Privacy Policy

1. Who We Are / Scope

FinVestPro LLC ("FinVestPro," "we," "us," or "our") is a Delaware limited liability company operating an AI-driven investment platform. Our principal address is 350 Fifth Avenue, Suite 4100, New York, NY 10118, United States.

This Privacy Policy applies to all personal information we collect and process in connection with:

• Your use of our website at finvestpro.net and all associated subdomains;
• Your use of the FinVestPro investment platform and dashboard;
• Any communications you send to us via email, support tickets, or other channels;
• Your participation in any promotions, surveys, or events we conduct.

This Policy does not apply to third-party websites, services, or applications that may be linked from our platform. We encourage you to review the privacy policies of any third-party services you access through our platform.

FinVestPro acts as the "data controller" for personal information processed under this Policy, meaning we determine how and why your data is processed. Where we engage third-party service providers who process data on our behalf, those parties act as "data processors" under our instruction.

2. Information We Collect

We collect several categories of personal information depending on your interaction with our platform:

2.1 Sensitive Information

Government-issued identification numbers and identity documents are considered sensitive personal information. We apply enhanced security controls and access restrictions to these data categories. We do not collect sensitive information such as health data, religious beliefs, or political opinions.

2.2 Automatically Collected Data

When you use our platform, we automatically collect certain technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. This data is collected even if you are not logged in and helps us maintain platform security and optimize the user experience.

3. How We Collect Information

3.1 Directly from You

We collect the majority of your personal information directly from you during the following interactions:

• Account Registration: Personal details, contact information, and KYC documentation submitted during sign-up;
• Account Settings: Updates to your profile, contact details, or KYC information;
• Transactions: Information provided when initiating deposits, withdrawals, or investment plans;
• Customer Support: Information included in support requests, emails, or live chat conversations;
• Surveys and Feedback: Optional information submitted in response to our surveys or feedback requests.

3.2 Automatically

Technical and usage data is collected automatically via:

• Browser cookies and local storage (see Section 7);
• Web server logs recording IP addresses, request timestamps, and user agents;
• Platform analytics tracking user interactions within the dashboard;
• Security systems monitoring for suspicious access patterns.

3.3 From Third Parties

We may receive information about you from third parties, including:

• Identity verification and KYC service providers who cross-reference your submitted documents against authoritative databases;
• Sanctions screening providers who check your identity against OFAC and other global watchlists;
• Payment processors who confirm transaction details and report payment outcomes;
• Fraud prevention services that flag unusual patterns associated with your IP address or device.

4. How We Use Your Information

We use your personal information for the following purposes:

4.1 Service Delivery

• Creating and managing your account;
• Processing deposits, withdrawals, and investment plan participation;
• Crediting returns upon investment maturity;
• Communicating important account and transaction updates;
• Providing customer support and resolving disputes.

4.2 Legal and Regulatory Compliance

• Verifying your identity through our KYC/CIP program;
• Screening against OFAC, FinCEN, and other sanctions and watchlists;
• Monitoring transactions for suspicious activity under BSA/AML requirements;
• Filing mandatory regulatory reports (SARs, CTRs) with FinCEN where required;
• Retaining records as required by applicable financial regulations;
• Responding to lawful requests from regulatory authorities and law enforcement.

4.3 Security and Fraud Prevention

• Detecting and preventing unauthorized account access;
• Identifying and investigating potentially fraudulent transactions;
• Maintaining audit logs for security incident investigation;
• Enforcing our Terms of Service and prohibited activities policy.

4.4 Platform Improvement

• Analyzing usage patterns to improve platform features and user experience;
• Conducting internal research and analytics;
• Testing new features and functionality;
• Training and improving our AI model using aggregated, de-identified market and interaction data.

4.5 Communications

• Sending account notifications, security alerts, and transaction confirmations;
• Notifying you of changes to our Terms of Service or Privacy Policy;
• Sending marketing communications about new features or investment plans, where you have opted in.

You may opt out of marketing communications at any time by clicking the "unsubscribe" link in any marketing email or by contacting us at privacy@finvestpro.net. Opting out of marketing does not affect transactional or regulatory communications.

5. Legal Bases for Processing

Where required by applicable privacy law, we process your personal information based on one or more of the following legal bases:

• Contract Performance: Processing necessary to provide you with the Services you have requested, including account management, investment plan execution, and withdrawal processing;
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC/AML obligations, sanctions screening, and mandatory regulatory reporting;
• Legitimate Interests: Processing for our legitimate business interests, including platform security, fraud prevention, analytics, and platform improvement, where those interests are not overridden by your rights;
• Consent: Processing for purposes such as marketing communications, where we have obtained your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We share information only as described below:

6.1 Service Providers

We share information with third-party service providers who process data on our behalf and under our instruction. These include:

• KYC and identity verification vendors;
• Payment processors and banking partners;
• Sanctions and AML screening providers;
• Cloud infrastructure and hosting providers;
• Email delivery and communication platforms;
• Analytics and monitoring services;
• Customer support platforms.

All service providers are contractually bound to process your data only as instructed by FinVestPro, maintain adequate security standards, and not use your data for their own purposes.

6.2 Legal and Regulatory Disclosure

We may disclose your information to:

• Regulatory authorities such as the SEC, FINRA, FinCEN, and applicable state regulators in response to lawful inquiries;
• Law enforcement agencies pursuant to valid legal process (subpoena, court order, warrant);
• OFAC and other sanctions agencies as required by US law;
• Tax authorities as required by applicable tax reporting obligations.

6.3 Business Transfers

In the event of a merger, acquisition, corporate reorganization, or sale of all or substantially all of FinVestPro's assets, your personal information may be transferred to the acquiring entity. We will provide notice of such a transfer and you will have the opportunity to close your account before the transfer is finalized if you object.

6.4 With Your Consent

We may share your information with other third parties when you have provided explicit consent for such sharing.

6.5 Aggregated / De-identified Data

We may share aggregated or de-identified data (which cannot reasonably be used to identify you) for industry research, analytics, and platform benchmarking purposes without restriction.

7. Cookies and Tracking Technologies

7.1 What We Use

FinVestPro uses browser-based storage technologies including cookies and localStorage to maintain your session, remember your preferences, and ensure platform security. Specifically:

• Session Storage: Used to maintain your logged-in session and dashboard state during an active session. This data is cleared when you close your browser tab.
• Local Storage: Used to persist user account data and investment records between sessions for the functioning of the platform. This data remains until manually cleared or the account is closed.
• Analytics Cookies: We use privacy-respecting analytics to understand aggregate usage patterns. These do not track you across third-party websites.

7.2 Cookie Consent

By using the FinVestPro platform, you consent to the use of the storage technologies described above. Certain storage is strictly necessary for the platform to function; you cannot opt out of these without ceasing to use the Services. You may opt out of analytics cookies through your browser settings.

7.3 Third-Party Tracking

We do not permit third-party advertisers to set tracking cookies on the FinVestPro platform. Any third-party scripts on our platform (such as analytics tools or fonts) are governed by the privacy policies of those respective services.

7.4 Do Not Track

Our platform does not currently respond to browser "Do Not Track" (DNT) signals. We will revisit this position as industry standards for DNT develop.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Policy, including our legal and regulatory obligations. Specific retention periods include:

• Account Information: Retained for the duration of your account and for a minimum of 5 years following account closure, as required by US financial regulations;
• KYC Documentation: Retained for a minimum of 5 years from the date of collection or the date of the last transaction, whichever is later, in compliance with BSA requirements;
• Transaction Records: Retained for a minimum of 5 years as required by applicable financial recordkeeping regulations;
• Suspicious Activity Reports: Retained for a minimum of 5 years from the date of filing;
• Communications and Support Records: Retained for 3 years following the close of the relevant matter;
• Technical / Log Data: Retained for up to 12 months for security monitoring purposes.

When retention periods expire, we securely delete or anonymize your data unless a longer retention period is required by law or necessary to resolve an outstanding dispute or legal claim.

9. Data Security

FinVestPro implements a comprehensive set of technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your browser and our servers is encrypted using TLS 1.2 or higher. Sensitive data at rest is encrypted using AES-256;
• Access Controls: Access to personal data is restricted on a need-to-know basis. All internal access is authenticated, logged, and subject to periodic review;
• Secure Infrastructure: Our platform is hosted on SOC 2 Type II certified cloud infrastructure with multi-zone redundancy;
• Vulnerability Management: We conduct regular security assessments, penetration testing, and code reviews;
• Incident Response: We maintain a formal data breach response plan. In the event of a breach affecting your personal information, we will notify you as required by applicable law;
• Employee Training: All employees with access to user data receive mandatory data security and privacy training.

Despite our best efforts, no security system is impenetrable. We encourage you to use a strong, unique password for your FinVestPro account and to enable any additional security features available in your account settings.

10. International Data Transfers

FinVestPro is headquartered in the United States and your personal information is primarily processed and stored on servers located in the United States. If you are accessing the Services from outside the United States, please be aware that your information will be transferred to, processed, and stored in the US, where data protection laws may differ from those in your home jurisdiction.

For users in jurisdictions with data transfer requirements (such as the European Economic Area or United Kingdom), we rely on appropriate safeguards for cross-border transfers, including standard contractual clauses where applicable. Please contact our Data Protection Officer at privacy@finvestpro.net for more information about our international transfer mechanisms.

FinVestPro also maintains a regional office in London, United Kingdom (FinVestPro UK Ltd, 1 Canada Square, London E14 5AB), which may process data related to European users in accordance with applicable UK and EU data protection law.

11. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal information:

11.1 Exercising Your Rights

To exercise any of the above rights, please submit a request to privacy@finvestpro.net. We will respond within 30 days for most requests (up to 90 days for complex requests, with notice). We may need to verify your identity before processing your request. Certain rights are subject to limitations, particularly where processing is required for legal compliance or contractual obligations.

11.2 Right to Lodge a Complaint

If you believe we have mishandled your personal information, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction. US residents may contact the Federal Trade Commission (FTC) at ftc.gov/privacy. UK residents may contact the Information Commissioner's Office (ICO) at ico.org.uk.

12. California Privacy Rights (CCPA / CPRA)

12.1 Categories of Personal Information Collected

In the preceding 12 months, FinVestPro has collected the following categories of personal information from California residents, as defined by CCPA:

• Identifiers: Name, email, phone, address, IP address, government ID number;
• Personal records: Signature, financial information, employment information;
• Protected classification characteristics: Age, national origin (collected for KYC purposes only);
• Commercial information: Investment history, transaction records, account balance;
• Internet or network activity: Browsing history within our platform, interaction data;
• Geolocation data: General location based on IP address;
• Professional/employment information: Occupation (collected for KYC purposes).

12.2 Sources

We collect this information directly from you, automatically through your use of our platform, and from third-party identity verification and AML screening providers, as described in Section 3.

12.3 Purposes for Collection

We collect this information for the purposes described in Section 4, including service delivery, legal compliance, security, and platform improvement.

12.4 Sale or Sharing of Personal Information

FinVestPro does not sell your personal information to third parties. FinVestPro does not share your personal information with third parties for cross-context behavioral advertising. You therefore have the right to opt out of sale/sharing, though we do not engage in these activities.

12.5 California Consumer Rights

As a California resident, you have the right to:

• Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources from which we collected it, the business or commercial purposes for collecting it, and the categories of third parties to whom we have disclosed it;
• Delete: Request that we delete personal information we have collected from you, subject to certain exceptions (e.g., where retention is required for legal compliance);
• Correct: Request that we correct inaccurate personal information we maintain about you;
• Opt-Out of Sale/Sharing: Opt out of the sale or sharing of your personal information (FinVestPro does not sell personal information);
• Limit Use of Sensitive Personal Information: Limit our use of sensitive personal information to purposes necessary for providing our services;
• Non-Discrimination: You will not receive discriminatory treatment for exercising your CCPA rights.

12.6 Submitting a California Privacy Request

To submit a CCPA rights request, email privacy@finvestpro.net with the subject line "California Privacy Request." We will verify your identity and respond within 45 days (extendable by 45 days with notice if reasonably necessary). You may designate an authorized agent to submit requests on your behalf, subject to our verification procedures.

12.7 Shine the Light

California residents may also request information about our disclosures of personal information to third parties for their direct marketing purposes under California's "Shine the Light" law. FinVestPro does not disclose personal information to third parties for direct marketing purposes without your consent.

13. Children's Privacy

The FinVestPro Services are not intended for, directed at, or available to individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a minor, we will take immediate steps to delete that information and close the associated account.

If you believe a minor has registered an account with FinVestPro, please contact us at privacy@finvestpro.net so we can investigate and take appropriate action.

Our platform complies with the Children's Online Privacy Protection Act (COPPA) and we have no intent to market financial services to individuals under the age of majority.

14. Third-Party Links

The FinVestPro platform may contain links to third-party websites, resources, or services. These links are provided for your convenience and do not signify our endorsement of such third parties. We have no control over the content or privacy practices of these external sites and are not responsible for their privacy policies.

We encourage you to review the privacy policy of any third-party website you visit through a link on our platform. This Privacy Policy applies only to FinVestPro's own services.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Services, applicable laws, or for other operational, legal, or regulatory reasons. When we make material changes to this Policy, we will:

• Post the revised Policy on this page with an updated "Last Updated" date;
• Send a notification email to your registered address;
• Display a notice in the platform dashboard for a reasonable period.

We encourage you to review this Policy periodically. Your continued use of the Services after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you disagree with the revised Policy, you may close your account in accordance with the Terms of Service.

16. Contact / Data Protection Officer

If you have any questions, concerns, or requests related to this Privacy Policy or our handling of your personal information, please contact our Data Protection Officer: