Privacy Policy

1. Scope; Definitions

1.1. This Privacy Policy (the “Policy”) governs the collection, use, disclosure, and retention of Personal Information by Cheng’s Data Service (“we”, “us”, or “our”), which operates the DoubleTrends™ website and subscription service (the “Service”).

1.2. “Personal Information” means information about an identifiable individual, as that term is understood under Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). This Policy is incorporated into and forms part of the Terms of Service.

1.3. By using the Service, you consent to the collection, use, and disclosure of your Personal Information as described in this Policy. Where required by law, we will obtain your consent at the time of collection; you may withdraw consent as described in Section 9, subject to legal and contractual restrictions and reasonable notice.

2. No Cookies, Analytics, or Tracking

2.1. Our website does not use cookies, web beacons, analytics services, advertising networks, or third-party tracking technologies, and does not create behavioural profiles of visitors. We do not sell, rent, or trade Personal Information.

3. Personal Information Collected and Processed

3.1. Information collected at checkout by our payment processor. When you subscribe, our payment processor (Stripe) collects and processes information required to complete the transaction, which may include your name, email address, billing information, and payment-card details. Such information is collected and processed by the payment processor under its own terms and privacy policy. WE DO NOT RECEIVE OR STORE YOUR FULL PAYMENT-CARD NUMBER.

3.2. Information we store. In our own records, we store only the limited information necessary to administer access, namely: a payment-processor customer identifier and subscription identifier; a checkout-session identifier; a one-time activation token; the Channel invite link issued to you; your Telegram user identifier (once you activate access); your subscription status; and associated timestamps. WE DO NOT STORE YOUR EMAIL ADDRESS, NAME, OR PAYMENT-CARD DETAILS IN OUR OWN RECORDS.

3.3. Information processed by Telegram. When you activate and access the Channel, you interact with the messaging platform Telegram, which processes your Telegram account information under its own privacy policy.

4. Purposes of Use

4.1. We use Personal Information only for the following purposes: (a) to establish, administer, and renew your subscription; (b) to grant, maintain, and revoke access to the Channel; (c) to deliver Signals and related communications; (d) to provide customer support and respond to inquiries; (e) to detect, prevent, and address fraud, abuse, or breaches of the Terms of Service; and (f) to comply with legal, regulatory, tax, and accounting obligations.

5. Service Providers and Disclosure

5.1. We engage a limited number of third-party service providers that process information on our behalf to operate the Service, namely: Stripe (payment processing and subscription billing); Telegram (delivery of the Channel and messages); Cloudflare (backend infrastructure and database); and GitHub (website hosting). Each processes information under its own terms and privacy policy.

5.2. We disclose Personal Information only: (a) to such service providers, to the extent necessary to perform their functions; (b) as required or permitted by applicable law, regulation, legal process, or governmental request; and (c) in connection with a sale, merger, financing, or transfer of all or part of our business or assets, subject to appropriate confidentiality protections.

6. Transfers Outside Canada

6.1. Certain service providers are located in, or process and store information in, the United States or other countries. Where Personal Information is transferred outside Canada, it may be accessible to courts, law-enforcement, and regulatory authorities of those jurisdictions under their laws. By using the Service, you acknowledge that your Personal Information may be processed outside your province of residence and outside Canada.

7. Retention

7.1. We retain Personal Information only for as long as your subscription remains active and thereafter only for as long as reasonably necessary to fulfil the purposes set out in this Policy or as required for legitimate business, legal, tax, and accounting purposes, after which it is deleted, destroyed, or anonymized.

8. Safeguards

8.1. We maintain reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the limited information we hold, in order to protect it against loss, theft, and unauthorized access, disclosure, copying, use, or modification. NO METHOD OF TRANSMISSION OR STORAGE IS COMPLETELY SECURE, AND WE CANNOT GUARANTEE ABSOLUTE SECURITY.

9. Your Rights

9.1. Subject to applicable law, including PIPEDA, you may, upon verified request: (a) access the Personal Information we hold about you; (b) request correction of inaccurate or incomplete information; (c) withdraw your consent to our continued processing, subject to legal and contractual restrictions and reasonable notice; and (d) request deletion of your information.

9.2. To exercise any of these rights, contact us at info@doubletrends.com using the email address associated with your subscription. We will respond within the time required by applicable law. Information held by Stripe or Telegram is subject to their respective policies, and certain requests may need to be directed to them.

10. Children

10.1. The Service is not directed to, and is not intended for, individuals under the age of majority, and we do not knowingly collect Personal Information from them. If you believe a minor has provided Personal Information, contact us and we will take reasonable steps to delete it.

11. Changes to this Policy

11.1. We may amend this Policy from time to time by posting the amended Policy on the website and updating the “Last updated” date. Amendments are effective upon posting. Your continued use of the Service after the effective date constitutes acceptance of the amended Policy.

12. Complaints

12.1. If you are not satisfied with how we have handled your Personal Information or a privacy request, you have the right to make a complaint to the Office of the Privacy Commissioner of Canada.