GLBA Financial Privacy Notice

Last updated: 2026-07-08

This GLBA Financial Privacy Notice describes how Lutz Consulting Group, LLC, a Nevada limited liability company doing business as Candella Labs ("Candella", "we", "us"), collects, uses, shares, and protects your nonpublic personal information in connection with the Service. It is provided under the federal Gramm-Leach-Bliley Act ("GLBA") and its implementing regulations, including the Consumer Financial Privacy Rule and the Safeguards Rule.

This notice is specific to the financial information described below. It is separate from, and supplements, our general Privacy Policy at candella.dev/privacy, which describes our overall data practices. Where a term is defined in the Candella Copytrade Addendum at candella.dev/terms/copytrade (the "Addendum") or the Master Terms at candella.dev/terms, it has the same meaning here, including Service, Lead Trader, Follower, Mirroring, Manual Approval Mode, Automated Mode, and Sponsorship Code.

The Service is currently operated by Lutz Consulting Group, LLC. It is expected to be assigned to a successor entity, currently anticipated to be Candella Inc, upon that entity's formation. This notice will apply to the successor entity with the same scope, and we will update the entity name and notify you at the time of assignment.

1. Why We Provide This Notice

Candella is treated as a "financial institution" under the GLBA because we access consumer financial account and transaction data to provide the Service. Specifically, to operate Mirroring and the rest of the Service, we connect to your brokerage account through a third-party connectivity provider, SnapTrade, operated by Passiv Technologies Inc. ("SnapTrade"), and we read account, order, and fill data from that connection.

We provide this notice so you understand what nonpublic personal information we collect, how we use it, the limited circumstances in which we share it, and your right to limit certain sharing. We are required to give you this notice, and we will send you a revised notice if our practices change in a way that requires one.

Candella is a technology and execution-software platform. We are not a registered investment adviser, broker-dealer, commodity trading advisor, or fiduciary. Your brokerage, connected through SnapTrade, is the regulated entity that effects trades in your own account. This notice is about privacy, not investment advice.

2. What We Collect (Nonpublic Personal Information)

"Nonpublic personal information" means personally identifiable financial information that you give us, that we get from your transactions, or that we obtain from a third party on your behalf. The categories we collect are:

Identity and contact information. Your name, email address, account credentials, and information you provide when you register or verify your account.
Brokerage-connection metadata and tokens. The connection metadata, authorization identifiers, and access tokens or secrets we obtain when you link a brokerage through SnapTrade's OAuth flow, along with which brokerage you connected and the account identifiers associated with that connection.
Transaction, order, and fill data. Orders, executions, fills, positions, symbols, quantities, prices, and timestamps read from your connected brokerage account, along with the Mirroring records the Service generates from that data.
Usage data. Information about how you configure and use the Service, including subscription settings, sizing and limit parameters, execution mode selections (Manual Approval Mode or Automated Mode), Sponsorship Code redemptions, and the logs of orders reviewed, approved, rejected, or mirrored.

We do not custody your funds or securities, and we do not have authority to withdraw funds or transfer assets. Your money and positions remain at your brokerage at all times.

3. How We Use It

We use the nonpublic personal information described above to operate the Service for you, including to:

Establish and maintain your brokerage connection through SnapTrade.
Detect a Lead Trader's trades and perform Mirroring into a Follower's connected brokerage account, sized and adjusted according to that Follower's settings and execution mode.
Apply your configured limits and caps before submitting any order.
Present orders for review in Manual Approval Mode, submit orders in Automated Mode within your configured limits, and log every mirrored order for your review.
Provide account, history, and reporting surfaces, deliver notifications, process subscription billing, prevent fraud and abuse, and comply with applicable law.

We earn flat platform and subscription fees. We never take a share of your trading profits and never charge a per-trade commission. A Lead Trader is an independent third party who may separately bill their own Followers off-platform; Candella is not a party to and is not responsible for those off-platform billing arrangements or a Lead Trader's own regulatory compliance.

4. Who We Share It With

Candella does not sell your personal information. We do not share it for anyone else's independent marketing.

We share nonpublic personal information only with the limited categories of nonaffiliated third parties needed to run the Service, or as required by law:

SnapTrade (Passiv Technologies Inc.). Our brokerage-connectivity provider, which reads account data and routes the orders you authorize.
Your own brokerage. The regulated entity that holds your account and effects trades in it.
Infrastructure and service providers. Vendors that host, secure, and operate the Service on our behalf (for example, hosting, database, payment processing, notification delivery, and error-monitoring providers), each permitted to use the information only to perform services for us.
As required by law. To respond to lawful requests, subpoenas, or legal process, to protect our rights, or to comply with applicable regulation.

Your use of SnapTrade and your brokerage is also governed by their own agreements and privacy notices. We are not responsible for the independent practices of these third parties.

5. Your Right to Limit Sharing

Federal law gives you the right to limit certain sharing of your nonpublic personal information with nonaffiliated third parties, subject to exceptions. The sharing described in Section 4 is done to provide the Service you requested, to process your transactions, at your direction, or as required by law, and those categories are permitted without opt-out under the GLBA.

We do not share your nonpublic personal information with nonaffiliated third parties for their own use, and we do not sell it, so there is no such sharing for you to opt out of today. If we ever propose to share your nonpublic personal information in a way that triggers an opt-out right, we will give you a revised notice and a reasonable opportunity to opt out before we do so.

To ask a question about your information, to limit sharing to the extent the law allows, or to disconnect your brokerage (which revokes the Service's access to that connection), contact us using the information in Section 8 or use the controls in your account settings. Disconnecting a brokerage stops further collection from that connection.

6. How We Protect It

We maintain a written information security program designed to meet the requirements of the GLBA Safeguards Rule. The program includes administrative, technical, and physical safeguards appropriate to our size and the sensitivity of the information, including access controls, encryption of sensitive credentials in transit and at rest (brokerage tokens and secrets are encrypted), least-privilege service access, monitoring, and periodic review of our safeguards and service providers.

No system is perfectly secure. If a breach of security affecting your nonpublic personal information occurs, we will investigate, take reasonable steps to contain and remediate it, and notify you and any applicable regulator as required by law, without unreasonable delay.

7. Retention

We keep your nonpublic personal information for as long as your account is active and as needed to provide the Service, and afterward as required to comply with legal, regulatory, tax, and recordkeeping obligations, including retention of trading-related records. Details are in our Privacy Policy at candella.dev/privacy.

8. Contact

Lutz Consulting Group, LLC, d/b/a Candella Labs
10120 W Flamingo Rd, Ste 4-2055
Las Vegas, NV 89147-8394
United States
Email: support@candella.dev

For our full data practices, see the Privacy Policy at candella.dev/privacy.