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GLBA Privacy Notice for U.S. Users of Financial‑Related Services

This GLBA Privacy Notice (“Notice”) is provided for users located in the United States who access Investvio’s financial‑related tools, data and services. It supplements our main Privacy Policy and, where applicable, is intended to address certain requirements of the Gramm‑Leach‑Bliley Act (GLBA) and related U.S. regulations governing the privacy of non‑public personal information.

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

Investvio is a technology and data provider. We do not operate as a bank, broker‑dealer, investment adviser or other financial institution directly holding consumer deposit or investment accounts. However, some of our services may involve access to or processing of information related to your financial interests or activities. We therefore provide this Notice to explain how we handle such information.

1. Information We Collect

Depending on how you use our services, we may collect non‑public personal information (NPPI) and other data, such as:

  1. Identification information

    • Name, email address, username, contact details, billing address and similar identifiers.

  2. Account and relationship information

    • Subscription details, service usage history, communication preferences, support interactions.

  3. Financial‑related information (limited)

    • Information about your interests in certain financial instruments or markets,
    • Aggregated or pseudonymised information about how you use market data, charts or analysis tools,
    • Limited billing or payment‑related information processed primarily by third‑party payment providers.

  4. Technical and usage information

    • IP address, device and browser information, timestamps, pages viewed, features used and similar log data.

We do not request or store:

  • Full payment card numbers or bank account numbers (these are handled by our payment processors),
  • Social Security Numbers, government‑issued ID numbers or similar highly sensitive identifiers, except where strictly necessary and clearly disclosed for specific purposes (for example, HR‑related processes).

2. How We Use Information

We may use the information described above for the following purposes:

  1. Providing and maintaining our services

    • Creating and managing your account,
    • Providing access to tools, data, features and content,
    • Processing subscriptions and payments through third‑party providers.

  2. Security and fraud prevention

    • Protecting accounts and systems from unauthorised access,
    • Detecting and responding to suspicious or fraudulent activity.

  3. Service improvement and analytics

    • Understanding how our services are used,
    • Improving performance, usability and reliability,
    • Developing new features and tools.

  4. Communications

    • Responding to your inquiries and support requests,
    • Sending administrative updates related to your account or our services,
    • Sending marketing or promotional messages where permitted by law and your preferences.

  5. Compliance and risk management

    • Complying with applicable laws and regulations,
    • Managing legal risks and exercising or defending legal claims.

3. How We Share Information

We do not sell your non‑public personal information.

We may share information, including NPPI, with the following categories of recipients:

  1. Service providers

    • Companies that perform services on our behalf (for example, hosting providers, payment processors, analytics vendors, customer support platforms, security and anti‑fraud providers). These service providers are contractually required to protect NPPI and use it only for the services they perform for us.

  2. Affiliates and business partners

    • Our affiliates and certain partners may receive information where necessary to provide integrated services or for internal administration, subject to appropriate safeguards.

  3. Professional advisers

    • Lawyers, auditors, consultants and similar advisers who assist us in fulfilling our legal and business obligations.

  4. Government authorities and regulators

    • Where required by law, legal process or regulatory requirements, or to protect our rights, property or the safety of our users and the public.

  5. Corporate transactions

    • In connection with a merger, acquisition, restructuring or sale of assets, your information may be transferred to a successor entity, subject to confidentiality and compliance with applicable privacy laws.

4. How We Protect Information

We use a combination of administrative, technical and physical safeguards designed to:

  • Maintain the security and confidentiality of non‑public personal information,
  • Protect against anticipated threats or hazards to the security or integrity of such information,
  • Protect against unauthorised access or use that could result in substantial harm or inconvenience.

Examples of these safeguards include:

  • Access controls and authentication mechanisms,
  • Encryption and secure transmission protocols where appropriate,
  • Network and system monitoring,
  • Secure development practices and regular updates,
  • Employee training and confidentiality obligations,
  • Vendor due diligence and contractual data protection requirements.

Despite our efforts, no system can be completely secure. We therefore encourage you to take steps to protect your own accounts and devices, such as using strong, unique passwords and enabling available security features.

5. Your Choices and Rights

Depending on your relationship with us and applicable law, you may have certain rights and choices regarding your information, including:

  • Access and correction: You may request access to the information we maintain about you and ask that we correct inaccuracies,
  • Deletion: In some cases, you may request deletion of information, subject to legal or contractual requirements to retain certain records,
  • Marketing preferences: You may opt out of certain marketing communications by following the instructions in those messages or adjusting your settings,
  • Cookie and tracking controls: You may manage your cookie and tracking preferences through browser settings or our cookie tools, where provided.

To exercise these rights or make a request, please contact us using the information in Section 7 below. We may need to verify your identity before fulfilling your request.

6. Data Retention

We retain information, including NPPI, only for as long as reasonably necessary to:

  • Provide services to you,
  • Fulfil the purposes described in this Notice and our Privacy Policy,
  • Comply with legal, regulatory and contractual obligations,
  • Protect our rights and manage risk.

When information is no longer needed for these purposes, we will delete, anonymise or otherwise handle it in accordance with applicable law and our internal policies.

7. Contact Us

If you have any questions about this GLBA Notice or our privacy practices, you can 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]

You may also wish to review our main Privacy Policy and CCPA/CPRA Notice, which provide additional details about how we collect, use and protect personal information.