Privacy Policy

This is a working draft for review.

It describes what the product actually collects and shares, so that legal counsel has an accurate starting point. Bracketed notes flag decisions counsel needs to make.

Last updated: [date]

Effective: [date]

The English version of this policy governs. Other languages are provided for convenience.

1. Introduction

Investo.AI Inc. ("Investo.AI", "we", "us") provides a subscription service that sends daily investment signals and allows users to connect a brokerage account for automated order placement.

It applies to our website, our web application, and the emails and Telegram messages we send.

2. Who we are, and what we are not

Investo.AI is not a registered investment adviser. We do not provide personalised investment recommendations or manage customer funds.

We publish a rule. The rule produces a daily amount from market conditions and the settings you choose. Whether to follow that amount is always your decision.

Company: Investo.AI Inc.

Registered address: [client to supply]

Contact: [see section 14]

3. Information you give us

  • Account details: your email address and password.

  • Verification codes: sent to your email when you create an account or reset your password.

  • Plan settings: which index or indices you follow, your daily amount, and how you want signals delivered.

  • Followed companies: the list of companies you choose to follow.

  • Messages: anything you write to us through the feedback control or by email.

  • Payment details: handled entirely by Stripe. We never see or store your card number. We hold only the last four digits, the card type, and your subscription status.

4. Information we collect automatically

  • Device and browser: type, version, operating system, language.

  • Network: IP address, and the general location it implies — country and region, not a precise position.

  • Usage: which pages you open, when, and what you interact with.

  • Logs: access times and error records.

  • Cookies: see section 8.

5. Information from others

  • Charles Schwab: if you connect your brokerage account. See section 7.

  • Stripe: your subscription and payment status, never your card number.

  • Telegram: whether you have joined the signal channel, if you chose Telegram delivery.

  • Market data providers: prices and company information. This is not about you and is not linked to you.

6. How we use it

  • To run your account and deliver your daily signal.

  • To place orders in your brokerage account, if you have connected one and switched Auto-Trade on.

  • To take payment and manage your subscription.

  • To send the emails and messages you have asked for.

  • To credit a free month when someone you invited subscribes.

  • To keep the service secure and investigate misuse.

  • To improve the product, using aggregated usage patterns.

  • To meet legal obligations.

7. Your brokerage connection

If you connect Charles Schwab, you grant us access through Schwab's own authorisation process. We never receive your Schwab username or password.

What we receive: an access token valid for seven days, your account balance, and a record of orders we have placed.

What we can do: place buy orders for the index you chose, at the amount your rule produces, once per trading day.

What we cannot do: withdraw money, transfer money, sell anything, trade anything other than the index you chose, or change your plan.

You can disconnect at any time from your account settings. Disconnecting switches Auto-Trade off immediately.

8. Cookies

Essential cookies keep you signed in and protect against unauthorised access. Preference cookies remember settings like your preferred display language.

For counsel — confirm whether analytics cookies are in use and which provider.

9. Security

For counsel — this section states security practices and must be confirmed rather than assumed. The draft says only what the design implies and no more.

Data in transit is encrypted. Passwords are stored hashed, never in plain text. Access to customer data is restricted to team members who need it to operate the service.

No system is completely secure, and we cannot guarantee absolute security.

10. How long we keep it

For counsel — retention periods below are placeholders and must be set against the client's actual obligations. We are not a registered adviser, so the adviser recordkeeping rule's five-year requirement does not apply automatically.
  • Account data: while your account is open, and for a period after closure.

  • Order records: where we have placed orders on your behalf.

  • Payment records: as required for tax and accounting.

  • Messages you send us: for support and dispute resolution.

11. Your rights

You can ask us to show you what we hold, correct it, delete it, or send it to you in a portable format. You can also object to or restrict certain uses of your data, or withdraw any consent you have given.

California residents have rights under the CCPA and CPRA, including the right to know, delete, correct, and opt out of the sale or sharing of personal information. We do not sell personal information.

Residents of Virginia, Colorado, Connecticut, Utah and Montana may have similar rights under their own state laws.

For counsel — confirm which state regimes apply given where the client operates and where customers are.

12. Children

The service is for people aged 18 and over. We do not knowingly collect information from anyone under 18.

13. Where your data is held

For counsel — this section needs particular attention. The product is published in English and Simplified Chinese, which implies customers outside the United States. If there are EU or UK users, GDPR applies and transfer mechanisms (SCCs) are needed.

Our systems are located in the United States. If you use the service from elsewhere, your information is transferred to and processed in the United States.

14. Changes, and how to reach us

We will post any changes here with an updated date, and tell you by email if the changes are significant.

Questions about this policy: [contact address]

We reply within [period].

Investo.AI Inc. · [Registered address]

Investo.AI is not a registered investment adviser and does not provide personalised investment recommendations.