Privacy Policy

Section 01Introduction

This privacy statement explains how we collect, use and disclose your personal information. It applies to anyone who uses the Sensible Investing website, application or services, or who otherwise interacts with us.

Sensible Investing® is operated by Candlestick Inc. In this statement, “we”, “us” and “our” mean Candlestick Inc., together with its affiliates and subsidiaries. Candlestick Inc. is the organisation accountable for the personal information described here.

Section 02Information we collect

Depending on how you interact with us, we may collect:

• your name and contact details;
• account credentials and settings;
• payment and billing details, handled by our payment providers;
• subscription status and usage information, including the securities you look up and the lists you build;
• device, browser and network information, including IP address;
• correspondence you send us, including support requests;
• information you choose to upload or share in order to use the service.

We do not ask for and do not want your brokerage credentials, account numbers or holdings statements. Please do not send them to us.

Section 03How we collect it

We collect personal information directly from you when you register, subscribe, or contact us; automatically when you browse our sites and use the application, including through cookies and similar technologies; and occasionally from third parties such as payment providers, analytics providers and publicly available sources.

Section 04How we use it

We use personal information to operate and support the service, create and administer accounts, process payments and manage subscriptions, provide customer support, monitor and improve how the service works, communicate with you about your account and about changes to the service, carry out marketing where you have not opted out, protect the security of the service and the rights and safety of others, and comply with our legal obligations.

We may also produce aggregated or de-identified information for research, development and reporting. That information does not identify you and is not treated as personal information.

Section 05How we disclose it

We may disclose personal information to affiliates and subsidiaries; to service providers who host, process payments, send email, or provide analytics and support on our behalf; to professional advisers; in connection with a merger, acquisition or other business transfer; and where required to comply with the law, respond to lawful requests, enforce our terms, or protect rights and safety.

We do not sell your personal information. Service providers are permitted to use personal information only to perform services for us and are bound by contractual confidentiality and security obligations.

Section 06Cookies and tracking

We use cookies, pixels and similar technologies to keep you signed in, remember your preferences, secure the service, and understand how the site is used. Essential cookies are necessary for the service to function. Non-essential cookies support analytics and marketing.

You can manage or block cookies through your browser settings. Blocking essential cookies may prevent parts of the service from working.

Section 07Your choices and rights

Under Canadian privacy law, including the Personal Information Protection and Electronic Documents Act, and under other laws that may apply to you, you may have the right to access the personal information we hold about you, ask us to correct it, ask us to delete it, withdraw consent, or object to or restrict certain processing.

You can update most account information yourself in your account settings, and unsubscribe from marketing email using the link in any such message. For anything else, write to [email protected]. We will respond within the time required by applicable law and may need to verify your identity first.

If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada or to your local supervisory authority.

If you are in the European Economic Area or United Kingdom, we rely on the following legal bases to process personal information: performance of our contract with you, our legitimate interests in operating, securing and improving the service, your consent where you have given it, and compliance with our legal obligations. You have the right to lodge a complaint with your local data protection supervisory authority.

If you are a California resident, you have the right to know what personal information we have collected about you, to request its deletion or correction, and to opt out of the “sale” or “sharing” of personal information. As noted above, we do not sell personal information and do not share it for cross-context behavioural advertising. We will not discriminate against you for exercising these rights, and you may designate an authorised agent to submit a request on your behalf.

Section 08Security and retention

We maintain an information security programme with administrative, technical and physical safeguards appropriate to the sensitivity of the information. No system is completely secure, and we cannot guarantee absolute security. If a breach of security safeguards creates a real risk of significant harm to you, we will notify you and the relevant privacy regulator as required by applicable law.

We keep personal information for as long as needed for the purposes described in this statement, and afterwards only as long as required to meet legal, accounting, tax or reporting obligations, or to establish or defend legal claims. Account information is generally deleted or anonymised within 90 days after an account is closed.

Section 09International transfers

We and our service providers may store and process personal information in countries other than the one you live in, including the United States. Those countries may have different privacy laws, and personal information may be accessible to courts, law enforcement and national security authorities there. Where we transfer personal information across borders, we take steps to ensure it remains protected by appropriate contractual and organisational measures.

Section 10Minimum age

The service is intended for adults. We do not knowingly collect personal information from anyone under eighteen years of age, or under the age of majority where that is higher. If you believe a minor has provided us with personal information, contact us and we will delete it.

Section 11Changes to this statement

We may update this statement from time to time. When we do, we will change the date shown at the top of this page and, where the change is material, notify account holders by email or through the service. Please review it periodically.

Section 12Contact

For questions about this statement or about our privacy practices, or to exercise any of your rights, contact our privacy team at [email protected], or write to the Privacy Officer, Candlestick Inc., 103-2727 Steeles Ave West, Toronto, Ontario, M3J 3G9, Canada.