Privacy Policy

1. Who we are

Invest Check is operated by Invest Check Inc., and Alberta corporation, and InvestCheck LLC, a Texas limited liability company (individually and collectively, "Invest Check", "we", "us", or "our"). Invest Check is the controller of personal information collected from Subscribers. In respect of Featured Trader trading data submitted for Verification, Invest Check acts as a processor on the Featured Trader's instruction. Both roles are explained in section 8.

This policy explains what personal information we collect, why we collect it, who we share it with, how long we keep it, and the rights you have over it. It applies to investcheck.com and any related services that link to this policy.

2. Personal information we collect

We collect personal information in the following ways.

Information you provide directly

• Account details — your name, email address, and (if you sign up with a password) a password, which we store in hashed form only.
• Profile preferences — for example, whether you opt in to receive the daily trade digest for traders you have access to.
• Payment information — billing name, email, country, and (where required) postal code. Payment card details are entered directly into Stripe and are never stored on Invest Check servers. We retain the Stripe customer identifier and a reference to the checkout session, so we can match purchases to your account.
• Support correspondence — if you contact us, we keep the message and our reply.

Information collected automatically

• Session and device data — when you sign in we record the IP address and user-agent string of your session, and an expiring session token, for security and fraud prevention.
• Usage data — aggregated information about page views and performance is collected through Vercel Analytics, Vercel Speed Insights, and PostHog. PostHog also collects custom product events (for example, when you view a trader profile or start a checkout) and, once you sign in, attaches your user identifier so we can connect anonymous browsing to your account. This data is not used to build a personal advertising profile. For visitors located in the EEA, the United Kingdom, Switzerland, or Quebec, these analytics tools load only after you give consent through our cookie banner.
• Email engagement — for emails we send through Resend, we may receive delivery, bounce, and complaint events so we can stop sending to addresses that are no longer reachable.

Information from third parties

• Google sign-in — if you choose to sign in with Google, Google provides us with your email address, name, and profile picture, plus OAuth tokens we use only to authenticate you. We do not access any other Google data and we do not post on your behalf.
• Stripe — Stripe shares with us the limited billing and event data we need to fulfil your purchase, manage your subscription, and reconcile receipts.

Information collected from Featured Traders

Featured Trader data falls into two categories that are treated differently under this Policy. Account, profile, compliance, and monitoring data are collected by Invest Check as controller. Brokerage credentials and source documents submitted for Verification are processed by Invest Check as processor, on the Featured Trader's instruction and solely for the Verification purpose described in section 8. In addition to the account and profile information described above, when an individual applies to become or is onboarded as a Featured Trader, we collect:

• Onboarding and identity documentation — government-issued identification or equivalent documentation required to verify identity and eligibility under the Featured Trader agreement and applicable law.
• Brokerage account access credentials — login credentials, API keys, or equivalent access information provided by the Featured Trader for the sole purpose of accessing their brokerage account to conduct Verification of trade records. These credentials are used only for Verification and are not used for any other purpose. Enhanced access controls apply to this category of information, as described in section 11 (Security).
• Brokerage statements and source documents — trade confirmations, account statements, and equivalent documents submitted by or on behalf of the Featured Trader for Verification purposes.
• Trading history and published profile data — trade records, entry and exit prices, quantities, dates, and related data extracted from source documents in the course of Verification, together with biographical information, strategy descriptions, and avatar images contributed for publication on the Service.
• Contractual and consent records — executed Featured Trader agreements, consent records, electronic signatures, and records of any amendments.
• Conflict of interest disclosures — information about positions held in securities published on the Service, and compensation arrangements.
• Compliance and monitoring records — records generated in the course of Invest Check's ongoing compliance monitoring of Featured Trader conduct, including records of any suspected or confirmed breach of the advice prohibition or market manipulation prohibition in the Featured Trader agreement.

3. How we use your information and our legal basis

We use personal information for specific purposes and rely on a corresponding legal basis under applicable privacy law (for users in Canada, generally consent; for users in the EEA, UK, or Switzerland, the basis listed below):

• Creating and securing your account. Performance of the contract between you and Invest Check; our legitimate interest in account security.
• Processing one-time purchases and subscriptions, issuing receipts. Performance of the contract; compliance with tax and accounting law.
• Granting access to the trade reports you have purchased or subscribed to, and removing access when a subscription ends. Performance of the contract.
• Sending operational email — sign-in codes, receipts, subscription notices, and account alerts. Performance of the contract; our legitimate interest in account security.
• Sending the daily trade digest and other marketing email. Your express, separate opt-in consent (which you can withdraw at any time).
• Detecting and preventing fraud, abuse, account-sharing, and credential theft. Our legitimate interest in protecting the service.
• Maintaining the integrity, performance, and security of the service. Our legitimate interest in operating a reliable service.
• Keeping records required by tax, accounting, anti-fraud, and other legal obligations. Compliance with legal obligations.
• Complying with applicable law and responding to lawful requests from public authorities. Compliance with legal obligations.
• Provide Customer Support — Address inquiries and disputes.
• Marketing (Optional) — Send promotional offers (only with explicit consent).
• Platform Optimization — Analyze usage trends to improve services.

We may infer additional information about you from the information you provide, or from your interactions with our services.

Where you are a Featured Trader, we also collect or process, as the case may be, and use your personal information for the following purposes:

• Identity and eligibility verification — to confirm identity, legal age, and eligibility under the Featured Trader agreement, to perform the contract; and comply with legal obligations.
• Verification of trade records — to access, review, and cross-reference brokerage statements and source documents against published trade data, so that the "Verified" label accurately reflects a confirmed match as described in the Terms of Service.
• Onboarding and agreement administration — to execute and administer the Featured Trader agreement, including capturing electronic signatures and maintaining consent records.
• Profile publication — to populate the Featured Trader's public-facing profile, including biographical information, trading background, strategy descriptions, and avatar image, as authorised under the Featured Trader agreement.
• Ongoing compliance and audit trail — to maintain records sufficient to respond to regulatory inquiries, securities regulator requests, or legal proceedings, and to demonstrate that Invest Check's Verification process was conducted in good faith and in accordance with its stated methodology.
• Conflict of interest monitoring and disclosure — to identify and disclose, where required, any changes in a Featured Trader's circumstances — including positions held, compensation arrangements, or regulatory status — that may be material to users of the Service, consistent with the Terms of Service.
• Fraud and market manipulation prevention — to detect and investigate conduct that may constitute market manipulation, front-running, or other misuse of the Service in breach of the Featured Trader agreement or applicable securities law.
• Communication and account management — to contact the Featured Trader regarding their account, Verification requests, content updates, agreement renewals, and compliance matters. Basis: performance of contract.

Where we rely on consent, you may withdraw it at any time by updating your account settings or contacting us. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal, and may mean we can no longer provide some or all of the service to you.

4. Email — anti-spam compliance

Invest Check sends two distinct categories of email, governed by different rules.

Operational messages

Sign-in codes, password resets, purchase receipts, subscription renewal and cancellation notices, security alerts, and similar messages that facilitate, complete, or confirm a transaction you have entered into with us. These messages are sent because you have an account with us. Some are required for the service to function and you cannot opt out of them without closing your account. Where these messages fall within the meaning of a commercial electronic message, they are exempt from the consent requirement under section 6(6) of Canada's Anti-Spam Legislation (CASL).

Marketing messages, including the daily trade digest

We send the daily trade digest and any other promotional or marketing email only after you have given express, opt-in consent for the relevant trader. The opt-in is presented to you separately from your acceptance of our Terms of Service so that your consent is meaningful and specific.

Each marketing email complies with Canada's Anti-Spam Legislation (CASL) and, for U.S. recipients, the U.S. CAN-SPAM Act. In particular, every such email:

• identifies Invest Check as the sender, and any person on whose behalf the message is sent, with our legal name and a valid postal mailing address;
• uses truthful subject lines and accurate header (From, Reply-To) information;
• is clearly identifiable as a commercial communication;
• contains a working unsubscribe mechanism that operates with a single click and remains functional for at least sixty (60) days after the message is sent; and
• honours unsubscribe requests within ten (10) business days, as required by both CASL and CAN-SPAM.

You can also manage your email preferences from your account at any time.

5. Cookies and similar technologies

Invest Check uses a small number of cookies and similar browser-storage mechanisms.

• Strictly necessary — session cookie set when you sign in, used to keep you logged in. It is HTTP-only, uses the SameSite attribute to mitigate cross-site request forgery, and expires automatically.
• Strictly necessary — UI state cookie called flash, used to display status messages after an action. It is removed within seconds.
• Analytics — Vercel Analytics, Vercel Speed Insights, and PostHog collect performance and usage information. PostHog uses localStorage and a first-party cookie to recognise returning visitors so we can build retention and funnel cohorts. For visitors located in the EEA, the United Kingdom, Switzerland, or Quebec (and elsewhere where consent is required), these tools are loaded only after you give consent through our cookie banner. You can change your preferences at any time by clearing the consent stored in your browser; once cleared, the banner will reappear on your next visit.

We do not use third-party advertising cookies, we do not use cookies to build cross-site behavioural advertising profiles, and we do not sell or share your personal information for cross-context behavioural advertising.

6. Service providers

We rely on a small set of third-party service providers ("subprocessors") to operate the service. They process personal information on our behalf, under contract, and only for the purposes we direct. The current list, including each provider's purpose, location, and link to their own privacy notice, is published at investcheck.com/legal/subprocessors. The list may change from time to time as we add or replace providers; that page is the authoritative reference.

7. International transfers

Our corporate structure. The Service is operated by two affiliated entities: InvestCheck Inc., a corporation incorporated under the Business Corporations Act (Alberta) ("Invest Check Canada"), and InvestCheck LLC, a limited liability company organized under the laws of the State of Texas ("Invest Check US"). Invest Check Canada and Invest Check US are joint controllers of the personal information collected through the Service. This means that both entities independently and jointly determine the purposes for which, and the means by which, your personal information is processed, and both entities bear full and independent accountability for that processing under their respective applicable privacy laws.

Where your information is processed. Depending on where you access the Service and which entity you are contracting with, your personal information may be stored and processed in Canada, in the United States, or in both jurisdictions. In addition, some of the Subprocessors we rely on to operate the Service are located in the United States, Canada, or other jurisdictions. A current list of Subprocessors, their locations, and their applicable privacy notices is maintained at investcheck.com/legal/subprocessors.

Your express, informed consent to cross-border transfer. By creating an account and using the Service, you expressly, freely, and with full knowledge consent to:

• the collection, use, storage, and processing of your personal information by Invest Check Canada in Canada and by Invest Check US in the United States, for the purposes described in this Policy;
• the transfer of your personal information between Invest Check Canada and Invest Check US as necessary to operate the Service, administer your account, conduct Verification, and fulfil our obligations to you;
• the transfer of your personal information to the Subprocessors identified at investcheck.com/legal/subprocessors, which may be located in the United States, Canada, or other jurisdictions; and
• the storage and processing of your personal information on servers located in the United States and Canada, and where applicable in other jurisdictions in which our Subprocessors operate.

You understand and acknowledge that:

• personal information transferred to or stored in the United States may be subject to access by US federal and state courts, law enforcement agencies, and national security authorities under applicable US law, including the USA PATRIOT Act and the Foreign Intelligence Surveillance Act, and those authorities may not provide the same protections as Canadian law;
• personal information transferred to or stored in Canada may be subject to access by Canadian federal and provincial courts, law enforcement agencies, and national security authorities under applicable Canadian law, including the Criminal Code (Canada) and the Canadian Security Intelligence Service Act;
• the protections available to you under Canadian privacy legislation, including PIPEDA and applicable provincial privacy statutes, may not follow your personal information into the United States once transferred; and
• the contractual safeguards described below reduce but cannot eliminate all risks associated with cross-border processing.

Notwithstanding your consent above, where personal information is transferred from the European Economic Area, the United Kingdom, or Switzerland to either entity, we rely on the European Commission's Standard Contractual Clauses or equivalent mechanism as the lawful transfer basis.

Withdrawal of consent. You may withdraw your consent to cross-border transfer at any time by closing your account and requesting deletion of your personal information in accordance with section 10. Because cross-border processing between Invest Check Canada and Invest Check US is inherent to the operation of the Service, withdrawal of consent will mean we can no longer provide the Service to you. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

Residents of Quebec. If you are a resident of Quebec, your personal information will be communicated to and processed by Invest Check US in the United States and by the Subprocessors identified at investcheck.com/legal/subprocessors. Before each such transfer, Invest Check conducts a privacy impact assessment as required by section 17 of the Act respecting the protection of personal information in the private sector (Law 25) to assess whether the personal information will receive adequate protection having regard to the sensitivity of the information, the purposes of the transfer, the applicable protective measures, and the legal regime of the destination jurisdiction. You may request a copy of any applicable privacy impact assessment by contacting legal@investcheck.com. This Policy and the Terms of Service are provided in English; a French language version will be made available to Quebec residents upon request at legal@investcheck.com.

8. Information about Featured Traders

The personal information described in this section is governed by two distinct legal relationships. Brokerage credentials and source documents submitted for Verification are processed by Invest Check as processor on the Featured Trader's instruction, under the Featured Trader Agreement which constitutes the applicable data processing agreement. All other personal information in this section, including published profile data, compliance records, and conflict of interest records, is processed by Invest Check as controller for the purposes described in section 3.

What we collect and publish. Invest Check publishes the trade history and profile of individuals who have agreed in writing to have their information displayed on the Service. For each Featured Trader, we may collect and publish: display name, biographical information, strategy description, avatar image, and individual trade records (instrument, side, entry and exit prices, quantities, dates, and computed profit-and-loss). The categories of information collected from Featured Traders upstream of publication are described in section 2 above.

What "Verified" means. When a trade is marked "Verified" on the Service, it means that an Invest Check team member has reviewed a brokerage statement or equivalent source document for that specific trade and confirmed that the entry price, exit price, quantity, and dates as published match the source document. As disclosed more fully in the Terms of Service, Verification is subject to material limitations: Invest Check relies on the accuracy of credentials and documents provided by the Featured Trader and on the accuracy of the brokerage's own reporting, and does not independently audit or authenticate those materials. Verification does not confirm overall account performance, account balances, strategy adherence, or future results. A "Verified" label is not a guarantee, audit, endorsement, or certification of any kind.

Source document handling. Brokerage statements and equivalent source documents provided for Verification are reviewed by authorized Invest Check personnel solely for the purpose of confirming the accuracy of specific trade records. We delete source documents immediately after Verification is complete. We retain only a verification audit record identifying which trade identifiers were verified, by whom, and on what date, for the lifetime of the associated profile and a reasonable period thereafter for regulatory and legal purposes.

Brokerage credentials. Login credentials or equivalent access information provided by Featured Traders for Verification are subject to enhanced security controls, including restricted access limited to personnel directly involved in the Verification process. Credentials are used solely for Verification and are not accessed for any other purpose. We retain credentials only for the period necessary to complete Verification and delete them promptly thereafter, subject to any obligation to retain records of access for audit purposes.

Compliance and monitoring records. Invest Check maintains compliance and monitoring records in respect of Featured Trader conduct for the period specified in section 9 (Retention) of this Policy. These records may be disclosed to securities regulators or law enforcement authorities where required by law.

Conflict of interest information. Where a Featured Trader discloses a conflict of interest, including a position held in a security they have published, that disclosure may be published on the Featured Trader's profile on the Service, as required by the Terms of Service. Featured Traders should refer to their Featured Trader agreement for the specific disclosure obligations that apply to them.

Featured Trader rights. Featured Traders may, at any time, request access to, correction of, or removal of personal information we hold about them that is not required to be retained for legal or regulatory purposes, by contacting legal@investcheck.com. In respect of data processed by Invest Check as processor, rights requests are directed to Invest Check as the operational point of contact but are discharged in accordance with the Featured Trader's own obligations as controller of that data. Removal of a profile stops further publication of the Featured Trader's information. Refund eligibility for users who have purchased that trader's content is governed by Section 9 of the Terms of Service.

For Featured Traders, cross-border transfers include transfer of brokerage credentials and source documents to any Subprocessor involved in the Verification workflow. The same contractual safeguards described above apply to those transfers.

9. How long we keep information

We retain personal information only for as long as necessary for the purposes described above:

• Account data — for the life of your account, plus a reasonable period afterwards for security audits and to defend against fraudulent chargebacks.
• Sessions, IP, and user-agent — sessions expire automatically and stale session records are pruned periodically.
• Purchase, subscription, and tax records — retained for the period required by applicable Canadian or United States tax and accounting law (typically up to seven years), even after an account is closed.
• Email logs — retained for a limited period for delivery, deliverability, and compliance purposes.
• Brokerage source documents — deleted immediately after the relevant trades have been verified.
• Featured Trader Agreement and processing records — The Featured Trader Agreement governs retention of data processed by Invest Check as processor. Invest Check's own Verification audit records are retained for the lifetime of the associated profile plus a period sufficient to respond to regulatory or legal proceedings, as set out in the Featured Trader Agreement.

10. Your rights

Subject to the limitations of applicable law, you have the following rights with respect to the personal information we hold about you:

• Access — request a copy of the personal information we hold about you.
• Rectification — ask us to correct information that is inaccurate or out of date.
• Erasure — ask us to delete your account and the personal information associated with it, subject to records we are legally required to retain.
• Restriction of processing — ask us to limit our use of your personal information in certain circumstances.
• Data portability — receive a copy of the personal information you have provided to us in a structured, commonly-used, machine-readable format.
• Objection — object to our processing of your personal information for direct-marketing or for our legitimate interests.
• Withdraw consent — withdraw any consent you have given us, subject to legal and contractual restrictions.
• Automated decision-making — request human review of any decision that produces legal or similarly significant effects and is based solely on automated processing of your personal information. Invest Check does not currently make such decisions; if that changes, we will update this policy and provide individual notice.
• Complaint — file a complaint with our Privacy Officer or with a privacy regulator (see section 14).

Featured Traders additionally have the right to request confirmation of whether their brokerage credentials have been deleted following Verification and to receive a copy of the verification audit record relating to their own trade records.

To exercise any of these rights, contact us at the email address in section 13. We will respond as soon as reasonably possible and within thirty (30) days where the law requires a specific response time. Where the request is complex or voluminous we may extend that period as permitted by applicable law (PIPEDA permits an additional thirty (30) days with notice; the EU/UK GDPR permits up to a further two months for complex requests). We may need to verify your identity before acting on your request.

11. Security

We take reasonable technical and organisational measures to protect personal information against loss, theft, unauthorised access, and disclosure, including encryption of data in transit, hashing of passwords, restricted administrative access, and audit logging of administrative actions. No system is perfectly secure, however, and we cannot guarantee absolute security.

Featured Trader brokerage credentials and source documents are treated as a sensitive category of personal information and are subject to enhanced security measures, including: access restricted to personnel directly and currently involved in the Verification process; logging of all access events for audit purposes; and prompt deletion following completion of Verification. These measures are maintained contractually with any Subprocessor involved in the Verification workflow.

If we determine that there has been a breach of security safeguards involving your personal information that creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada (and, where applicable, the Office of the Information and Privacy Commissioner of Alberta, and the Commission d'accès à l'information du Québec) as required by law. For users in the EEA or the United Kingdom, we will notify the competent supervisory authority within seventy-two (72) hours of becoming aware of a personal-data breach where required by the EU or UK GDPR.

12. Children

Invest Check is not directed at, and is not intended for use by, individuals under the age of eighteen (18). We do not knowingly collect personal information from anyone under 18. If you believe a child has provided personal information to us, please contact legal@investcheck.com and we will delete the information.

13. Privacy Officer and contact

Invest Check has designated a Privacy Officer to oversee compliance with this policy. You can reach the Privacy Officer at:

Invest Check Inc.
Attn: Privacy Officer
Email: legal@investcheck.com

14. Complaints to a regulator

If you are not satisfied with how we have handled your personal information or your privacy request, you may file a complaint with:

• the Office of the Privacy Commissioner of Canada (federal);
• the Office of the Information and Privacy Commissioner of Alberta;
• for residents of Quebec, the Commission d'accès à l'information du Québec;
• for residents of the EEA, your national supervisory authority — a list is published by the European Data Protection Board at edpb.europa.eu; or
• for residents of the United Kingdom, the Information Commissioner's Office (ICO).

15. Region-specific information

Residents of Quebec

We process the personal information of Quebec residents in accordance with the Act respecting the protection of personal information in the private sector (CQLR c. P-39.1, "Law 25").

Cross-border transfer notice (Law 25, s. 17). If you are a resident of Quebec, your personal information will be communicated to and processed by service providers located outside Quebec, primarily in the United States. Before each such transfer we assess whether the personal information will receive an adequate level of protection in light of, in particular, the sensitivity of the information, the purpose of the transfer, the protections that apply, and the legal regime of the destination jurisdiction. The current list of destination providers and jurisdictions is published at /legal/subprocessors.

Language. We are preparing French-language versions of this Policy and our Terms of Service. In the meantime, French-speaking residents of Quebec may request a French-language copy by contacting legal@investcheck.com.

Residents of the EEA, the United Kingdom, and Switzerland

For the purposes of the EU General Data Protection Regulation, the UK GDPR, and the Swiss Federal Act on Data Protection, Invest Check Inc. is the controller of the personal information described in this policy. The legal bases on which we rely for each processing activity are listed in section 3 above. The rights you can exercise are listed in section 10. If you have unresolved concerns, you have the right to lodge a complaint with your national supervisory authority (see section 14).

Invest Check has not currently designated a representative under Article 27 of the EU GDPR or the UK GDPR; if processing of EEA or UK personal information becomes regular and large-scale, we will appoint and disclose a representative.

Residents of California and other U.S. states

We do not currently meet the revenue or data-volume thresholds that would make Invest Check a "business" subject to the California Consumer Privacy Act or California Privacy Rights Act as a matter of strict statutory obligation. However, as a matter of policy, we extend the following rights to California residents and, where equivalent state laws apply, to residents of other US states: the right to know what personal information we collect and how it is used; the right to request deletion of personal information, subject to retention obligations; the right to correct inaccurate personal information; and the right to non-discrimination for exercising these rights. We do not sell personal information, and we do not share personal information for cross-context behavioural advertising. To exercise any of these rights, contact legal@investcheck.com. Nothing in this paragraph limits any rights available to you under mandatory consumer protection law as identified in the Terms of Service.

16. Changes to this policy

We may update this policy from time to time to reflect changes in the service, in the law, or in our practices. The "Last updated" date at the top of the page reflects the most recent revision. If a change is material we will give reasonable notice — for example, by email or by an in-product notice — before the change takes effect.