Privacy Policy
Last Updated On: March 18, 2020
At Investsize, we respect your privacy, and we understand the importance of the information you entrust to us. This Privacy Policy describes our practices concerning the information collected by Investroom A.S. (“Investsize”, “we”, “us”, “our”) through the use of (i) our Investsize website (the “Website”) and (ii) our Investsize mobile applications (collectively, the “Services”).
Below we describe what information we collect when you use our Services, how we protect that information, how long we retain it, with whom we share it, and what your privacy options are. By using the Services, you consent to our collection and use of your information as described in this Privacy Policy. The Privacy Policy is incorporated by reference into and is made a part of the Terms of Service.
We will continue to evaluate this Privacy Policy against new technologies, business practices, and our users’ needs, and may make changes to the Privacy Policy accordingly. Please check this page periodically for updates. If we make any material changes to this Privacy Policy, we will post the updated Privacy Policy here, along with its effective date, and for material changes will notify you by email or by means of a notice on our Website. Your continued use of the Services after our posting of changes to this Privacy Policy means that you agree to be bound by such changes.
1. What information do we collect about you?
We explain below the main ways that we collect and process information about you.
Information You Provide To Us:
Your use of the Services may require registration, in which case we will ask you to provide certain personal information, including an email address, username, and password. If you are enrolling in any of our membership, your registration may require further information, including, without limitation, address and/or phone number. You may also decide to provide us with some optional personal/demographic information to enhance your profile, such as your full name, professional title, year of birth, company name, and household income, investment interests, retirement information, and communications preferences. If you are a Financial Advisor participating in our Advisor Insights program, you may provide us further information about your credentials, including, without limitation, your broker CRD number, job title, state, zip code, phone number, professional website URL, biographical information, licences and designations, and profile picture.
You may also provide personal information to us, if you choose to:
- submit a help request, a customer services inquiry or other inquiry to us, or fill in any other forms for the purposes of receiving our Services;
- participate in some of the features accessible via the Services (for example, message boards, games, surveys, polls, promotions, contests, sweepstakes or other incentives);
- sign up to receive any information and/or services from any third party provider or partner using our Website (If you submit information to a third party provider or partner, please note that their use and disclosure of your information is subject to their own privacy policy);
- contact us about employment opportunities posted to the Services; or
- otherwise use the Services in a manner that you have requested.
Depending on which of these or any other Services you use, the personal information you provide may include your name, email address, user name, home address, telephone number, and information posted by you on sites accessed via the Services. Please be aware, that by posting information to message boards, chat groups or social networking facilities available via the Services, you will be making this information available to other users of these Services to the public. You should be careful about revealing any sensitive details about yourself.
Please note that we do not currently collect or retain credit card numbers internally. We partner with third party payment providers. All direct payment gateways are required to adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements are intended to promote the secure handling of credit card information.
Email Referral:
We also have features that allow you to send an email to yourself and/or others about an item on our site. If you choose to use our email referral service, you will be required to provide the e-mail address or addresses that will be used in the notification. Upon form submission an email will be generated to your recipient(s) inviting them to visit the URL you have recommended. We do not store this information other than for the sole purpose of sending this one-time e-mail.
Information Collected Automatically:
When you use the Services, we automatically collect and store certain information about your computer or device and your activities, including:
(1) IP address of your computer
(2) Unique device identifiers
(3) Technical information about your computer or mobile device such as type of device, mobile device ID number, web browser (Internet Explorer 8, etc.), other browser information (e.g. size, connection speed and connection type), and operating system or platform (Mac, Windows XP, etc.)
(4) Your preferences and settings (time zone, language, etc.)
(5) Internet provider or mobile carrier name
(6) The URL of the last webpage you visited before visiting the Website
(7) Information about your activity on the Services (e.g., your search queries, mis-formatted DNS entries, search results selected, clicks, pages viewed, search history, comments, forms filled out and submitted)
(8) If you are using a mobile device, your mobile device’s geographic location (specific geographic location if you’ve enabled collection of that information, or general geographic location automatically). Please see the section “Mobile Device Location Information” below for further information.
Cookies and Similar Technologies:
We, as well as other companies, use tracking technologies to collect and store data about your computer or mobile device and your activities on the Services. When you visit our sites, we place cookies, pixel tags, web beacons and other such similar technologies to collect and store the information we automatically collect about your computer, device and Services usage. A cookie is a small text file that is stored on your computer and a pixel tag (also called a web beacon or clear GIF) is a tiny graphic with a unique identifier, embedded invisibly on a webpage (or an online ad or email). We use the term “cookies” in this policy to refer to cookies and all such similar technologies. We use these technologies to store your preferences and track your use of the Services. Ad companies place cookies on your computer to track your activities across various sites so that they can display targeted ads. Some ad companies and game developers use "flash cookies" for ads and games that use Flash media technology.
There are two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, and (2) third party cookies, which are served by a third party on our behalf. Cookies have a lot of jobs. For example, our cookies enable us to recognize you (e.g. as a registered user) when you visit our website and to store your preferences and settings. We use third party cookies for functionality, performance / analytics, advertising and social media purposes. Cookies from advertising companies, for example, help to ensure that the advertisements you see online are more relevant to you and your interests. To understand more about cookies and pixel tags.
How To Control Or Delete Cookies:
Most browsers allow you to change your cookie settings. Users can usually set their browsers to block all third-party cookies (which are those set by third-party companies collecting information on websites operated by other companies), block all cookies (including first-party cookies such as the ones Investsize uses to collect search activity information about its users), or block specific cookies. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.
Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
Please note that if you choose to block cookies, this may interfere with certain functionality on our website. Also, if you have disabled one or more cookies, we may still use information collected from cookies prior to your disabled preference being set; however, we will stop using the disabled cookie to collect any further information.
Third parties whose products or services are accessible or advertised through the Services, including social networking services, may also use cookies or similar tools, and we advise you to check their privacy policies for information about their cookies and other practices. We do not control the practices of such partners and their privacy policies govern their interactions with you. We encourage you to read their privacy policies.
Information from third parties. We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.
2. How do we use the information we collect?
We use the information we collect from and about you for a variety of purposes, including:
- verify your eligibility for our Services;
- understand our users (their demographics, what they do on our Services, what features they like, how they use them etc.) and improve our Services, such as by personalizing content to your interests, and to process and complete your transactions;
- administer our Services, diagnose technical problems and otherwise manage our business;
- send you communications that you have requested or that may be of interest to you in accordance with your preferences. Please see the section “Reviewing, changing or deleting information” for further information about how you can control these communications;
- deliver prizes in connection with contests and sweepstakes, deliver perks earned in connection with certain incentive programs, or otherwise facilitate the use of our Services;
- provide you with customer support;
- enable us to show you ads that are more relevant to you; and
- perform functions as otherwise described at the time of collection.
We may aggregate and/or de-identify information collected by the Services or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.
3. How do we share the information we collect?
We will not share the personal information we collect about you with any third party except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared. We will share your information in the following ways:
- Our suppliers, subcontractors and business partners (“service providers”): We may share your data with our services providers who process your personal information to provide services to us or on our behalf, including, without limitation, our email marketing providers, who are required to treat the data in accordance with confidentiality requirements.
- Service requests: We enable you to request information and/or services from third party service providers or partners by filling out a registration, information request, or similar service request form for specific services from them (e.g., filling in a sponsored partner’s form to identify your retirement risk profile and/or submitting a request with such information for more information from that partner or another party). When you fill out and submit a service request form through our Website, you consent to our providing your personal information and request to the third party provider and/or partner. Sharing this information with the party provider and/or partner allows them to contact you using the contact information you provided. Additionally, we have other contractual partners that that utilize their own service provider to supplement our offering, and we share your information with them in order to attempt to provide the services requested.
- Companies within the Investsize Group of Companies: We may share your information with our affiliates, which are entities under common ownership or control of our ultimate parent company, Investsize.
- Law Matters: We may disclose your information when we believe in good faith that such disclosure is appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or the Terms of Service for the Services you accessed, and/or to protect the rights and property of Investsize, our employees, users and the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.
- Sale or merger of our business: We may transfer your information to a third party if we or any of our affiliates are involved in a corporate restructuring (e.g., a sale, merger, or other transfer of assets).
- Advertisers: We may share your information with third-parties with whom we have a contractual relationship, including without limitation third-party advertisers and advertising networks.
You may opt-out of having your personal information shared with third parties or for any purpose that is materially different than the purpose you shared it with us by sending a request to the following address with a preference on how our response to your request should be sent (email or postal mail). Send an email to us at info@investsize.com, or you may contact us via regular mail at: Investsize, LLC, Gursu Mh. 312sk. No:10/2 Antalya, Konyaaltı 07070, Attn: Your Privacy Rights c/o Lead Counsel. All requests sent via regular mail must be labeled "Your Privacy Rights" on the envelope or post card and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code (your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping).
4. Online and Mobile Interest Based Advertising
When you use the Services, we may serve you with ads based on various factors such as the content of the page you are visiting, information you provide such as your age or gender, your searches, demographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests.
Advertisers and advertising networks may also place ads (including sponsored links in search results) on our Services. These companies, as well as data analytics companies who service them, may use cookies, pixel tags, mobile device advertising IDs and other similar technologies to collect data about you when you visit our Services (for example, web pages visited and searches made). They use the data to enable them to track your activity across various sites where they display ads and record your activities, so they can show ads that they consider relevant to you. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. You may opt-out of receiving interest-based online advertising from advertising networks that is delivered on the Services and other websites by visiting the following websites:
Please bear in mind that there are many more companies listed on these sites than those that drop cookies on our Services.
When using a mobile application you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. We do not control how the applicable platform operator allows you to control receiving tailored in-application ads; thus, you should contact the platform provider if the above options are no longer available.
Mobile Device Location Information: When you use one of our location-enabled services (for example, when you access Services from a mobile device), we may need to collect and process information about your specific GPS location (including the latitude, longitude or altitude of your mobile device) and the time the location information was recorded, and we may use that information to customize the Services with location-based information, advertising, and features. Some of these services require us to associate location data with your device ID and other information we hold about you. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling the relevant feature. If you do not want your location information collected when you use the Services from a mobile device, please see your device manufacturer’s settings.
5. Right to Access, Review, change or delete information
To access, review, change or delete personal information we have collected from you, login to your account and visit the Manage Profile page.
To delete your account, visit the Contact Us page and send a message to our Support team. Be sure to select "Delete Account" under the dropdown box that's labeled "Type," and include your email address so that we can confirm your request.
Do Not Track: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services.
We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the Network Advertising Initiative and the Digital Advertising Alliance opt-out links above. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
6. How Do We Protect Your Information?
We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology.
Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.
7. How long do we keep the information we collect?
We retain the information we collect about and from you for as long as necessary to fulfill a business purpose or comply with a legal request. We may also choose to anonymize certain of the information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.
8. Children under 13
The Services are not intended for users under the age of 13. We do not knowingly collect any personal information from children under 13. If we become aware that a person submitting information is under 13, we will attempt to delete the information as soon as possible. You hereby represent that you are at least 13.
9. Use Outside Turkey
The Website and any Investsize mobile applications are controlled and offered by Investroom A.S. from the Turkey and, regardless of your place of residence, your use of them is governed by the law of Turkey. Investsize makes no representations that the Website and any Investsize mobile applications are appropriate for use in other locations or are legal in all jurisdictions. Those who access or use the Website and any Investsize mobile applications from other locations do so at their own risk and are responsible for compliance with local law. You consent to the transfer and processing of your data in Turkey and any other jurisdiction throughout the world.
10. Linked Sites and Advertisements.
The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites. We have relationships with third-party providers to provide content, products, services, and functionality through the Services. Such providers may collect information from you directly, in which case the provider’s privacy policy (which may differ from this Privacy Policy) would apply. If you have any questions regarding the privacy policy of any of our providers, you should contact the provider directly for more information.
11. General Data Protection Regulation (GDPR)
We are a Data Controller of your information.
Investsize legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect the information:
- Investsize needs to perform a contract with you
- You have given Investsize permission to do so
- Processing your personal information is in Investsize legitimate interests
- Investsize needs to comply with the law
Investsize will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you.
- The right of rectification.
- The right to object.
- The right of restriction.
- The right to data portability
- The right to withdraw consent
12. Log Files
Investsize.com follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the website, and gathering demographic information.