Investabl Privacy Policy

Controller: Investabl Limited

1. Who we are

1.1

Investabl Limited, registered at Ground Floor, The Sotheby Building, Rodney Bay, Gros-Islet, Saint Lucia (postal address: P.O. Box 838, Castries, Saint Lucia) ("Investabl", "we"), operates app.investabl.ai and decides how your personal data is used. We are the data controller (called the "Data Fiduciary" under India's Digital Personal Data Protection Act, 2023).

1.2

Questions and requests go to support@investabl.ai.

2. What this covers

2.1

This policy covers our website, the trading app, checkout, payouts, the affiliate programme, the AI coach and journal, and support chat. It should be read with our Terms & Conditions.

3. What we collect

CategoryWhatWhere it comes from
AccountEmail address, display name, profile picture, login ID, referral codeYou, via our login provider (email or Google sign-in)
Identity verificationWhether you passed, the date, and a reason if you did not. We do not store your ID document, selfie or date of birth; our verification provider holds them.Our verification provider
Device and networkIP address at sign-up and at each login from a new IP; a device identifier generated in your browser; browser typeYour browser
PaymentsAmount, currency, payment method, order IDs, the wallet address a crypto payment came from, and the payment provider's status messages, which may include details the provider sends usYou and your payment provider
Payout detailsWallet address and network for Rewards, and a Telegram handle if you choose to give oneYou
Trading activityEvery order, position, balance and rule outcome on your AccountsYour use of the platform
App usageScreens viewed and actions taken (for example opening an order ticket or adding a chart drawing), with IP address and browser details; page-performance timingsYour browser
AI coach and journal (optional)Trade notes, voice notes, daily check-ins, answers about your strategy, and summaries the AI writes about your tradingYou, and our AI provider's analysis
Imported accounts (optional)MT5 login number, server name, and the investor password, used once to link the accountYou
Affiliate programmeYour public handle, who you referred, commissions and withdrawal wallet; for referral link clicks, a one-way hash of the visitor's IP plus browser detailsYou and referred visitors
SupportConversations with our support teamYou, via the support chat
Funded-trader questionnaire (optional)Your answers, and whether you agreed to their publicationYou

4. Why we use it

PurposeData usedLegal basis
Run your account, Challenges and payoutsAccount, payments, payout details, trading activityPerforming our contract with you
Verify identity and screen against sanctions lists before paying RewardsIdentity verificationLegal obligation, and our contract
Prevent fraud and enforce the Terms: duplicate accounts, coordinated trading, payment abuseDevice and network, payments, trading activityLegitimate interest in protecting the firm and honest traders
SupportAccount, support conversationsContract
Improve and debug the productApp usageLegitimate interest. You can object (clause 10.4)
Measure advertisingHashed email, IP address, browser details, ad cookie IDsLegitimate interest. You can object (clause 10.4)
AI coaching and journalAI coach and journal dataConsent: you turn these features on

5. Automated decisions

5.1

Rule enforcement is automatic. Our system checks each Account against its Program Rules continuously. When a loss limit is reached, it closes positions and ends the Account without a person being involved. This is necessary to run the service you signed up for.

5.2

Risk checks can hold a payout, but never refuse one on their own. Automated checks look for patterns such as linked accounts, copied or opposite trading, and account cycling. A match holds a payout request for review. Only a person can refuse a payout or end an Account for a breach of the Terms.

5.3

You can ask for any automated outcome to be reviewed by a person and can contest it, as set out in clause 12 of the Terms.

6. Who we share it with

6.1

We do not sell personal data. We share it only with the service providers below, who process it for us, and with authorities where the law requires.

ProviderWhat they doWhat they receive
PrivyLogin and embedded walletsEmail, Google profile, wallet addresses
Didit (and a Fillout form as backup)Identity verification and sanctions screeningYour ID document, selfie and the details you enter, collected directly by them; our user ID
Google CloudHosting and databaseAll data we hold
Google (Gemini)AI coach, journal and voice transcriptionYour notes, check-ins, strategy answers, voice recordings and related trades. Not your email.
Google Analytics and Tag ManagerProduct analyticsApp-usage events, your user ID, a shortened wallet address
PostHogProduct analytics, session recordings and the in-app feedback formApp-usage events, your email, name and user ID, and how you move through pages. Anything you type is masked in recordings.
MetaAdvertising measurementA one-way hash of your email and user ID, IP address, browser details, ad cookie IDs, and purchase and sign-up events
IntercomSupport chatEmail, name, user ID (signed), conversations
SlackInternal alerts to our operations teamYour email address with payment, payout and account events
Payment providers (Cashfree, PFU, Spayz, IG and crypto networks)Taking paymentsOrder amount and reference, plus whatever you enter on their payment page. We do not send Cashfree your real phone number.
MetaApiLinking MT5 accounts you importMT5 login, server and investor password
Public blockchainsCrypto payments and RewardsWallet addresses and amounts. These are public and permanent by the nature of blockchains.
6.2

The device identifier in clause 3 is produced by an open-source library that runs in your browser. It does not send data to any third party.

6.3

If Investabl is sold or merged, personal data may pass to the new owner under this policy.

7. What is made public

7.1

When we pay a Reward, we may post the amount and a masked form of your email (for example ve***@gmail.com) in our Telegram and Discord communities. To opt out, email support@investabl.ai.

7.2

Our payout-proof and transparency pages show an anonymous handle, never your email or name.

7.3

Certificates show the display name you choose and are visible to anyone with the certificate link.

7.4

The referral leaderboard shows affiliate handles and counts. You can opt out of it.

7.5

Funded-trader questionnaire answers are published only if you tick the consent box on the questionnaire.

8. Where it is stored

8.1

Our servers and database are in Google Cloud's United States (Iowa) region. We may move them to India (Mumbai). Our service providers operate in the United States, the European Union and elsewhere.

8.2

When data leaves your country, we rely on the providers' contractual commitments, including standard contractual clauses where the law requires them.

9. How long we keep it

DataKept for
Page-performance timings30 days
Risk-check results90 days, or longer if linked to an open dispute or a finding under the Terms
Voice recordingsDeleted as soon as they are transcribed
MT5 investor passwordDeleted once the account is linked, or when linking fails
Everything else, including account, trading, payment and payout records, the IP address log, app-usage events, AI coach and journal data, and support conversationsFor as long as your account is open, and afterwards for as long as we need it for legal, accounting, tax, dispute or fraud-prevention purposes. You can ask us to delete it earlier (clause 11).

10. Cookies and tracking

10.1

Needed to run the service: your login token, checkout and payment progress, referral attribution, and your saved app settings. These are kept in your browser's local storage. We do not set our own cookies.

10.2

Security: the in-browser device identifier used to detect duplicate accounts (clause 6.2).

10.3

Analytics and advertising: Google Analytics, Google Tag Manager, PostHog analytics and session recording, and the Meta cookies (_fbp, _fbc) load when you visit our site. We also report purchases and sign-ups to Meta from our servers. We do not currently show a cookie banner.

10.4

How to opt out: you can block or delete these cookies in your browser settings, or use Google's Analytics opt-out add-on. To stop us reporting your purchases to Meta, email support@investabl.ai.

10.5

Our login provider and support chat set their own storage to keep you signed in and to keep your conversation.

11. Your rights

11.1

Depending on where you live, you can ask us to:

  1. give you a copy of your personal data;
  2. correct data that is wrong;
  3. delete your data (see 11.2);
  4. give you your data in a portable format;
  5. stop using your data for analytics or advertising, or withdraw any consent you gave;
  6. have a person review an automated decision (clause 5);
  7. name someone to exercise these rights for you if you die or cannot act (India).
11.2

When you ask us to delete your data, we delete or anonymise it within 30 days. The exceptions are records we must keep by law (payments, payouts and identity-verification results) and data needed for an open dispute or fraud investigation. Those are kept only for as long as clause 9 allows. Data on public blockchains cannot be deleted by anyone.

11.3

Email support@investabl.ai from the address on your account. We reply within 30 days. You can also complain to your local data-protection authority (for India, the Data Protection Board of India).

12. Security

12.1

What we do:

  • All traffic to our servers is encrypted in transit (TLS).
  • We never receive or store your ID documents; our verification provider holds them.
  • Wallet private keys we manage for trading are encrypted at rest (AES-256-GCM).
  • Messages from payment and verification providers are checked with cryptographic signatures before we act on them.
  • Staff access to admin tools requires a secret key, and every admin action is logged.
  • Payouts are sent from a smart-contract wallet with an on-chain daily limit, so a compromised signing key cannot empty the treasury.
  • Service secrets are held in Google Cloud Secret Manager.
12.2

No system is perfectly secure. If a breach affects your personal data, we will notify you and the relevant authority as the law requires.

13. Age

13.1

Investabl is only for people aged 18 or over. We do not knowingly collect data from anyone younger. If we learn that we have, we close the account and delete the data, except payment records we must keep.

14. AI features

14.1

The AI coach and journal are optional. When you use them, your notes, voice recordings, check-ins and related trades are sent to Google's Gemini service to produce transcripts, summaries and coaching.

14.2

Voice recordings are deleted from our systems as soon as they are transcribed. AI output is guidance only and is not investment advice.

15. Marketing

15.1

We do not currently send marketing emails, SMS or WhatsApp messages. If we start, we will ask first where the law requires, and every message will include a way to unsubscribe.

16. Changes

16.1

We will post changes here. For significant changes we will also notify you by email or in the app at least 14 days before they take effect.

17. Contact

17.1

Investabl Limited · Ground Floor, The Sotheby Building, Rodney Bay, Gros-Islet, Saint Lucia (postal address: P.O. Box 838, Castries, Saint Lucia) · support@investabl.ai

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