Privacy Policy

Invo Tech, Inc. ("Invo," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, store, and protect information when you access or use our website at ourinvo.com, our Developer Dashboard at console.invo.network, our Software Development Kits ("SDK"), Application Programming Interfaces ("APIs"), and any related services, tools, and features (collectively, the "Services").

This Privacy Policy applies to game developers, studio representatives, website visitors, and other users who interact with our Services. It does not apply to end-user players of games that integrate our SDK, as player data is collected and controlled by game developers. We serve as a data processor for aggregated, pseudonymized transaction data related to premium currency value transfers between participating applications.

By accessing or using the Services, you acknowledge that you have read, understood, and agree to the data practices described in this Privacy Policy. If you do not agree with our policies and practices, you must not access or use the Services.

1. Information We Collect

We collect several categories of information from and about users of our Services. The information we collect depends on how you interact with our Services and the choices you make.

1.1 Developer Account Information

When you register for a developer account to access our SDK, APIs, and Developer Dashboard, we collect:

Identity Information: Full legal name, company or organization name, business registration details, tax identification numbers, and authorized representative information
Contact Information: Email address, phone number, business address, and mailing address
Account Credentials: Username, password (stored in encrypted form), security questions and answers, and authentication tokens
Payment Information: Bank account details, payment processor account information, billing address, and tax withholding documentation for processing transfer fee distributions
Professional Information: Game titles, studio information, development team size, game genres, target platforms, and integration timeline

1.2 Game Integration Information

When you integrate our SDK into your games, we collect:

Game Configuration Data: Game identifiers, economy settings, currency configurations, exchange rate parameters, API keys, secret keys, and webhook endpoints
Technical Implementation Data: SDK version, game engine type and version (Unity or Unreal Engine), programming language, integration method (Blueprints, C++, Bolt, Playmaker), build environment, and technical specifications
Game Metadata: Game title, description, genre, release date, platforms, age ratings, and promotional images

1.3 Transaction and Analytics Data

To facilitate premium currency value portability and provide analytics through the Developer Dashboard, we collect:

Transaction Information: Transaction identifiers, timestamps, amount transferred, source application, destination application, transaction status, and fees applied
Aggregated Player Data: Pseudonymized player identifiers (generated by your game), transaction patterns, currency conversion events, transfer frequency, and geographical region (country-level only)
Analytics and Performance Data: Transaction volumes, success rates, failure rates, average transaction values, player retention metrics related to value transfers, revenue generated from transfer fees, and network performance metrics
System of Record Data: Internal transaction records, processing logs, and validation timestamps

1.4 Usage and Technical Information

We automatically collect certain information when you access or use our Services:

Device Information: Computer or device type, operating system and version, browser type and version, screen resolution, device identifiers, and hardware specifications
Connection Information: Internet Protocol (IP) address, internet service provider, connection type, and approximate geographic location derived from IP address
Usage Information: Pages visited, features accessed, time spent on pages, links clicked, search queries within the Developer Dashboard, navigation paths, and interaction with our Services
Log Data: Access times, error logs, crash reports, API call logs, authentication attempts, and system performance data
Cookies and Tracking Technologies: Data collected through cookies, web beacons, pixels, local storage, and similar technologies (see Section 8 for details)

1.5 Communications and Support Information

When you communicate with us, we collect:

Support Tickets: Technical issues reported, bug descriptions, feature requests, error messages, screenshots, and correspondence history
Email Communications: Content of emails, attachments, email metadata, and communication preferences
Survey Responses: Feedback, satisfaction ratings, feature preferences, and demographic information voluntarily provided
Marketing Communications: Newsletter subscriptions, event registrations, webinar attendance, and content downloads

1.6 Information from Third Parties

We may receive information about you from third-party sources, including:

Payment Processors: Payment verification, transaction confirmation, fraud detection signals, and payout processing status
Business Partners: Game engine providers, platform holders, and technology partners who may share information about your games or integrations
Public Sources: Publicly available information about your games, press releases, app store listings, and professional profiles
Fraud Prevention Services: Risk scores, verification results, and security signals

1.7 Information We Do Not Collect

It is important to note what we do NOT collect:

Player Personal Information: We do not directly collect names, email addresses, birthdates, or other personally identifiable information from end-user players. This data remains under the control of game developers
Game Content: We do not collect or store player-generated content, chat messages, gameplay recordings, or other in-game content
Payment Card Information: We do not directly collect or store credit card numbers, CVV codes, or other payment card details. All payment processing is handled by certified third-party payment processors
Precise Geolocation: We do not collect GPS coordinates or precise location data. Geographic information is limited to country-level identification based on IP addresses

2. How We Use Your Information

We use the information we collect for various business and operational purposes. The legal bases for our processing under applicable data protection laws (including GDPR) include: performance of our contract with you, our legitimate interests, your consent, and compliance with legal obligations.

2.1 Providing and Operating the Services

We use your information to:

Create, maintain, and authenticate your developer account
Process and facilitate premium currency value portability transactions between participating applications
Generate and distribute API keys and authentication credentials
Provide access to the Developer Dashboard and its features
Calculate and process transfer fee distributions and payments
Monitor transaction integrity through our system of record and validation processes
Generate real-time analytics, reports, and insights about your game's economy and player transactions
Enable game discovery and network effects within the Invo ecosystem

2.2 Improving and Developing the Services

We use your information to:

Analyze usage patterns and trends to improve user experience
Develop new features, products, and services
Test and troubleshoot new and existing features
Conduct research and development for transaction processing and value portability technologies
Optimize SDK performance and reduce integration friction
Enhance security measures and fraud detection capabilities
Perform data analytics and create aggregated, anonymized statistics about platform usage

2.3 Customer Support and Communications

We use your information to:

Respond to your inquiries, support requests, and feedback
Provide technical assistance and troubleshooting
Send service-related communications, including account notifications, security alerts, and system updates
Notify you of changes to our Services, policies, or terms
Request feedback through surveys and questionnaires
Provide documentation, tutorials, and educational resources

2.4 Marketing and Business Development

With your consent where required by law, we use your information to:

Send newsletters, promotional materials, and marketing communications about our Services
Promote your game as part of the Invo network on our website, blog, and marketing materials
Invite you to events, webinars, and conferences
Conduct market research and competitive analysis
Create case studies and success stories (with your explicit permission)
Personalize marketing messages based on your game genre and interests

You can opt out of marketing communications at any time by following the unsubscribe instructions in our emails or contacting us directly.

2.5 Security and Fraud Prevention

We use your information to:

Detect, prevent, and investigate fraudulent transactions and activities
Identify and prevent security threats, abuse, and violations of our Terms of Service
Verify identity and authenticate users
Monitor for suspicious patterns or anomalies in transaction data
Protect against unauthorized access to accounts and systems
Investigate security incidents and data breaches
Enforce our policies and protect our rights and property

2.6 Legal Compliance and Protection

We use your information to:

Comply with applicable laws, regulations, and legal processes
Respond to lawful requests from public authorities, including law enforcement
Enforce our Terms of Service and other agreements
Establish, exercise, or defend legal claims
Protect the rights, property, and safety of Invo, our users, and the public
Comply with tax obligations and financial reporting requirements
Maintain records for audit and compliance purposes

2.7 Business Transactions

We may use your information in connection with:

Mergers, acquisitions, or sales of all or a portion of our business
Corporate restructuring or reorganization
Due diligence in connection with potential business transactions
Bankruptcy or similar proceedings

3. How We Share Your Information

We may share your information with third parties in the following circumstances. We require third parties to respect the security of your data and treat it in accordance with applicable laws.

3.1 Service Providers and Business Partners

We share information with trusted third-party service providers who perform services on our behalf, including:

Cloud Infrastructure Providers: For hosting our Services, storing data, and providing computing resources (e.g., Amazon Web Services, Google Cloud Platform, Microsoft Azure)
Payment Processors: For processing payments, distributing transfer fee revenues, and managing financial transactions
Analytics Services: For analyzing usage patterns, generating reports, and improving our Services
Customer Support Tools: For managing support tickets, live chat, and customer relationship management
Email Service Providers: For sending transactional emails, newsletters, and notifications
Security Services: For fraud detection, identity verification, DDoS protection, and security monitoring
Transaction Infrastructure: For facilitating transaction processing, maintaining our system of record, and settlement operations

These service providers have access only to the information necessary to perform their specific functions and are contractually obligated to maintain confidentiality and security.

3.2 Other Game Developers in the Network

To facilitate premium currency value portability and enable the Invo network, we share limited information with other developers:

Game titles and descriptions for display in player-facing transfer interfaces
Transaction metadata necessary to complete transactions (timestamps, amounts, transaction IDs)
Aggregated, anonymized statistics about network activity and trends
Publicly available information about your participation in the Invo network

We do NOT share your account credentials, payment information, proprietary game economy settings, or detailed revenue information with other developers.

3.3 Transaction Records

Transaction records are maintained in Invo's system of record to ensure accuracy, auditability, and security. Information stored in our transaction records may include:

Transaction identifiers
Pseudonymized account references
Transaction amounts and timestamps
Processing and validation data

We employ privacy-enhancing technologies and access controls to minimize the exposure of sensitive information in our transaction records.

3.4 Legal and Regulatory Authorities

We may disclose your information to law enforcement, government agencies, regulators, courts, or other third parties when we believe in good faith that disclosure is necessary to:

Comply with applicable laws, regulations, legal processes, or enforceable governmental requests
Enforce our Terms of Service or other agreements, including investigation of potential violations
Detect, prevent, or address fraud, security, or technical issues
Protect against harm to the rights, property, or safety of Invo, our users, or the public as required or permitted by law
Respond to court orders, subpoenas, or other legal processes
Cooperate with tax authorities and financial regulators

3.5 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, sale of assets, or other business transaction involving Invo, your information may be transferred to the acquiring or successor entity. We will notify you of any such transaction and any choices you may have regarding your information.

3.6 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so, such as:

Featuring your game in case studies, testimonials, or promotional materials
Sharing your contact information with potential business partners
Integrating with third-party services you explicitly authorize
Publishing success metrics or revenue information about your game

3.7 Aggregated and Anonymized Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you or your users. This includes:

Industry trends and statistics
Platform-wide transaction volumes and metrics
Research and development insights
Benchmarking data for the gaming industry

This information is not considered personal information and may be used and shared for any lawful purpose.

4. Data Security and Protection

We take the security of your information seriously and implement comprehensive technical, administrative, and physical safeguards designed to protect your data from unauthorized access, disclosure, alteration, and destruction.

4.1 Technical Security Measures

Our security measures include:

Encryption: All data transmitted between your systems and our Services is encrypted using industry-standard TLS/SSL protocols. Sensitive data at rest is encrypted using AES-256 or equivalent encryption standards
Transaction Integrity: Transaction integrity is maintained through our system of record and validation processes, making unauthorized alterations detectable and preventing tampering
Privacy-Enhancing Technologies: We employ techniques that support transaction validation while minimizing exposure of underlying sensitive data
Access Controls: Multi-factor authentication (MFA), role-based access controls (RBAC), and the principle of least privilege limit access to your data
API Security: API keys, secret keys, OAuth tokens, rate limiting, and request validation protect against unauthorized API access
Network Security: Firewalls, intrusion detection and prevention systems, DDoS protection, and network segmentation protect our infrastructure
Secure Development: Code reviews, security testing, vulnerability scanning, and penetration testing are integrated into our development lifecycle

4.2 Administrative Security Measures

We maintain organizational security through:

Security Policies: Comprehensive information security policies and procedures governing data handling
Employee Training: Regular security awareness training for all employees with access to data
Background Checks: Background screening for employees with access to sensitive systems and data
Confidentiality Agreements: Contractual obligations requiring employees and contractors to maintain confidentiality
Incident Response: Documented procedures for detecting, responding to, and recovering from security incidents
Vendor Management: Security assessments and contractual requirements for third-party service providers

4.3 Physical Security Measures

Our data centers and facilities employ:

24/7 security monitoring and surveillance
Restricted access controls and badge-based entry systems
Environmental controls for temperature, humidity, and fire suppression
Redundant power supplies and network connections
Regular security audits and compliance assessments

4.4 Data Breach Notification

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will:

Notify affected users without undue delay, and where feasible, within 72 hours of becoming aware of the breach
Describe the nature of the breach, categories of data affected, and approximate number of affected records
Provide information about the likely consequences of the breach
Describe measures taken or proposed to address the breach and mitigate harm
Provide contact information for inquiries
Notify relevant data protection authorities as required by applicable law

4.5 Limitations of Security

While we implement robust security measures, no system is completely secure. You acknowledge that:

Internet transmission and electronic storage are never 100% secure
You are responsible for maintaining the security of your account credentials
You should use strong, unique passwords and enable multi-factor authentication
You should promptly report any suspected security incidents or unauthorized access
We cannot guarantee the absolute security of your information

5. Data Retention

We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

5.1 Retention Periods

Our retention periods vary based on the type of information:

Account Information: Retained for the duration of your account plus seven (7) years after account closure for legal, tax, and audit purposes
Transaction Data: Retained for the duration required by audit trails, financial record-keeping requirements, and applicable law
Analytics Data: Aggregated analytics data is retained for up to five (5) years; granular usage data is retained for up to two (2) years
Communications: Support tickets and correspondence are retained for three (3) years; marketing communications data is retained until you opt out
Log Data: System logs are retained for ninety (90) days to one (1) year depending on the log type and regulatory requirements
Backup Data: Backups containing your information are retained for up to one (1) year and are securely deleted thereafter

5.2 Factors Affecting Retention

We determine retention periods based on:

The nature and sensitivity of the information
The purposes for which we process the information
Legal, regulatory, accounting, and reporting requirements
Our legitimate business interests
The need to establish, exercise, or defend legal claims
Tax and financial audit requirements

5.3 Deletion and Anonymization

After the retention period expires, we will:

Securely delete or destroy personal information
Anonymize information so it can no longer identify you
Aggregate information into statistical data that cannot be linked to you

Note that certain transaction records may be retained for extended periods where required for audit, compliance, or legal purposes. These records use pseudonymous identifiers and access controls to minimize exposure of personal information.

6. Your Rights and Choices

Depending on your location and applicable law, you may have certain rights regarding your personal information. This section describes these rights and how to exercise them.

6.1 General Rights

You have the right to:

Access: Request access to the personal information we hold about you and receive a copy of that information
Correction: Request correction of inaccurate or incomplete personal information
Deletion: Request deletion of your personal information, subject to legal retention requirements
Portability: Request a copy of your personal information in a structured, commonly used, machine-readable format
Objection: Object to our processing of your personal information for certain purposes, including marketing
Restriction: Request that we restrict processing of your personal information in certain circumstances
Withdrawal of Consent: Withdraw consent for processing based on consent, without affecting the lawfulness of processing before withdrawal

6.2 GDPR Rights (European Economic Area, UK, and Switzerland)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR) and equivalent laws:

Right to Information: Receive clear information about how we process your personal data
Right of Access: Obtain confirmation of whether we process your personal data and access to such data
Right to Rectification: Have inaccurate personal data corrected
Right to Erasure ("Right to be Forgotten"): Have your personal data deleted in certain circumstances
Right to Restriction of Processing: Restrict processing in certain circumstances
Right to Data Portability: Receive your personal data in a portable format
Right to Object: Object to processing based on legitimate interests or for direct marketing
Rights Related to Automated Decision-Making: Not be subject to decisions based solely on automated processing with legal or similarly significant effects (we do not engage in such automated decision-making)
Right to Lodge a Complaint: File a complaint with your local data protection authority

6.3 CCPA/CPRA Rights (California)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know: Request information about the categories and specific pieces of personal information we have collected, the sources, purposes, and third parties with whom we share information
Right to Delete: Request deletion of personal information we have collected, subject to certain exceptions
Right to Correct: Request correction of inaccurate personal information
Right to Opt-Out: Opt out of the "sale" or "sharing" of personal information (we do not sell personal information in the traditional sense)
Right to Limit Use of Sensitive Personal Information: Limit our use of sensitive personal information (we do not use sensitive personal information beyond what is necessary to provide the Services)
Right to Non-Discrimination: Not be discriminated against for exercising your CCPA/CPRA rights
Right to Designate an Authorized Agent: Designate an authorized agent to make requests on your behalf

Note: We do not "sell" personal information as defined by CCPA/CPRA. We do not share personal information for cross-context behavioral advertising.

6.4 Marketing Communications

You can opt out of marketing communications by:

Clicking the "unsubscribe" link in any marketing email
Updating your communication preferences in the Developer Dashboard
Contacting us at support@ourinvo.com with "Unsubscribe" in the subject line

Please note that even if you opt out of marketing communications, we will still send you transactional and service-related communications necessary for account administration.

6.5 Exercising Your Rights

To exercise any of these rights, please contact us at:

Email: privacy@ourinvo.com
Subject Line: "Privacy Rights Request - [Type of Request]"
Include: Your name, email address associated with your account, description of your request, and any relevant details

We will respond to your request within the timeframes required by applicable law (generally 30 days, extendable by an additional 60 days if necessary). We may need to verify your identity before processing your request to protect your privacy and security.

6.6 Limitations on Rights

Your rights may be limited in certain circumstances, such as when:

Disclosure would adversely affect the rights and freedoms of others
The request is manifestly unfounded or excessive
We are required to retain information by law
Information is necessary for the establishment, exercise, or defense of legal claims
Information is required for audit, compliance, or financial record-keeping purposes
Processing is necessary for compliance with legal obligations

7. International Data Transfers

Invo is based in the United States, and your information will be collected, processed, and stored in the United States and potentially in other countries where our service providers operate. These countries may have data protection laws that differ from those in your country of residence.

7.1 Transfers from the EEA, UK, and Switzerland

If you are located in the European Economic Area, United Kingdom, or Switzerland, we implement appropriate safeguards for international data transfers:

Standard Contractual Clauses: We use European Commission-approved Standard Contractual Clauses (SCCs) with our service providers and partners
Adequacy Decisions: We may transfer data to countries that have received adequacy decisions from the European Commission
Supplementary Measures: We implement additional technical and organizational measures to ensure data protection, including encryption, access controls, and contractual protections
Binding Corporate Rules: Where applicable, we rely on binding corporate rules approved by data protection authorities

7.2 Cross-Border Data Transfers

When we transfer data internationally, we ensure:

Data is encrypted during transit and at rest
Service providers are contractually bound to protect data according to applicable standards
Appropriate security measures are in place in all jurisdictions
Compliance with applicable data protection laws in both the sending and receiving countries

7.3 Your Consent to International Transfers

By using our Services, you acknowledge and agree that your information may be transferred to, stored in, and processed in the United States and other countries. If you do not consent to such transfers, you should not use the Services.

8. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to collect and store information about your interactions with our Services.

8.1 Types of Cookies We Use

We use the following categories of cookies:

Essential Cookies: Necessary for the Services to function properly. These enable core functionality such as account authentication, security features, and session management. You cannot opt out of these cookies.
Functional Cookies: Enable enhanced functionality and personalization, such as remembering your preferences, language settings, and customization options.
Analytics Cookies: Help us understand how users interact with our Services by collecting aggregated usage data, page views, session duration, and navigation patterns. We use this information to improve our Services.
Marketing Cookies: Track your browsing activity to deliver relevant advertisements and measure the effectiveness of marketing campaigns. These cookies may be set by third-party advertising partners.

8.2 Specific Technologies

Our Services use:

HTTP Cookies: Small text files stored on your device that contain information about your session and preferences
Local Storage: Browser-based storage for larger amounts of data that persists across sessions
Session Storage: Temporary storage that is cleared when you close your browser
Web Beacons (Pixels): Tiny transparent images embedded in web pages and emails to track interactions
JavaScript: Code that executes in your browser to enable interactive features and collect usage information

8.3 Third-Party Cookies and Analytics

We use third-party services that may set their own cookies, including:

Google Analytics: For website analytics and user behavior tracking
Customer Support Platforms: For live chat and support ticket management
Payment Processors: For secure payment processing
Content Delivery Networks: For optimized content delivery

These third parties have their own privacy policies governing their use of cookies and tracking technologies.

8.4 Managing Cookies

You can control cookies through:

Browser Settings: Most browsers allow you to view, manage, and delete cookies through settings or preferences. You can typically block all cookies, accept only first-party cookies, or receive notifications before cookies are set
Cookie Preference Center: You can adjust your cookie preferences through our cookie banner when you first visit our website
Opt-Out Tools: You can opt out of certain advertising cookies through industry opt-out pages such as the Digital Advertising Alliance (DAA) or Network Advertising Initiative (NAI)

Please note that blocking or deleting cookies may affect the functionality of our Services, and some features may not work properly without cookies enabled.

8.5 Do Not Track Signals

Some browsers support "Do Not Track" (DNT) signals. Currently, there is no industry standard for how to respond to DNT signals, and our Services do not respond to DNT browser signals. We will continue to monitor developments in DNT standards.

9. Children's Privacy

Our Services are not directed to children under the age of 13 (or the applicable age of digital consent in your jurisdiction), and we do not knowingly collect personal information from children.

9.1 Age Restrictions

To use our Services, you must:

Be at least 18 years old to register for a developer account
Have the legal authority to enter into binding contracts
Represent a legitimate business entity if registering on behalf of a company

9.2 COPPA Compliance

We comply with the Children's Online Privacy Protection Act (COPPA). If you are a game developer whose game is directed to children under 13, you are responsible for:

Obtaining verifiable parental consent before collecting personal information from children
Implementing appropriate privacy protections in your game
Complying with all applicable children's privacy laws
Ensuring that any data shared with Invo through the SDK is COPPA-compliant

Our SDK is designed to facilitate premium currency value portability using pseudonymized identifiers, which minimizes the need to collect or process personal information from child players. However, developers remain responsible for ensuring their data practices comply with COPPA and other applicable laws.

9.3 Parental Rights

If you believe we have inadvertently collected personal information from a child under 13, please contact us immediately at privacy@ourinvo.com. We will take prompt steps to delete such information and terminate the associated account.

10. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, and services that are not owned or controlled by Invo.

10.1 Third-Party Responsibility

We are not responsible for:

The privacy practices of third-party websites and services
The content or accuracy of third-party materials
The security of third-party platforms
How third parties collect, use, or share your information

10.2 Third-Party Integration

If you integrate third-party services with your Developer Dashboard account (such as analytics tools or marketing platforms), those third parties may collect information directly from you. Your use of third-party services is governed by their respective privacy policies and terms of service.

10.3 Recommendation to Review Third-Party Policies

We encourage you to read the privacy policies of any third-party websites or services that you visit or use. By clicking on third-party links or accessing third-party services, you acknowledge that we are not responsible for their privacy practices.

11. California Privacy Rights Disclosures

This section provides additional information for California residents as required by the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

11.1 Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information:

Identifiers: Name, email address, account username, IP address, device identifiers
Commercial Information: Transaction history, payment information, purchase records
Internet Activity: Browsing history, search history, interaction with our Services
Geolocation Data: Approximate geographic location derived from IP address (country-level)
Professional Information: Business name, game titles, studio information
Inferences: Preferences, behavior patterns, and characteristics derived from your activity

11.2 Sources of Personal Information

We collect personal information from:

Directly from you when you register, use our Services, or communicate with us
Automatically through cookies and tracking technologies
From your game's integration with our SDK
From third-party payment processors and service providers
From publicly available sources

11.3 Business and Commercial Purposes

We use personal information for the business and commercial purposes described in Section 2 of this Privacy Policy, including:

Providing and maintaining the Services
Processing transactions and payments
Customer support and communications
Security, fraud prevention, and legal compliance
Improving and developing our Services
Marketing and business development

11.4 Categories of Third Parties

We share personal information with the categories of third parties described in Section 3, including:

Service providers and business partners
Other developers in the Invo network (limited information)
Transaction record systems
Legal and regulatory authorities
Business transaction parties (in the event of a merger or acquisition)

11.5 No Sale of Personal Information

We do not "sell" personal information as defined by the CCPA/CPRA. We do not share personal information with third parties for cross-context behavioral advertising purposes. We have not sold personal information in the preceding 12 months.

11.6 Retention

We retain personal information as described in Section 5 of this Privacy Policy, typically for the duration of your account plus seven (7) years, with certain exceptions for transaction records and legal compliance.

11.7 California "Shine the Light" Law

California Civil Code Section 1798.83 permits California residents to request information about our disclosure of personal information to third parties for direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.

12. Nevada Privacy Rights

If you are a Nevada resident, you have the right to opt out of the sale of certain personal information to third parties. We do not sell personal information as defined under Nevada law. If you have questions about our data practices or wish to exercise your Nevada privacy rights, please contact us at privacy@ourinvo.com.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will notify you of material changes by:

Posting the updated Privacy Policy on our website at https://ourinvo.com/privacy-policy
Updating the "Last Updated" date at the top of this Privacy Policy
Sending an email notification to the email address associated with your developer account for significant changes
Displaying a prominent notice on the Developer Dashboard
For material changes that affect your rights, obtaining your consent where required by law

Your continued use of the Services after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree to the changes, you must stop using the Services and may request deletion of your account.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

14. Data Controller and Data Protection Officer

14.1 Data Controller

For the purposes of applicable data protection laws, the data controller responsible for your personal information is:

Invo Tech, Inc.
2000 PGA Boulevard, Suite 4440
Palm Beach Gardens, Florida 33408
United States of America

14.2 EU Representative

If you are located in the European Economic Area or United Kingdom and have questions about our data processing activities, you may contact our EU representative at privacy@ourinvo.com with "EU Representative" in the subject line. We will designate a formal EU representative if required by law as our operations expand.

14.3 Data Protection Officer

For questions about data protection, you may contact our data protection team at privacy@ourinvo.com with "Data Protection Officer" in the subject line.

15. Supervisory Authority

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have the right to lodge a complaint with a data protection supervisory authority if you believe we have processed your personal information in violation of applicable law.

You can find your local data protection authority at:

EEA: https://edpb.europa.eu/about-edpb/board/members_en
UK: Information Commissioner's Office (ICO) - https://ico.org.uk
Switzerland: Swiss Federal Data Protection and Information Commissioner (FDPIC) - https://www.edoeb.admin.ch

We encourage you to contact us first at privacy@ourinvo.com so we can address your concerns directly before you file a complaint with a supervisory authority.

16. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Invo Tech, Inc.
2000 PGA Boulevard, Suite 4440
Palm Beach Gardens, Florida 33408
United States of America

Email: Contact Privacy Team
General Inquiries: Contact Support
Website: https://ourinvo.com
Developer Dashboard: https://console.invo.network

For privacy-related inquiries, please include "Privacy Request" in your email subject line. For data subject rights requests, please include "Data Rights Request" in the subject line.

We aim to respond to all privacy inquiries within thirty (30) days, or as otherwise required by applicable law.

By using the Services, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your information as described in this Privacy Policy.