Last updated: 4 August 2021

JAVLIN Invest LLC (hereinafter referred to as “JAVLIN Invest”, “we” or “us”) is committed to upholding a high standard in order to protect the personal information of customers and users of our Platform (as defined below). It is important to us to maintain the security of your personal information within our care.

This Privacy Policy is an integral part of our Terms of Use. By using our website, our iOS mobile application, Android mobile application (the “Platform”), you agree to proceed on the basis of this Privacy Policy and you agree with the conditions of processing your personal information contained in this document. If you are a former user or customer, this Policy will apply to you; we treat your information with the same care as we do information about current customers.

Personal Information Collected

Information that you voluntarily provide us with:

You may provide us with your personal information in a number of ways, including, without limitation, when you sign up for and use the Platform or mobile app; have previously provided us with personal information prior to this Privacy Policy or last updates coming into effect; sign-up as a customer; subscribe to alerts, information releases, updates, and media releases; complete and submit any forms to us; contact us directly in person or via any medium including but not limited to by mail, telephone, social media, and commercial electronic messages; communicate with us for any matters and interact with or browse the Platform generally.

Personal information that we may receive includes, but is not limited to:

your full name, email address;
physical address, phone number;
financial details;
more detailed contact preferences.

JAVLIN Invest may receive this information from you when you manually enter such information, or we may receive such information from third parties and other users of our Platform who use the Platform. By using the Plaid service to link a brokerage account when signing up for a JAVLIN Invest account, you acknowledge and agree that JAVLIN Invest will collect information about the balances, holdings, and transactions history of that brokerage account. Any information provided to JAVLIN Invest through Plaid will be treated by Plaid in accordance with their respective privacy policies available at  and by this Policy accordingly.

By giving us this information, you consent to this information being collected, used, disclosed, transferred to the U.S., and stored by us, as described in this Privacy Policy.

To the extent you enter identifying information as part of the account application process, we are required by law to store that information to comply with federal regulations.

Data that we collect automatically

We collect information from every visitor and user of the Platform, in particular, we automatically collect information about your visit to the Platform, your usage of our services, and your browsing and mobile activities. This anonymized information may include IP address, browser type, browser language, cookies data, performance specifications of the user’s hardware and software, date and time of access to the website and the URL of the page requested, other information about how you interacted with our Platform and services.

Data from your use of the Platform

We may receive information about how and when you use the Platform, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the Platform. This type of information helps us to improve our Platform and services for both you and for all of our users.

Cookies and tracking

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Website owners use cookies to make their websites operate, improve functionality and user experience, as well as to provide reporting information.

We may set our own cookies and use third parties cookies (e.g. for advertising, interactive content, and analytics).

We use different types of cookies, including:

Essential website cookies: these are important cookies as they are necessary to provide you with services available through our Platform, such as access to secure areas.

Performance and functionality cookies: these cookies are necessary to enhance the performance and functionality of our Platform but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

Analytics and customization cookies: these cookies collect information that is used either in aggregate form to help us understand how our Platform is being used or how effective our marketing campaigns are, or to help us customize our Platform for you in order to enhance your experience.

Advertising cookies: these cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests.

You may opt-out from cookies at any time by customizing your cookie preferences. However, in some cases, we will not be able to provide you with all services.

Data from third party sources

We may receive some information about you, such as name, email address, demographic information, IP address, and location from third parties.


You may decline to have your personal information collected via third party tracking technologies by navigating to the settings feature in your browser and declining all third party cookies or declining third party cookies from specific sites, or, for mobile, limiting ad tracking or resetting the advertised identifier via the privacy settings on your mobile device.

You can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising:


Children under the age of 18 (or other legal age of your country of residence) should not use our Platform and services. We do not knowingly provide any services to minors. If you access our Platform and services, you represent that you have the legal capacity to enter into a binding agreement.

Use of the Information

We only use your personal information for the following purposes:

to provide you with the financial services that you requested;

to open, operate, and maintain your account in accordance with the U.S. law;

to bill and collect money owed to us for services;

to promote the use of our Platform;

to send you informational and promotional content that you may subscribe to or unsubscribe;

to send you notifications, including notifications on changes of our Platform;

to communicate with users about our Platform and provide customer support in response to their inquiries;

to enforce compliance with the applicable law;

to protect our rights and safety as well as rights and safety of our users and third parties;

to provide information to representatives and advisors;

to prosecute and defend a court, arbitration, or similar legal proceeding;

to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements;

to provide, support, and improve the services we offer;

to provide suggestions about products or services that you may be interested in and which you may opt-out;

to transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.

If you link external accounts to JAVLIN Invest, we may use holdings and transactional data from those accounts to provide you with financial analytics.

Sharing of Information

We do not share personal information, unless:

doing so is appropriate to carry out your own request;

we believe it is needed to enforce our Privacy Policy, or if it is legally required;

we believe it is needed to detect, prevent or address fraud, security, or technical issues;

otherwise protect our property, legal rights, or that of others.

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share personal information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use personal information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of personal information with our Agents.

Safeguarding your Personal Information

The protection of your personal information is vital to us. We use the strongest available encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information. Our employees, contractors, and any business partners can access personal information on a need-to-know basis, and under strict duties of maintaining confidentiality. We use encryption for sensitive information and we test our system on a regular basis to ensure we comply with industry practices and standards. While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet, or method of electronic storage, is completely secure, and we cannot guarantee the absolute security of any data.

You agree to protect the security of your login information and password and not to transfer such information to any third party. We will not be liable to you for the use of your account by any third party.

If you become aware of any unauthorized use of your account, you shall immediately notify us in writing.

Access to your Personal Information

You may access your personal information held by us to correct, update and remove inaccurate or incorrect data. You have the following rights:

delete some or all personal information that we held about you;

change or correct your personal information that we held about you;

object to, or limit or restrict, use of your personal information;

right to access your personal information.

If you request us to view, change and remove your data associated with your account, please contact us at We will process your request within 15 business days. In accordance with the applicable laws, additional fees may be applied.

Changes to the Privacy Policy

We may amend this Privacy Policy from time to time. The use of the information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make major changes in the way we collect or use information, we will notify you by posting an announcement on the Platform or sending you an email.

Merge of Company

If JAVLIN Invest merges with, or is acquired by, another company or organization, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser or any prospective purchaser’s adviser and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

Additional Information for California Residents

In this section, we describe how we handle the personal information of California residents under the California Consumer Privacy Act (“CCPA”). This clause covers personal information that we collect, share and use for the last 12 months.

We describe the personal information that we collect in section “Data Collected”. The section “Use of the Data” contains information on how we use personal information.

We share certain personal information in accordance with section “Sharing of Data”. However, we do not sell your personal information to third parties.

In accordance with the CCPA, California residents are entitled, in addition to other rights described in this Privacy Policy, to:

Request deletion. You have the right to request deletion of the personal information that we collect from you;

Request copy. You have the right to ask for a copy of all or part of personal information that we retain about you over the last 12 months;

Designated agent. You are entitled to designate an agent who is able to make requests on your behalf. The agent should access your account to make a request.

List of service providers. You have the right to request a list of third parties with whom we shared personal information (if any) and what kind of information we shared during the previous calendar year.

If you want to exercise your rights, please contact us at

JAVLIN Invest does not tolerate discrimination. The quality of our services is equal for all our users, irrespective of whether you decide to exercise your rights under the CCPA.

Additional Information for Vermont Residents

We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, which you have provided to us by agreeing to our Terms of Use, please contact us at Please note, however, that we will not be able to provide you with services through JAVLIN Invest without the ability to share this financial information.

International Visitors

Our Platform and services are hosted in the U.S. By giving us your personal information, you consent to this information being collected, used, disclosed, transferred to the U.S., and stored by us, as described in this Privacy Policy.

Contact us

Should you have any questions or concerns, please email us at