Privacy Policy

1. Introduction

This Privacy Policy explains how XANADA INVESTMENT LTD, a company registered in Cyprus under number HE461071 with its registered office at Anastasiou Sioukri 1, Themis Court, Office 402, 3105, Limassol, Cyprus, operating the XInvest service (“XInvest”, “we”, “us”, “our”), collects, uses, stores and protects personal data when you visit xinvest.tech, register an account, subscribe to a paid plan, interact with our Telegram bot or channel, or otherwise use our Service. XANADA INVESTMENT LTD acts as the data controller of the personal data described below.

We respect your privacy and aim to comply with applicable data-protection laws, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the EU General Data Protection Regulation (EU GDPR), where they apply to you.

2. What Data We Collect

2.1 Data you provide directly

• Contact data: name, email address, phone number, country, Telegram username/ID.
• Account data: login credentials, subscription tier, preferences.
• Communications: messages you send us via forms, email, chat or the Telegram bot.
• Payment data: billing details collected by our payment processors. We do not store full card numbers; we receive transaction confirmations and minimal billing metadata.
• Onboarding data: information you choose to share for set-up of signals, MetaTrader integration or auto-bot configuration (e.g. broker name, terminal version).

2.2 Data collected automatically

• Technical data: IP address, device type, browser, operating system, language, time-zone.
• Usage data: pages visited, click events, referring URLs, time spent, interaction with the Telegram bot (commands, timestamps).
• Cookies and similar technologies: see our Cookie Policy.

2.3 Data from third parties

• Identifiers and metadata from Telegram when you start the bot or join the channel.
• CRM and marketing data from Leeloo (sales-funnel and message tracking).
• Confirmation data from payment processors and analytics providers.

We do not collect special-category personal data (such as data about health, religion or political opinions). Please do not send us such data.

3. How and Why We Use Your Data

4. Third-Party Services and Data Sharing

We share personal data only with trusted service providers acting on our instructions, or where required by law. Categories of recipients include:

• Telegram — messaging platform used to deliver signals and the bot interface.
• Leeloo — CRM, marketing automation and funnel analytics.
• Payment processors — for billing, refunds and fraud prevention.
• Hosting and infrastructure providers — for website, database and email delivery.
• Analytics providers (e.g. Google Analytics, Meta Pixel) — subject to your cookie preferences.
• Professional advisers — lawyers, accountants and auditors, where strictly necessary.
• Public authorities — where required by law or court order.

We do not sell your personal data.

5. International Data Transfers

Some of our service providers are located outside your country, including outside the European Economic Area. Where we transfer personal data internationally, we rely on appropriate safeguards such as Standard Contractual Clauses or adequacy decisions of the European Commission. You may request a copy of the safeguards in place by contacting us.

6. Data Retention

We keep personal data only for as long as needed for the purposes described in this Policy:

• Account and subscription data — while your account is active and for up to 24 months after closure;
• Billing and tax records — for the period required by applicable law (typically 5–7 years);
• Marketing data — until you withdraw consent or object;
• Support correspondence — up to 24 months after the last interaction;
• Logs and analytics — up to 14 months in identifiable form.

After the retention period, we delete or anonymise your data.

7. Your Rights

Depending on your jurisdiction, you have the following rights regarding your personal data:

• Access — obtain a copy of the data we hold about you;
• Rectification — correct inaccurate or incomplete data;
• Erasure (“right to be forgotten”) — request deletion, subject to legal retention obligations;
• Restriction — ask us to limit processing in certain situations;
• Portability — receive your data in a structured, commonly used format;
• Objection — object to processing based on legitimate interests or to direct marketing;
• Withdraw consent — for any processing based on your consent, at any time;
• Lodge a complaint with your local data-protection authority.

To exercise your rights, contact us at support@xinvest.tech. See also our Personal Data Deletion Policy for the deletion procedure.

8. Security

We use technical and organisational measures designed to protect your data, including encryption in transit, access controls, monitoring and regular security reviews. No system is perfectly secure; we cannot guarantee absolute security but we work to mitigate risks responsibly.

9. Children

The Service is not directed to anyone under 18 years old. We do not knowingly collect data from minors. If you believe a minor has provided us with data, please contact us so we can delete it.

10. Changes to this Policy

We may update this Policy from time to time. The “Last updated” date at the top reflects the latest revision. For material changes, we will notify you through the website or by email where appropriate.

11. Contact

Questions or requests regarding this Policy can be sent to support@xinvest.tech, or by post to: XANADA INVESTMENT LTD, Anastasiou Sioukri 1, Themis Court, Office 402, 3105, Limassol, Cyprus. You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection (Cyprus) at dataprotection.gov.cy, or with the data-protection authority of your country of residence.