Last Updated: September 22, 2022

<aside> <img src="https://s3-us-west-2.amazonaws.com/secure.notion-static.com/13f3ae93-b27f-4636-adad-7eb4c3e2364b/Google_Logo_PP_(4).png" alt="https://s3-us-west-2.amazonaws.com/secure.notion-static.com/13f3ae93-b27f-4636-adad-7eb4c3e2364b/Google_Logo_PP_(4).png" width="40px" /> Infinity CTB hereinafter referred to as “the Company”, “We”, “Us,”, “Our”

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<aside> <img src="/icons/globe_gray.svg" alt="/icons/globe_gray.svg" width="40px" /> ***https://www.app.infinity-ctb.com/** hereinafter referred to as the “Website”, “Site” or “Platform” interchangeably*

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If you use the Site, even just to browse, you will be deemed to have consented to the terms of this Privacy Policy. We may also ask you to indicate your consent more formally by checking a box or otherwise taking an affirmative action.

1. Purpose

  1. This Privacy Policy (“Policy”), as amended from time to time, sets out how Infinity CTB **collects, processes, uses, maintains, stores, transfers, discloses, erases or destroys your personal data, obtained from and through our platforms and related services offerings, via the website, mobile application, related platforms or portals, and any other features or related content, linked, or otherwise connected thereto (the “Sites”), as well as the Infinity CTB Platform. The specific data points which we collect from you are explained below in this Policy. When you visit our Sites, or use any of our services, we take your privacy very seriously as we are committed to protecting your personal information and right to privacy.
  2. Please read this Policy carefully to understand our practices regarding your personal information and how we treat it. If you do not agree with this Policy, or you do not have the right ,power, or authority to act on behalf of and bind the business, organisation, or other entity you represent, do not access or otherwise use the Sites. This Policy also explains how we use cookies. Please read this carefully as this Policy is legally binding when you access or use the Site.
  3. This Policy, together with our Terms & Conditions govern your access to and use of the Sites. By using the Sites, you agree to be bound by these policies, which supplement and are incorporated into our Terms & Conditions. This Policy does not intend to override any of our Terms & Conditions.

If you have any queries about your rights, possible remedies, or any other matter relating to our privacy policy, you can contact our DPO by email [email protected].

2. Scope

This Privacy Policy applies to all Infinity CTB platforms, websites, applications and services and the parties that operate those services, including, but not limited to, the legal entities, organisations and teams that provide and are responsible for the Infinity CTB services. This Policy applies to all of your interactions with us via the Sites, and your interactions with us in connection therewith.

By using Infinity CTB services, you consent to the collection, storage, processing and transfer of your personal information as described in this policy.

3. Changes to this Policy

From time to time, we may revise, amend or supplement this Policy to reflect necessary changes in law, our personal data collection and usage practices, the features of our services or Sites, or certain advances in technology. If any material changes are made to this Policy, the changes may be prominently posted on the relevant or affected Sites. However, this is not obligatory for us; the onus is on you to periodically familiarise yourself with the contents of this Policy for your own information; and particularly to do so every time you access our Sites or make use of our services. Changes to this Policy are effective when they are published. You can determine when this Policy was last revised by referring to the “LAST UPDATED” legend at the top of this Policy. We recommend that you check our site frequently for recent changes. If you do not agree with the revised content, you should stop using our services. Your continued access of the Sites after such changes conclusively demonstrates your acceptance of those changes.

4. Eligibility

  1. Age. By accessing or using the Site, you represent and warrant that you are at least eighteen (18) years of age. If you are under the age of eighteen (18), you may not, under any circumstances or for any reason, use the Sites.
  2. Legality. You are solely responsible for ensuring that this Policy follows all laws, rules, and regulations applicable to you and in your specific jurisdiction. If your use of the Sites, or any functionality provided or activity enabled thereby, is prohibited or conflicts with any applicable law, rule or regulation in your jurisdiction, you may not, under any circumstances or for any reason, use the Sites.
  3. Criteria. We may in our sole discretion refuse to offer the Sites to any person or entity and change the eligibility criteria for use thereof at any time.

5. Minors

Infinity CTB’s products and services are not intended for persons under the age of 18. Only persons of legal age may register for our services. Therefore, we do not process personal data of minors.

We do not knowingly allow anyone under the age of 18 years to submit any data to our Site. If you believe your child may have provided us with their data, you can contact us using the information in the Contact section of this Policy and we will delete the data from our Sites.

6. Consent for legal obligations and legitimate interests

You provide consent to your personal data (whether provided directly by you, whether collected by us, or received by us from third parties or otherwise) being processed to satisfy all legal obligations arising from any contracts entered into/ with/ involving you or to deliver any services to you; or to take steps at your request prior to entering into a contract with you; or for our legitimate interests to protect our property, rights, or safety of either the Company, its users, customers, clients, other persons or other entities.

7. Data processing in connection with the Site

The information you provide, or which we obtain from other sources will be used by us, in accordance with this Policy, other policies, applicable laws, and the European Union’s General Data Protection Regulation (“GDPR”). The table below specifies which data points we collect, by what method and for what purposes:

What Data we collect

  1. Operating System information;

  2. Domain server;

  3. Device data;

  4. Data related to usage, performance, Site security;

  5. Data related to traffic patterns;

  6. Geo-location (country, location);

  7. Browser, browser type and version, browser plug-in types and versions;

  8. Comments;

  9. Media;

  10. Contact forms;

  11. Personal data from you, such as your first and last name, e-mail and mailing addresses, blockchain address, and Infinity CTB password when you create an Infinity CTB Account to log in to our network; (details from Section 8 to 13)

How we collect Data

  1. We collect it through the users’ IP address, internet browser and device;

  2. We collect it through automated technology when users are visiting and navigating the Sites;

  3. We collect it through GPS and other technologies;

  4. We collect it through third-party marketing partners who you have given consent to share your personal information with other parties in limited necessary cases

Why we collect Data

  1. To provide you the services;

  2. To rectify any errors you face when trying to access our services;

  3. To maintain security and operation of the Sites;

  4. To improve the quality of your user experience when you interact with the services

  5. To develop and display personalised content tailored to your interests and or location

  6. For internal record keeping, analytics and reporting purposes;

  7. To analyse trends; operate, administer and maintain the facilities, track users’ movements and activity around and within the Sites;

  8. To gather demographic information about our user base as a whole, and better tailor our Sites to our users’ needs;

  9. To log in and use service-related diagnostic, usage and performance information on our servers; and

  10. To protect our legitimate interests, where our doing so will not unduly affect your rights.

8. Personal Data categories

We may process the following personal data on the basis mentioned in section 7:

  1. Contact data. When creating a new account or communicating with us, we may process, for example, the following personal data: surname, first name, address, nationality, e-mail, account photo.
  2. Financial data. When purchasing and selling our services, we may process, for example, the following data: bank details (IBAN, BIC), public blockchain addresses, payment service provider information, payment details, transaction identification data.
  3. Account operation data. To ensure the proper operation of your account, we may process the following data: language preferences, login/password, transaction data, products and strategies chosen, user profile type, trading data, list of connected exchanges, API keys of connected exchanges, subscription date, amount of assets allocated and allocation(s), login time(s) and date(s), affiliate and referral program data, performance reports, billing data.
  4. Activity analysis data. During certain activities on the website, we may process for example the following data: your IP address, computer or mobile device information, frequency, time, operating system, browser type, device type, unique device identification number, cookies, possibly form data, crash reports, performance data, third party cookies, etc., performance data and only with your explicit consent, data from camera, microphone, storage, phone.
  5. Data related to a support/complaint request. If you contact our support team, we may process for example personal data provided to our team for this purpose.
  6. Data for marketing purposes. If you visit our website or social networks, or during the use of mobile applications, we may process statistical and marketing data, e.g. number of visitors, frequency, clicks, time, locations, target groups, data from cookies and similar technologies, consumer behaviours, interests and preferences, data relating to market research and target group surveys etc.

9. On which grounds do we use your personal data?

We process your personal data on one or more of the following legal grounds (in accordance with Article 6 of the GDPR):

Processing for the performance of a contract or prior to entering a contract (article 6. 1. b GDPR)

The processing of your personal data is necessary to take the necessary steps for your request, prior to entering into a contract or to perform that contract with you.

Processing based on your consent (Art. 6. 1. a. GDPR)

If you have given us your consent to process your personal data, the processing will only be carried out for the purposes and to the extent stated in the declaration of consent. If you no longer agree with this processing, you have the possibility of revoking your consent at any time, without the need for justification.

Processing necessary for the purposes of our legitimate interests (Art. 6. 1. f. GDPR)

We process some of your personal data to best protect our legitimate interests and those of our users, for example as part of our risk management, or when we detect and prevent fraud and abuse to protect the safety of our users, ourselves or others.

Processing necessary for the purposes of our legitimate interests (Art. 6. 1. f. GDPR)

We process some of your personal data to best protect our legitimate interests and those of our users, for example as part of our risk management, or when we detect and prevent fraud and abuse to protect the safety of our users, ourselves or others.

10. Data retention period

Infinity CTB retains the data collected for the time strictly necessary for the purpose of the processing, and within the limits provided for by European and national legislation if it allows longer retention.

Unless explicitly stated in this Privacy Policy, the personal data we process is deleted as soon as it is no longer necessary for the purpose for which it was collected and the deletion does not conflict with our legal retention obligations.

10.1 We retain your personal data for a period of 5 years. When we no longer need personal data, we securely delete or destroy it.

10.2 Aggregated de-identified data, which cannot identify a device/ browser/ individual and are used for purposes of reporting and analysis, are maintained for as long as commercially necessary.

10.3 Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. When we do so, we will take your explicit consent for the same. Reasons we might retain some data for longer periods of time include:

a) Security, fraud & abuse prevention;

b) Financial record-keeping;

c) Complying with legal or regulatory requirements; and

d) Ensuring the continuity of our services at our Site.

11. Personal data recipients

We do not sell the personal data we collect from our users. Infinity CTB may only share personal data collected from users as described below, and with subsidiaries or affiliates of Infinity CTB, or its parent company, that follow practices at least as protective as those described in this policy.

Data transfer within the company

Within the company, the relevant departments/employees will receive the personal data they need to fulfill the purposes of processing. We transfer data as part of our day-to-day business operations, such as the management of customer accounts and other operations you have requested, as well as to carry out our internal administrative activities efficiently and to improve our products and services.