collect and the sources from which we may collect them:

• Information You Provide. We collect personal information that you provide to us when using our Services or otherwise interacting with us.  This includes the following types of personal information
• Account and contact information: Our Services enable you to create an account.  If you do, we may collect your name, email address, mailing address, phone number, login credentials, and any further account information you provide, such as (for example) preferences you set.

• Order information and transaction history: Our Services offer products and services for purchase, membership, subscription, or other transaction.  We collect data about the transactions you engage in with respect to our Services.  Your orders and/or transaction history will be associated with the account(s) under which you log into our Services.

• Payment or financial information: Our Services may facilitate the collection of your payment and billing information by our payment processor(s).  If you provide payment method information, you authorize CU, or a credit card processor of CU’s choosing, to receive appropriate card and billing information, bill such credit card, and make such charges as applicable.  We may also receive financial information from you when you request bid limit increases or other bidding or payment options.

• Information about collectibles.  Our Services may enable you to send us collectibles, provide information about collectibles you own, and/or buy, sell or consign collectibles.  If you do, we collect all information you provide us about such collectibles, such as (for example) a description of the collectible(s) and its condition, prior grading information, the collectible’s estimated value, and photos or images of collectibles.  If you send collectibles to us, we may also record additional information in connection with receiving, grading, storing, returning, or taking any other action in respect of your collectible(s), such as taking photographs of your collectible(s), adding condition or grading information, providing verification or certification numbers or taking any other action in respect to a collectible.

• Your posts.  If you create an account with us, you may join message boards or similar user forums within our Services.  We collect all information you post, share, or otherwise submit or provide while using message boards or similar fora.

• Event registration and participation information: Our Services may enable you to sign up or register for events.  If you do, we collect your name, contact information, and registration information.

In general, providing the above information is optional.  You can opt out of providing information to us by not entering it or not using our Services.  However, not providing personal information to us may hinder our ability to provide and/or your ability to use our Services.

• Information Provided By Others. Others may provide information to use relating to you in connection with your use of our Services.
• Information about you or your collectibles. We may obtain information relating to you or your collectibles from third-party sources. As an example, we may use third-party sources to verify your identity and/or information about collectibles; verify existing grades, certifications, or similar prior examinations; confirm information about ownership and/or prior sales; obtain information about potential market value; determine general level of potential market interest in collectibles; determine your financial status; determine whether you have a claim relating to the loss, damage, or other event relating to a collectible; or obtain any further information relating to you or your collectibles.

• Data from generally-accessible sources. We may obtain personal information and/or information about your collectibles from data providers, and/or from publicly available sources, such as online marketplaces, social media channels, or other publicly-accessible channels where you have made information about yourself available.

• Data Collected Automatically. When you use our Services, certain information about your device and web browser are automatically collected in connection with providing the Services to you, such as your IP address, device type, and operating system. This data is collected directly from your interaction with our Services.

• Other Information. We may collect information about how you use and engage with our Services, such as searches you conduct within our Services, how long you spend on specific pages, information or features you engage with, customizations or preferences you request or create, and other activity you engage in while using our Services. We collect this information directly from you and/or your device or browser.

• Information Collected by Cookies. Our Services may use cookies or other similar technologies. These technologies may collect information about your device, your browser, and your use of and activity within our Services. The data collected by cookies may include all of the “Data Collected Automatically” and “Other Information” described above. This information may be collected directly from your device or browser. For more information on the cookies and similar technologies we use, please see our Cookie Statement below.

• Communications Between You, Us, and Others. We may collect information about you in connection with requests or inquiries you make to us, whether done by email, phone, online submission, or otherwise. Our Services may also enable you to communicate with others, in which case we may receive a copy of messages you send to others.

We may combine the information you provide to us with information that we collect through automated methods, and with information we receive from other sources. For example, when you add a method of payment to your account, we may combine your profile with information we receive from our payment processors or other providers regarding transactions made with the same payment credentials.

II. How We Use Information: We process personal information for the following purposes:

• Operate, Manage, and Provide Our Business and Our Services. We use personal information to operate our business and provide our Services to you and others.  This includes providing the Services and all their technologies and functionality; receiving, storing, authenticating and grading collectibles; operating and/or managing collectible marketplaces and/or transactions or other interactions between TGA, dealers or other sellers, consignors or consignees, or others; evaluating and providing information about collectibles, such as actual or potential collectible prices or market values; facilitating events; enabling bidding capacity; managing relationships with our customers and prospective customers; reporting, monitoring, accounting, and other management activities; and any other activity relating to the operation of our business.  

• Communicate With You and Process Your Requests. We use personal information to communicate with you, including (without limitation) regarding your transactions, or via our newsletters.  You can opt-out of receiving our newsletters at any time by clicking the “Unsubscribe” link in any newsletter, or by emailing us as outlined in the “Contact Us” section below.  We also use your information to process, evaluate, and respond to any requests or inquiries you may make.

• Analytics, Improvement, and Product/Service Development. We may use personal information to analyze, evaluate, and improve our Services, our technologies, and our business; to develop new technologies, products, and services; learn about our users; conduct research; evaluate user engagement with our Services; and facilitate the functionality and new functionalities in our Services.  

• Marketing. We use personal information to market to you and others regarding matters that may be in your interest, including via sending you direct marketing, and/or by delivering targeted and interest-based marketing within our Services and elsewhere, each as permitted by law.  You can opt-out of marketing emails at any time by clicking the “Unsubscribe” link in any such email, or by emailing us as set forth below in the “Contact Us” section.

• Personalization. We may personalize the Services we offer to you or to others, including (but not limited to) by showing you content, features, or other Services provided by TGA that we think you might like or be interested in.

• Protection of Interests, Security and Integrity. Personal information may be used to protect the health, safety, welfare, rights, or interests of you, us, any third party, or the general public.  It can also be used to protect the safety and integrity of our Services, troubleshoot issues, and detect and prevent errors, fraudulent activity, or other potentially wrongful, harmful, or illegal activity.

• Compliance and Claims. We may use personal information to comply with, establish, assert, exercise, defend against, or enforce any legal claims, legal rights, legal obligations, legal process, government requests, TGA policies, internal investigations, or prudent security or business practices.  This includes (but is not limited to) enforcing this Privacy Notice, and any other contract(s) or agreement(s) we may have with you.

• As Otherwise Notified or Permitted. We may also use information we collect for any other purpose notified to you or to which you consent, or which is permitted by applicable law.

• Interest-Based Advertising. Our Services may work with third parties such as advertising networks to provide you with advertisements that you see as part of the Services, or on other websites or apps.  These parties may use technology that can collect personal information about your online activities over time and across different websites when you use our Services.

III. How We Share Information: We may share information with third parties for any purpose described in Section II above (“How We Use Information”), or for any other purpose that has been notified to you or to which you have consented.  This generally includes sharing information with the following categories of recipients:

• Affiliates. We may share personal information with TGA’ affiliates.

• Service Providers. We may share information with service providers and business partners who provide services to us or otherwise help us operate our business or the Services, such as (without limitation) by hosting data or our Services, helping us send newsletters, processing payments, and detecting and preventing payment and other fraud.

• Other TGA and Users, or the General Public. Our Services may enable you to share information about your collectibles with other TGA or the public, or to offer your collectibles for sale, such as by (a) posting information about your collectibles on our Services, and/or (b) listing collectibles for sale via a publicly-accessible marketplace.  In such cases, as applicable, your information (including information you provide about your collectible(s)) may be accessible to other TGA or to the general public.  Similarly, if you post about, bid on, or purchase a collectible, your information may became publicly available, and/or may be shared with the seller of the collectible.  Lastly, if you participate in our user fora and/or message boards, anything you post may be viewed by other users or the public, as applicable.

• Event-related Sharing. If you register for an event we organize, we may share your personal information in connection with enabling your participation in the event, such as (for instance) by sharing your name with the facility where the event is occurring.  Your information may, to the extent permitted by law, be shared with other event participants.

• Compliance- and Security-related Transfers. We may share personal information with third parties in connection with (a) complying with, establishing, asserting, exercising, defending against, or enforcing any legal claims, legal rights, legal obligations, legal process, TGA policies, government requests, or prudent security or business practices; (b) protecting the health, safety, welfare, rights, or interests of you, us, any third party, or the general public; or (c) protecting the safety and integrity of our Services, troubleshooting issues, and detecting and preventing errors, fraudulent activity, or other potentially wrongful, harmful, or illegal activity.  This may include disclosures to other TGA, businesses, insurance companies, law enforcement, third-party owners, or others.

• As You Direct. We may share information with other companies to whom you request that we share it.  For instance, our Services may enable you to designate others authorized to act on your behalf; if so, we share information about you with such third parties.

• Business Transactions. We may share or transfer information with another business in connection with a merger, acquisition, or sale of our assets.

IV. Your Privacy Rights & Choices: You have options regarding our collection, use, and disclosure of your personal information. The precise choices available to you may depend on legal rights you have as a resident of certain jurisdictions, but generally include:

• Email Preferences. You can opt-out of receiving marketing emails or newsletters from us at any time by clicking the “Unsubscribe” link in any such email, or by emailing us as set forth below in the “Contact Us” section.  Please note that even if you opt out, we may still send communications to you about your transactions, any accounts you have with us, any request or inquiry you have made, or other non-marketing related matters.

• Cookie Preferences. You can use the “Your Privacy Choices” or “Cookie Preferences” link in the footer of TGA websites to restrict certain types of cookies and similar identifiers, as follows:
• Essential or Strictly Necessary Cookies: These Cookies are necessary for our Services to operate and cannot be switched off.

• Functional Cookies: These Cookies enable the Services to remember your choices and to provide features and functionalities to you. Our cookie preference manager lets you disable these cookies, but please note that if you do, some of our Services may not function.  

• Analytics or Performance Cookies: These Cookies collect information about your use of the Services.  They enable Us to see Canadage and traffic patterns on the Services, assess the performance of the Services, and improve the Services. Our cookie preference manager lets you disable these cookies.

• Marketing or Targeting/Advertising Cookies: These Cookies are used to deliver relevant advertising to you on our site or other websites. They may also be used to limit the number of times you see an advertisement, or to help measure the effectiveness of any advertising campaigns. Our cookie preference manager lets you disable these cookies.

• Do Not Track Signals. As of the Effective Date listed below, there is no commonly accepted response to Do Not Track signals initiated by browsers. Therefore, our Services are not designed to respond to such signals.

Depending on the CANADIAN jurisdiction where you reside, you may exercise additional rights, detailed below in subsection F, “Your Province Law Privacy Rights” of Section IX, “Additional Disclosures for Residents of Certain CANADIAN Provinces.”

V. How We Secure Your Information: The TGA Cybersecurity Team is responsible for securing your information. We employ industry best practices intended to safeguard data from misuse, unauthorized access or disclosure, loss, alteration or destruction including but not limited to end-to-end encryption, multi-factor authentication, and regular penetration testing. We apply an adaptive risk-based approach to security, ensuring resilience against evolving threats while complying with applicable laws and regulations. We have established an incident response protocol to minimize the impact of security incidents. These controls are strengthened by a security training and awareness program for all employees.

VI. Children’s Privacy: Our Services are intended solely for use by persons 18 years of age or older. If you are under the age of 18, you may not use our Services.

VII. Notice of Monitoring: We and our service providers and third-party partners may monitor any use of or activity on our sites and Services and may capture and retain records reflecting your activity on our sites and Services for our business purposes. This may include records reflecting actions you take while using our sites and Services (such as clicks on pages or links, items viewed, scrolling, time spent on pages, and other activities), records of parts or all of your sessions on our sites or Services, information you submit on or via our sites or Services, or communications or information sent through or using our sites or Services. The cookies and similar tracking technologies described in this Privacy Notice may also collect the foregoing information reflecting your use of and activity on our sites and Services, or may enable our third-party partners to collect such information. This information may be collected, retained, captured, and/or monitored by us or by our service providers and third-party partners.  If you do not consent to the monitoring described here, you should not use our sites or Services.

VIII. Links to Other Sites:  Our Services may contain links to other websites or platforms. These websites operate independently from us, and their privacy practices are subject to their own privacy notices or policies, which we strongly encourage you to review to understand their procedures for collecting, using and disclosing personally identifiable information. We are not responsible for the content of the linked websites, any use of these sites, or the privacy practices of these sites.

IX. Additional Disclosures for Residents of Certain CANADIAN Provinces 

The following disclosures apply, as applicable, to residents of California, Colorado, Connecticut, Utah, Texas, and Virginia. 

A. Categories of Personal Information We Collect. We describe the personal information we collect in the above section titled "Information We Collect.”  California residents, please note that the data we have collected in the past twelve (12) months includes the following categories of personal information set forth in California law: 

1. Identifiers as well as identifying information described in Cal. Civ. Code § 1798.80(e), such as name; social security, driver’s license, and passport number; email and mailing address; phone number; account name and other online identifiers; credit and debit card number; and billing information;
2. Commercial information, including products and services you purchased, obtained, or considered; 
3. Audio, electronic, visual, or similar information, such as records of images of you provide to us or our Services, or (as permitted by law) records of your calls to customer service lines;
4. Characteristics of protected classifications under California or federal law, such as demographic information such as age and gender.
5. Sensitive Personal Information, such as account login credentials, payment card information, and the content of certain communications with third parties you  may send via our services;
6. Professional or employment-related information, such as information provided by memorabilia dealers; 
7. Internet or other electronic network activity information, such as browsing history and information regarding your interaction with our Services;
8. Inferences drawn from the information listed above.

B. Sources of Information. We collect the above categories of Personal Information directly from you or your device, from your interactions with our Services, from publicly available sources, and from third parties. For more information, see “Information We Collect,” above.

C. Business or Commercial Purposes for Collection.  The above section titled “How We Use Information” describes the business and commercial purposes for which we collect personal information.

D. Retention of Personal Information.  We retain Personal Information for the period(s) necessary to perform the purposes outlined in this Notice, unless applicable law permits or requires a longer period.  Please note that this means that we may be required to retain Personal Information after the end of our direct relationship with you. 

E. Disclosures of Personal Information; Targeted Advertising.  The above section titled “How We Share Information” describes the categories of third parties to whom we disclose personal information for the following purposes:

• Disclosures for business purposes.  We disclose all or substantially all of the above-listed categories of personal information with all categories of third parties identified in this Privacy Notice for our business purposes.

• Sales/Sharing and Targeted Advertising.  We do not sell data for monetary consideration, but like many companies that operate online, we may at times engage vendors that leverage your data for targeted advertising on our behalf.  Under certain province laws this may result in us “sharing” your data for “targeted advertising” that you can opt-out from. We may share identifiers, internet and other electronic activity information, and inferences with ad networks, social media providers, or advertising providers for this purpose. We do not knowingly sell or share personal information of individuals under 16 for targeted advertising. To opt-out of the sharing of your data for targeted advertising, see the “Your Province Law Privacy Rights” section immediately below.

F. Your Province Law Privacy Rights. If you are a resident of California, Colorado, Connecticut, Utah, Texas, or Virginia, you can request to exercise the following rights:

• The Right to Access / Know. You may confirm whether we process your Personal Information and request access to the specific pieces of personal information we maintain about you.

• The Right to Correct. You have the right to correct any Personal Information we maintain about you that is inaccurate. 

• The Right to Delete. You have the right to request that we delete the Personal Information we have collected from you. Please note that exercising this right may affect our ability to provide you Services that require us to have certain Personal Information about you.

• Opt-Out of Sharing for Targeted Advertising. To opt-out of sharing for targeted advertising that is facilitated by cookies on our site, click “Cookie Preferences” in the footer below to access our cookie preference manager – then either turn off “Marketing” cookies or activate the setting titled “Do Not Sell or Share My Personal Information.” (You can also click "Your Privacy Choices" or “Cookie Preferences” in the footer of our websites to access our cookie preference manager.) To opt-out of offline sharing for targeted advertising and , you can submit a request to Opt-Out. Note: We do not currently engage in offline sharing for targeted advertising, but your opt-out will be honored if in the future we do so.

Some province laws may grant you a right to appeal a denial of your rights request.  If this is applicable to you, our response to your request will provide details on how to submit an appeal. 

We do not process sensitive personal information in a way that requires us to provide a “Right to Limit” use or disclosure of sensitive information.  As required by applicable law, we will not discriminate against you because of your exercise of any of the above rights.

G. How to Exercise Your Rights. To exercise a right applicable to you, please submit your request via email

Additionally, you can submit a request to opt-out of Sharing for Targeted Advertising using an opt-out preference signal as permitted by applicable law. We process opt-out preference signals from Global Privacy Control (“GPC”), a technical specification you can use to automatically inform websites of your privacy preferences regarding “sales,” “sharing,” and “targeted advertising.”

Please note that, as required by applicable law, we may take steps to verify your identify before fulfilling your privacy rights request. We may require you to provide your name, contact information, and other information necessary to help verify your identity. If we cannot verify your identity, or if another applicable law prevents us from fulfilling your request, we may deny your request. 

X. Changes to this Privacy Notice: We may modify this Privacy Notice from time to time, and will post any revisions on this website.  We will indicate at the bottom of this Notice the Effective Date of the most recent update. By using our Services following an update, you accept and agree to this Privacy Notice in its updated form.

XI. Contact Us: If you have any questions about the content or subject matter of this Privacy Notice.