Privacy Policy

1. Who we are and what this policy covers

Walter Grades, Inc. ("Walter," "we," "us," "our") operates the website at waltergrades.com and related web and mobile applications (together, the "Service"). The Service is an analytics and ratings platform that evaluates investment newsletters and presents grades, scores, and related analytics.

This Privacy Policy explains what information we collect, how and why we use it, when we share it, how long we keep it, and the choices and rights you have. It applies to visitors to our site, registered users, and users who connect a Gmail account so that Walter can analyze newsletters they receive.

Walter is an analytics and information provider — NOT a financial adviser. Walter is not a registered investment adviser, broker-dealer, or financial planner. Our grades, scores, and analytics are statements of opinion and informational analysis. They are not investment advice and not recommendations to buy, sell, or hold any security.

2. How Walter accesses your Gmail — please read

When you connect your Gmail account, you select which newsletter senders Walter may access. From that point:

• We only access messages from the senders on your selected list. Everything else in your mailbox is off-limits to Walter and is never retrieved, read, or stored.
• You stay in control. You can review, add, or remove selected senders at any time, and you can disconnect Walter from your Gmail entirely with one click. Disconnecting stops all further access immediately.
• We do not use Gmail data for advertising, and we never sell it.
• Humans do not read your Gmail data, except in the narrow circumstances described in Section 7.

Google API Limited Use disclosure. Walter's use and transfer 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 of the Service and the newsletter analytics described in this policy, and for no other purpose.

3. Information we collect

Information you give us:

• Account information: name, email address, password (stored hashed), and account settings.
• Your selected newsletter senders: the list of senders you authorize Walter to access.
• Payment information: if you purchase a paid plan, payment is processed by our third-party payment processor, Stripe; we do not store full card numbers.
• Communications: messages you send us (support, feedback).

Information we collect automatically:

• Usage and device data: pages viewed, features used, IP address, browser/device type, and similar analytics, collected via cookies and similar technologies.

Information we access from your connected Gmail account:

• OAuth tokens that let Walter access only your selected senders.
• The content of newsletter emails from your selected senders — including text, sender, dates, and any investment calls, recommendations, or performance claims contained in them.

4. How we use information

We use information for two distinct purposes. We keep these separate on purpose, and we describe both plainly.

(A) To provide the Service to you:

• Authenticate you and operate your account.
• Retrieve and analyze newsletters from your selected senders.
• Generate and display grades, scores, tracking, and analytics for the newsletters you follow.
• Provide customer support and send service-related messages.
• Maintain security and prevent abuse.

(B) To build and improve the Walter ratings database and analytics:

• Walter extracts content from the newsletters processed through the Service into a pooled dataset that we use to generate the Walter grades, scores, peer-group comparisons, and aggregate analytics that are the core of our product.
• We use this data to develop, test, and improve our rating methodology and analytics, and to produce aggregated and de-identified insights about newsletters and the newsletter industry.
• This commercial use is described in detail in Section 5, and your authorization for it is obtained separately and explicitly when you connect your account.

5. The Walter ratings database and aggregated analytics

• What we build. Walter extracts and analyzes newsletter content to create grades, scores, track records, and aggregate analytics about investment newsletters. These outputs are derived from the content of the newsletters — not from your personal identity — and are combined across many users and sources into a pooled dataset.
• De-identification and aggregation. The grades and analytics we publish or commercialize describe the NEWSLETTERS, not you. We do not attach your identity to public or commercial outputs.
• Persistence. Aggregated and de-identified data derived from newsletter content may be retained and used in our ratings database even after you close your account or disconnect Gmail, because it is no longer associated with you and forms part of the integrity and history of the ratings. We delete your personal and account information as described in Section 8.
• Methodology independence. Walter's economics are not tied to grade outcomes. Newsletters and publishers cannot pay to influence their grade.

6. How we share information

We share information only as described here:

• Service providers / subprocessors: vendors that host our infrastructure, process payments, send email, and provide analytics, under contracts that limit their use of the data to providing services to us.
• Aggregated and de-identified outputs: we publish and may commercialize grades, scores, and aggregate analytics. These do not identify you.
• Legal and safety: where required by law, legal process, or to protect the rights, safety, and security of Walter, our users, or the public.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to this policy.
• With your direction or consent.

7. What we do not do (Google Limited Use commitments)

• We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising as those terms are defined under California law.
• We do not use Google user data for advertising, and we do not transfer it to third parties to build advertising profiles.
• Humans do not read your Gmail data, except: (a) with your explicit consent; (b) where necessary for security or to investigate abuse; (c) to comply with applicable law; or (d) where the data has been aggregated/de-identified.
• We do not use Google user data for any purpose other than providing and improving the user-facing features of the Service and the newsletter analytics described here.

8. Data retention and deletion

• Account and personal data are retained while your account is active and for a limited period afterward as needed for our legitimate business purposes, unless a longer period is required by law.
• Gmail-derived personal data is deleted when you disconnect Gmail or delete your account, except as needed to complete a transaction, comply with law, or resolve disputes.
• Aggregated and de-identified data derived from newsletter content may be retained as described in Section 5.
• How to delete. You can delete your account and request deletion of your personal data at support@waltergrades.com. We will honor verified requests as required by applicable law.

9. Security

We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit, restricted access, and secure storage of OAuth tokens. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Your privacy rights

California (CCPA/CPRA). If you are a California resident, you have the right to know what personal information we collect and how we use and disclose it; to access and delete it; to correct inaccurate information; and to opt out of "sale" or "sharing" of personal information. We do not sell or share your personal information for cross-context behavioral advertising. You may exercise these rights at support@waltergrades.com; we will not discriminate against you for doing so.

EEA / UK (GDPR), if applicable. Where GDPR applies, our legal bases are: performance of our contract with you (providing the Service), your consent (Gmail access and database use), and our legitimate interests (operating and improving the Service and ratings) balanced against your rights. You have rights of access, rectification, erasure, restriction, portability, and objection, and the right to lodge a complaint with a supervisory authority.

11. Children

The Service is not directed to, and we do not knowingly collect personal information from, anyone under 18. If we learn we have collected such information, we will delete it.

12. International users and data transfers

Walter is operated from the United States. If you access the Service from outside the U.S., you understand your information will be processed in the U.S.

13. Changes to this policy

We may update this policy. We will post the updated version with a new effective date and, for material changes affecting how we use Gmail data or the ratings database, provide more prominent notice and obtain renewed consent where required.

14. Contact

Questions or requests: support@waltergrades.com