Privacy Policy

Updated and effective as of July, 12 2017.

This document (“Privacy Policy”) describes how Smoke Supply, LLC. (“Smoke Supply”)  collects, uses, and discloses information about you when you use Smoke Supply's products and services. This policy applies to personal information we collect when you sign up for Smoke Supply; when you access or use our website, products, or services (collectively, the “Site”); or when you otherwise interact with us, including through e-mail, text and other electronic messages. It does not apply to information collected by (i) us offline or through any other means not described herein, or (ii) any third party, including through any application or content (including advertising) that may link to or be accessible from our Site.

This Privacy Policy refers to personal information which is information that can be associated with a specific person and used to identify that person. Personal information does not include information that has been anonymized so that it does not identify a specific user, which may be used for any legal purpose.

GUIDING PRINCIPLES

The relationship between Smoke Supply and our users is the most important asset of our firm. We strive to maintain our users’ confidence, an essential aspect of which is our commitment to protect your personal information to the best of our ability. We believe that all of our users value their privacy, so we will not disclose your personal information to anyone unless it is required by law, at your direction, or is permitted by law and necessary to provide you with our services. We have not and will not sell your personal information to anyone.

WHAT IS Smoke Supply?

Smoke Supply operates a website and series of web-based applications designed to aggregate and analyze financial account data on behalf of individual investors, investment advisors, and financial institutions. Some of our products and services are available for free without registering as a user on our site; other products and services require registering as a user on our system; and other products and services may involve certain fees. Please also reference our Terms of Use for more information on your rights as a Smoke Supply user.

INFORMATION WE COLLECT

To become a registered user on Smoke Supply, you will use a series of online forms to create an account on our systems. Smoke Supply may ask for some personal information when you create an account, including contact information and a password, which is used to protect your account from unauthorized access. Your contact and login information is considered non-public personal information. Smoke Supply will not disclose non-public personal information about its users, except as required and permitted by law, and it restricts access to non-public personal information about users to certain employees who require that information in order to maintain and operate Smoke Supply's systems.

You may be given access to the Site by your financial advisor, in which case your advisor may input your information on your behalf in order for you to use the Site.

Smoke Supply may ask for other personal information in order to provide additional services and products to you. Some of these services may require entering into additional agreements or contracts, as discussed below.

Smoke Supply stores, processes, and maintains data related to your account in order to provide various services and products to you. Our uses for this data are described below.

Smoke Supply also uses standard web analytics tools to gather site usage information for the purpose of improving user experience. As part of this web analytics activity, Smoke Supply may place cookies on users’ computers. Smoke Supply may also place cookies on users’ computers to enable certain Site features. Users who block cookies may not be able to take advantage of all Site functionality. Additionally, for specific sites or applications, Smoke Supply may use web analytics to track usage to confirm compliance with the terms of use of those sites or applications.

We may collect your usage information about how you use the Site, including your access times, location, browser types and language, and Internet Protocol addresses. We may collect device-specific information when you access our Site, including your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device’s interaction with our Site.

We may also collect information about you from third parties, including but not limited to third-party verification sites, credit bureaus, mailing list providers, and publicly available sources. This information may include your Social Security number.

CHILDREN’S PRIVACY

The Site is not directed at children under the age of 13. We operate our websites in compliance with the Children’s Online Privacy Protection Act and will not knowingly collect or use personally identifiable information from anyone under 13.

USE OF INFORMATION

Smoke Supply uses and maintains user information to provide our products and services to you and to help improve these products and services in the future.

Smoke Supply’s systems process the information you provide us for various purposes, including displaying the information to you, delivering related content, performing analysis on your financial accounts, and other purposes relating to Smoke Supply’s products and services. In some cases, if you are using the Site in connection with your financial advisor, information may be displayed to your financial advisor, as described below.

Smoke Supply may send you information related to your account or our products and services. If you decide at any time that you no longer wish to receive such communications from us, please follow the “unsubscribe” instructions provided in the communications.

We may also use information about you (i) to track and analyze trends and usage in connection with our Site; (ii) to process and deliver contest and promotion entries and rewards; (iii) to protect our rights or property; (iv) to compare information for accuracy; (v) to verify your identity; (vi) to investigate and prevent fraud or other illegal activities; and (vii) for any other purpose disclosed to you in connection with our Site.

Additionally, we use information that we collect about you or that you provide to us, including any personal information:

To provide you with information, products or services that you request from us.

To fulfill any other purpose for which you provide it.

To provide you with notices about your account/subscription, including expiration and renewal notices.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

To notify you about changes to our Site.

In any other way we may describe when you provide the information.

For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.

We may use third-party service providers to process and store personal information in the United States and other countries.

USE OF INTERCOM SERVICES

We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as your email address and sign-up date) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. Intercom analyzes your use of our website and/or product and tracks our relationship so that we can improve our service to you. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). As part of our service agreements, Intercom collects publicly available contact and social information related to you to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us at info@smokesupply.com.

INFORMATION SHARING AND ONWARD TRANSFER

We do not sell, rent, or otherwise share your personal information with any third parties except as permitted or required by law.

If you submit, or we otherwise receive, information in connection with an advisor, Smoke Supply may share your information with such advisor. Smoke Supply does not have control over, and shall not be responsible for, how such advisor may subsequently use your information.

Additionally, we may share personal information about you as follows:

To our subsidiaries and affiliates.

To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

To comply with any court order, law or legal process, including to respond to any government or regulatory request.

To enforce or apply our terms of service, available at https://www.smokesupply.com/legal/terms/, and other agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Smoke Supply, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Smoke Supply’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Smoke Supply about our users is among the assets transferred.

To fulfill the purpose for which you provide it.

With your consent or direction.

We may also share non-personally identifiable information (aggregated or otherwise) with third parties for any reason.

INFORMATION SECURITY

We take reasonable measures to safeguard the security of your personal information with industry-standard physical, electronic, and managerial procedures. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on or within the Site.

Q-SYNC

Q-Sync is a service Smoke Supply offers that gives users insights into their current investment portfolios located elsewhere, such as at an online brokerage. Using Q-Sync is entirely optional, but to use Q-Sync, a user must provide our systems with private information to allow our systems to retrieve the information located on the third party’s systems.

Q-Sync will retrieve information about your investment holdings (such as position names, values, trades, transfers, and other information) and store it on our systems. This information will be used in ways described previously.

We extend the same level of information security to this information (such as encryption, limitation of access by Smoke Supply personnel, and other measures) as to other personal information on our systems.

At any time, you may delete this account data from our system by using the appropriate links in the Synced Accounts management area on our website. This will delete all portfolio information from our servers; however, statistics related to aggregating this data with other users’ portfolios (such as the average performance of all Smoke Supply user portfolios) may remain on our servers.

DATA RETENTION

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.

TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

Smoke Supply is based in the United States and we process and store information in the U.S. and other countries. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA

If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing

If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:

• We need to use your personal data to perform our responsibilities under our contract with you (e.g., providing the services you have requested).
• We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our services, and to provide, secure, and improve our services.
• You have given your consent to the processing of your personal data for one or more specific purposes.

Data Subject Requests

If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us at info@smokesupply.com.

Questions or Complaints

If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

YOUR CHOICES AS A USER

You may delete your Smoke Supply account by emailing info@smokesupply.com (please provide information to identify that you are the owner of the account in question). We will endeavor to act on these deletion requests as soon as reasonably practicable. Deletions take effect when we act on them. Residual information related to your account may remain for some time on our servers. Some areas of Smoke Supply’s website and some of Smoke Supply's services will not be available to you unless you choose to share certain personal information (such as our Q-Sync application, which requires access to your outside brokerage account).

Using the “Settings” area of our website, you may delete or change the personal information that you have previously provided the Smoke Supply community. Where our “Settings” tools do not allow you to delete or alter information, you may request such changes by emailing info@smokesupply.com (please provide information to identify that you are the owner of the account in question). As described above, we will endeavor to act on these requests as soon as reasonably practicable, and residual information may remain on our servers. However, we may retain such information, as well as any data related to your trades, in accordance with applicable laws.

THIRD PARTY LINKS

Smoke Supply web sites may contain links to other sites, some of which are not owned by Smoke Supply. Smoke Supply is not responsible for the security or privacy practices of non-Smoke Supply sites, the products or services offered by such sites, or the content appearing at such sites. Likewise, Smoke Supply does not endorse any of the products or services marketed at non-Smoke Supply sites.

Smoke Supply prohibits the framing of any materials available through the Smoke Supply web sites and unauthorized hypertext links to Smoke Supply's web sites. Smoke Supply reserves the right to disconnect or otherwise disable any unauthorized frames or hypertext links.

CHANGES TO THIS POLICY

We may update, amend, revise or otherwise change this Privacy Policy from time to time. We will post any Privacy Policy changes on this page and, if the changes are substantial, we may provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). Each version of this Privacy Policy will be identified at the top of the page by its effective date. Your continued use of the Site constitutes your acceptance of the then-effective Privacy Policy. We encourage you to review the Privacy Policy whenever you access our services or otherwise interact with us to stay informed about our information practices and the choices available to you.

MORE INFORMATION

If you have questions or comments about this Privacy Policy, please email us at info@smokesupply.com.