Huddle Privacy Policy

Last updated: June 3, 2026

Huddle Financial Technologies Inc. (“Huddle”, “Company”, “we”, “us”, “our”) has created this Privacy Policy (“Privacy Policy”) to set out how we collect, use, and disclose information about identifiable individuals and information which can be used to identify an individual (“Personal Information”) through our Website (defined below) and in the course of providing our Website, App, and any other products or services that Huddle may offer from time to time (collectively, all of the foregoing the “Services”).

Privacy is of great importance to us. We do not actively collect Personal Information for the purpose of selling or marketing that Personal Information to third parties. Personal Information may be collected about Users and visitors to the Website, as well as anyone else with our Services. By visiting our website located at https://huddletrade.ca, including subdomains, (collectively, the “Website”), or using the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy. If you are using Third Party Services (as defined in our Terms of Service), then the collection, use and disclosure of your Personal Information will be subject to that Third Party Service provider’s relevant privacy policy.

1. Overview

1.1 A Note About Children. The Services are not intended to be used by anyone younger than the age of majority in their jurisdiction, and in any case, younger than eighteen (18) years old. We do not knowingly collect Personal Information from children under 18. If you are younger than the age of majority in your jurisdiction or under 18, do not use the Services, create an Account, or provide any information to us through any of the Services. If a child under 18 submits Personal Information to Huddle and we learn that the Personal Information is the Personal Information of a child under 18, we will attempt to delete the Personal Information as soon as possible. If you believe that we might have any Personal Information from a child under 18, please contact us at the contact details listed at the end of this Privacy Policy.

1.2 International Users. Huddle is based in Ontario, Canada. If you are a non-U.S. or non-Canadian user of the Services, by visiting the Services and providing us with data, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Privacy Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

1.3 Lawful Processing. We process your Personal Information only to the extent necessary for the purposes described in this Privacy Policy. We set out below the type of Personal Information we collect and how we use such Personal Information. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your Personal Information at any time, however, withdrawing consent may result in your inability to continue using the Services.

1.4 Scope. This Privacy Policy covers the activities of Huddle but does not apply to the practices of companies that we do not own or control, including Third Party Service providers and any services offered by other companies or other sites linked from our Website or Services. This Privacy Policy does not govern any external websites or services, even if such websites or services are linked on Huddle’s Website or through the Services. Huddle is not responsible for the protection of your privacy and/or any information you may provide while visiting any websites or services offered by other companies. You should exercise caution when leaving our Website and read any privacy policies that may apply to external websites or services. You are responsible for ensuring that you have obtained the necessary authorizations and consents for any Personal Information you make available to us for use in accordance with this Privacy Policy.

2. Collection and Use of Personal Information

2.1 What we Collect. Set out below are the ways in which we may collect Personal Information:

  • Personal Information Collected from Users. We may collect Personal Information about our Users through web forms, when a User creates an Account, and through other communications methods used by the Services. The Personal Information provided by Users may consist of their first name, last name, email address, phone number, and any other Personal Information as may be required to provide the Services. We may also collect images, and audio and/or video recordings that are provided by Users. Users will always have control over which of their images, audio, and video files are shared within the Services. We may also collect payment credentials or related information from our Users in order to allow those Users to pay Huddle for Services procured by such customers.
  • Contributions. You may provide information to be posted or displayed on the Website and accessible to other Users and or Third through the Website and the App. Your Contributions are posted and displayed to others at your own risk. We cannot control the actions of the Users with whom you share Contributions, and despite the security measures that we have in place, no system is immune to cyberattacks and we cannot guarantee that your Contributions will not be viewed by unauthorized parties.
  • Derived Data. We may also collect and use Derived Data such as statistical data in the course of offering the Services. Derived Data may be derived from your personal information but is not considered personal information in law as this information will be anonymized, meaning that it does not directly or indirectly reveal your identity. For example, we may anonymize and aggregate your usage data to calculate the percentage of users accessing a specific feature of the Services.
  • Device information. We may collect information about devices you use to access the Services and information about how you use the Services, such as your IP address and which websites you visited before accessing our Services.
  • Logs. Our servers automatically record information created by your use of our Services to help us diagnose and fix technical issues, and to improve the overall quality and user experience of our Services. Logs may include information such as your IP address, browser type, operating system, details of how you used our Services (such as the functions you asked our Services to perform), diagnostic information related to the Services (such as crash activity reports), the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information.
  • Cookies. We use technologies like cookies and pixel tags to gather information about how you are interacting with the Services, which may include identifying your IP address, browser type, and referring page. We may also use Cookies to promote our services through marketing and advertising. Some of the information collected through Cookies can constitute your personal information. You can opt-out of Cookies or prevent third-party websites from accessing our Cookies through privacy settings in your browser, however, opting-out of Cookies may disable some of the Website’s features or cause them not to work properly, and may prevent us from providing you with some information and services that you request.
  • Employee and Contractor Candidate Information. When we seek candidates for potential jobs or contracting engagements with Huddle, we collect information that those candidates choose to provide to us when applying, which may include contact information, education and employment history, credentials, place of residence and other information the candidate believes to be relevant. For people who become our employees or contractors, we will typically retain the information provided by those candidates in the application process along with additional information to manage their employment or contractor relationship with us, including, without limitation, information related to income tax reporting and withholding and enrollment in Huddle benefit plans (in each case, to the extent applicable for the relevant relationship).
  • Marketing Information. From time to time, we may conduct surveys or hold contests or other events and in connection with such surveys, contests, or events, we may collect information you elect to provide about yourself, such as your name, email address, telephone number, organization name and address; and general information about the company for whom you work. In addition, we may use third-party service providers to collected business-related information about your employer such as its name, size, and publicly available revenue in connection with potentially offering the Services to your employer.
  • Huddle Suppliers and Partners. Huddle collects business contact information of individuals who work for our suppliers and other partners to communicate with those suppliers and partners about their business relationship with the Company.

2.2 Use of Personal Information. We may use your Personal Information and Usage Information in a manner that is consistent with this Privacy Policy and the context of our relationship with you. We will use your Personal Information and Usage Information collected through the Site for the following purposes:

  1. provide, operate, maintain and improve the Services;
  2. send technical notices, updates, security alerts and support and administrative messages;
  3. respond to comments, questions, and requests and provide service and support;
  4. communicate with you and provide news or information about us or new products or services, special offers, or other information we think you may find useful or interesting;
  5. determine your eligibility or suitability for certain products, services, opportunities or promotions;
  6. investigate and prevent unauthorized access to the Services and other illegal activities;
  7. monitor and analyze trends, usage, and activities in connection with the Services, including generating aggregated and anonymized statistics;
  8. internal record keeping;
  9. to process your authorized payments for any applicable Huddle Services;
  10. conduct business and contractual relationships that we have with various persons and companies (such as Third Party Service providers, suppliers, partners and employees);
  11. from time to time, to contact you for market research purposes;
  12. for other purposes which we will notify you about and seek your consent; and
  13. as otherwise specifically described in this Privacy Policy.

3. Storage Location and Transfer of Personal Information

Huddle processes and stores its data, including Personal Information, on servers located in the United States. Huddle also transfers data to third-party service providers, including the third-party service providers described on our Sub-Processors webpage, available at: https://huddletrade.ca/subprocessors (“Sub-Processors”). You agree to this transfer, storing or processing of your Personal Information in Canada and United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.

4. Disclosure of Personal Information with Third Parties

4.1 Service Providers and Business Partners. We may from time to time employ third parties to perform tasks for us and we may need to share Personal Information (including account information) with them to perform those tasks. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them perform the relevant tasks for us. The third parties we currently engage include third-party companies and individuals employed or contracted by us to provide certain capabilities within the Services and for certain general business functions, including the provision of database management and payment processing, including the Sub-Processors.

4.2 Third Parties Integrated by User. The integration, use, and/or enabling (as applicable) of any Third Party Services, including but not limited to SnapTrade or any brokerage application, will be subject to the privacy policies which govern and/or apply to such Third-Party Services. If User chooses to integrate the Services with any Third Party Services, acquisition by User of such, and any exchange of data between User and such Third Party Services is solely between User and the applicable third-party provider. Huddle is not responsible for, and Huddle’s Privacy Policy does not govern, any disclosure, modification or deletion of data resulting from access by such Third Party Service or its provider.

4.3 Business Transfers. If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law. Your Personal Information may also be transferred in connection with due diligence for any such transactions. In all cases, if any such transactions occur, your Personal Information will remain subject to the restrictions and protections set forth in this Privacy Policy.

4.4 With Your Consent. If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.

4.5 As Required by Law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:

  • satisfy any applicable law, regulation, legal process or governmental request (including in pursuant to subpoenas, civil investigative demands, or similar processes); enforce our contracts or user agreements, including investigation of potential violations hereof; and
  • detect, prevent, or otherwise address fraud, security, or technical issues.

The above may include exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and know-your-customer purposes.

Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms of this Privacy Policy to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders (including in respect to depositions, interrogatories, subpoenas, civil investigative demands, and other court or regulatory-mandated discovery processes).

5. Retention

We will keep your Personal Information and Contributions indefinitely or until deleted by you, or for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of your Account or our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

6. Security

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure of your information, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online. See our Terms of Use for more details.

7. Access, Correction and Accuracy

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that Personal Information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant Personal Information available to you, such as where that Personal Information also pertains to another individual. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access to and modifications of Personal Information in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your Personal Information. Having accurate Personal Information about you enables us to give you the best possible service.

8. Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated above in the “LAST UPDATED” field. We may amend this Privacy Policy from time to time. Processing of Personal Information we collect is subject to the Privacy Policy in effect at the time such Personal Information is collected, used or disclosed as this Privacy Policy may subsequently be updated in accordance with this Section 10. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or via the Services or sending you an email prior to the change becoming effective. By accessing the Website or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted and agree to be bound by such changes. Please refer back to this Privacy Policy on a regular basis.

9. Contact

Questions regarding this Privacy Policy or Huddle’s privacy practices should be directed to our team:

or by email to info@huddletrade.ca