Personal Information being collected
As used herein, “Personal Information” means information that relates to an identifiers or is reasonably capable of identifying an identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual, directly or indirectly, and information that is capable of being associated with an identified or reasonably .
1. Personal Information we collect from you
We may collect the following categories of Personal Information directly from you:
- Identification Information, such as name, email, phone number, postal address;
- Commercial Activity, such as trading activity, order activity, deposits, withdrawals, account balances;
- Correspondence, such as information you provide to us in correspondence, including account opening and customer support;
- Sensory Information, such as images that you upload to your User Profile.
2. Personal Information collected automatically
We may collect the following categories of Personal Information automatically through your use of our services:
- Online Identifiers, such as IP address, domain name;
- Device Information, such as hardware, operating system, browser;
- Usage Data, such as system activity, internal and external information related to Infinity8 pages that you visit, clickstream information;
- Geolocation Data.
3. Personal Information we collect from third parties
We may collect and/or verify the following categories of Personal Information about you from third parties:
- Identification Information, such as name, email, phone number, postal address;
- Transaction Information, such as public blockchain data (bitcoin, etherium, and other Digital Assets) are not truly anonymous. We, and any others who can match your public Digital Asset address to other Personal Information about you, may be able to identify you from a blockchain transaction because, in some circumstances, Personal Information published on a blockchain (such as your Digital Asset address and IP address) can be correlated with Personal Information that we and others may have. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you;
- Financial Information, such as bank account information, routing number, credit card number, debit card number;
- Additional Information, at the our discretion to comply with legal obligations.
4. Accuracy and retention of Personal information
We take reasonable and practicable steps to ensure that your Personal Information held by us is (i) accurate with regard to the purposes for which it is to be used, and (ii) not kept longer than is necessary for the fulfilment of the purpose for which it is to be used.
In specific circumstances we may also retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
How We Use Your Personal Information
We collect Personal Information about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Information to:
- Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations.
- Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
- Protect the security and integrity of our Services. We use your Personal Information, including information about your device and your activity on Infinity8 to maintain the security of your account and the Infinity8 platform.
- Provide you with customer support. We process your Personal Information when you contact our support team with questions about or issues with your account.
- Market our products. We may contact you with information about our Services. We will only do so with your permission, which can be revoked at any time.
- Other business purposes. We may use your Personal Information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent.
How We Share Your Personal Information
If you are based in the United Arab Emirates, your continued use of our website means that you understand and agree that we may share your Personal Information with third parties, as further detailed in this section. If you do not wish for your Personal Information to be shared with third parties as per this section, please do not visit our website.
We will not share your Personal Information with third parties, except as described below:
- Service Providers. We may share your Personal Information with third-party service providers for business or commercial purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising and marketing, network infrastructure, storage, transaction monitoring. We share your Personal Information with these service providers only so that they can provide us with the services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose.
- Law Enforcement. We may be compelled to share your Personal Information with law enforcement, government officials, and regulators.
- Corporate Transactions.
- Corporate Transactions. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
- Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
- Consent. We may share your Personal Information with your consent.
(i) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities;
(ii) assess and improve our services and advertising campaigns.
Where we have obtained your express opt-in consent, we may from time to time send direct marketing materials via email promoting services, products, facilities, or activities to you using information collected from or about you. You may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy to not provide your Personal Information for those third parties’ direct marketing purposes without your consent.
No security is foolproof, and the Internet is an insecure medium. We can therefore not guarantee absolute security, but we do our best in protecting Infinity8 and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Some of the measures we take include encryption of the Infinity8 website communications with SSL; optional two-factor authentication; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Information For Persons Subject to EU Data Protection Law
Since we have customers who are located in the European Union (“EU”), European Economic Area (“EEA”) or the Channel Islands, or other locations subject to EU data protection law (collectively, “Europe”), we recognize and, to the extent applicable to us, adhere to relevant EU data protection laws. For purposes of this section, “personal data, in particular the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
Lawful bases for processing
We process Personal Information subject to GDPR on one or more of the following legal bases:
- Legal Obligation: to conduct anti-fraud and to fulfill our retention and other legal obligations;
- Legitimate Interest: to monitor the usage of Infinity8, conduct automated and manual security checks of our Services, to protect our rights;
- Consent to market Infinity8 and our Services. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before consent is withdrawn.
European privacy rights
European residents have the following rights under GDPR, subject to certain exceptions provided under the law, with respect to their Personal Information:
- It is no longer needed for the purposes for which it was collected;
- You have withdrawn your consent (where the data processing was based on consent);
- Following a successful right to object (see 'Objection' below);
- It has been processed unlawfully;
- To comply with a legal obligation to which we are subject.
- For compliance with a legal obligation;
- For the establishment, exercise or defence of legal claims.
- Its accuracy is contested (see Rectification above), to allow us to verify its accuracy;
- The processing is unlawful, but you do not want it erased;
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims;
- You have exercised the right to object, and verification of overriding grounds is pending.
- we have your consent;
- to establish, exercise or defend legal claims;
- to protect the rights of another natural or legal person.
- produces legal effects concerning you (such as the rejection of a claim);
- otherwise significantly affects you.
- Is necessary for entering into or performing a contract with you;
- Is authorised by law and there are suitable safeguards for your rights and freedoms;
- Is based on your explicit consent.
- Rectification. You can ask that we correct any inaccurate Personal Information we hold about you. We may seek to verify the accuracy of the Personal Information before rectifying it.
- Right to Erasure. You may submit a request that Infinity8 deletes the Personal Information that we have about you. This is not an absolute right and is only exercisable under certain circumstances, including:
We are not required to comply with your request to erase your Personal Information if the processing of your Personal Information is necessary:
There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request
- Right to Restriction of Processing. You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
We can continue to use your personal data following a request for restriction, where:
- Right to Data Portability. You have the right to receive the Personal Information you have provided to us in an electronic format and to transmit that Personal Information to another data controller.
- Right to Objection. You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
We aim to respond to any valid requests within one month unless it is particularly complicated or you have made several requests in which case we aim to respond within three months. We will let you know if we are going to take longer than one month. We might ask you if you can tell us what exactly you want to receive or are concerned about. This will help us to action your request more quickly.
We do not have to comply with a request where it would adversely affect the rights and freedoms of other data subjects.
Collection and transfer of data outside the EEA
The marketplace of Infinity8 operates with many of our systems based in the United Arab Emirates. As a result, we may transfer
Personal Information from Europe to third countries outside of Europe, including United Arab Emirates, under the following conditions:
- Consent: where you have consented to the transfer of your Personal Information to a third country. Where transfers to a third country are based on your consent, you may withdraw your consent at any time. Please understand, however, that our services may not be available if we are unable to transfer Personal Information to third countries.
When we transfer Personal Information to third countries, we endeavour to ensure adequate safeguards are implemented, for example through the use of standard contractual clauses or Privacy Shield certification.]
[You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Economic Area. We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.]
Automated Decision Making
Automated decision making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.
We may engage in automated decision-making for purposes of fraud detection and prevention.
You can ask not to be subject to a decision which is based solely on automated processing, but only where that decision:
In such situations, you can also obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.
Your right not to be subject to automated decision making does not apply where the decision which is made:
However, in these situations you can still obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.
If you have a complaint or concern about how we use your Personal Information, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.