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 (Invstr Limited, Invstr Financial LLC and Invstr Securities LLC) (“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 which is personally identifiable, including but not limited to your name, location, mobile phone number, email, sentiment data in terms of what news you read, like, share or comment on, or the choice of instruments you may add to your watchlist and interactive investment games, including game capital you purchased and your game performances.
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 ZA449300.
We may collect and process the following information about you:
We may use your personal information in the following ways:
Invstr may disclose your Personal Data in the good faith that such action is necessary to:
With your permission, we may also disclose your personal information to third parties for the following purposes:
We maintain strict security standards and procedures with a view to preventing unauthorised access to your data by anyone, including our own staff. We use leading technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your data.
Whilst the security of your data is important to us, remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. In the event of a personal data breach, We will, where feasible not later than 72 hours after having become aware of it, notify the breach to the supervisory authority (Information Commissioner’s Office) unless the personal data breach is unlikely to result in a risk to the rights and freedoms of said persons.
Through your account settings, you can choose to keep your personal information private and, should you decide to leave the Invstr Services, the ‘right to erasure’ by which any data referencing you is removed from the Service. 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 may include: private chat, public chat, public posts to the social feed, quick comment and comment forums and other ways of communicating with other users of the Invstr Services.
If you choose to use any messaging facility which We provide, your messages may be visible to other users of the Invstr Services, and may be shared externally. By posting messages via messaging facilities, 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. 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
These technologies are not required for site functionality. Additionally, third-party widgets such as Twitter, Facebook, Google+, YouTube and Instagram may install cookies, depending on their configuration.
Additionally, we use the following services (but not limited to);
We use Amazon’s virtual computer services to store and process all our data, including your personal data. This includes Amazon’s S3 storage and delivery component and DynamoDb and Redshift databases.
We use Crashlytics to monitor your in-app sessions for service performance purposes.
We use Google Firebase services for two purposes: a) monitoring and reporting of application crashes (we share Person IDs to identify the user who crashed and nothing else; b) analysing and reporting of time spent in various sections of the Invstr app. We do not share any other information with Google Firebase and do not use it for any other purpose. Google Firebase’s privacy and security statement can be read here
Facebook & Twitter Conversion Tracking Cookies
We use a technology called Facebook Conversion Tracking. This allows Us to track those visitors who have been referred through a Facebook page, application or advertisement and then visited the Website within a 30 day period.
We will share information regarding your visit to the Website with Facebook but this will not include any information specific to your application or other personal information. Facebook will use this information to monitor, on our behalf, the effectiveness of our advertising and applications.
The information we share with Facebook will only be used in accordance with Facebook’s data use policy (here). Facebook Conversion Tracking may also enable Us and our partners to serve ads on and off Facebook.
We use Appsflyer, a marketing analytics and attribution platform, to analyse your in-app behavior for advertising and marketing purposes.
We use Mailchimp marketing automation platform and email marketing service tools, to gather certain information that helps Us to better understand your needs related to the Invstr service, and to ensure relevant email communication with yourself. This information will never be shared with third parties unless explicitly allowed by you.
We use the collaboration tool Slack to track and respond to users’ feedback and incident records.
Mobile Identifiers. When you are using our Services, we may also automatically record your Google Advertising ID (if you are using an Android device) or your Advertising Identifier (IDFA – if you are using an iOS device), together “Mobile Advertising IDs”), for advertising or analytics purposes. The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we may collect and use it for advertising and user analytics purposes. If your device does not have Advertising ID, we may use other persistent identifiers. The information collected may be also stored on your device.
Disabling Cookies. You should refer to your browser or device help material to learn what controls you can often use to remove or block cookies or other similar technologies or block or remove other data stored on your computer or device (such as by using the various settings in your browser). Be aware, if you do this, it may affect your ability to use the Services as well as other websites and apps.
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.
GDPR and CCPA require us to disclose data we have about you, and may have shared, to carry out the Invstr Services as described above. 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.
Under the EU’s General Data Protection Regulation (GDPR) You have the right to request for your personal information to be deleted (Right to be Forgotten). You can request this by going to your Profile setting in the app, selecting Contact Support / Deactivate My Account, or emailing Us at email@example.com. (You can also request to see your data by selecting Contact Support / Request My Data.) In order to comply, we may require further information from You in order to confirm that it is You making such a request.
You also agree that for regulatory and legal purposes, Invstr has an obligation to store certain personal data in a secure and encrypted way. Furthermore, You acknowledge that Invstr may continue to use certain personal data in an anonymized non-reverse engineering form for back-testing and community-level performance models. You also acknowledge that comments You posted in the Invtr Feed or direct or group messaging, may remain visible to other users in order to ensure a logical continuity of perspective in a post or messaging conversation. Notwithstanding, as per the Community Guidelines, We have the right to remove any content we may deem offensive or unsuitable.
If you have any questions, complaints or comments about Us or the Services then please contact Us by going to your Profile in the app, selecting Help / Contact Support, or by email using firstname.lastname@example.org or in writing by post to Invstr Limited, 17 Waterloo Place, London, SW1Y 4AR, United Kingdom, or 845 Third Avenue, New York, NY 10022, USA.
Invstr is not a bank and banking services are provided by Vast Bank, N.A.
Brokerage and Banking services are currently only available to U.S. residents.
Invstr app and web services are provided by Invstr Ltd. Advisory services are provided by Invstr Financial LLC, an investment adviser registered with the Securities Exchange Commission (SEC) details of which can be obtained here. Securities brokerage and custody services are provided by Apex Clearing, a broker dealer registered with the SEC and a member of FINRA and SIPC. There is no bank guarantee on securities and securities may lose value.
Investing involves risk and can lead to losses. Past performance does not guarantee future results.
Invstr app and web services are provided by Invstr Ltd. Invstr+ advisory services are provided by Invstr Financial LLC, an investment adviser registered with the Securities Exchange Commission (SEC). Securities brokerage and custody services are provided by Apex Clearing, a broker dealer registered with the SEC and a member of FINRA and SIPC. There is no bank guarantee on securities and securities may lose value. Vast Bank N.A. a nationally chartered bank and member of the FDIC, provides the banking products, including the products and services related to digital asset accounts. As with any asset, the value of Digital assets can go up or down and there can be a substantial risk that you lose money buying or holding digital assets. You should carefully consider whether trading or holding Digital assets is suitable for you in light of your financial condition. Your digital account does not support wallet to wallet transferring of your digital assets (i.e. cryptocurrencies) outside the platform. Any Digital Assets in your digital asset account are not insured by any government entities, including but not limited to FDIC or SIPC. The Invstr Visa® Debit Card is issued by Vast Bank, N.A. pursuant to a license from Visa U.S.A Inc and may be used everywhere Visa debit cards are accepted. Invstr Ltd, Invstr Financial LLC and Invstr Securities Ltd are subsidiaries of Marketspringpad Holdings (collectively “Invstr”) and Invstr is solely responsible for the application services and website content.