Legal & Security
Disclosures

Censible operates a website at www.Censible.co (“Website” or “Censible”) and is registered with the U.S. Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended. SEC registration does not imply a certain level of skill or training; nor does it imply that the SEC has sponsored, recommended, or otherwise approved of Censible. Censible does not provide personalized financial planning to investors, such as estate, tax, or retirement planning. Nothing on this Website should be construed as a solicitation or offer, or recommendation, to buy or sell any security. Financial advisory services are only provided to investors who become Censible Clients (“Clients”) pursuant to a written Client Agreement, which investors are urged to read and carefully consider in determining whether such agreement is suitable for their individual facts and circumstances.

This site is for informational purposes only and does not constitute a complete description of our investment services or performance. A copy of our Form ADV Part 2, which contains additional information regarding Censible's business, is available upon request. Information concerning our licensure status or regulatory history may be available from certain state or federal securities administrators, including the SEC. Information throughout this site, including information regarding market or other financial information, is obtained from sources which we and our suppliers believe reliable, but we do not warrant or guarantee the timeliness or accuracy of this information. Neither we nor our information providers shall be liable for any errors or inaccuracies, regardless of cause, or the lack of timeliness of, or for any delay or interruption in the transmission of information to the user.

PAST PERFORMANCE IS NO GUARANTEE OF FUTURE PERFORMANCE, AND ANY EXPECTED RETURNS OR HYPOTHETICAL PROJECTIONS MAY NOT REFLECT ACTUAL FUTURE PERFORMANCE. FURTHERMORE, PAST RETURNS MAY REFLECT THE PERFORMANCE OF ASSETS FOR A FINITE TIME, OR DURING A PERIOD OF EXTREME MARKET ACTIVITY. ALL INVESTMENTS INVOLVE RISK AND MAY LOSE MONEY. There can be no assurance that an investment mix or any projected or actual performance shown on the Website will lead to the expected results shown or perform in any predictable manner. It should not be assumed that investors will experience returns in the future, if any, comparable to those shown or that any or all of Censible's Clients experienced such returns.

Performance information is presented net of all management fees and expenses unless marked otherwise. Commissions are not considered since Clients on the Censible platform are not charged trading commissions. For all periods, the performance information includes the reinvestment of dividends and interest unless otherwise noted.

Any comparison to traditional financial advisors is based on an evaluation of average fees and returns. Actual results may be different for each investor and there can be no guarantee of enhanced returns due to additional diversification or the use of Censible's investment management service.

ANY COMPARISONS TO INDICES ARE PROVIDED FOR ILLUSTRATIVE PURPOSES ONLY. AN INDEX IS A BROADLY DIVERSIFIED, UNMANAGED GROUP OF SECURITIES, WHICH MAY INCLUDE ONLY LARGE CAPITALIZATION COMPANIES OR COMPANIES OF A CERTAIN SIZE. BROADLY BASED INDICES MAY BE SHOWN ONLY AS AN INDICATION OF THE GENERAL PERFORMANCE OF THE FINANCIAL MARKETS DURING THE PERIODS INDICATED. BECAUSE OF THE DIFFERENCES BETWEEN THE CLIENT ALLOCATIONS AND ANY INDICES SHOWN, CENSIBLE CAUTIONS INVESTORS THAT NO INDEX IS DIRECTLY COMPARABLE TO THE PERFORMANCE SHOWN SINCE EACH INDEX HAS ITS OWN UNIQUE RESULTS AND VOLATILITY, AND SUCH INDICES, IF SHOWN, SHOULD NOT BE RELIED UPON AS AN ACCURATE COMPARISON. ONE CANNOT INVEST DIRECTLY INTO AN INDEX.

Recommendations and fees may vary for each Client. Advisory fees are calculated based upon the amount of assets being managed (as detailed further in Censible's Form ADV Part 2).

Censible does not make any representations regarding the execution quality of orders placed with Interactive Brokers or any other brokerage partner. However, Censible does monitor the execution quality of transactions to help ensure that Clients receive the best overall trade execution pursuant to regulatory requirements.

Privacy Policy

Censible’s most essential priority is earning and maintaining your trust. Accordingly, Portfolio.me, LLC, which is the legal name of Censible, believes the privacy and security of your data is of primary importance. This statement summarizes our policies and procedures meant to protect the privacy and security of the personal information you entrust to us.

Personal Data That You Provide Through the Site

The types of personal information that we collect, or are collected on our behalf, depend on your interactions with us, the service(s) available to you and/or the service(s) you have with us. This information may include:

Information that you provide, such as your name, age, salary, investment holdings and preferences, contact information, records of the advice that we provide to you and your communications to us about our services.

Information from third parties such as your financial account information including financial institution, account balances and contributions, name, age, salary, contact information and investment holdings

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Censible and its third-party partners.

We collect server log data which may include your IP address, browser type, domain name, the length of time of your visit, and the number of times you visit. We use this information to aid us in providing services and information that are relevant to you, and to help enhance the customer experience. Censible may store such information itself or such information may be included in databases owned and maintained by Censible affiliates, agents or service providers.

What are cookies and pixels, and how are they used?

Cookies are small amounts of data that are sent to your browser from a web server and stored on your computer’s local storage. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies. We may store some personal information in a cookie and/or pixel, such as the site that you visited immediately prior to visiting Censible and relevant financial information that allows us to enhance your user experience and for marketing purposes. Cookies may be used to measure traffic patterns, analyze clickstreams, or help keep your session secure. If you do not wish to receive cookies, most Internet browsers allow you to turn cookies off so that you do not receive them. If you do turn your cookies off, you will not be able to use some services or features. Additionally, we may use a cookie and/or pixel that only stores anonymous information to track visitors across websites in order to better customize our marketing and advertising campaigns.

How is my information used?

Your personal, investment and forecast information are used by Censible to provide you with services, including information about new features or services from Censible you may be interested in, and to fulfill our legal and regulatory requirements. By having more information about you, we are better able to customize our services to your particular situation.

Data that does not include personally identifiable information may be used for academic research or other research purposes. For instance, we may compile data, excluding personally identifiable information, for purposes of demographic analysis and research.

Also, if you choose to participate in voluntary surveys, webinars or user research which you may receive from time to time, any information you provide will be handled in the manner specified.

How is my information protected?

We follow specific policies and procedures to maintain the confidentiality of your personal information. We maintain physical, electronic and procedural safeguards to protect your information. We also restrict access to your personal information to those of our employees with a business need to know such information.

With whom is my information shared?

Censible will not sell, reveal or share any of your personally identifiable information to others except in one or more of the following limited circumstances:

  • We have your permission to share the information;
  • We need to share your information with companies who work on our behalf to provide a product or service to you or to maintain or service your account (for example with a financial institution to execute transactions, or with a mailing service company to send communications to you; unless we tell you differently, these companies do not have any right to use the personally identifiable information we provide to them beyond what is necessary to assist us); or
  • We are required or authorized by law to disclose your information (for example, to comply with a subpoena or regulatory requirement, or to protect against fraud or illegal activity).

When you are no longer our customer, we may continue to share your personal information as described in this section.

What choices are available to me regarding use of my information?

If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. However, note that as user of the Service we and/or our custodian will send you administrative communications that are reasonably necessary to the Service, such as billing, brokerage or service notifications.

In addition, if we make any material changes in our privacy practices that do not affect information we have already collected, we will post a prominent notice on our Web site notifying you of the change. In some cases we will also notify you by e-mail of certain changes in our privacy practices.

This privacy statement applies to individuals who are current, former, and prospective customers. Our site links outbound to other Web sites and services. Censible is not responsible for the privacy practices or content of these other Web sites or services.

If you have any question, please contact Censible by emailing [email protected].