We respect your privacy and understand that you have a right to know why we collect your personal
information and what we do with it. This Privacy Policy applies to information we collect through our
Services (defined below) as well as information we may collect offline.
This policy describes the type of information we collect from you and/or that you may provide us when
you visit and/or use this website and/or any of our mobile applications (individually or collectively,
“Services”). “You/your/user(s)” means you as a user of our Services. The use of the word “our”, “we”
refer to Sandbox, Sandbox Limited and Sigma Sandbox and its offering of portfolio construction
information provided at www.sigmasandbox.com.
By accessing the Services, you acknowledge this Privacy Policy and agree to be bound by the terms
hereof, the Terms of Service, and any other terms or policies we post on the Sites. If there is anything
you do not understand, please email any inquiry to info@sigmasandbox.com.
If at any time you do not agree to this Privacy Policy, please do not use the Services or provide us
with any personal information.
We reserve the right to change or update this Privacy Policy by posting such changes or updates to the
Services or emailing you notice of the changes. Amendments to this Privacy Policy will be posted at this
URL and will be effective when posted. You can tell if this Privacy Policy has changed by checking the
last modified date that appears at the end of this Privacy Policy. Your continued use of the Services
following the posting of any amendment, modification or change shall constitute your acceptance thereof.
1. TYPES OF INFORMATION WE COLLECT
We collect personal information from you and any devices you use when you purchase
products or use our services. Some of this personal information, such as a way to identify you, is
necessary to complete orders or provide requested information.
We collect various Personal Information in two ways. First, we collect Personal
Information that you provide to us for billing & log in fulfillment. Second, we collect certain
Automated Information that may contain Personal Information that you provide to us.
1.1 Personal Information You Provide To Us
a) Subscription and ordering: Before ordering products through our Services, you
must complete an order form and/or create an account. This will require you to provide certain personal
information, including your name, and billing addresses, phone number, e-mail address, and payment
information. If we encounter a problem when processing your order, we will use the personal information
to contact you.
b) E-mail address: We use your email address as the primary user name for Sandbox
website access. Your email address may also be used for registering for our newsletters and advising you
of new features, user tips, investment themes and information which we believe will be useful to you
including certain 3rd party advertising.
c) Credit Card Information and Bank Account Information: Sandbox uses a 3rd party
Credit Card processor (Stripe) to process subscriptions. We will collect credit card number(s), and
related information through our third party payment processor when you place an order on our Sites. The
credit card credentials will be stored by the 3rd party processor for future use. The card will be
charged at the rate and frequency agreed to in the initial order, and the credit card credentials will
be stored and utilized. Such information will be disclosed to third parties as necessary to complete the
requested purchase transaction.
d) We may collect information that such as MAC address, IP address, UDID and other
unique identifiers to ensure that the user is not re-licensing the software and that the Sandbox license
is accessed by one subscriber.
1.2 Automated Information
We may collect information automatically pertaining to how you use our Services, the
areas of our Sites that you visit, what services you access, and certain information about your computer
hardware and software, including your Internet protocol (IP) address, geographic location, browser
preference, operating system type, domain names in order to facilitate and enhance the Sandbox
experience.
1.3 No Information Collected from Children:
We only collect information from
registered users and never knowingly collect any personal information from children under the age of 13.
If we obtain actual knowledge that we have collected personal information about a child under the age of
13, that information will be immediately deleted from the database. Because we do not collect such
information, we have no such information to use or to disclose to third parties.
1.4 No Sensitive Health Information Is Collected:
We do not collect
information about past, present or potential future medical
conditions or treatments.
2. COLLECTION OF INFORMATION THROUGH COOKIES, WEB BEACONS, AND JAVASCRIPT
Browser information: Browser information is used by us to analyze user trends,
administer our Sites, help prevent fraudulent activity, and help collect demographic information.
Individual activity will not be shared externally unless we are required to do so by law, or to protect
the Sites, our other customers, or anyone else who may be at risk.
2.1 Generally, we, as well as third-party vendors and supporting advertisers, use
technologies such as cookies, web beacons, and JavaScripts. These technologies collect IP addresses,
browser type, ISP, referring/exit pages, operating system, date/time stamp, and/or clickstream data.
This information is used to analyze trends, administer our Sites, track users’ movements through our
Sites and gather demographic information about our user base as a whole.
2.2 Cookies: “Cookies” are a feature in your browser software. If enabled, cookies
store small amounts of data on your computer about actions you take on the pages of our Sites. Cookies
assist us in tracking which of our features you visit most often, and what content you viewed on past
visits. You may read more about cookies at http://cookiecentral.com. In order to use all of the
features and functionality of our Sites, you must accept cookies.
2.3 JavaScript: We use JavaScript and associated software to enhance the
functionality of the Sandbox website, particularly with respect to calculated items and interactive
graphs and pictures. We also use it to analyze and improve our website’s functions. If you de-activate
JavaScript, you will disable key Sandbox functionality.
3. SECURITY
3.1 We endeavor to safeguard and protect your personal information. We employ
physical, electronic, and procedural safeguards to protect the personal information you provide to us.
When you submit information on our Sites, such information is protected both online and offline. We have
security measures in place to protect against the loss, misuse, and alteration of personal information
under our control. The servers in which we store your information are operated and maintained on the
cloud by internationally known 3rd party providers. These providers also have an enhanced level of
security to protect your data. Currently, Sandbox uses Secure Socket Layer (SSL) software to protect
data and secure any transactions. SSL encrypts information, including credit card number(s) and names
and addresses, as they are transmitted over the Internet. All payment transactions will be handled
through our third party payment processor. Please be advised that although we take commercially
reasonable technological precautions to protect your data, no data transmission over the Internet can be
guaranteed to be 100% secure; therefore, we cannot and do not warrant that your information will be
absolutely secure. We cannot guarantee that such information will not be intercepted by third parties,
and we will not be liable for any breach of the security of your Personal Information resulting from
causes or events that are beyond our control, including, without limitation, your own act or omission,
corruption of storage media, defects in third-party data security products or services, power failures,
natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible
for unauthorized circumvention of any privacy settings or security measures contained on the Sites.
However, access to your information is strictly limited and not accessible to the public.
4. HOW WE USE YOUR PERSONAL INFORMATION
We use the personal information we collect from you for a range of different business
purposes. The following is a summary of how and according to which legal bases we use your personal
information.
4.1 We use your personal information to fulfill a contract with you and provide you
with our services, to comply with our legal obligation, protect your vital interest, or as may be
required for the public good. This includes:
a) To provide payment processing and account management; operate, measure and improve
our services; keep our services safe, secure and operational; and customize Site content that includes
items and services that you may like in response to actions that you take.
b) To contact you regarding your account, to troubleshoot problems with your account
or as otherwise necessary to provide you with customer service. When contacting you for such purposes as
outlined above, we may contact you via e-mail, telephone, SMS/text messages, postal mail, and/or mobile
push notifications.
c) To provide other services requested by you as described when we collect the
information.
d) We use general location information to provide you with location-based services
such as advertising and other personalized content).
e) To prevent, detect, mitigate, and investigate fraud, security breaches, or other
potentially prohibited or illegal activities.
4.2 We use your personal information to pursue our legitimate interests where your
rights and freedoms do not outweigh these interests. We have implemented controls to balance our
interests with your rights. This includes:
a) Contacting you via e-mail or postal mail in order to offer you upgrades, discounts
and special promotions; poll your opinions through surveys or questionnaires; and inform you about our
services, as authorized by applicable law.
b) Delivering targeted marketing, service updates, and promotional offers based on
your communication preferences.
c) Monitoring and improving the information security of our Sites.
a) use your personal information to provide you with marketing via telephone calls,
e-mail, SMS, or text.
b) In the future, we may provide you with marketing from third parties.
5.We may disclose your information to the following parties for the following purposes:
5.1 As disclosed in or contemplated by this privacy policy, Sigma Sandbox may
disclose your personal information to government agencies or regulatory authorities where required by
law. It may also be used to help detect, investigate, mitigate, and prevent potentially fraudulent and
illegal acts, violations of our Terms of Use, and data security breaches.
5.2 We may disclose necessary personal information to third parties or service
providers that help us provide services to you or deliver paid products to you. For example, we will
disclose your billing information to payment processors for the purpose of processing transactions you
execute with us; to firms who assist us in providing customized advertising, and help us with the
prevention, detection, mitigation, and investigation of potentially illegal acts, violations of our
Terms of Use, fraud, and/or security breaches.
We may also provide your name, customer history, and mailing address to third
parties—such as service providers, contractors, and third-party publishers and advertisers—for a variety
of purposes.
5.3 In addition we will share your personal information with third parties only
in the ways that are described in this privacy policy.
(a) Website functionality: By inference, we share your information with companies
and individuals we employ to perform technical functions on our behalf. Examples include third parties
Cloud base suppliers who host our Sites, suppliers who analyze our data, provide marketing assistance,
process credit card payments, and provide customer service.
(b) Anonymous information: We share aggregated anonymous information about you,
combined with other persons using our Sites, with third parties, so that they can understand the kinds
of visitors that come to our Sites and how those visitors use our Sites. This includes demographic
information and behavioral information.
(c) Acquisition or merger: We may disclose and transfer your information to a
third party who acquires any or all of our business, whether such acquisition is by way of merger,
consolidation, or purchase of all or a substantial portion of our assets. In the event we become the
subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator,
administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of such
information in a transaction approved by the court.
6. YOUR CHOICES ABOUT HOW WE USE YOUR INFORMATION AND OPTING OUT
6.1 Tracking
You can set your browser to refuse some or all cookies or to alert you when cookies
are being sent. Please visit your specific browser’s instructions for doing this. The “Help” function on
most browsers contains information on how you can set your browser to notify you before accepting
cookies, or you can disable them entirely. If you opt out of cookies, you will not be able to take
advantage of various features of the Sites that are available to other users. For example, we
may use cookies to recognize you by name when you return to this Site so you don’t have to login again
and provide your password each time. If you use more than one browser, you will need to change each
browser’s settings in order to refuse cookies.
7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION?
You may delete your personal information by contacting us at info@sigmasandbox.com and we will delete the
personal information and terminate your usage (unless we need to retain it for the purposes set out in
this Privacy Policy).
8. DATA TRANSFERS
8.1 In the future, personal information that you submit through the services may be
transferred to countries other than where you live, such as, for example, to Cloud-based servers in
North America.
9. CHANGES TO PRIVACY POLICY AND TERMS OF USE
9.1 We reserve the right to make material changes to the substance of this Privacy
Policy. We will post those changes through a prominent notice on the Site so that you will always know
what information we gather, how we might use that information, and to whom we will disclose it.
10 Personal Information You Provide To Us
The following applies to you only if you are a California resident.
10.1 Under California Civil Code sections 1798.83-1798.84, California residents are
entitled to ask us for a notice describing what categories of Personal Information we share with third
parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing
purposes. That notice will identify the categories of information shared and will include a list of the
third parties and affiliates with which it was shared, along with their names and addresses. At this
time, we do not share any Personal Information with third parties or affiliates for their direct
marketing purposes. In addition, California residents have the right to know if we respond to do not
track signals or cookies. We do not respond to such signals or cookies.
10.2. As stated in this Policy, you have agreed to allow us to share information with
third parties for their direct marketing purposes until you remove your information, and thus you have
agreed to this disclosure. California customers may request further information about our compliance
with this law by sending us an e-mail at info@sigmasandbox.com.
Please note that we are only required to respond to one request per customer each year, and we are not
required to respond to requests made by means other than through this e-mail address.
10.3 Please note the following:
Please note the following:
- Users cannot utilize the Sites without providing their Personal Information, including billing
information and IP address through the use of cookies or other tracking technologies; - We will add a link to this Privacy Policy on our home page, or at a minimum, on the first
significant page after entering the Sites; - Our Privacy Policy link includes the word “Privacy” and can be easily be found on the page specified
above; - Users will be notified of any privacy policy changes on our Privacy Policy page;
- We allow the collection of users’ behavioral tracking by third parties for analytical purposes. We
do not authorize the collection of Personal Information on the Sites by third parties, except for
the collection of IP addresses which may BINDING ARBITRATION, AND CLASS-ACTION WAIVER
a. You and we agree that any dispute, claim, or controversy arising out of or relating
in any way to the use of our Sites or sale of our products, Terms and Conditions of Use, shall be
determined by binding arbitration or in small claims court governed by the laws of the Province of
Ontario and the UNCITRAL model law arbitration process of The ADR Institute of Canada (ADRIC). Disputes
will be heard in the Province of Ontario. This arbitration provision shall survive termination of this
Agreement and the termination of your account with us.
b. If you elect to seek arbitration or file a small claim court action, you must
first send us, by certified mail, a written Notice of your claim (“Notice”). The Notice to us must be
addressed to: Sigma Sandbox at 212 Clouston Road, Grafton, Ontario) (“Notice Address”). If we initiate
arbitration, we will send a written Notice to the e-mail address used for your membership account. A
Notice, whether sent by you or us, must (a) describe the nature and basis of the claim or dispute, and
(b) set forth the specific relief sought (“Demand”). If we and you do not reach an agreement to resolve
the claim within 30 days after the Notice is received, you or we may commence an arbitration proceeding
or file a claim in small claims court.
c. YOU AND WE AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS
INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE
PROCEEDING. Further, unless both you and we agree otherwise, the arbitrator may not consolidate more
than one person’s claims with your claims, and may not otherwise preside over any form of a
representative or class proceeding. You agree that all claims will be adjudicated by the courts and
arbitration facilitators as noted. If this specific provision is found to be unenforceable, then the
entirety of this arbitration provision shall be null and void. The arbitrator may award declaratory or
injunctive relief only in favor of the individual party seeking relief and only to the extent necessary
to provide relief warranted by that party’s individual claim.
11. CHILDREN
We do not knowingly permit non-adult persons to use the Sites. If we determine upon
collection of Personal Information that a user is not an adult or does not qualify for some other
reason, we will not use or maintain his/her Personal Information without the parent/guardian’s
consent.
12 NOTICE: ELECTRONIC CONSENT
12.1 These terms and conditions apply to all transactions made on or through this
Site. This Agreement is intended to be governed by the Electronic Signatures in Global and National
Commerce Act. You manifest your agreement to the terms and conditions in this document by any act
demonstrating your assent thereto, including clicking the submit button for the order, or by merely
accessing the Site, whether you have read these terms or not. This includes your authorization to charge
your credit card or debit your bank account. Please print these terms and conditions for your personal
records.
In addition, you consent to receiving electronic communications from Sandbox Limited
relating to your account. You agree that any notices, agreements, disclosures, or other communications
that we send to you electronically will satisfy any legal communication requirements, including that
such communications be in writing. You should maintain copies of electronic communications by printing a
paper copy or saving an electronic copy. You also consent to receiving certain other communications from
us, such as newsletter special offers, promotional announcements, and customer surveys via e-mail or
other methods. By placing an order with us, you will be deemed to have read, understood, and agreed to
these Terms and Conditions of Use (collectively, “Terms”). If you do not agree to be bound by these
Terms, you may not access or use the Site or purchase any products through the Site. By accessing,
using, or ordering products through the Site, you affirm that you have read this Agreement and
understand, agree, and consent to all Terms contained herein.
If Sandbox facilitates use of a third-party website or application (e.g. Facebook,
Google +, Twitter) to access our Sites or your account on our Sites, your activities on such third-party
sites or apps are governed by the privacy practices of those sites or apps. The privacy policies of
other sites and apps may differ significantly from ours, and we have no control over the operation of
those sites or apps or the manner in which the collect, store, or process data.
13. OTHER
Persons under the age of 18 are denied access. By viewing our content, you waive all
rights to claims of damages for any reason, including negligence, arising from the use of Sigma Sandbox.
By viewing our content, you indemnify and hold us harmless from and against all claims. We reserve the
right to deny access to the Sigma Sandbox platform by any person for any reason.
14. CONFIDENTIAL INFORMATION
We do not want you to send to us any confidential or proprietary information through
email or otherwise. If you upload data, including portfolio return information to Sandbox for your
personal use and analysis, this information will be held in confidence for your use only. Other
information, materials, suggestions, ideas or comments sent to us will be considered non-confidential,
and may be utilized in refining our site with no payment or other compensation to you. However, we will
not use your name unless we are required by law to identify the source of the materials, information,
suggestions, ideas or comments, or unless we first obtain your permission.
15. ASSIGNMENT
We may freely assign this Privacy Policy or any of our rights and/or obligations
hereunder to any successor.