Spitzer Data Privacy Policy
The following Privacy Policy provides information about how CTFN ("CTFN," "we," "us," or "our") collects, uses, and discloses Personal Data when you access or use Spitzerdata.com, Spitzernews.com, the Spitzer Data iOS application, our related Excel add-in, and all associated online content and services we manage (collectively, the "Services").
This Privacy Policy covers information that identifies or can be used to identify a natural person ("Personal Data"). It is incorporated into and supplements our Terms of Service. By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you have any questions, please contact us using the information in the "Contact Details" section below.
This Privacy Policy applies to all users of the Services, whether you have a paid subscription, a trial, or complimentary access. It supplements any other notices or policies you may receive from CTFN regarding privacy or fair processing and is not intended to override them.
Personal Data We Collect and How It Is Used
CTFN collects Personal Data directly from you, through automated technologies or interactions, and from third parties and public sources, as described below.
- Personal Data collected directly. We collect Personal Data when you interact with our Services, create an account, subscribe, or engage with us by email or phone.
- Automated technologies or interactions. As you use our Services, we may automatically collect technical data about your equipment, browsing actions, and usage. We collect this data using cookies, server logs, and similar technologies, as described in the Cookie Policy below.
- Personal Data from third parties and public sources. We may receive Personal Data about you from our payment and service providers and from publicly available sources.
| Category of Personal Data | Purposes for Collection and Use |
|---|---|
| Name, contact information, and other identifiers — such as your name, email address, account username and password, and similar account identifiers. |
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| Professional or organization information — such as your company or organization, which we may also derive in part from your email domain. |
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| Financial and transaction information — records that link your account to your subscription. Payments are processed by our payment providers; we do not collect or store your payment card number or full payment credentials. |
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| Internet or other electronic network activity information that we collect automatically — information about your device and how you use the Services, collected through cookies and analytics technologies (including Google Analytics and Microsoft Clarity). This may include approximate location derived from IP address, device and browser type, pages and situations viewed, deal pages visited, news headlines and articles clicked or read, links followed, and, via session-analytics tools, interactions such as clicks and scrolling. See the Cookie Policy below. |
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| Mobile app and device information — if you use our iOS app: a push-notification device token (only if you enable notifications), in-app purchase and subscription information processed by Apple and RevenueCat, and an app identifier added to requests so we can serve an app-tailored layout. |
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| Other information that you provide — including preferences and settings you save (such as your watchlist and display choices) and the content of communications you send us. |
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We also collect, use, and share data that has been anonymized or aggregated, such as statistical or demographic data. Anonymized or aggregated data may be derived from your Personal Data but is not considered Personal Data because it cannot be related, directly or indirectly, to an individual's identity.
In addition to the purposes listed above, we may process any of the categories of Personal Data above for the following legitimate business purposes:
- to prevent fraud;
- to protect information security;
- to protect the rights, safety, and property of CTFN, you, and/or others; and
- to comply with legal obligations and/or protect our legal interests.
If you use our iOS app, we do not request access to your location, camera, contacts, or microphone, do not use the Advertising Identifier (IDFA), and do not track you across other companies' apps or websites. To protect paywalled content, the app detects when a screenshot is taken on certain article pages and may end your session; we detect only that the event occurred and do not capture, view, or store the screenshot image.
If You Fail To Provide Personal Data
In some cases, we may need to collect Personal Data by law, or under the terms of a contract we have with you. If you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In that case we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
How We Share Your Information
We do not sell your Personal Data. We do not disclose Personal Data except as may be required or permitted by law, rule, or regulation, or as outlined below:
- To service providers that perform functions on our behalf such as hosting, email delivery, analytics, and payment processing, under contractual obligations to protect your Personal Data and use it only for the services they provide to us. Our service providers include: Stripe (payment processing on the website); Apple and RevenueCat (in-app purchases and subscription management); Resend (sending transactional and notification emails); Apple Push Notification service (delivering push notifications); Railway (database and application hosting); our content-delivery and security provider; and Google and Microsoft (the analytics services described in the Cookie Policy). Where a service provider collects data directly from you, it may do so as set out in its own privacy policy.
- To professional advisers acting as processors, including lawyers, bankers, auditors, and insurers based in the United States who provide consultancy, banking, legal, insurance, and accounting services;
- If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger, restructuring, or business transfer, including as part of a due diligence and transaction process;
- To pursue available remedies or limit damages we may sustain;
- To protect our operations;
- To protect the rights, privacy, safety, or property of us, you, and others; and
- To enforce any applicable terms and conditions.
Where we share Personal Data with the service providers above, we require them by contract to provide a level of protection for your Personal Data comparable to that described in this Privacy Policy. Market-data and news sources we use to build the Services receive only non-personal queries, such as ticker symbols, and do not receive your Personal Data.
International Data Transfers
We are based in the United States and process Personal Data there. We may transfer Personal Data (both nationally and internationally) within our company where necessary, proportionate, and consistent with the purpose for which it was collected. If you access the Services from outside the United States — including from the European Economic Area (EEA) or the United Kingdom — you understand that your information will be transferred to, stored, and processed in the United States, where data-protection laws may differ from those in your jurisdiction.
Where Personal Data is transferred internationally, we use appropriate legal instruments consistent with applicable international legal requirements. Please contact us if you want further information on the specific mechanism we use when transferring your Personal Data out of the EEA or the United Kingdom.
Data Security and Confidentiality
Your Personal Data will be kept confidential in accordance with our policies and procedures. We have put in place reasonable technical and organizational measures designed to protect your Personal Data from loss, misuse, and unauthorized access or disclosure, including encryption of traffic in transit, hashed (bcrypt) storage of passwords, and access controls. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure, and you are responsible for keeping your account credentials confidential.
Data Retention
We will only retain Personal Data for as long as necessary to fulfil the purposes for which we collected it, including for satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and applicable legal requirements.
When you delete your account, we delete or de-identify the Personal Data associated with it — including your activity history and subscription records — except where we are required or permitted by law to retain certain records. You may delete your account as described in the "Your Privacy Rights" section below.
Children's Privacy
The Services are intended for users who are at least eighteen (18) years old and are not directed to children. We do not knowingly collect Personal Data from children under 16. If you are under 16, please do not use the Services or provide any Personal Data. If you believe a child under 16 has provided us with Personal Data, please contact us using the information in the "Contact Details" section and we will take steps to delete it.
Third-Party Links and Services
The Services may include links to, or rely on, third-party websites, plug-ins, and applications, including Apple's App Store and in-app purchase system. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit. Purchases made through Apple are also subject to Apple's privacy policy.
Your Privacy Rights
We provide you with the ability to exercise certain rights regarding our collection, use, and sharing of your Personal Data. In accordance with applicable law, your rights may include the right to:
- request access to, and a copy of, the Personal Data we hold about you;
- request that we correct or update the Personal Data we hold about you;
- request that we restrict processing of, or delete, the Personal Data we hold about you;
- withdraw consent where we have relied on your consent to process Personal Data;
- object to the processing of the Personal Data we hold about you; and
- request an electronic copy of the Personal Data you provided to us, for the purpose of transmitting it to another company (data portability).
You also have the right not to receive discriminatory or differentiated treatment by us because you exercised any of these rights. We process your Personal Data on the legal bases of performing our contract with you (providing the Services), our legitimate interests (such as securing and improving the Services), your consent (for non-essential analytics where required), and compliance with our legal obligations.
You may delete your account, and the Personal Data associated with it, at any time: on the website, from the account menu under LOG OUT; in the iOS app, from the "Delete account" link in the footer; or by contacting us. If you subscribed through the App Store, deleting your account does not cancel that subscription — manage it in your Apple ID settings.
How to Exercise Your Privacy Rights
If you would like to exercise any of these rights, please contact us at the email or phone number in the "Contact Details" section below. Please note that certain Personal Data may be exempt from such requests pursuant to applicable data-protection laws. We will respond to your request consistent with applicable law. In order to protect your Personal Data, we may need to verify your identity by reference to your account before acting on your request, and where the law permits you may use an authorized agent to make a request on your behalf.
California Privacy Rights
If you are a California resident, you have the right to know the categories and specific pieces of Personal Data we collect, the purposes for which we use them, and the categories of third parties with whom we share them; to request deletion or correction of your Personal Data; and to be free from discrimination for exercising your rights. We do not sell your Personal Data and do not "share" it for cross-context behavioral advertising as those terms are defined under California law. California's "Shine the Light" law (Civil Code Section 1798.83) further permits California residents to request information about our disclosures, if any, of Personal Data to third parties for their direct marketing purposes; we do not disclose Personal Data to third parties for their own direct marketing. To exercise any of these rights, contact us as described in the "Contact Details" section.
Cookie Policy
CTFN uses cookies and similar technologies to distinguish you from other users of the Services. This helps us provide you with a good experience and allows us to improve the Services. A cookie is a small file of letters and numbers that we store on your browser or device. We use the following types of cookies:
- Strictly necessary cookies. Required for the operation of the Services — for example, cookies that let you log in to secure areas.
- Analytical/performance cookies. Allow us to recognize and count visitors and to see how users move around the Services, so we can improve how they work.
- Functionality cookies and local storage. Used to recognize you when you return and to remember your preferences and settings.
We do not use advertising or targeting cookies. The specific cookies we use are described in the table below:
| Cookie | Provider | Purpose | More information |
|---|---|---|---|
| ctfn_site_session | CTFN | Strictly necessary. Keeps you signed in to the Services (your authentication session). Set HttpOnly and, in production, Secure. | — |
| sso_checked | CTFN | Strictly necessary. A short-lived marker that coordinates single sign-on between spitzerdata.com and spitzernews.com. | — |
| _ga, _ga_* | Google (Google Analytics) | Analytical/performance. Used to distinguish users and to measure how the Services are used. | policies.google.com/privacy |
| _clck, _clsk | Microsoft (Clarity) | Analytical/performance. Used to recognize and count visitors and to record interactions such as clicks and scrolling, to help us improve usability. | privacy.microsoft.com |
In addition to cookies, the Services use your browser's local storage to remember your preferences and interface state (such as your chosen tickers, ticker-format choice, and layout choices) and, for our Excel add-in, an access token used to authenticate add-in requests. This data stays on your device, and when you are signed in your preferences are also synchronized to your account.
Can I opt out?
Most web browsers automatically accept cookies. You can change your browser settings to notify you when cookies are set or updated, and to block cookies. Please note that if you block all cookies, some features of the Services may not be available or may not function as intended. To learn how to manage cookies on different browsers, you can visit www.allaboutcookies.org. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Add-on (tools.google.com/dlpage/gaoptout). For more information on the privacy practices of Google and Microsoft, see policies.google.com/privacy and privacy.microsoft.com.
"Do Not Track" Browser Settings
We do not currently use technology that recognizes "do not track" signals from your web browser.
Updates to This Privacy Policy
This version was last updated on the date shown at the top of this Privacy Policy, and historic versions can be obtained by contacting us. We reserve the right to change the terms of this Privacy Policy at any time. We will notify you of any material changes before they take effect, by a notice on the Services or by other means, and we will update the "Last Revised" date accordingly. By continuing to use the Services, you agree to the terms of the most current Privacy Policy.
Contact Details
You may contact us by emailing [email protected], or by calling +1 203 635 6555 (US) or +44 (0) 203 514 5314 (UK).
If you are based in the European Union or the United Kingdom, you also have the right to make a complaint at any time to your local supervisory authority for data-protection matters. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please contact us in the first instance.