Data Protection and GDPR Notice

1. Controller and contact

For personal data processed in connection with Invyra, the controller is Thinkrium, operator of Invyra. Privacy questions and data-rights requests may be sent to [email protected].

Invyra does not appoint a Data Protection Officer merely by publishing this notice. If an appointed representative or Data Protection Officer becomes legally required, this notice will be updated with the applicable contact details.

2. Purposes and lawful bases

Depending on the feature and your relationship with Invyra, we rely on the following lawful bases:

• Contract. To provide requested research, operate an account, verify subscription access, save portfolio information you submit and provide customer support.
• Legitimate interests. To secure the service, prevent fraud and abuse, diagnose errors, maintain reliability and understand non-advertising product performance. We balance these interests against your rights.
• Consent. Where required, for non-essential analytics or similar storage. You may withdraw consent at any time without affecting earlier lawful processing.
• Legal obligation. To maintain required records and respond to valid legal or regulatory requests.

Where information is required to provide a requested account, subscription or support service, not providing it may prevent us from delivering that particular service. Invyra does not sell personal data or use it for third-party advertising.

3. Your data-protection rights

Subject to applicable law and any permitted exceptions, you may request:

• access to and a copy of your personal data;
• correction of inaccurate or incomplete data;
• deletion of personal data;
• restriction of processing;
• data portability for information processed by automated means on consent or contract;
• an objection to processing based on legitimate interests; and
• withdrawal of consent where consent is the lawful basis.

You also have the right to complain to the data-protection authority in the country where you live, work or believe an infringement occurred. We encourage you to contact us first so we can try to resolve the concern.

4. Recipients and international transfers

Invyra uses service providers for hosting, security, authentication, analytics, support, App Store subscription administration and selected AI functionality, as described in the Privacy Policy. These providers may process data outside your country.

Where applicable law requires a transfer mechanism, we use an available lawful safeguard appropriate to the provider and transfer, such as an adequacy decision, approved standard contractual clauses, or another legally recognised mechanism. You may request information about relevant safeguards by contacting us.

5. Automated processing and investment scores

Invyra calculates research outputs such as valuations, quality indicators, Prism context and portfolio research using market and company data. These outputs concern securities and companies, not a legal or similarly significant decision about an individual user.

Invyra does not use personal data to make solely automated decisions about you that produce legal or similarly significant effects. It does not provide personalised investment recommendations.

6. Exercising your rights

Email [email protected] with the subject Privacy Request and describe the right you want to exercise. We may request information reasonably necessary to verify your identity and protect your data.

We will respond within the period required by applicable law. Requests are generally free, although the law may permit a reasonable fee or refusal for requests that are manifestly unfounded or excessive.