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For issuersAbout

Candor Privacy Policy

Last updated June 13, 2022

This Privacy Policy describes the specific policies and procedures we use to collect, utilize, disclose, share and protect your Personal Information in connection with your use of the products and services offered by Candor Inc. and our subsidiaries (“Candor,” “we,” “us,” “our”). Together with our Terms and Conditions , this Privacy Policy governs your use of our technology and services available at candor.co.

If you are an advisory client of Candor Financial LLC, please note that the Privacy Notice describes how we use your personal data to provide financial services and supplements these terms.

Types of Data collected

Candor collects the following Personal Data from and about Users: Cookie data, Usage Data (as defined below), email address, first name, last name, company name, Social Security number, date of birth, address, citizenship information, bank account information, and any other Personal Data communicated while using the service. In some cases, we may also collect scans of your passport, Social Security card, or other information to verify your identity. Depending on the Candor Service you are using, we may collect some or all of this Personal Data.

Personal Data may be provided by the User, or, in case of Usage Data, collected automatically when using Candor. We may also obtain Personal Data from third-party sources such as publicly or commercially available databases.

It is your choice whether to provide Candor with any data Candor requests. However, if you do not provide Candor with such data, Candor may not be able to provide the Services or some features thereof. Unless stated otherwise, requested data is necessary for the services to function properly. If you are unsure about what data the Services need to function properly, please contact Candor using the information above.

Any use of Cookies – or of other tracking tools – by Candor or by the owners of third-party services used by Candor serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Candor and confirm that they have the third party's consent to provide the Data to the Owner.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Heat mapping and session recording, Managing contacts and sending messages, Analytics, Tag Management, User database management, Remarketing and behavioral targeting, Advertising, Handling payments, Contacting the User, Content performance and features testing (A/B testing), Infrastructure monitoring, Hosting and backend infrastructure, Managing web conferencing and online telephony and Displaying content from external platforms.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest- based advertising on mobile apps.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

How Personal Data is disclosed

Candor discloses Personal Data to the following parties and in the following circumstances.

  • Service Providers. Candor provides access to or discloses Personal Data to select third parties who help Candor deliver or improve the Service or perform services on Candor’s behalf, including billing and payment, advertising and marketing, analytics, “know your customer” services, research, data storage, website hosting, security, and consulting and legal services.
  • Protection of Candor and Others. By using the Service, you acknowledge and agree that Candor may access, retain, and disclose Personal Data that Candor collects and maintains about you if required to do so by applicable law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce any contracts with you; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of Candor, its agents and affiliates, its Users and/or the public.
  • Business Transactions. In accordance with applicable legal obligations, Personal Data may be provided to third parties in connection with a merger or acquisition (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Candor or its assets, or as part of a corporate reorganization or stock sale or other change in corporate control or business change, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
  • Aggregate/De-Identified Information. From time to time, Candor may disclose Aggregate/De-identified Information about use of the Services or Candor’s user base to partners and others in Candor’s discretion, but such information will not identify Users personally.
  • With Your Consent. We may disclose Personal Data to third parties whenever you consent to such disclosure.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Candor or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Candor may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Candor and any third-party services may collect files that record interaction with Candor (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Candor does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Additional privacy information for California residents

If you are a California resident, California law requires Candor to provide you with some additional information regarding how Candor collects, uses, and discloses your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

A. Categories of Personal Information Candor Collects

Candor collects the following categories of personal information from and about you:

  • Identifiers, such as name, address, email address, and IP address
  • Other personal information regulated by California law, such as Social Security number, passport number, and financial information such as bank information
  • Professional or employment information (such as the name of the company you work for)
  • Device and online information (such as information about your browser and operating system, and other information within the definition of Usage Data, below)

B. How Candor uses and discloses these categories of personal information

Candor uses the above categories of personal information for the purposes as described throughout this Privacy Policy. Candor may disclose personal information in any of these categories to the parties listed in the section above titled “How Personal Data is disclosed.” These parties include service providers, third parties to business transfers (e.g., a company that Candor acquires or is acquired by), professional advisors (such as lawyers and accountants), government authorities and law enforcement (as described above), or other third parties for purposes of fulfilling legal obligations, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property, or safety of you, Candor, or another party; enforcing any agreements with you; responding to claims; and resolving disputes.

The CCPA sets forth certain obligations for businesses that “sell” personal information to third parties, meaning that the business provides personal information in exchange for something of value. In the past twelve months, Candor has “sold” personal information in this sense in the following ways:

  • Usage Data (made available to advertising networks for personalized or interest-based advertising)

You can opt out of these “sales” of personal information by contacting Candor.

C. Your California privacy rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information
  • Provide access to and/or a copy of certain personal information we hold about you
  • Delete certain personal information we hold about you

The CCPA further provides you with the right not to be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, Candor needs certain information in order to provide the Service to you. Candor will take reasonable steps to verify your identity before responding to a request. In doing so, Candor may ask you for verification information so that Candor can match at least two verification points with information Candor maintains in its files about you. If Candor is unable to verify you through this method, Candor shall have the right, but not the obligation, to request additional information from you. If you would like further information regarding your legal rights under California law or would like to exercise any of them, or if you are an authorized agent making a request on a California consumer’s behalf, please contact Candor using the information at the beginning of this Privacy Policy.

The CCPA requires Candor to inform you of any financial incentives we offer. While Candor does not offer incentives that are monetary or “financial” in nature, the salary comparison Service does require you to provide information about your job and salary in order to view all information in the Service. Thus, although this exchange is not monetary, Candor requests something of value from you (data about your job and salary) in return for providing you with something of value (data about other people’s jobs and salaries).

Changes to this privacy policy

We may update this Privacy Policy from time to time by posting the updated version on the Site and updating the “Last updated” date at the top of the page containing the updated text.

Contact information

If you have questions, or to contact us as provided in this Privacy Policy, you can email us at hello@candor.co or write to us at:

Candor Inc.
2021 Fillmore St #9007
San Francisco, CA 94115

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Advisory services provided by Candor Financial LLC, an SEC registered investment adviser. Brokerage services provided to clients of Candor Financial LLC by Apex Clearing, an SEC registered broker-dealer and member of FINRA/SIPC.
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Investments in securities: Not FDIC Insured • No Bank Guarantee • May Lose Value

Investing in securities involves risks and there is always the potential of losing money when you invest in securities. Before investing, consider your investment objectives and Candor Financial LLC's charges and expenses. Candor Financial LLC's internet-based advisory services are designed to assist clients in achieving discrete financial goals. They are not intended to provide comprehensive tax advice or financial planning with respect to every aspect of a client's financial situation and do not incorporate specific investments that clients hold elsewhere. For more details, see Form CRS (conversation starters) and Wrap Fee Program Brochure.

Past performance does not guarantee future results and the likelihood of investment outcomes are hypothetical in nature. Not an offer, solicitation of an offer, or advice to buy or sell securities in jurisdictions where Candor Financial LLC is not registered.