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Privacy Policy

Last updated: 2026-05-01

This Privacy Policy describes how Shears Capital ("Shears Capital," "we," "us," or "our") collects, uses, discloses, and protects the personal information of visitors and subscribers ("you," "your") in connection with the websites located at shearscapital.ca and shearscapital.com (the "Site") and the Morning Market Brief subscription service (collectively, the "Service").

We are committed to handling your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Personal Information Protection Act (PIPA, Alberta).

1. Information We Collect

1.1 Information You Provide

We collect personal information that you voluntarily provide to us, including:

  • Account information: name, email address, country of residence
  • Payment information: processed by Stripe, Inc. We do not store full card numbers, CVV codes, or full bank account details on our systems. Stripe holds this information under its own privacy practices and security standards (PCI-DSS Level 1)
  • Communication content: the contents of emails, support requests, or other communications you send us

1.2 Information Collected Automatically

When you visit the Site or interact with our emails, we may automatically collect:

  • Device and usage data: browser type, device type, operating system, IP address, referring URL, pages visited, time spent, and other anonymous diagnostic data
  • Cookies and similar technologies: small data files stored on your device that help us recognize you across sessions, maintain your subscription state, and measure aggregate usage
  • Email engagement data: open and click events on emails we send, used to measure deliverability and improve content

We do not use third-party advertising trackers. We do not sell your personal information.

1.3 Information from Third Parties

We may receive limited information from:

  • Stripe — subscription status, billing events, and the masked last four digits of your payment card to display in your account
  • Email infrastructure providers (Resend or equivalent) — bounce, complaint, and delivery diagnostic information

2. How We Use Your Information

We use your personal information to:

  • create and maintain your account and subscription;
  • deliver the Morning Market Brief and related communications;
  • process payments and manage billing;
  • respond to your enquiries and provide customer support;
  • improve the Service through aggregate analytics;
  • comply with legal obligations and enforce our Terms of Service; and
  • with your express consent, send marketing or product-update communications you have opted in to receive.

We do not use your information to make automated decisions that produce legal or similarly significant effects on you.

3. Legal Basis and Consent

We collect, use, and disclose your personal information based on:

  • Contract: information necessary to provide the Service you have purchased;
  • Consent: for marketing communications and certain optional features (you may withdraw consent at any time);
  • Legitimate interests: for product improvement, security, and fraud prevention; and
  • Legal obligation: where required by applicable law.

In compliance with Canada's Anti-Spam Legislation (CASL), we will not send you commercial electronic messages without your express or implied consent. Every commercial email we send identifies us as the sender and includes a working unsubscribe mechanism.

4. How We Share Your Information

We share personal information only as described below:

4.1 Service Providers

We use third-party service providers to operate the Service. These providers process your information on our behalf and are contractually obligated to protect it:

  • Stripe, Inc. — payment processing and subscription management (United States; subject to Stripe's privacy policy)
  • Resend (or equivalent transactional-email provider) — email delivery (typically United States; subject to provider's privacy policy)
  • Cloudflare, Inc. or equivalent hosting provider — Site hosting, content delivery, and security
  • Analytics providers (privacy-respecting, e.g., Plausible or Cloudflare Analytics) — aggregate site usage measurement

4.2 Legal and Compliance

We may disclose your information when we believe in good faith that disclosure is necessary to:

  • comply with a legal obligation, court order, or lawful request from a government authority;
  • enforce our Terms of Service or investigate potential violations;
  • protect the rights, property, or safety of Shears Capital, our subscribers, or the public; or
  • prevent or investigate suspected fraud, security, or technical issues.

4.3 Business Transfers

If we are involved in a merger, acquisition, financing, sale of assets, or other change of control, your personal information may be transferred to the successor entity, subject to the same protections set out in this Privacy Policy.

4.4 With Your Consent

We may share your information with other third parties with your express consent.

We do not sell your personal information to anyone.

5. International Transfers

Your personal information may be processed and stored in jurisdictions outside Canada, including the United States, where our service providers operate. When we transfer your personal information outside Canada, we use providers that maintain comparable protection standards and rely on contractual safeguards as required by Canadian privacy law. By using the Service, you acknowledge and consent to such transfers.

6. Data Retention

We retain your personal information for as long as your account is active and for a reasonable period thereafter to:

  • meet legal and tax record-keeping obligations (typically up to seven years for financial records);
  • resolve disputes, enforce our agreements, and prevent fraud; and
  • back up our systems for disaster recovery.

When we no longer need your personal information for these purposes, we will securely delete or anonymize it.

7. Your Rights

Subject to applicable law, you have the right to:

  • Access — request a copy of the personal information we hold about you;
  • Correct — request that we correct inaccurate or incomplete information;
  • Delete — request that we delete your personal information, subject to legal retention obligations;
  • Withdraw consent — withdraw consent for marketing communications or other consent-based processing at any time;
  • Restrict or object — restrict or object to certain processing in limited circumstances; and
  • File a complaint — file a complaint with the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca) or the Office of the Information and Privacy Commissioner of Alberta (https://www.oipc.ab.ca) if you believe we have not handled your information appropriately.

To exercise any of these rights, contact us at admin@shearscapital.com. We will respond within thirty (30) days unless a longer period is permitted by law.

8. Security

We use commercially reasonable technical, organizational, and administrative measures to protect your personal information, including:

  • HTTPS/TLS encryption for all Site traffic;
  • payment information processed exclusively by Stripe, never stored on our systems;
  • access controls limiting employee and contractor access to personal information on a need-to-know basis;
  • regular review of our security practices.

No method of internet transmission or electronic storage is one hundred percent secure. While we strive to protect your information, we cannot guarantee absolute security. You should also take care to protect your account credentials and notify us promptly of any suspected unauthorized access.

9. Children

The Service is not directed at children under the age of eighteen (18). We do not knowingly collect personal information from children under 18. If you believe we may have inadvertently collected information from a child, please contact us and we will take prompt action to delete it.

10. Cookies and Tracking

The Site uses cookies and similar technologies to:

  • maintain your authenticated session and subscription state;
  • remember your preferences;
  • measure aggregate usage to improve the Site and Service.

You can configure your browser to refuse cookies or alert you when cookies are being sent. If you disable cookies, certain features of the Service may not function properly.

We do not use cross-site advertising trackers or behavioural-advertising cookies.

11. Email Marketing and CASL

In compliance with Canada's Anti-Spam Legislation:

  • We send transactional emails (including the Morning Market Brief and account notices) on the basis of your subscription contract with us;
  • We send marketing emails only with your express or implied consent;
  • Every commercial email we send identifies Shears Capital as the sender, includes valid contact information, and includes a one-click unsubscribe mechanism;
  • Unsubscribing from marketing emails will not affect your receipt of transactional emails necessary to provide the Service. To stop transactional emails, you must cancel your subscription.

12. Do Not Track

Some browsers send a "Do Not Track" signal. Because no industry-standard interpretation of this signal currently exists, we do not respond to it. We do not engage in cross-site behavioural advertising regardless of any signal.

13. Third-Party Links

The Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites. You should review the privacy policies of any third-party site you visit.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The version dated above is the operative version. Material changes will be communicated to active subscribers by email and prominently displayed on the Site for at least thirty (30) days before they take effect.

15. Contact

For questions or concerns about this Privacy Policy or our handling of your personal information, contact our privacy contact:

Shears Capital Privacy Contact Alberta, Canada Email: admin@shearscapital.com

If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca) or the Office of the Information and Privacy Commissioner of Alberta (https://www.oipc.ab.ca).