Privacy Policy

1. Who we are and what this policy covers

Ivolved Systems LLC, a Wyoming limited liability company doing business as Ivolution (“Ivolution,” “we,” “us,” or “our”), is the business responsible for the personal information described here. Our mailing address is c/o Republic Registered Agent LLC, 5830 E 2nd St, Ste 7000, Casper, WY 82609 and our privacy contact is privacy@ivolution.io.

This policy explains what personal information we collect through ivolution.io, terminal.ivolution.io, the Ivolution terminal, our reports and research library, our AI features, our indicators, our APIs, and our Discord community (together, the “Service”), why we collect it, who we disclose it to, how long we keep it, and the choices and rights you have. It serves as our notice at collection for California residents and, together with the notices presented in the product, as the disclosure required by other United States state privacy laws.

It does not cover the independent practices of platforms we integrate with. Whop, Discord, and TradingView each collect information under their own privacy policies and are responsible for their own processing. Review those policies as well.

2. Personal information we collect

The categories below use the terminology of the California Consumer Privacy Act as amended by the California Privacy Rights Act. We collect only what the Service needs.

2.1 Identifiers and account information

Your name or display name, email address, Whop user and membership identifiers, subscription tier and status, Discord user identifier and roles where you link Discord, and TradingView username where an indicator is provisioned to you. Source: you, and Whop, Discord, and TradingView acting on your instruction. Purpose: creating and authenticating your account, provisioning and enforcing entitlements, and supporting you.

2.2 Commercial information

Records of the subscription you purchased, its billing period, renewal and cancellation events, refund and chargeback records, and support correspondence. Source: Whop and you. Purpose: providing and billing the Service, handling refunds and disputes, and keeping the records that tax and accounting rules require. We do not receive or store your full payment-card number, expiry, or security code; Whop processes payment credentials as the merchant of record.

2.3 Internet and network activity

Pages and panels you open, features and workspaces you use, requests your browser makes to our servers, referring URLs, approximate location inferred from IP address at city level, device and browser type, operating system, screen size, language, session identifiers, and timestamps. Source: automatically from your device and our servers. Purpose: operating and securing the Service, diagnosing faults, measuring which features are used, preventing credential sharing and abuse, and enforcing rate limits.

2.4 AI conversation content

The questions and messages you send to the AI analyst, the context the product attached to them, and the responses returned. Source: you. Purpose: producing the response, operating the feature, investigating abuse and safety incidents, and diagnosing faults. See Section 7.

2.5 Content you submit

Chart annotations, saved layouts and settings, feedback, bug reports, support messages, and anything you post in our Discord community. Source: you. Purpose: providing the feature you used it for, supporting you, and moderating the community.

2.6 Diagnostic and error data

Error reports, stack traces, performance traces, and the technical context attached to them, which may incidentally include an account identifier or a URL. Source: automatically from your device and our servers via our error-monitoring provider. Purpose: finding and fixing defects and monitoring reliability.

2.7 Inferences

Limited inferences drawn from the above about which features you use and your engagement with the product. Source: derived. Purpose: improving the Service and deciding what to build. We do not build behavioural advertising profiles and we do not use inferences to make any decision that produces a legal or similarly significant effect about you.

2.8 What we do not collect

We do not solicit, request, or knowingly store your brokerage credentials, account numbers, balances, holdings, positions, order history, or trade confirmations, and the Service is deliberately built not to ingest them. Do not send that information to us or to the AI analyst. We do not collect sensitive personal information as the CCPA defines it — such as government identifiers, precise geolocation, racial or ethnic origin, religious beliefs, union membership, health information, biometric identifiers, or the contents of your mail — for the purpose of inferring characteristics about you, and we do not otherwise seek it. We do not collect personal information from anyone under 18. If you send us information we did not ask for, we will delete it when we identify it.

2.9 Optional advertising measurement

With your permission, we collect the OpenAI ad click identifier included in a link that brought you to our website and record your measurement choice. If you complete an eligible paid subscription, we use the verified payment record to measure that ad. We send OpenAI the ad click identifier, an event identifier, the subscription plan identifier, payment amount and currency, payment time, and a fixed page address without your browsing query parameters. This integration does not send your name, email address, payment-card details, brokerage data, or AI conversations.

We do not load OpenAI's browser measurement SDK in this implementation. Measurement is optional. Declining it does not prevent you from purchasing or using the service. You can withdraw permission through Ad measurement settings; withdrawal stops future eligible reporting for the revoked consent grant. It cannot undo an event already sent. Browser Global Privacy Control and Do Not Track signals prevent new measurement consent from being used. We send OpenAI's personalization opt-out on reported events.

3. How we use personal information

We use personal information for these business purposes and no others without notice to you:

• —providing, maintaining, and improving the Service and the features you ask for;
• —authenticating you and enforcing subscription entitlements;
• —processing subscriptions, renewals, cancellations, refunds, and disputes through our commerce platform;
• —providing support and responding to your requests;
• —monitoring reliability, diagnosing faults, and debugging;
• —detecting, investigating, and preventing fraud, credential sharing, scraping, abuse, and threats to security or integrity;
• —measuring feature usage in aggregate to decide what to build;
• —optional advertising measurement with your permission, subject to Section 4;
• —sending service, security, billing, and legal communications, and — where you have not opted out — product announcements;
• —complying with law, responding to lawful requests, and establishing, exercising, or defending legal claims; and
• —enforcing our Terms of Service and our community rules.

We do not use AI conversation content to train or fine-tune any general-purpose model.

4. Optional advertising measurement and your choices

We do not exchange personal information for money. With your permission, we disclose the limited ad-click and payment information described above to OpenAI to measure our advertising. Privacy laws may treat disclosures to advertising providers as selling, sharing, or targeted advertising even when no money is exchanged for the information. You can opt out by declining optional ad measurement or using Ad measurement settings. We also honor Global Privacy Control and Do Not Track browser signals. No account or identity verification is required to make this choice.

We do not send a conversion when permission is absent or the consent grant has been revoked. Withdrawal stops future reporting for that grant; it does not recall data already disclosed. If a server withdrawal cannot be confirmed immediately, the site shows the pending status and retries. You can also contact privacy@ivolution.io to exercise your privacy rights. We do not knowingly send advertising measurement data about anyone under 18.

5. When we disclose personal information

We disclose personal information only:

• —to service providers and contractors who process it on our behalf, under written contracts that limit them to our documented instructions, forbid retaining or using it for their own purposes, and forbid selling or sharing it (Section 6 lists them);
• —to Whop, Discord, and TradingView as necessary to provision the access you purchased, in each case in accordance with their own privacy policies;
• —to OpenAI for optional advertising measurement with your permission, as described in Sections 2.9, 4, and 6;
• —where you direct us to, or where you post it publicly in our community;
• —to our professional advisers — lawyers, accountants, auditors — under duties of confidentiality;
• —to comply with law, a subpoena, a court order, or a lawful request from a public authority, and to establish, exercise, or defend legal claims;
• —to protect the rights, property, or safety of Ivolution, our users, or the public, including to investigate fraud, abuse, or a security incident; and
• —to an acquirer or successor, or as part of a due-diligence process, in connection with a merger, acquisition, financing, reorganization, or sale of assets, in which case we will require the recipient to honour this policy or give you notice and a choice before your information becomes subject to a materially different one.

In the preceding twelve months we disclosed for business purposes the categories described in Sections 2.1 through 2.7 to the categories of recipients described in this Section. We did not disclose sensitive personal information for any purpose beyond those permitted without a right to limit.

6. Service providers and subprocessors

The following providers process personal information on our behalf. Each is bound by a contract that restricts processing to our instructions and prohibits selling or sharing.

• —Whop — commerce, checkout, payments, membership and entitlement records. Merchant of record for subscription payments.
• —Vercel — hosting and content delivery for the web application; request logs.
• —Railway — hosting for the analytics engine and background workers; application logs.
• —Neon — managed Postgres database for application and account data.
• —Upstash — managed Redis for caching, rate limiting, and job queues.
• —Cloudflare — object storage for generated reports and artifacts, and network services.
• —Anthropic — large-language-model inference for the AI analyst and generated market reads. Prompts and responses are processed to return the output; under our commercial terms they are not used to train Anthropic's models.
• —Sentry — error and performance monitoring.
• —Discord — community hosting and role-based access for members who link Discord.

TradingView is not a service provider to Ivolution and receives no personal information from us. Our indicators execute on TradingView's platform in your own browser session; where a tier includes an indicator, provisioning consists of granting access to the TradingView username you supply. Your use of TradingView is governed by TradingView's own terms and privacy policy.

A current list of subprocessors is maintained in this Section. We may add or replace a provider as the Service evolves and will update this Section when we do.

Separate recipient for optional advertising measurement

OpenAI receives optional advertising measurement data under its advertising and conversion terms and may act as an independent controller. Its processing is governed by those terms and its applicable privacy notice. We request the available personalization opt-out on every conversion event and do not upload customer lists or configure personalized retargeting through this integration. See OpenAI's privacy policy (https://openai.com/policies/privacy-policy/) and Conversion Terms (https://openai.com/policies/conversion-terms/).

7. AI analyst conversations

When you use the AI analyst or an AI-generated report, your message and the market context attached to it are sent to our model provider, which returns a response. Numbers presented to you originate in our analytics engine rather than from the model.

We retain conversation content for ninety (90) days from the date of the conversation, and then delete it or irreversibly de-identify it, except where a longer period is required to investigate an open abuse or security incident or to comply with a legal obligation or hold. Aggregate, de-identified counts and quality metrics that cannot reasonably be linked back to you may be kept longer.

Human review is limited. A person reads a conversation only to investigate suspected abuse, a safety concern, a security incident, a support request you raise, or a suspected defect you report, and access is restricted to the staff who need it for that purpose. Conversations are not reviewed for marketing, profiling, or general quality browsing, and are not used to train or fine-tune any general-purpose model.

Do not enter brokerage credentials, account numbers, positions, other people's personal information, confidential or proprietary material, or material non-public information into an AI feature. You can ask us to delete a conversation before the retention period ends by writing to privacy@ivolution.io.

8. Cookies and similar technologies

We use cookies and equivalent browser storage for purposes that are strictly necessary to operate the Service: keeping you signed in, maintaining your session, remembering your workspace and panel preferences, enforcing rate limits, and protecting against fraud and abuse.

We use browser storage to remember your measurement choice and, only with your permission, the OpenAI ad click identifier as described in Sections 4 and 9. We do not load OpenAI's browser measurement SDK in this implementation. Our error-monitoring provider sets an identifier so that related errors from one session can be correlated.

You can block or delete cookies in your browser settings, but the Service cannot keep you signed in without the strictly necessary ones. We honor Global Privacy Control and Do Not Track as described in Section 4.

9. How long we keep personal information

We keep each category only for as long as it is needed for the purpose it was collected for, and then delete or de-identify it. Our current criteria:

• —Account and entitlement records: for the life of your account and for up to twelve (12) months after it closes, so that a returning member and a billing question can both be resolved.
• —Commercial and transaction records: for as long as tax, accounting, and audit rules require, which is generally seven (7) years.
• —AI conversation content: ninety (90) days, as described in Section 7.
• —Server, request, and security logs: up to ninety (90) days, except where a log is preserved for an open security investigation.
• —Error and performance diagnostics: up to ninety (90) days.
• —Support correspondence: up to twenty-four (24) months after the matter is closed.
• —Community posts: for as long as the community keeps them, subject to Discord's own retention and to your ability to delete your own posts.

The browser's saved permission choice and consented ad-click identifier have a validity period of up to 30 days for optional measurement. A withdrawal reference remains usable for up to 61 days. These are validity limits, not guarantees of physical deletion from browser storage at expiry. Expired records no longer authorize measurement, but browser records can persist until the site clears them or you delete site data through your browser's storage controls. The server's grant expires no later than that click's original 30-day measurement period. The server may retain its click record for up to seven additional days to deliver delayed receipts for payments made before expiry. Withdrawal removes the click identifier from the grant. A server revocation record may remain through the delivery retry period. Whop retains checkout and payment records under its own practices; our metadata there contains a signed grant reference rather than the ad-click identifier. Our ordinary billing-record retention is separate from optional advertising measurement.

Where a legal hold, an open dispute, or a live security investigation applies, we retain what is relevant to it until it is resolved.

10. Your California privacy rights

If you are a California resident, the CCPA gives you the following rights, subject to its exceptions:

• —Right to know — to request the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collecting it, and the categories of third parties to whom we disclosed it.
• —Right to delete — to request that we delete personal information we collected from you, subject to the exceptions the statute allows (for example, completing a transaction, security and fraud prevention, and legal compliance).
• —Right to correct — to request that we correct inaccurate personal information we hold about you.
• —Right to data portability — to receive the specific pieces we hold in a portable and, where technically feasible, readily usable format.
• —Right to opt out of sale, sharing, or targeted advertising — decline optional ad measurement or withdraw permission in Ad measurement settings; see Section 4.
• —Right to limit the use of sensitive personal information — we do not collect sensitive personal information for purposes that would give rise to this right; see Section 2.8.
• —Right to non-discrimination — we will not deny you the Service, charge you a different price, provide a different level of quality, or retaliate against you because you exercised a privacy right. We offer no financial incentive in exchange for personal information.

Residents of other states with comprehensive privacy laws — including Colorado, Connecticut, Virginia, Utah, Texas, Oregon, and Montana — have comparable rights of access, correction, deletion, portability, and opt-out, and where those laws provide an appeal from our decision, you may appeal by replying to our response or writing to privacy@ivolution.io with “Privacy Appeal” in the subject line. We will respond to an appeal within the period the applicable law allows and will tell you how to contact your state attorney general if you disagree with the outcome.

11. How to exercise your rights

Send your request to privacy@ivolution.io from the email address associated with your account, stating which right you are exercising. You may also write to us at the postal address in Section 1.

Verification. To protect you, we verify a request before acting on it. For most requests, confirming control of the account email is enough. For a request for specific pieces of personal information, we may ask for additional confirmation matched against information we already hold. We use information you provide for verification only for that purpose and delete it afterwards. If we cannot verify a request, we will tell you and will treat a deletion request we cannot verify as a request to opt out where that is available.

Authorized agents. You may use an authorized agent. We will ask the agent for written permission signed by you, or for a valid power of attorney, and we may ask you to verify your own identity directly with us and to confirm that you gave the agent permission.

Timing. We acknowledge a request within ten (10) business days and respond substantively within forty-five (45) calendar days. Where reasonably necessary we may extend once by a further forty-five (45) days and will tell you why within the first period. Requests are free unless they are manifestly unfounded or excessive, in which case we will explain the reason and any fee before proceeding.

Some information is held by Whop, Discord, TradingView, or OpenAI under their own controllership. Where a request concerns information we do not control, we will tell you and point you to the right provider.

12. California “Shine the Light”

California Civil Code section 1798.83 permits California residents to request information about personal information disclosed to third parties for those third parties' own direct-marketing purposes. Ivolution does not disclose personal information for that purpose. You may confirm this by writing to privacy@ivolution.io with “Shine the Light” in the subject line.

13. Children

The Service is intended for adults and is not directed to children. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a person under 18, we will delete it and terminate the account. A parent or guardian who believes a child has provided us with personal information should write to privacy@ivolution.io.

14. Security

We use reasonable administrative, technical, and organizational safeguards appropriate to the nature of the information we hold: encryption in transit, encryption at rest with our infrastructure providers, access controls and least-privilege access for staff, secrets held in managed configuration rather than in code, dependency and error monitoring, and logging of administrative access.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Protect your credentials, use a unique password, and tell us at support@ivolution.io if you believe your account has been compromised. Where a breach affecting your personal information occurs, we will notify you and the authorities as and when the law requires.

15. International users

Ivolution is based in the United States and the Service is operated from and hosted in the United States. If you access it from outside the United States, your personal information will be transferred to, stored in, and processed in the United States and in other countries where our providers operate, whose data-protection laws may differ from those of your country. By using the Service you understand that this transfer is necessary to provide it to you.

Where a transfer mechanism such as standard contractual clauses is required for personal information originating in a jurisdiction that requires one, we put an appropriate mechanism in place with the relevant provider. If you are in a jurisdiction with rights beyond those described in Section 10 — for example a right to object, a right to restrict processing, or a right to complain to a supervisory authority — write to privacy@ivolution.io and we will handle your request in accordance with the law that applies to you.

16. Changes to this policy

We may update this policy. When we do, we will change the effective date and version at the top of this page. For a material change — a new purpose, a new category, or a change to retention or to our position on selling or sharing — we will give notice by email or through the Service before the change takes effect. We review this policy at least once every twelve months, as California law requires.

17. Contact

Ivolved Systems LLC, doing business as Ivolution. Notices by mail: c/o Republic Registered Agent LLC, 5830 E 2nd St, Ste 7000, Casper, WY 82609.

• —Privacy requests, questions, and appeals: privacy@ivolution.io
• —Account and billing support: support@ivolution.io
• —Legal notices: legal@ivolution.io

We will provide this policy in an alternative format on request from anyone who needs one because of a disability. Write to privacy@ivolution.io.