LEGAL

Privacy Policy

Last updated: August 7, 2026


1. What We Collect

Account information (name, email, credentials); newsletter email you direct to Walter — by forwarding, by linking a mailbox, or delivered by Walter for marketplace subscriptions — filtered to an allowlist of newsletter senders so personal mail is never read, fetched, or stored; usage and device data; and payment information, which is processed by our payment processor (Walter does not store card numbers). We use cookies and similar technologies for sign-in, security, and product analytics; your browser controls apply.

2. How We Use It — The Three Uses

(1) Your features: we render your issues, extract and track their recommendations, and generate alerts and summaries — for you alone. (2) Ratings: we extract structured facts (ticker, direction, price condition, timestamps, outcomes) and de-identify them at extraction; those facts feed the public rating engine and cannot be traced back to you. (3) Never distribution: your mailbox is never a source for showing newsletter content to anyone else. We also use data to operate, secure, and improve the Service and to communicate with you.

3. Google User Data — Limited Use

If you connect a Google mailbox, our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. We use Google user data only to provide and improve the user-facing features described above; we transfer it only to service providers as necessary to provide those features (including our model-inference provider, whose commercial terms prohibit training on our inputs and outputs), for security purposes, to comply with applicable law, or with your explicit consent; we do not use it for advertising; and humans do not read it except with your explicit consent, for security purposes, or as required by law. Aggregated, de-identified derivations feed the rating engine with your consent, as described in Section 2. You may revoke access at any time in the Service settings or through your Google account settings.

4. Sharing

We share personal data only with: service providers under contract (hosting, payments, model inference, email delivery); the publisher of a newsletter you purchase through the marketplace, which receives your subscription information for fulfillment and account purposes; a publisher you separately choose to share your identity with by opting in at follow; professional advisers; and parties to whom disclosure is required by law — with notice to you before we respond to legal demands, where lawful. We do not sell personal data, and we honor Global Privacy Control signals.

5. Retention and Deletion

Your newsletter archive is retained, encrypted, as your personal feature for as long as your account exists. If you delete your account, we delete your personal archive, mailbox connections, and identity-linked data within 30 days (backup cycles may take up to 90 days). De-identified facts already in the rating ledger persist — they carry no link to you. Records required for legal, tax, or security purposes are retained as required.

6. Security

We use encryption in transit and at rest, least-privilege access controls, and logging, and the mailbox-connection path undergoes independent security assessment. No system is perfectly secure; we will notify affected users of security breaches as required by law.

7. Your Privacy Rights

Depending on your state of residence, you may have the right to: know and access the personal data we hold about you; correct inaccurate data; delete your data; obtain a portable copy; opt out of targeted advertising, sale, or profiling (Walter does not sell personal data or use it for targeted advertising); and limit the use of sensitive personal data. To exercise any right, use the tools in Settings or email support@waltergrades.com with the subject "Privacy Request." We verify requests using your account email and will respond within the time required by your state's law. You may use an authorized agent by providing signed permission. If we decline a request, you may appeal by replying to our response, and we will answer your appeal as your state's law requires. We will never discriminate against you for exercising your rights. The Service is for United States residents 18 and older; we do not knowingly collect data from children, and we do not currently offer the Service outside the United States.

8. Changes; Contact

We will post changes to this policy here and notify you of material changes. Any change of control of Walter will honor the commitments in this policy, including the Limited Use restrictions on Google user data. Contact: support@waltergrades.com · Walter Grades, Inc., 43996 Woodward Ave, Ste 5 #2240, Bloomfield Twp, MI 48302.

Walter Grades is an independent analytics and ratings provider. Walter Grades does not provide investment, tax, or legal advice. Grades and scores are information only and are not recommendations to buy, hold, or sell any security or product. Past performance does not guarantee future results.

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