Lexarry Financial Management Ltd.

Privacy Policy

Effective Date: November 28, 2025. Last updated: September 22, 2026

Lexarry Financial Management Ltd. respects your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use Portfolio Club web application (the “Service”).

By using the Service, you agree to the practices described in this Privacy Policy.

1. Information We Collect

We collect only the information needed to operate the Service:

Account Information:

  • Email address, membership status (trial or subscribed), and account settings. Emails and birthdates for you and/or your spouse are stored as encrypted.
  • Payment details for paid memberships are collected and processed securely by a third-party payment processor. We do not store payment or card information and the limited information required for third part processing is stored as encryption.

Investment Account Data:

  • Account holdings, balances, and related financial information that you choose to provide.
  • We do not collect your account numbers. Before a holdings file or a form leaves your browser, each account number in it is replaced with a stand-in made in your browser; the real number cannot be recovered from it.
  • We store only that stand-in and the number's last four characters, which is what links a holdings file to the right account and tells your accounts apart.

User Activity:

  • Information you submit (such as posts, comments, analysis, or shared resources).
  • Interactions with other members inside the Service.

Technical Data:

  • IP address, browser type, device type, operating system, and access times.
  • Cookies to keep you logged in, manage sessions, and understand how you use the Service.

We do not collect more personal information than is necessary for these purposes.

2. How We Use Your Information

We use the information we collect to:

  • Provide, operate, and improve the Service.
  • Manage your membership account and process payments.
  • Communicate with you about updates, support requests, and important notices.
  • Personalize your experience inside the Service.
  • Protect against fraud, abuse, and security threats.
  • Enforce our Terms of Service.

3. Sharing of Information

We do not sell, rent, or trade your personal information to anyone.

We only share information with:

  • Service providers who help us operate the Service (e.g., hosting companies, payment processors, analytics providers), under confidentiality obligations.
  • Legal authorities if required by law, court order, or government request.

4. Visibility of User Content

Some information you post within the Service will be visible to other members (for example, contributions, analyses, or comments shared in member areas).

You should not share personal, confidential, or sensitive information in any area visible to other members.

5. Cookies and Tracking

We use cookies and similar technologies to:

  • Keep you signed in and manage sessions.
  • Remember your preferences.
  • Analyze how members use the Service to improve it.

You can disable cookies in your browser settings, but some features may not work without them.

6. Data Retention

We keep your personal information for as long as your membership is active.

When your membership ends — whether you close it, cancel it, or it lapses — we keep your information for six months and then delete it permanently. That window is there so you can come back and pick up where you left off. During it we stop updating your data: your accounts and holdings stay exactly as they were on the day your access ended.

You can ask us to delete your information sooner at any time, from your account settings or by contacting us, and we will do it right away.

We always tell you before anything is deleted. You will hear from us when the six months begins, again about a month before the end, and once more a week before. These notices reach you whatever your email settings say — they are how we make sure nothing is deleted without warning you first.

After deletion we keep one small record: a scrambled, non-reversible form of your email address and your billing reference. We keep these to meet our tax record-keeping obligations and to recognise you if you sign up again. Neither can identify you on its own, and we never use them to contact you.

If you asked us to keep sending you the newsletter, we keep your email address for that alone. You can unsubscribe at any time using the link in any newsletter.

7. Security

Your data is stored on servers that are encrypted at rest and reached only over encrypted connections. Backups are taken daily and are encrypted too.

Inside the database, we add a second layer: your email address and other identifiers are encrypted by the app itself, with a key that never leaves our server environment. Someone with a copy of the database would not be able to read them.

Your investment account numbers we never receive at all. Before a holdings file or a form leaves your browser, the number in it is replaced with a stand-in made in your browser, from which the real number cannot be recovered; we store only that stand-in and the number's last four characters.

Every page that shows your accounts and plans is tied to your login. Our own staff tools have no pages that browse members' accounts, holdings or plans.

Sign-in uses a password plus a code we email you, which is on for every member unless you turn it off. Repeated wrong passwords pause sign-in for that email from that connection. Staff accounts always use the code and have no separate way in.

We review our security each month alongside our software updates.

No method of storage or transmission is completely secure, so we cannot promise absolute security. You can help by choosing a strong password, keeping the emailed code on, and not sharing either.

8. Your Rights

Under Canadian privacy laws, you have the right to:

  • Request a copy of your personal information.
  • Request corrections to your personal information.
  • Withdraw consent for us to use your information (which may limit your use of the Service).

To exercise your rights, contact us at the email address below.

9. Where Your Data Is Stored

Our servers and backups are located in the United States, with a hosting provider certified to SOC 2 and ISO 27001. Your information is protected there in accordance with this Privacy Policy and applicable Canadian law.

10. Changes to this Policy

We may update this Privacy Policy from time to time. If we make significant changes, we will notify you by email or through the Service.

11. Contact Us

If you have any questions or concerns about this Privacy Policy or our privacy practices, you can contact us at:

Lexarry Financial Management Ltd.
admin@portfolioclub.ca