PRIVACY POLICY

Last Updated: January 2, 2026

Mark Kaan & "The Insider’s Portfolio" (collectively, "We", "Us", or "Our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, and share your personal information when you visit www.markkaan.com (the "Site") or subscribe to our services. By using the Service, you consent to the data practices described in this policy.

1. INFORMATION WE COLLECT

We collect data to provide our services, process payments, and enforce our Terms of Service. 1.1. Personal Information:

• Account Data: Name, email address, and login credentials.

• Contact Data: Phone number (specifically for SMS/Telegram trade alerts).

• Financial Data: We do NOT store your full credit card number. All payments are processed by PCI-DSS compliant providers (e.g., Stripe, PayPal). We only retain transaction metadata (date, amount, transaction ID) for tax and accounting purposes.

1.2. Automated Device Data (The "Fingerprint"): To prevent fraud and account sharing, we automatically collect:

• IP Address & Geolocation: To verify your identity matches your billing address.

• Device Fingerprinting: Device type, operating system, browser type, and unique device identifiers (UDID).

• Usage Logs: Login times and concurrent session data. We use this data strictly to enforce the "Liquidated Damages" clause in our Terms of Service regarding unauthorized account sharing and to validate your identity in case of payment disputes.

2. HOW WE USE YOUR DATA

We use your information for the following specific "Business Purposes":

• Service Delivery: To deliver real-time trade alerts, "Playbooks," and access to the membership dashboard.

• Aggressive Marketing: To serve you personalized advertisements on platforms like TikTok, YouTube, and Meta (Facebook/Instagram) based on your interaction with our Site.

• Ad Targeting & Lookalikes: We use your hashed (encrypted) email address to create "Lookalike Audiences" on social media platforms to target users with similar interests.

• Fraud Defense: To detect "Friendly Fraud" (chargebacks) by proving that the IP address of the purchaser matches the IP address of the user who accessed the content.

3. COOKIES, PIXELS & TRACKING TECHNOLOGY

3.1. Advanced Tracking: We use cookies, web beacons, and Server-Side Pixels (including the TikTok Pixel, Meta CAPI, and Google Analytics) to track your behavior across the web. 3.2. Retargeting Consent: By visiting our Site, you explicitly consent to our use of these tools to track your browsing behavior for the purpose of showing you relevant "Retargeting" ads. 3.3. Affiliate Disclosure: We participate in affiliate programs (e.g., Interactive Brokers, Binance). If you click an affiliate link, a tracking cookie is placed on your device to ensure we receive a commission. This does not affect the price you pay.

4. SMS & EMAIL MARKETING (TCPA & CAN-SPAM COMPLIANCE)

4.1. Express Consent: By entering your phone number and email in our checkout or opt-in forms, you expressly consent to receive marketing communications and urgent trade alerts from Mark Kaan, potentially using automated dialing systems. 4.2. Opt-Out:

• Email: Click the "Unsubscribe" link at the bottom of any email.

• SMS: Reply "STOP" to any text message to cancel trade alerts.

• Note: You cannot opt-out of transactional emails regarding your subscription status, billing, or Terms of Service updates.

5. DISCLOSURE OF YOUR INFORMATION

We do not sell your personal data to data brokers. However, we share data with:

• Service Providers: Trusted partners who assist in operating our business (e.g., AWS Hosting, Email Service Providers, SMS Gateways).

• Ad Networks: We share hashed data and usage events with platforms like Meta, TikTok, and Google to measure ad performance.

• Legal & Fraud Enforcement: We reserve the right to disclose your personal information (including IP logs) to legal authorities, debt collection agencies, or credit bureaus if you breach our Terms of Service (e.g., piracy, chargeback fraud).

6. SPECIFIC CLAUSE: CREATOR ANONYMITY & ANTI-DOXING

You acknowledge that the Service operates under the pseudonym "Mark Kaan" for privacy and security reasons. You explicitly agree not to use data subject access requests (such as GDPR or CCPA requests) for the malicious purpose of "doxing," reverse-engineering, or exposing the physical identity or location of the creator. Any such attempt is a material breach of our Terms and will result in immediate termination and potential legal action for harassment.

7. INTERNATIONAL DATA TRANSFERS

The Service operates globally. Your information may be transferred to, stored, and processed in jurisdictions outside of your country of residence (including the United States and the United Arab Emirates), where data protection laws may differ. By using the Service, you consent to this transfer.

8. YOUR DATA RIGHTS (GDPR & CCPA)

Depending on your location, you may have specific rights:

• Right to Access & Deletion: You may request a copy of your data or request deletion. Exception: We retain data related to active subscriptions or chargeback disputes for a minimum of 7 years for legal protection and tax compliance.

• California Residents: We do not "sell" personal information as defined by the CCPA, but we do share data for cross-context behavioral advertising (as described in Section 3).

9. CONTACT US

For privacy-related inquiries, please contact our Compliance Team at: Email: [support@markkaan.com]