This is the privacy policy (“Policy”) of Investing Insider Publishing Ltd., its subsidiaries and affiliates (collectively, “INVESTING INSIDER”). INVESTING INSIDER is committed to protecting your right to privacy when you provide us with personal information. This Policy sets out how we collect and manage personal information, whether that information is collected via our website investinginsider.com (“Website”), including through selling our products (the “Products”) on the Website or otherwise, including via our other websites (the Website, collectively with the other websites, the “Sites”). In this Policy, the terms "you", "user" and "your" refer to a visitor of any of our Sites or user of the Products (or of our services provided on the Sites (“Services”)) and the terms “we”, “us” and “our” refer to INVESTING INSIDER.

Please read this Policy carefully before using any of our Sites. We may also update or modify this Policy at any time by posting our revised policy to our Sites. We include an “effective date” in the Policy displayed on our Sites. We strongly encourage you to refer back to the Policy periodically to ensure that you stay up to date with our practices and procedures.

By using any of our Sites, you agree that you have read, understood and agree to be bound by this Policy, including any updates to the Policy, and approve of the collection, use and disclosure by us of your personal information according to its terms. 

By submitting personal information to us or by otherwise using any of our Products or our Sites, you hereby consent to the collection, use and disclosure of your personal information in accordance with this Policy.

If you do not agree with some or all of this Policy, please do not use the Sites or Services, or order our Products.

Collection of Personal Information

In the course of providing Services through our Sites and off-line, we may collect your personal information.

“Personal information” means information that can identify an individual, and includes, for example, a person’s name, home address, home phone number, email address, credit card information or bank account information. Personal information in Canada does not include information to enable an individual at a place of business to be contacted, such as their name, position name or title, business telephone number, business address, or business email address.

We will only collect personal information as permitted under the applicable federal, provincial and state privacy legislation. We may collect personal information in a variety of ways, including where you:

• submit an application to use the portions of our Sites and, where the option is available, create an account;
• place an order for any of our Products;
• request us to provide you information about our company and promotional offers;
• submit an employment application to us;
• send us an email inquiry either through one of our Sites or directly to our email;
• contact us by telephone; and
• provide feedback in an online survey.

By submitting personal information to us, you consent to us collecting the personal information that you have submitted and using such personal information for the purposes set out in this Policy.

We may also collect aggregate information which tells us about visitors to our Sites, but not the identity of those visitors. For example, we may collect information about the date, time and duration of visits and which pages of our Sites are most commonly accessed. The purpose of collecting this aggregate information is to help us administer and improve our Sites. Data collected through our Sites on an anonymous and aggregated basis helps us measure interest in and use of our Sites. We reserve the right to provide our analyses based on such anonymous and aggregated data to third parties.  Information that we collect about the date, time and duration of visits and which pages of our Sites are most commonly accessed cannot be collated to create a profile about your preferences and/or characteristics.

The Sites also use Google Analytics to gather information about users’ usage of the Sites. We utilize this information to make educated metric-based decisions to improve the user experience of the Sites. You can opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-on. 

How We May Use Your Information

Personal information collected by us is used only for the purposes described in this Policy, or for other purposes which are disclosed to you and to which you consent.

We generally use your personal information to:

• create and secure your registered member account and identify you as a registered member in our system;
• communicate with you about our Sites, Products and Services;
• process orders that you submit to purchase our Products;
• send newsletters, reports, and action alerts and updates to our registered members;
• improve our Sites, Products and Services, diagnose problems and develop new Products and Services;
• investigate security breaches, or co‑operate with government authorities pursuant to a legal matter;
• fulfill your requests;
• send to you surveys, offers and promotional materials related to our Sites, Products and Services and for our other marketing services, including offers from third party affiliates and partners that we think may be of interest to you;
• monitor traffic on our Sites;
• determine the future direction of our Sites, including technical upgrades;
• protect, investigate and prevent potentially fraudulent, unauthorized or illegal activities;
• protect our rights and the rights of other registered members;
• analyze usage information, your feedback, support queries and survey responses to identify issues and help us understand usage and to improve our Sites, Products and Services; and
• otherwise manage our relationship with you.

How We Share Your Personal Information

Investing Insider does not sell or rent personal information to third parties, or share personal information with third parties, except as described in this Policy as it may be revised from time to time. We may disclose or share your personal information in the following circumstances:

• protecting our rights and property, including for security breach, loss or fraud prevention, investigation or mitigation purposes;
• protecting the safety of a person or a group of persons;
• with third party service providers and partners that help us to provide our Sites, Products and Services, including website content, website hosting, data warehousing, data analysis, event logging, information technology, customer service, payment processing, user analytics and email delivery and messaging;
• with a third party, in the event of a change in ownership of all or a part of us through some form of merger, purchase, sale, lease or amalgamation or other form of business combination, provided that the parties are bound by appropriate agreements or obligations which require them to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Policy, unless you indicate otherwise;
• other purposes identified when your personal information is collected, or as permitted or required by law;
• with any third party, where you have provided your consent for such disclosure or where disclosure is required or permitted by law; and
• other purposes, some of which have been identified in other sections of this Policy.

Our Sites, Services, and Products may, from time to time, discuss investment strategies and our research into a range of industries to evaluate corporate investments. However, we do not currently provide financial, investment or economic advisory services that are specific to any user in the same manner as services offered by credit counselors, financial planners, tax preparers, accountants, and/or investment advisors. As such, we do not qualify as a financial institution and are not subject to the Gramm-Leach-Bliley Act with respect to the privacy of any information that you provide.

Links

Our Sites and Products may contain links to the websites of other organizations which may be of interest to you. Similarly, you may be directed to the websites of other organizations to perform certain functions provided on our Sites. Linked websites are operated by third parties who are responsible for their own privacy practices and you should check those websites for their respective privacy policies. Please refer to our Terms of Service for further information in relation to links to third party websites.

Articles on the Sites may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.  These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. INVESTING INSIDER is not responsible for these websites.

Consent

It is important to us that we collect, use or disclose your personal information only where we have your consent to do so or as provided in this Policy. Depending on the sensitivity of the personal information, your consent may be express, implied or deemed. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you order our Products or Services, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to carrying out your order or for other purposes identified to you at the relevant time. Deemed consent is consent we assume if you do not exercise an opt-out mechanism that is expressly offered to you.

By submitting your personal information to us or obtaining our Products or Services, you consent to the collection, use and disclosure of your personal information in the manner described in this Policy. To the extent that we are required by applicable laws to obtain your express consent for the collection, use or disclosure of your personal information in accordance with this Policy, such consent will be requested at the appropriate time. Further, if we plan to use or disclose your personal information for a purpose not previously identified (either in this Policy or separately), we will advise you of that purpose before such use or disclosure.  However, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us using the contact information set out below. In some circumstances, a change or withdrawal of consent may limit our ability to provide Products or Services to you or your ability to access certain areas of our Sites.

We assume, unless you advise us otherwise, that by receiving a copy of this Policy or by continuing to deal with us, you have consented to the collection, use and disclosure of your personal information as explained in this Policy.

Security

We use reasonable and appropriate measures, including encryption software, designed to help you secure your personal information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the personal information collected by us are authorized to do so. Unauthorized use of personal information by anyone affiliated with INVESTING INSIDER is prohibited and constitutes grounds for disciplinary action. 

Unfortunately, no data transmission over the Internet can be guaranteed as completely secure. While we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us and you do so at your own risk.

You are solely responsible for ensuring that you do not disclose your account access information to third parties.  This includes but is not limited to not disclosing such information to anyone, ensuring that sufficient security software is installed and running on your computer, smartphone or tablet, that your network firewall is of sufficient quality and that your wireless connection is encrypted to a degree that will prevent third party access.  We are not responsible for any failure by you to secure your own device and its access to the Internet or your use of public, unsecured networks. We are also not responsible for any failure by you to eliminate malware.  These failures and others can make you vulnerable to privacy breaches and would put you and your data at risk.

Personal information collected by INVESTING INSIDER or third parties referenced herein may be stored and processed in another country and by using the Sites, you consent to any such transfer of information outside of Canada, including in the United States.  We will use reasonable measures to ensure all personal information is protected, but cannot ensure that the laws of other countries will offer the same level of protection as Canadian and United States laws.  By submitting your personal information to us, you hereby consent to the transmission, processing and/or storage of personal information outside of Canada.

Cookies and similar technologies

In order to improve our Sites on an ongoing basis, we use cookies, web beacons and similar technologies to track your visit.  

A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the website that gave it to you. It functions as your identification card. It is not a program and cannot be executed as code or deliver viruses.  Cookies can also customize a website to your particular interests or store your personal information – like passwords or user IDs. If a site ever greets you with your name, chances are it’s using a cookie to do so.

The cookies and similar technologies we use collect information regarding the type of device, your operating system, the browser you use, your internet service provider, your domain name, your internet protocol (IP) address, the date and time that you accessed our service, the website that referred you to one of our Sites, the web pages you requested and the subject of the ads you click or scroll over, and use such information to evaluate service performance and service quality and to optimize the user’s experience of our Sites.  The Sites also use cookies to provide users with certain features and preference settings.

Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie – this gives you the chance to decide whether to accept it. To learn more about cookies and how to change your settings, please use the help function in your browser.

You can use the Sites without cookies, but you may have to re-enter information each time you visit. When you visit our Sites, Google Analytics adds a cookie to distinguish you from other users and track your behaviour across our Sites. We use this information to improve the user experience of the Sites. The cookie lasts for up to 2 years. You can read about this in the Google Analytics Privacy Policy.

The Sites also utilize the Conversion Tracking Pixel service of Facebook Inc ("Facebook"). This tool allows us to follow the actions of users after they are redirected to a provider's website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remains anonymous, which means we cannot see the personal data of any individual user. However, the collected data is saved and processed by Facebook. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook's Data Use Policy found under: https://www.facebook.com/about/privacy/.

Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside of Facebook. In addition, a cookie will be saved to your computer for these purposes. Please click the following link if you would like to revoke your permission:  https://www.facebook.com/ads/website_custom_audiences/ Failure to click the link will constitute deemed permission to allow Facebook to use your collected data.

Direct Marketing

We are committed to complying with Canada’s Anti-Spam Legislation. Where we have your consent or it is lawful to do so, we may provide you with direct marketing communications about our Products and Services which may be of interest to you. Such information may be sent to you by post, email, telephone or SMS.

If you have consented to receiving marketing materials from us, you can withdraw your consent to receiving those communications at any time by:

• using the “unsubscribe” mechanism in our emails;
• if you have created an account on one of our Sites, logging into your account and changing your contact preferences; or
• contacting us using the contact information provided below.

Even if you exercise one of the above options, we reserve the right to send you transactional or informational emails such as customer service communications in connection with the Products and Services you have purchased or changes to our Sites, your account or our policies for as long as you maintain an account for use on our Sites.

Access to and Corrections of Your Information

You have the right to know what personal information we have about you and to correct any inaccuracies. If a Site allows you to create an account, your personal information is available when you log in to your account and you may correct this information at any time. Otherwise, please direct any such requests by email to support@investinginsider.com.

Data Retention

We may retain your personal information only as long as it is necessary in order to manage our relationship with you (or fulfill the purposes for which it was collected) or as otherwise permitted by law.  We will destroy personal information when it is no longer required for the purposes for which it was collected or as required by applicable law.

Other Pixel Technology Disclosure

This site is being monitored by one or more third-party monitoring software(s), and may capture information about your visit that will help us improve the quality of our service. You may opt-out from the data that Identitypxl is collecting on your visit through a universal consumer options page located at https://pixel.identitypxl.com

Contacting Us

If you have any questions or comments about this Policy, your information, our third-party disclosure practices or your consent choices, please contact us at support@investinginsider.com.

Effective date: 09/17/21.