Privacy and Cookie Policy

Privacy Policy

The following describes the privacy policy (the “ Privacy Policy ”) upon which InvestGame (the “ Company ” or “ InvestGame ” or “ We”) offers access to the Internet site found at https://investgame.net/ alongside its related country specific sites and any related sub-domains and/or mobile applications thereof (respectively, the “ Site ” or “ App ”, and together the “ Services ”) to you, the customer, irrespective of whether or not you are an Account (as defined below) holder (“ you ” or “ You ”). InvestGame is committed to protecting your privacy. This Privacy Policy is designed to help you decide whether to use the Service and in what manner, and it describes how we collect, store and use information on individuals who use the Service.

As InvestGame Limited is a UK-based company, we comply with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and other applicable UK data protection and privacy laws, including the Privacy and Electronic Communications Regulations 2003. Where applicable, we also adhere to the EU General Data Protection Regulation (EU GDPR) in relation to users located in the European Economic Area (EEA). We are committed to handling your personal data responsibly, lawfully, and transparently, in line with the obligations set out by the Information Commissioner’s Office (ICO) and relevant supervisory authorities.

Data Controller

InvestGame Ltd is the data controller responsible for your personal data for the purposes of applicable data protection law.

If you have any questions about this Privacy Policy or our data practices, you can contact us at:

Registered office: Newfrith House, 21 Hyde Street, Winchester, United Kingdom, SO23 7DR 

Company number: 16292353 

VAT number: 489 7336 26 

Contact: info@investgame.net

By using the Services, you acknowledge that your personal data may be processed in accordance with this Privacy Policy.

Where we rely on consent as a legal basis, we will request it separately and in a manner that complies with applicable law. In particular, consent for non-essential cookies and similar technologies will be requested through our cookie banner or other appropriate consent tools. 

The definitions in the Terms and Conditions apply to this Privacy Policy unless stated otherwise. In addition to this Privacy Policy, please review our Terms and Conditions, which are incorporated herein by reference, together with such other policies of which you may be notified by us from time to time.

Information We Collect 

Usage and Technical Information

We collect certain technical and usage information when you interact with our Services. This may include your IP address, browser type, language, device type, operating system, referring URLs, pages viewed, time spent on pages, clicks, and other diagnostic or analytics information.

We use this information to operate, secure, maintain, analyse, and improve the Services. Some of this information may constitute personal data under applicable law, particularly where it can be linked to an identifiable individual.

We may also collect personal data that you provide directly to us, such as your email address when you subscribe to our newsletter, contact us, or create an account.

We also use cookies and similar technologies. We may also use similar technologies such as local storage and session storage to store user preferences, remember consent choices, and support analytics or session-monitoring tools. Where required by law, we will request your consent before placing non-essential cookies on your device. Further details are set out in the Cookie Policy section below.

Personal Data We Collect

We collect personal data that you choose to provide to us and personal data generated through your use of the Services.

Depending on how you interact with us, this may include:

• your name;
• email address;
• account and login details;
• subscription and billing-related information;
• communications you send to us;
• technical and usage data associated with your account or device.

We process this data only where we have a valid legal basis to do so under applicable data protection law.

Legal Basis for Processing

We process your personal data on one or more of the following legal bases:

• performance of a contract, where processing is necessary to provide the Services, manage your account, or process your subscription;
• legitimate interests, including improving the Services, ensuring security, preventing misuse, and administering our business;
• consent, where required, including for certain marketing communications and non-essential cookies;
• compliance with a legal obligation, where we must retain or disclose data under applicable law.

How We Use Your Information

We use personal data and related technical information to:

• provide, operate, and maintain the Services;
• create and manage user accounts;
• process subscriptions, billing, and related administration;
• communicate with you about your account, subscriptions, support requests, or service updates;
• send newsletters or marketing communications where permitted by law;
• monitor usage, performance, and security;
• prevent fraud, misuse, and unauthorised access;
• improve our website, platform, and related services;
• comply with legal, regulatory, accounting, and reporting obligations.
• measure engagement with our emails, including whether emails are opened and whether links are clicked, in order to analyse the effectiveness of our communications and improve our newsletters, updates, and marketing materials, where permitted by applicable law
• We use third-party email service providers to deliver service-related communications. These providers may automatically collect technical data — including whether an email was delivered, opened, or a link was clicked — in order to ensure reliable delivery, measure engagement, and improve our communications, where permitted by applicable law.

We do not use your personal data for automated decision-making or profiling.

How We Share Your Information

We may share or transfer information, including Personal Data, internally within our group of companies for the purposes outlined in this Privacy Policy. These companies may be located in countries that do not provide the same level of data protection as your jurisdiction.

We may share personal data with:

(i) service providers that support the operation of the Services, including hosting providers, analytics providers, payment processors such as Stripe, email communication and email campaign providers such as Brevo, and monitoring or error tracking providers such as Sentry;

(ii) contractors, advisers, auditors, legal or financial consultants who need access to the data for legitimate business purposes;

(iii) prospective investors, buyers, or restructuring counterparties in connection with a corporate transaction, subject to appropriate confidentiality obligations; and

(iv) regulators, law enforcement bodies, courts, or other authorities where required by law or where necessary to protect our rights, users, or the public.

All such third parties are contractually bound to process data solely in accordance with InvestGame’s instructions and in compliance with applicable data protection laws.

All data processed through the Services, including data stored via our platform available at app.investgame.net, is hosted within the European Union.

Where personal data is transferred outside the UK or the EEA, we take appropriate steps to ensure that such transfers comply with applicable data protection laws, such as using Standard Contractual Clauses (SCCs) or the UK International Data Transfer Agreement (IDTA).

We may also share your Personal Data and other information in special cases if we have a good reason to believe that it is necessary to: (i) comply with law, regulation, subpoena, request by an applicable authority or court order; (ii) detect, prevent or otherwise address fraud, security, violation of our policies or technical issues; (iii) enforce the provisions of this Privacy Policy or any other agreements between you and InvestGame, including investigation of potential violations thereof; or (iv) protect against harm to the rights, property or safety of the Company, its partners, its affiliates, users or the public.

How long we keep the information

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, including to provide the Services, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements.

In particular:

• cookie and consent preferences are retained for the period specified in our Cookie Policy or until they are deleted by the user, depending on the relevant technology used and the configuration of the relevant service;
• newsletter contact details are retained until you unsubscribe or until they are no longer needed for that purpose;
• account-related data is retained for as long as your account remains active and for a reasonable period thereafter where necessary for legal, compliance, security, or record-keeping purposes;
• technical logs and security records are retained for limited periods appropriate to their purpose.

Links to other websites

Where applicable, InvestGame may provide links to one or more third-party sites within our products or services. This Privacy Policy does not apply to those sites. We encourage you to read any third-party site’s privacy policy before providing any of your personal data to them.

Account deletion

You may request deletion of your account and associated personal data by contacting us at info@investgame.net.

We will review and process such requests in accordance with applicable data protection law. In some cases, we may need to retain certain information where required for legal, regulatory, security, accounting, or legitimate business purposes.

Your Rights

Subject to applicable law, you may have the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request erasure of your personal data;
• request restriction of processing;
• object to certain processing activities;
• request portability of personal data where applicable; and
• withdraw consent at any time where processing is based on consent.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) or another relevant supervisory authority.

Cookie Policy

The following describes the Cookie Policy (the “Cookie Policy”) upon which InvestGame (the “Company” or “InvestGame” or “We”) offers access to the Internet site found at https://investgame.net/ alongside its related country-specific sites and any related sub-domains and/or mobile applications thereof (respectively, the “Site” or “App”, and together the “Services”) to you as the customer, irrespective of whether or not you are an account (as defined below) holder (“you” or “You”).

Our Site, like many websites, uses cookies to run the content management system and to collect anonymous visitor data. In keeping with applicable legislation, we are making users more aware of these cookies and providing links to help visitors decline or remove them.

What are cookies?

A cookie is a small file of letters and numbers placed on your device as part of your use of the Site. More details about cookies are available from several online sources, including All About Cookies

For the purposes of this Cookie Policy, references to “cookies” may also include similar technologies, such as local storage and session storage, where these are used to store information on your device.

We use strictly necessary cookies and similar technologies to ensure the proper functioning and security of the Site and App. These do not require user consent.

We use analytics and performance-related technologies only with your consent. You may withdraw your consent at any time by revisiting the cookie banner.

Why do we use cookies?

We use cookies and similar technologies to ensure the Services function properly, maintain security, manage user sessions, remember consent choices and preferences, understand how visitors use our Services, and improve performance and user experience.

Which cookies do we use?

We use the following cookies and similar technologies across our websites and platform.

Cookies used on app.investgame.net

Strictly necessary cookies:

• csrftoken — used to help protect the platform against Cross-Site Request Forgery (CSRF) attacks and to ensure that requests are submitted intentionally by the user. Provider: Django. Duration: approximately 1 year.
• sessionid — used to maintain the authenticated user session on the platform. Provider: Django. Duration: approximately 2 weeks.

Similar technologies:

• cookie_consent (localStorage) — used to remember that the user has provided cookie consent. Duration: persistent until deleted by the user.
• cookie_preferences (localStorage) — used to store the user’s cookie preference settings. Duration: persistent until deleted by the user.
• _fs_tab_id (sessionStorage) — used by FullStory to distinguish browser tabs and support session monitoring. Duration: until the browser tab is closed.

At present, app.investgame.net uses strictly necessary cookies for authentication and security, together with similar technologies to store preferences and support session-monitoring tools. It does not use advertising or marketing cookies.
On app.investgame.net we also use FullStory, a session monitoring and performance tool, which is activated only after the user has provided consent. FullStory helps us understand how users interact with the application and identify usability issues. This tool may use similar technologies such as session storage to function.

Cookies used on investgame.net

Analytics cookies:

• _ga — used by Google Analytics 4 to distinguish users and generate website usage statistics. Duration: approximately 2 years.
• _ga_3EEPY3677H — used by Google Analytics 4 to persist session state. Duration: approximately 2 years.

Consent-management cookies:

• cookielawinfo-checkbox-necessary — records consent for necessary cookies. Duration: approximately 1 year.
• cookielawinfo-checkbox-functional — records consent for functional cookies. Duration: approximately 1 year.
• cookielawinfo-checkbox-performance — records consent for performance cookies. Duration: approximately 1 year.
• cookielawinfo-checkbox-analytics — records consent for analytics cookies. Duration: approximately 1 year.
• cookielawinfo-checkbox-advertisement — records consent for advertising cookies. Duration: approximately 1 year.
• cookielawinfo-checkbox-others — records consent for other cookies. Duration: approximately 1 year.
• · viewed_cookie_policy — used to store whether the user has acknowledged the cookie banner. Duration: approximately 1 year.

Some pages of the Site may include embedded third-party content (such as widgets or external media). These third parties may set their own cookies or use similar technologies. We do not control these technologies. Please refer to the respective third-party privacy policies for more information.

Analytics and session monitoring tools

We may use third-party analytics and session-monitoring tools, such as FullStory, to understand how users interact with the Services, improve usability, and troubleshoot issues. Where required by law, such technologies will be used on the basis of an appropriate legal ground, including user consent.

Opting out, removing and managing cookies

If you are uncomfortable with the use of cookies, most browsers now permit users to opt out or block them. The method varies by browser – see “Managing cookies” below. Please note that blocking cookies may affect your ability to access certain sections of the Site or impair functionality. Alternatively, you may wish to delete cookies from your system at the end of your visit.

Managing cookies

You can adjust your browser settings to manage cookies, including blocking or deleting them. The website About Cookies offers browser-specific instructions for managing cookies. If you would like to prevent all Google Analytics cookies from being set, you may install the Google Analytics Opt-Out Browser Add-On.

Please be aware that disabling cookies may impair the functionality of this and other websites.

Further information about disabling cookies can be found in the help section of your browser or on your browser provider’s website. You may also wish to consult All About Cookies
for guidance.

Please note that certain similar technologies, such as local storage or session storage, may also be cleared through your browser settings.