This Privacy Policy explains how Aldiyar Zharkimbayev, an individual entrepreneur registered under the laws of the Republic of Kazakhstan (State registration No. 951127300803), conducting business under the trade name Investreak ("Investreak," "we," "us"), collects, uses, discloses, and protects information when you use our website, app, and related services (the "Service"). Investreak is the data controller for the purposes of this Policy.
Account information. Name, email address, password (hashed), and any profile information you provide.
Payment information. Billing details are collected and processed by Dodo Payments (dodopayments.com), which acts as merchant of record for your purchase and, in that role, is an independent controller of your payment data for tax, fraud-prevention, and payment-compliance purposes — not solely our processor. We receive limited information back from Dodo Payments (e.g., last 4 digits of card, subscription status) but do not store full card numbers. See Dodo Payments' own privacy policy for how it handles data it controls as merchant of record.
Usage data. Pages viewed, lessons and quizzes completed, streak and progress data, feature interactions, device/browser type, IP address, and approximate location (derived from IP).
Communications. Support requests, survey responses, and other messages you send us.
Cookies and similar technologies. See our separate Cookie Policy, incorporated into this Privacy Policy by reference.
We use the information above to: provide and maintain the Service; process subscriptions and payments; personalize your learning path and progress tracking (not investment advice — see the Risk Disclosure); operate the AI Coach; send transactional emails (billing, account, security); with your permission, send marketing communications; monitor and improve the Service; detect fraud and abuse; and comply with legal obligations.
We do not use your account to generate personalized investment recommendations, and we do not sell your data to data brokers.
If you are located in the EEA or UK, we process your personal data on the following legal bases under the GDPR/UK GDPR:
You can withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
If you are located in Kazakhstan, we process your personal data in accordance with the Law of the Republic of Kazakhstan "On Personal Data and Its Protection," on the basis of your consent given at registration and as necessary to perform our agreement with you (the Terms of Service).
We share information with:
We do not sell your personal information for money.
Investreak is based in the Republic of Kazakhstan. If you are located outside Kazakhstan, your information will be transferred to and processed in Kazakhstan and any other country where our subprocessors operate (which, depending on final vendor selection, may include the United States and EU/EEA). Where required, we rely on Standard Contractual Clauses or another approved transfer mechanism to protect data transferred from the EEA/UK. See the data-localization open item above regarding Kazakhstan-citizen data specifically.
Our use of cookies and similar technologies, including the categories in use and how to control them, is described in full in our separate Cookie Policy, incorporated into this Privacy Policy by reference.
If you are a US resident in a state with a comprehensive privacy law (e.g., California, and other states with similar laws), you have the right to: know/access the personal information we hold about you; delete it; correct inaccuracies; opt out of sale/sharing and of targeted advertising; and not be discriminated against for exercising these rights. To exercise these rights, contact support@investreak.com. We will verify your identity before fulfilling your request.
If you are in the EEA or UK, you have the right to: access your data; rectify inaccurate data; erase your data ("right to be forgotten"); restrict or object to processing; data portability; and lodge a complaint with your local supervisory authority (or, for UK residents, the Information Commissioner's Office). Contact support@investreak.com to exercise these rights.
If you are in Kazakhstan, you have the right to: access your personal data; request correction of inaccurate data; withdraw consent to processing; and request deletion of your data, subject to our legal obligations to retain certain records (e.g., billing records). Contact support@investreak.com to exercise these rights.
We retain personal data for as long as your account is active and as needed to provide the Service, comply with legal obligations (including tax/financial recordkeeping in Kazakhstan and, where applicable, in your home jurisdiction), resolve disputes, and enforce our agreements.
The Service is not directed to individuals under 18, and we do not knowingly collect personal information from anyone under 18. If we learn we have collected such information, we will delete it. Contact support@investreak.com if you believe a minor has provided us information.
We use reasonable administrative, technical, and physical safeguards designed to protect your information. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
We may update this Privacy Policy from time to time. We will post the updated policy with a new "Last updated" date and, for material changes affecting your rights, provide additional notice (e.g., email or in-app notice).
Investreak Aldiyar Zharkimbayev, Individual Entrepreneur Kazakhstan, Almaty, Medeu District, Zholdasbekov street, 9/2