Privacy Policy

1. Introduction and Scope

‍The Circle ("Investors Circle Inc.," "we," "us," or "our") operates in Ontario, Canada, and is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information (as defined by applicable law).‍This policy applies to your use of the The Circle website, newsletters, and all related services (collectively, the "Service"). It is designed to ensure compliance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL).‍Our policy is built upon the 10 Fair Information Principles mandated by PIPEDA.‍

2. Principle 1 – Accountability

‍We are responsible for the personal information under our control. We have designated a Privacy Officer who is accountable for our compliance with this Policy and applicable privacy laws.‍

‍Contact Information:Attn: Privacy Officer The Circle,

‍Investors Circle Inc.49 Wellington St. East, Suite 500

Email: contact@theinvestorscircle.ca

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3. Principle 2 – Identifying Purposes

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‍We identify the purposes for which personal information is collected at or before the time of collection. These primary purposes include:

• To Provide the Service: To create and manage your account, deliver newsletters, research reports, and provide access to member-only content.
• To Manage Subscriptions: To process payments, manage your subscription, and handle billing inquiries through our processor, Stripe.
• To Communicate with You: To send transactional messages (such as subscription confirmations and password resets) and respond to your inquiries.
• To Market and Promote (CASL Compliance): To send Commercial Electronic Messages (CEMs), such as our newsletters, special offers, or information about new services, only with your express, verifiable consent.
• To Improve Our Offerings: To analyze usage data in an aggregated and anonymized format to understand how our Service is used, enhance content, and improve user experience.
• To Maintain Security and Compliance: To protect against fraud, detect unauthorized account sharing, and meet our legal and regulatory requirements.‍

4. Principle 3 – Consent

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‍We obtain your meaningful consent for the collection, use, or disclosure of your personal information, except where authorized or required by law.

• Express Consent: By subscribing (Open Circle or Inner Circle), affirmatively checking a consent box, and providing your information, you expressly consent to the collection, use, and disclosure of your information as described in this Policy and to receive electronic communications from us.
• Withdrawing Consent:
  • CEMs: You may withdraw your consent to receive CEMs at any time by clicking the "unsubscribe" link found in every email. We will process this request promptly and within the 10-business-day timeframe required by CASL.
  • Personal Information: You may withdraw your consent for the collection or use of your personal information by contacting our Privacy Officer. However, withdrawal of consent for uses that are necessary to provide the Service (e.g., your email address) will result in your inability to access the Service, and your subscription will be terminated.‍

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5. Principle 4 – Limiting Collection

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We limit the collection of personal information to that which is necessary for the purposes identified.‍

a. Information You Provide Directly:

• Contact Information: Name and email address.
• Optional Profile Information: Any information you choose to provide (e.g., self-identified investor type or interests).
• Communications: Any comments you submit or communications with us.‍

b. Financial Information:

• Payment details are collected and processed directly by our third-party processor, Stripe. We do not store or have access to your full credit card details.‍

c. Information Collected Automatically:

• Usage Data: Information on how you interact with the Service (e.g., newsletters opened, links clicked, page views).
• Technical Data: IP address, browser type, device type, and operating system, collected via our platform (WordPress) and privacy-focused analytics tools.

6. Principle 5 – Limiting Use, Disclosure, and Retention

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a. Use and Disclosure:We do not sell, rent, or trade your personal information. We may share information only as necessary with trusted third-party service providers under strict confidentiality agreements for the following purposes:

• Payment Processing: Stripe (or its successor).
• Platform and Hosting: Our website hosting provider.
• Email Delivery: Our third-party email service provider (e.g., Mailgun, SendGrid, etc.).

We may also disclose information if required by a valid legal order (such as a warrant or subpoena) or during a business transfer (e.g., merger or acquisition), in which case we will ensure the new entity honors this Policy.‍

b. Retention:We retain personal information only as long as necessary to fulfill the identified purposes, to maintain your subscription, or as required by law (e.g., for tax and corporate record-keeping). After this period, personal information is securely destroyed or anonymized.‍

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7. International Data Transfers

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We are based in Canada. However, some of our essential service providers (like Stripe, our hosting service, or our email provider) are located in or process data in the United States or other countries.‍As a result, your personal information may be transferred, processed, and stored outside of Canada. While outside of Canada, your information is subject to the laws of the country in which it is held (e.g., the USA PATRIOT Act), and may be accessible to the government, courts, or law enforcement agencies of that country. We use contractual and other measures to ensure our service providers protect your information in a manner consistent with Canadian privacy laws.‍

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8. Principle 6 – Accuracy

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We strive to ensure your information is accurate and up-to-date. You can update your information (such as your email address) through your account settings or by contacting us.‍

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9. Principle 7 – Safeguards (Data Security)

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We use appropriate physical, organizational, and technological safeguards to protect your information from unauthorized access, use, disclosure, or destruction. These measures include SSL encryption, strong access controls, and secure hosting environments.‍However, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.‍

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10. Principle 8 – Openness

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We make information about our policies and practices readily available. This Privacy Policy is accessible on our website at all times.‍

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11. Cookies and Tracking Technologies

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We use cookies and similar technologies (like pixels in emails) for essential and analytical purposes:

• Essential Cookies: To ensure the website functions correctly (e.g., managing login sessions, account security).
• Analytical Cookies: To analyze website traffic and newsletter performance (e.g., open rates).‍You can control cookies through your browser settings, but disabling essential cookies may impair website functionality.‍

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12. Principle 9 – Individual Access

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You have the right to access and correct the personal information we hold about you. To request access, please contact our Privacy Officer in writing. We will respond within the statutory 30-day period, subject to any legal exceptions (e.g., if the information is subject to solicitor-client privilege or contains information about other individuals).‍

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13. Principle 10 – Challenging Compliance

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You have the right to challenge our compliance with this Policy. Please contact our Privacy Officer with any complaints. We will investigate and respond to all complaints.‍If you are unsatisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada.‍

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14. Changes to this Privacy Policy

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We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. We will notify you of any changes by posting the new Policy on this page and updating the "Last Updated" date. For material changes, we will also provide notice via email.

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