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CCPA / CPRA Privacy Notice for California Residents

This CCPA/CPRA Privacy Notice (“Notice”) supplements the information contained in our main Privacy Policy and applies solely to California residents in their capacity as “consumers” under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA).

In this Notice, “Investvio”, “we”, “us” and “our” refer to Investhub Yazılım ve Teknoloji Hizmetleri A.Ş., the company operating the Investvio brand.

We do not sell your personal information for money. Certain disclosures may, however, be considered a “sale” or “sharing” under California law for cross‑context behavioural advertising. Where applicable, we will provide appropriate opt‑out mechanisms.


1. Categories of Personal Information We Collect

In the past 12 months, we may have collected the following categories of personal information about California residents, as defined by the CCPA/CPRA:

  1. Identifiers

    • Real name, postal address, email address, account name or username, unique identifiers, IP address and similar identifiers.
  2. Customer records

    • Billing address, limited payment information (processed via third‑party payment processors), subscription details.
  3. Commercial information

    • Records of services purchased or considered, subscription history and related usage activity.
  4. Internet or other electronic network activity information

    • Browsing history, search history, and information regarding interactions with our Site, apps or advertisements (e.g. pages viewed, features used, time spent, referring URLs).
  5. Geolocation data (approximate)

    • General location derived from IP address (e.g. country, region).
  6. Inferences drawn from other personal information

    • Inferences reflecting preferences, interests or behaviour patterns, used to improve and personalise services (where permitted).

We do not intentionally collect:

  • Protected classification characteristics under California or federal law (such as race, gender, religion, etc.) unless you voluntarily provide them in a limited context (e.g. HR applications),
  • Biometric information,
  • Precise geolocation data,
  • Sensitive personal information for unrelated purposes, as defined under the CPRA.

2. Sources of Personal Information

We collect personal information from the following sources:

  • Directly from you: when you create an account, subscribe to services, contact support or otherwise interact with us,
  • Automatically: through cookies, log files, device identifiers and similar technologies when you use our Site or apps,
  • Third parties: such as payment processors, analytics providers, advertising partners or social login providers (e.g. when you choose to sign in via another service).

3. Purposes for Collecting Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  1. Providing and maintaining services

    • Creating and managing accounts,
    • Providing access to tools, data and features,
    • Processing subscriptions, payments and transactions.
  2. Security and fraud prevention

    • Detecting, preventing and responding to security incidents,
    • Protecting against malicious, deceptive, fraudulent or illegal activity.
  3. Debugging and improving services

    • Identifying and repairing errors,
    • Maintaining and improving performance and functionality.
  4. Analytics and personalisation

    • Measuring usage, understanding user behaviour and trends,
    • Personalising content and experiences (where permitted).
  5. Marketing and communications

    • Sending promotional messages, newsletters and offers (where permitted by law and your preferences),
    • Measuring and optimising marketing campaigns.
  6. Compliance and legal obligations

    • Complying with applicable laws, regulations and legal processes,
    • Protecting our rights, property and safety, and those of our users and third parties.

We will not use personal information we collect for materially different, unrelated or incompatible purposes without providing you with notice and, when required, obtaining your consent.


4. Disclosures of Personal Information for a Business Purpose

We may disclose your personal information to the following categories of third parties for the business purposes described above:

  • Service providers (as defined under the CCPA/CPRA):
    hosting providers, analytics and monitoring services, customer support platforms, email and notification providers, payment processors, security and anti‑fraud vendors.

  • Business partners and affiliates:
    where necessary to provide joint offerings, integrations or for internal administration, subject to appropriate contracts.

  • Professional advisers:
    such as lawyers, auditors, accountants and consultants.

  • Public authorities and regulators:
    including law enforcement, where required by law or to protect legal rights.

In the past 12 months, we have disclosed the categories of personal information listed in Section 1 for one or more of the business purposes outlined above.


5. “Selling” or “Sharing” Personal Information

Under the CCPA/CPRA, a “sale” or “sharing” of personal information can occur when personal information is disclosed to a third party for certain types of targeted advertising or other valuable consideration.

We do not sell personal information in the traditional sense (i.e. for money). However, we may work with third‑party advertising or analytics partners that use cookies or similar technologies which, under California law, could be considered a “sale” or “sharing” of personal information for cross‑context behavioural advertising.

Where required, we will:

  • Provide clear notice about such activities,
  • Offer opt‑out mechanisms (e.g. “Do Not Sell or Share My Personal Information” links or cookie preference tools),
  • Honour your choices with respect to targeted advertising and data sharing.

6. Your California Privacy Rights

Subject to certain exceptions and limitations, California residents have the following rights:

  1. Right to Know / Access

    • You may request that we disclose:
      • The categories of personal information we have collected about you,
      • The categories of sources from which we collected personal information,
      • The business or commercial purposes for collecting, selling or sharing personal information,
      • The categories of third parties to whom we disclose personal information,
      • The specific pieces of personal information we have collected about you.
  2. Right to Delete

    • You may request that we delete personal information we have collected from you, subject to certain exceptions (for example, where the information is needed to complete a transaction, detect security incidents or comply with a legal obligation).
  3. Right to Correct

    • You may request that we correct inaccurate personal information we maintain about you, considering the nature of the information and the purposes of processing.
  4. Right to Opt‑Out of Sale or Sharing

    • You may direct us not to sell or share your personal information for cross‑context behavioural advertising. Where applicable, we will provide mechanisms to exercise this right (for example, through cookie settings or specific links).
  5. Right to Limit Use of Sensitive Personal Information

    • To the extent we collect any sensitive personal information (as defined by the CPRA), you may have the right to limit our use of such information to specific permitted purposes.
  6. Right to Non‑Discrimination

    • We will not discriminate against you for exercising any of your CCPA/CPRA rights. This means, for example, that we will not:
      • Deny you goods or services,
      • Charge you different prices or rates,
      • Provide a different level or quality of services,
      • Suggest that you may receive a different price or level of services.

7. How to Exercise Your Rights

To exercise any of your rights described above, you may contact us using one of the following methods:

  • Email: [email protected]
  • Web form: via the contact or privacy request form on investvio.com

When you submit a request:

  • We may need to verify your identity to protect your privacy and security,
  • We may ask you to provide certain information (such as your email address, account details or recent interaction information) to match with our records,
  • Authorised agents may submit requests on your behalf, provided that they demonstrate appropriate authorisation as required by law.

We will respond to verifiable consumer requests within the timeframes set out in applicable law and will provide additional information if we cannot comply with a request, including the reasons for our decision.


8. Updates to This Notice

We may update this CCPA/CPRA Notice from time to time to reflect changes in our practices, services or applicable law. When we do so, we will revise the “last updated” date (where provided) and post the updated version on our Site.


9. Contact Us

If you have any questions about this Notice or our privacy practices, or if you would like to exercise your rights under the CCPA/CPRA, you may contact us at:

Investhub Yazılım ve Teknoloji Hizmetleri A.Ş.
(Investvio brand)
Esentepe Mah. Büyükdere Cad. Levent 199 No: 199, Inside Door:6 Şişli/ İstanbul
[email protected]

For more general information about how we collect, use and protect personal information, please refer to our main Privacy Policy.