Privacy Policy
Partiki ("we," "us," "our," or "the Company") operates InvestorPilot ("the App," "the Service"), a virtual stock trading simulator with AI-powered coaching. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services.
By using InvestorPilot, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use the Service.
1. Information We Collect
1.1 Account Information
When you create an InvestorPilot account, we collect:
- Email address
- Display name (chosen by you)
- Encrypted password (managed by Firebase Authentication)
- Account creation date
1.2 Trading and Usage Data
As you use the Service, we collect data about your virtual trading activity:
- Virtual stock trades (buy/sell transactions, quantities, prices)
- Portfolio holdings and virtual cash balance
- Stop loss and take profit settings
- Trade reasoning and thesis entries you provide
- Confidence levels and emotion tags you select
- Predictions and their outcomes
- Investor Score and leaderboard rankings
- Users you follow and followers
1.3 AI Interaction Data
When you interact with AI-powered features, we collect:
- AI coaching insights generated from your trading patterns
- Behavioral analysis data (e.g., patterns like FOMO, overconfidence, emotional trading)
- Trade Intel requests and generated analysis
- Your interactions with AI-generated content
1.4 Device and Technical Information
We automatically collect certain technical information:
- Device type and operating system (iOS or Android)
- Push notification tokens (via Expo)
- App version
- General usage analytics (feature engagement, session duration)
1.5 Information We Do Not Collect
InvestorPilot does not collect:
- Real financial account information (bank accounts, brokerage accounts)
- Social Security numbers or government identification
- Credit card or payment card details (subscriptions are handled entirely by Apple/Google)
- Precise GPS location
- Contacts or address book data
2. How We Use Your Data
| Purpose | Data Used |
|---|---|
| Provide the Service | Account info, trading data, portfolio data |
| AI behavioral coaching | Trading patterns, thesis entries, emotion tags, confidence levels |
| Trade Intel generation | Trade details, stock symbols, your thesis |
| Leaderboard rankings | Portfolio performance, Investor Score, display name |
| Push notifications | Push tokens, trade events, portfolio alerts |
| Follow system | User relationships, display names, trading activity |
| Subscription management | Subscription status (via RevenueCat) |
| Service improvement | Aggregated usage analytics, feature engagement data |
3. AI and Data Processing
How AI Processes Your Data
InvestorPilot uses OpenAI to power AI coaching and Trade Intel features. When you use these features, certain trading data is sent to OpenAI's API for processing. We take the following precautions:
- Data sent to AI: Your trading history, thesis entries, emotion tags, confidence levels, and portfolio data may be sent to OpenAI for generating coaching insights and Trade Intel analysis
- Anonymization: Where possible, data sent to AI services is anonymized or pseudonymized. Your email address and personal identifiers are not sent to OpenAI
- Purpose limitation: Data is sent to AI solely for generating coaching insights, behavioral analysis, and Trade Intel. It is not used to train third-party AI models on your behalf
- No human review: AI processing is automated. Your data is not routinely reviewed by humans at OpenAI as part of normal service operation
- Retention by AI providers: Data sent to OpenAI is subject to OpenAI's data retention and usage policies. We encourage you to review OpenAI's Privacy Policy
4. Data Storage and Security
4.1 Storage Infrastructure
Your data is stored using Firebase (Google Cloud Platform) infrastructure. This includes:
- Firebase Authentication: Secure storage of account credentials
- Cloud Firestore: Storage of trading data, portfolio information, leaderboard data, AI insights, and user relationships
Data is stored in Google Cloud data centers, which maintain industry-standard security certifications including SOC 1, SOC 2, SOC 3, and ISO 27001.
4.2 Security Measures
We implement appropriate technical and organizational measures to protect your data:
- Encryption in transit (TLS/SSL) for all data transfers
- Encryption at rest for stored data via Google Cloud
- Firebase Security Rules to restrict unauthorized data access
- Secure authentication with hashed passwords
- Regular security reviews of application code
However, no method of electronic storage or transmission is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.
5. Data Sharing and Disclosure
5.1 We Do Not Sell Your Data
We do not sell, rent, or trade your personal information to third parties for marketing or advertising purposes.
5.2 Service Providers
We share data with the following third-party service providers solely to operate the Service:
- Firebase / Google Cloud: Authentication, database storage, and cloud infrastructure
- OpenAI: Processing trading data for AI coaching insights, behavioral analysis, and Trade Intel generation
- Finnhub: Providing real-time stock market price data (we send stock symbol queries; no personal data is shared with Finnhub)
- RevenueCat: Subscription status management and verification (anonymous user IDs)
- Expo: Push notification delivery (device push tokens)
5.3 Legal Requirements
We may disclose your information if required to do so by law, or in response to valid requests by public authorities (e.g., a court order or government agency).
5.4 Business Transfers
If Partiki is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your data.
6. Publicly Visible Data
Certain data you provide may be visible to other InvestorPilot users:
- Leaderboard: Your display name, Investor Score, and portfolio return percentage are visible on the public leaderboard
- Follow system: If other users follow you, they may see your display name and trading activity (stocks traded, trade timing)
- Premium visibility: Premium users who follow you may see additional details about your trade strategies and reasoning
Your email address is never publicly displayed. You can choose your display name, and it does not need to be your real name.
7. Data Retention
We retain your data for as long as your account is active or as needed to provide the Service. Specifically:
- Account data: Retained until you delete your account
- Trading history: Retained for the life of your account to provide ongoing AI coaching and leaderboard calculations
- AI-generated insights: Retained for the life of your account
- Analytics data: Retained in aggregated, anonymized form indefinitely for service improvement
Upon account deletion, we will delete or anonymize your personal data within 30 days, except where retention is required by law or for legitimate business purposes (e.g., fraud prevention, legal compliance).
8. Your Rights and Choices
8.1 Access and Portability
You have the right to request a copy of the personal data we hold about you. Contact us at investorpilotsupport@gmail.com to request a data export.
8.2 Correction
You can update your display name and email address through the app settings. For other corrections, contact us directly.
8.3 Deletion
You have the right to request deletion of your account and associated personal data. You can:
- Delete your account through the app settings
- Contact us at investorpilotsupport@gmail.com to request deletion
Please note that account deletion is permanent and cannot be reversed. Your virtual portfolio, trading history, AI insights, and leaderboard position will be permanently removed.
8.4 Push Notifications
You can opt out of push notifications at any time through your device settings. Disabling push notifications will not affect the core functionality of the app.
8.5 AI Processing Opt-Out
AI coaching and Trade Intel are core features of InvestorPilot. If you do not wish for your trading data to be processed by AI, you may choose not to use these features. However, certain baseline behavioral analysis may still occur to calculate Investor Score and leaderboard rankings.
9. Children's Privacy
InvestorPilot is not intended for children under the age of 13 (or 16 in the European Economic Area). We do not knowingly collect personal information from children under these ages.
If we become aware that we have collected personal data from a child under the applicable minimum age without parental consent, we will take steps to delete that information as quickly as possible. If you believe we may have collected data from a child, please contact us at investorpilotsupport@gmail.com.
10. International Data Transfers
InvestorPilot is operated from the United States. If you are accessing the Service from outside the United States, please be aware that your data may be transferred to, stored, and processed in the United States and other countries where our service providers operate.
By using the Service, you consent to the transfer of your data to these countries, which may have different data protection laws than your country of residence. We take appropriate safeguards to ensure your data is protected in accordance with this Privacy Policy.
11. Cookies and Tracking
InvestorPilot is a mobile application and does not use browser cookies. Our tracking is limited to:
- In-app analytics: We collect aggregated, anonymized usage data to understand feature engagement and improve the app
- Push notification tokens: Device tokens used solely for delivering push notifications
- No third-party ad tracking: We do not use third-party advertising SDKs or ad-tracking technologies
- No cross-app tracking: We do not track your activity across other apps or websites
Our website (investor-pilot.com) is a simple informational site that does not use cookies or tracking technologies.
12. California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
12.1 Right to Know
You have the right to request that we disclose what personal information we have collected, used, disclosed, and sold about you in the preceding 12 months.
12.2 Right to Delete
You have the right to request deletion of personal information we have collected from you, subject to certain exceptions.
12.3 Right to Opt-Out of Sale
We do not sell your personal information. Therefore, there is no need to opt out of the sale of personal information.
12.4 Right to Non-Discrimination
We will not discriminate against you for exercising any of your CCPA/CPRA rights. You will not receive different pricing, quality, or service levels for exercising your rights.
12.5 Categories of Information
In the preceding 12 months, we have collected the following categories of personal information:
- Identifiers: Email address, display name, device tokens
- Internet/electronic activity: App usage data, trading activity, AI interaction data
- Inferences: AI-generated behavioral insights drawn from your trading patterns
12.6 Exercising Your Rights
To exercise your California privacy rights, contact us at investorpilotsupport@gmail.com. We will verify your identity before processing your request.
13. European Privacy Rights (GDPR)
If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):
13.1 Legal Bases for Processing
We process your personal data based on the following legal bases:
- Contract performance: Processing necessary to provide the Service (account management, virtual trading, leaderboard)
- Legitimate interests: Service improvement, security, fraud prevention
- Consent: AI data processing, push notifications, marketing communications (where applicable)
13.2 Your GDPR Rights
You have the right to:
- Access: Request a copy of your personal data
- Rectification: Request correction of inaccurate data
- Erasure: Request deletion of your personal data ("right to be forgotten")
- Restriction: Request restriction of processing
- Portability: Receive your data in a structured, machine-readable format
- Object: Object to processing based on legitimate interests
- Withdraw consent: Withdraw consent at any time where processing is based on consent
13.3 Data Protection Authority
If you are in the EEA, you have the right to lodge a complaint with your local Data Protection Authority if you believe we have not complied with applicable data protection laws.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:
- Update the "Last Updated" date at the top of this page
- Notify you through the app or via email for significant changes
- Provide at least 30 days' notice before material changes take effect
We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.
15. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
- Email: investorpilotsupport@gmail.com
- Website: investor-pilot.com
For data protection inquiries, privacy rights requests, or complaints, please email us with the subject line "Privacy Request" and include your account email address so we can verify your identity and process your request.
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