Privacy Policy

HoldLens (“we”, “us”, “our”) operates holdlens.com (the “Service”). This page explains what information we collect, how we use it, who we share it with, and the choices you have. By using the Service you agree to this policy.

Who we are

HoldLens is an independent research tool that surfaces publicly-filed SEC 13F data from institutional investors. We are not a broker, investment adviser, or financial services company. Contact: [email protected].

Information we collect

We try to collect as little personal information as possible. The Service runs as a static website, so most browsing activity never reaches our servers. The categories of information that may be collected:

• Information you give us voluntarily. When you subscribe to an email alert or join the waitlist, we collect your email address.
• Technical information from your browser. IP address, device type, operating system, browser type, referring URL, and pages visited. This is collected by the third-party services listed below, not directly by HoldLens.
• Local browser storage. Your watchlist, personal portfolio, saved screener filters, and UI preferences are stored in your browser’s localStorage. This data never leaves your device and we cannot read it.
• Cookies. See the Cookies section below.

How we use information

• To provide, operate, and improve the Service
• To send email alerts and the weekly digest (only if you subscribed)
• To measure traffic and usage patterns in aggregate
• To serve personalized and non-personalized advertising via Google AdSense
• To comply with legal obligations

We do not sell your personal information. We do not build user profiles to sell to third parties.

Cookies

A cookie is a small text file placed on your device by a website. HoldLens itself does not set any first-party cookies. However, the third-party services we use may set their own cookies:

• Google AdSense sets cookies to serve and measure ads, and to prevent the same ad from being shown repeatedly.
• Plausible Analytics is a privacy-first, cookie-free analytics provider that does not use cookies or collect personal data.

You can clear cookies at any time through your browser settings. Blocking cookies will not break the core functionality of HoldLens but may reduce ad relevance.

Third-party advertising (Google AdSense)

HoldLens uses Google AdSense to display advertisements. Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of advertising cookies enables it and its partners to serve ads to users based on their visit to HoldLens and/or other sites on the Internet.

• Third-party vendors, including Google, use cookies to serve ads based on a user’s prior visits to this website or other websites.
• Google’s use of advertising cookies enables it and its partners to serve ads to users based on their visit to this site and/or other sites on the Internet.
• Users may opt out of personalized advertising by visiting Google Ads Settings.
• Alternatively, users may opt out of a third-party vendor’s use of cookies for personalized advertising by visiting www.aboutads.info.
• For users in Europe, visit www.youronlinechoices.eu to manage your ad preferences.
• Read Google’s policy on How Google uses information from sites or apps that use our services for the canonical description of data Google receives when you visit a site that uses Google AdSense.

Analytics

We use Plausible Analytics, a privacy-focused analytics service hosted in the European Union. Plausible does not use cookies, does not collect personal data, and does not track users across websites. It gives us aggregate metrics like page views and referrer sources, nothing more. See the Plausible data policy.

Email data

If you sign up for an email alert or the waitlist, we store your email address. We use it only to send you the alerts you requested. We never sell, rent, or share your email address with third parties. You can unsubscribe at any time by clicking the unsubscribe link in any email.

Data retention

Email addresses are kept until you unsubscribe. Aggregate analytics data is kept for up to 24 months. Server access logs are kept for up to 30 days for security purposes.

Your rights

Depending on where you live, you may have the right to access, correct, delete, or export your personal information, and to object to or restrict certain processing. To exercise any of these rights, email us at [email protected]. We will respond within 30 days.

EU / EEA / UK users — GDPR rights

Under the General Data Protection Regulation (GDPR) and the UK GDPR, if you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights regarding your personal data:

• Right of access (Article 15) — request a copy of the personal data we hold about you.
• Right to rectification (Article 16) — correct inaccurate or incomplete data.
• Right to erasure (“right to be forgotten”, Article 17) — request deletion of your personal data.
• Right to restrict processing (Article 18).
• Right to data portability (Article 20) — receive your data in a machine-readable format.
• Right to object (Article 21) — including objecting to processing for direct marketing or personalised advertising at any time.
• Right to withdraw consent — where processing is based on consent (Article 7), you may withdraw it without affecting prior lawful processing.
• Right to lodge a complaint with a supervisory authority (e.g. the Dutch Autoriteit Persoonsgegevens for NL residents, or your local Data Protection Authority).

For personalised advertising, HoldLens uses a Google-certified Consent Management Platform (CMP) compliant with the IAB Transparency & Consent Framework v2.2. You may withdraw or adjust your advertising consent at any time via the cookie-consent banner on this site.

California residents — CCPA / CPRA rights

Under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), if you are a California resident you have the following rights:

• Right to know what categories of personal information we collect, sources, purposes, and third parties with whom we share it.
• Right to access the specific pieces of personal information we hold about you.
• Right to delete your personal information (subject to legal exceptions).
• Right to correct inaccurate personal information.
• Right to opt out of sale or sharing of personal information. HoldLens does not sell personal information for money. The use of cookies for personalised advertising (Google AdSense) may constitute “sharing” under CPRA — you may opt out via the cookie-consent banner or by emailing [email protected] with subject line “Do Not Sell or Share My Personal Information”.
• Right to limit use of sensitive personal information.
• Right to non-discrimination — we will not deny service or charge different prices because you exercised your rights.

Opt-out of personalised advertising

You may opt out of Google’s use of cookies for personalised advertising by visiting Google Ads Settings. You may also opt out of third-party vendor use of cookies for personalised advertising by visiting aboutads.info (US) or youronlinechoices.eu (EU). On this site, you can also adjust or withdraw advertising consent at any time via the cookie-consent banner. Even if you opt out, you may still see ads — they will simply not be personalised based on your interests.

Children’s privacy

HoldLens is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information, please contact us and we will delete it.

Changes to this policy

We may update this policy from time to time. When we do, we will revise the “Last updated” date at the top of this page. Material changes will be announced via a notice on the homepage for at least 30 days.

Contact

Questions? Email [email protected].

This policy is provided for informational purposes and does not constitute legal advice.