Privacy Policy

1. Introduction

This is the privacy policy of Infinium Holdings Ltd ("Infinium", "we", "us", "our"). It applies to all Invezz products and services, including:

The Invezz website and all editorial content at invezz.com and its subdomains
The Invezz Portfolio Platform, which allows users to connect brokerage accounts and view portfolio visualisations and analytics
Any newsletters, alerts, or other communications we send

Infinium respects your privacy and is committed to protecting your personal data. This policy explains what data we collect, why we collect it, how we use it, and your rights in relation to it. It applies regardless of where you access our services from.

This website and Platform are not intended for children. We do not knowingly collect data from children under 16 in the EEA or under 13 in the UK/US. If you believe a child has provided us with their data, please contact us and we will delete it.

2. Important Information: Who We Are

Controller

Infinium Holdings Ltd is the data controller responsible for your personal data. When we refer to "Infinium", "we", "us", or "our" throughout this policy, we mean the relevant Infinium Holdings entity operating the service you are using.

Data Protection Manager

We have appointed a Data Protection Manager (DPM) who oversees compliance with this policy.

Full legal name: Infinium Holdings Ltd

Email: contact@invezz.com

Changes to this policy

We keep this policy under regular review and will publish updates on this page. For material changes, we will notify you by email or in-Platform notification. Continued use of our services after a change is posted constitutes acceptance of the revised policy.

Third-party links

Our website and Platform may contain links to third-party websites and services. We are not responsible for their privacy practices and encourage you to read their policies when you leave our services.

3. The Data We Collect About You

Personal data means any information from which a person can be identified. We collect and process the following categories:

3.1 Website and editorial services

Identity Data: first name, last name, username, date of birth, gender
Contact Data: email address, billing address, telephone numbers
Technical Data: IP address, browser type and version, device type, operating system, time zone, and other technology on devices you use to access our services
Usage Data: how you navigate and interact with our website, which articles you read, and how long you spend on pages
Profile Data: your username and password, preferences, survey responses, and feedback
Marketing and Communications Data: your preferences for receiving marketing from us and selected third parties

3.2 Portfolio Platform

When you use the Portfolio Platform and choose to connect a brokerage account via SnapTrade, we additionally collect and process:

Portfolio Data: holdings (asset names, tickers, quantities, values), historical performance data, transaction history, and account balance and allocation information — retrieved via SnapTrade's read-only API
Connection Data: an encrypted SnapTrade OAuth connection token (this is a secure reference, not your brokerage username or password)

We do not collect or store your brokerage login credentials at any point. All credential authentication is handled exclusively by SnapTrade.

3.3 Aggregated data

We also collect, use, and share aggregated statistical data (for example, the percentage of users reading a particular topic). Aggregated data is not personal data. If we ever combine aggregated data with personal data in a way that identifies you, we treat it as personal data under this policy.

3.4 Special categories

We do not collect special category data (such as health, biometric, political, or religious data) or data about criminal convictions.

4. How We Collect Your Data

Direct interactions

You may provide data directly when you:

Register for an account on our website or Platform
Subscribe to our newsletter or alerts
Connect a brokerage account via SnapTrade on the Portfolio Platform
Enter a competition, promotion, or survey
Contact us or give feedback

Automated technologies

As you use our services, we automatically collect Technical and Usage Data via cookies, server logs, and similar technologies. See Section 5 (Cookies) for more detail.

Third parties and publicly available sources

We may receive data about you from:

SnapTrade — portfolio and holdings data from your connected brokerage account(s), provided via their read-only API
Analytics providers (e.g. Google Analytics)
Advertising networks and affiliate partners
Third-party data exchanges (e.g. Lotame)
Publicly available sources such as Companies House and the Electoral Register

5. Cookies

We use cookies and similar technologies on our website and Platform. Essential cookies are necessary for our services to function. For non-essential cookies (analytics, advertising, personalisation), we rely on your consent via our cookie banner.

You can withdraw consent at any time by adjusting your preferences through our cookie banner or your browser settings. Disabling certain cookies may affect the functionality of our services.

For more on cookies and how to manage them, visit allaboutcookies.org.

6. How We Use Your Data

We only use your personal data where the law permits. Our lawful bases are: performance of a contract with you, compliance with a legal obligation, and legitimate interests (where your rights do not override ours). Where required by law (e.g. for direct marketing by email), we rely on consent.

We use your data for the following purposes:

Website and editorial services

Registering and managing your account
Sending newsletters, alerts, and content you have subscribed to
Displaying personalised content and relevant advertising
Analytics: understanding how users interact with our content to improve it
Fraud prevention, security, and legal compliance
Marketing communications (where you have opted in)

Portfolio Platform

Retrieving your portfolio data from connected brokerage accounts via SnapTrade to generate visualisations and analytics
Displaying charts, performance summaries, and portfolio breakdowns within the Platform
Maintaining your SnapTrade connection token so the Platform can refresh data on your behalf
Providing contextual market data alongside your portfolio holdings

Portfolio data is used exclusively to deliver Platform features to you. It is not used for advertising profiling, sold to third parties, or processed for any purpose beyond providing the Platform.

All services

Communicating changes to our terms, policies, or services
Responding to your enquiries and complaints
Obtaining professional advice and complying with legal obligations

7. Marketing

We may use your Identity, Contact, Technical, Usage, and Profile Data to determine which products, services, or content may be of interest to you.

You will receive marketing from us only if you have requested it and not opted out. We will obtain your express opt-in consent before sharing your data with any third party for their own marketing purposes.

You can opt out of marketing at any time by clicking the unsubscribe link in any email, or by contacting us at contact@invezz.com.

Where we engage in personalised advertising through cookies and similar technologies, we do so only on the basis of your consent, which you can withdraw at any time via our cookie banner.

8. Disclosure of Your Data

We may share your personal data with:

Within the Infinium group

Other companies within Infinium Holdings, acting as joint controllers or processors.

SnapTrade (Portfolio Platform only)

Your portfolio data is shared with SnapTrade solely to enable the brokerage account connection. SnapTrade acts as a data processor under our instruction, and we have a Data Processing Agreement in place with them. SnapTrade's own Privacy Policy is available at snaptrade.com.

Service providers and processors

Third-party providers who support the operation of our services, including:

Website infrastructure and hosting providers
Analytics providers (e.g. Google Analytics)
Email and marketing platforms (e.g. HubSpot)
Advertising networks (e.g. Mediavine — see Section 12 for detail)
Payment processors
Professional advisers (lawyers, auditors, insurers)

All processors are contractually bound to protect your data and to use it only for the purposes we specify.

Legal and regulatory

HM Revenue & Customs, regulators, law enforcement, and other authorities where required by law.

Business transfers

If Infinium sells, transfers, or merges any part of its business, personal data may be transferred to the new owner, who will be required to handle it in accordance with this policy.

We will never sell your personal data to third parties for their own commercial purposes.

9. International Transfers

We may transfer your personal data outside the UK and EEA. Where we do, we ensure an equivalent level of protection through one or more of:

Adequacy decisions by the UK Government or European Commission
Standard Contractual Clauses (SCCs) with the UK Addendum where applicable
Other legally recognised transfer mechanisms

10. Data Security

We have put in place appropriate technical and organisational measures to protect your personal data from accidental loss, unauthorised access, alteration, or disclosure. These include:

Encryption of data in transit (TLS 1.2 or higher)
Encryption of sensitive data at rest (including SnapTrade connection tokens)
Access controls limiting data to staff and contractors who need it
Procedures for detecting and responding to personal data breaches

We will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, regulatory, accounting, or reporting requirements.

Contact Data is retained for three years from our last contact or dealing with you
All other personal data is retained for two years from our last contact or dealing with you
Portfolio Data retrieved via SnapTrade is retained in cached form for as long as your account is active. On disconnection of a brokerage account, cached portfolio data is deleted within 30 days
Anonymised, aggregated data derived from portfolio data may be retained indefinitely

You may request deletion of your data before the end of the applicable retention period — see Section 13 (Your Legal Rights).

12. Your Legal Rights

Under data protection law, you have the following rights in relation to your personal data:

Right of access: to receive a copy of the personal data we hold about you
Right to rectification: to have inaccurate or incomplete data corrected
Right to erasure: to ask us to delete your data where there is no good reason to continue processing it
Right to object: to processing based on legitimate interests, or to direct marketing
Right to restriction: to ask us to suspend processing in certain circumstances
Right to portability: to receive your data in a structured, machine-readable format (where applicable)
Right to withdraw consent: at any time where we rely on consent as our lawful basis, without affecting the lawfulness of prior processing

To exercise any of these rights, contact us at contact@invezz.com. We will respond within one month. We may need to verify your identity before acting on a request.

You also have the right to complain to:

The Information Commissioner's Office (ICO): ico.org.uk (for UK residents)
Your local supervisory authority within the EEA

We would appreciate the chance to address your concerns before you contact a supervisory authority.

13. Glossary

Legitimate Interests: Processing necessary for Infinium's business purposes where those interests are not overridden by your rights. We assess this balance before relying on this basis.

Performance of Contract: Processing necessary to deliver a service you have requested or to take steps at your request before entering a contract.

Legal Obligation: Processing required to comply with a law that applies to us.

SnapTrade: A third-party platform that enables secure, read-only connections between the Invezz Portfolio Platform and users' brokerage accounts. SnapTrade is a data processor acting under Infinium's instruction.

Portfolio Platform: The Invezz product that connects to brokerage accounts via SnapTrade and generates portfolio visualisations and analytics.

Internal Third Parties: Other companies within Infinium Holdings Group.

External Third Parties: Professional advisers; HMRC, regulators, and authorities; technology and service providers (including SnapTrade, WordPress, HubSpot); fraud prevention agencies; advertising networks and analytics providers; and business partners whose products are listed on our website.

Infinium Holdings Ltd | Intershore Chambers, Road Town, Tortola, British Virgin Islands | Company no. 2124246

Questions: contact@invezz.com