Last Modified: October 30, 2019
- You must be over 13 years old to use the Invstr Services
- We collect information about you as you use the Invstr Services
- We use this information in order to provide you a personalized experience
- Information we collect from you may be shared, stored or processed with our service providers and in countries outside the European Economic Area. In these cases we ensure your data is treated securely
- You are in control of your data and can modify your preferences at any time
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified below. Consent is required for Invstr Limited (“We” or “Us”) to process your personal data, but it must be explicitly given by you. You may withdraw your consent at any time. Please note that if you do not upgrade the Services, specifically the Invstr app, to the latest version releases and accept our terms, You will neither be able to receive nor transfer personal data to another third party.
Personal information means information about you that is personally identifiable, including your name, location, mobile phone number, email address, sentiment or performance data in terms of what news you read, like, share or comment on, the choice of instruments you may add to your watchlist and interactive investment games, including game capital you purchased, your game performances, or your learning performance (“Invstr Academy”).
Are We Registered?
We have notified the Information Commissioner’s Office that We are a data controller and are registered on the Data Protection Register under registration number ZA061953.
What Personal Information do We Collect?
We may collect and process the following information about you:
- any personal information you provide to Us when you create an account, including details supplied by but not limited to Facebook, Twitter, Google or LinkedIn, if you use the social login function, to use some or all of the Invstr Services
- any personal information you provide when using the Invstr Services (including all behavioral and activity data generated through your activity with respect to the Invstr Services), for example our messaging facilities, performance and behavioural data generated through your participation in our interactive investment games, or Invstr Academy;
- details of transactions you carry out via our App or Website, including any payment or billing information you provide to Us through the App or Website. Notwithstanding, please note that purchase details via App Store and Google Play are held by them and not Us
- if you contact us by whatever means, We may keep a record of that correspondence;
- where you agree to an error report being sent to us, any information contained in that error report, for example an error report contains details of the error and other potentially relevant information collected from your device (for example: operating system version, drivers, etc)
- details of your use of the Invstr Service, the resources you access, which may include IP addresses, ISP, clickstream data, viewed and exit pages and date or time stamps
- details about the devices you may use to access the Invstr Services, which may include the device’s unique identifiers, operating system, browser type and network information; and personal information posted by other users through the messaging and chat functionalities of the App and Website
- geo-location data solely for the purpose of tailoring the layout and information on the App and Website to be most appropriate to the jurisdiction in which you are located
How do We Use Your Personal Information?
We may use your personal information in the following ways:
- to store and retrieve your account data, so that your preferences and customisations can be remembered as well as your achievements and progress in our interactive investment games
- to help Us improve the Invstr Services
- to help Us protect against attacks to the Invstr Services
- to help Us fix problems with the Invstr Services
- to ensure that content from the Invstr Services is presented in the most effective manner for you and for your device
- to allow you to participate in interactive features of the Invstr Services (including our interactive investment games)
- to notify you about changes to the Invstr Services
- to send you marketing emails, unless you have asked Us not to. You can unsubscribe from our emails at any time by following the unsubscribe link at the bottom of each message, or by changing your marketing communication settings in your profile settings
- to send you our newsletter, unless you have asked Us not to. You can unsubscribe from our newsletter at any time by following the unsubscribe link at the bottom of each newsletter, or by contacting Us using the contact details provided at the end of this policy
- to send you in-app notifications related to marketing, or to direct you to relevant information within the Invstr Services. You can opt-out of in-app notifications via the Appstore or Google Play store settings
- to support our marketing, retargeting and behavioral targeting activities
- to process any transactions you make via the Invstr Services and to monitor, prevent and detect fraud
- to send you transactional messages via app or email related to the management of your Invstr account and your use of the Invstr app. These messages are critical to the use of the service and you are not able to opt-out of them. They will not be used to send you marketing messages
Will We Share Your Personal Information?
With your permission, we may disclose your personal information to third parties for the following purposes:
- Games promotions: We may use your name in any publicity material should you win a Game competition, in accordance with current UK data protection legislation
- Service providers: We contract with service providers who perform certain functions on our behalf. Examples include e-commerce platform providers, website hosts, content delivery providers and businesses which assist Us in undertaking communications or monitoring and analysis of our website and the Invstr app. Their access is limited only to the personal information needed to perform the functions carried out on our behalf, and only for the purpose of performing those functions
- Reviews: If you have permitted marketing from us, we may disclose your contact details to review sites (such as Trustpilot) to enable it to email you inviting you to leave a review about your experience with Invstr. You will be able to opt-out of these communications at any time
- Third party contact details: if you supply Us with a third party’s personal information (such as email) when referring that person to the Invstr app (Invstr’s Refer A Friend), we will use that information only to transmit the referral message
- Exchanges: We source market data from financial exchanges. We may be under an obligation to provide the exchanges with your details in order for them to verify usage of the market data supplied by them, and comply with local regulatory requirements
- Research Providers: We may source research reports and commentaries from various research providers. We might provide your details to those providers on an aggregated and anonymized basis
- Payment processors: If you conduct a transaction via the Invstr Services, We will be required to share certain personal information with third party payment processors in order to process your payment
- Money Transfer and eDebit Card. Should We be required to transfer monies to You, for instance for winning a game competition prize, We will be required to process the transfer in accordance with the third party money transfer services requirements, including corroboration of the name and account details to which monies will be remitted
- Order Management. If you carry out an investment transaction through the Trading Service, We may need to share limited personal information with the third party order management services and, or your broker in order to on-pass order messages. Notwithstanding, the actual execution and therefore security login and detailed personal information is securely carried out only between You and your broker dealer
- if We (or any one of our group companies) are bought or sold, or our assets (or the assets of any of our group companies) are bought, sold or consolidated, in which case We may disclose your personal information to the prospective seller or buyer of such business or assets
- if We share or sell anonymized data on an aggregated basis to third parties (in each case so that it is not capable of identifying you) for the purpose of providing an indication of prevailing market sentiment
- if We are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to comply with or enforce our terms and conditions at www.Invstr.com/app/tac.html and other agreements We have with you; or to protect the rights, property, or safety of Invstr Limited, our group companies, our customers, or others
Do We Transfer Your Personal Data Outside of the European Economic Area?
Through your account settings, you can choose to keep your personal information private. We shall use our best efforts to process your personal information in accordance with your account settings but please do note, however, that it may not be possible to make certain information private, such as your avatar.
Our messaging facilities include public chat and posts to the Invstr social feed, closed chat groups in Private Leagues and the Invstr Academy, as well as from time to time other ways of communicating with users of the Invstr Services.
If you choose to use any messaging facility which We provide, other than private chat groups, your messages may be visible to other users of the Invstr Services, and may be shared externally. By posting messages via our messaging facilities, other than private chat groups, you are consenting to your message being published on the Invstr Services and you acknowledge and agree that it may be visible to the public. For your safety, We recommend that you do not post any personal information using our messaging facilities, and do not post any information which you do not wish to be shared, seen or used by others. Our messaging facilities may not be encrypted, so do not use them to make available any sensitive or private information. In the case of private chat groups, we use end-to-end encryption, which means your messages our secured from falling into the wrong hands – in other words outside the chat group. Our messaging facilities are intended only for chatting about the Invstr Services. We may store content, information and data sent via our messaging facilities in order to satisfy regulatory compliance and reporting requirements in any jurisdiction.
Access to and Correcting Your Personal Information
To find out more about how your data is used, or to make a complaint, please contact Us using the details provided at the end of this policy, or via the feedback feature in Settings / About Invstr.
You have the right to request a copy of the personal information that We hold about you. If you would like a copy of some or all of the personal information We hold about you, you can contact Us using the contact details provided at the end of this policy, or via the ‘My Report’ feature in Settings. We want to make sure that your information is accurate and up to date. You may update your personal data through the ‘Settings’ screen of the App or you may ask Us to correct or remove personal information you think is inaccurate by contacting Us using the contact details provided at the end of this policy, or via the feedback feature in Settings.