Privacy Policy

Effective Date 01.01.2016

This policy describes the way how we collect, process and protect your personal data (“Privacy Policy”). This Privacy Policy applies on personal data processing within our Platform and via your Account. This Privacy policy applies to any Services which incorporate this policy or contain a link hereto.

Data collection.

We collect data you provide us with within your registration process. These data include your
name,username, password, indentation details (including identification number and address), details on Payment
Instruments, e-mail distribution lists, tracking activity and contact details (including e-mail and phone
number). Although our Services offer analysis of data of your customers, we do not collect, have access to or
process such data in any way.

Purpose of data processing.

We process your personal data for the following purposes:

  • Registration and granting access to our Services;
  • Provision of our Services;
  • Payment for Services;
  • Protection of assets and legitimate interests of ourselves and other customers; and
  • Direct marketing.

Cookies and web beacons.

For the purpose of analysing your visits of our Platform, we also collect cookies
(codes stored locally on your computer). By enabling cookies in your browser, you have expressed your consent
that we may collect cookies for this purpose. Collection of cookies may be turned off by resetting your browser.
In case you turn off cookies, functionality of our Platform may be limited. Our Services and/or Platform and the
communications generated from using and/or registering to our Services and/or Platform, such as promotional
emails, may contain electronic images known as “web beacons”. Web beacons generally work in conjunction with
cookies, and we may use them in the same way we use cookies (see above).

Data combination.

We may, within the extent enabled by legal regulation (i) combine personal data provided by
you via your Account with information provided otherwise; and (ii) store this information collectively in one or
more separate databases.

Data retention period.

We will not store your personal data for a longer period that what is necessary given the
purpose for which they were provided or collected, i.e. it will typically process your personal data for the
period of your registration via your Account. Subject to situations set out below, your personal data will be
removed once you deregister your Account. We will retain only those personal data serving legitimate purposes
(e.g., some data are required to be retained by applicable legal regulations, some data are necessary for
purposes of outstanding billing, etc). Personal data shall be retained also if removal would require undue
efforts or costs – in these cases the personal data shall be dislocated and not entirely removed.

Proportionality.

We will neither collect any excessive amount of personal data nor relevant for the purposes for
which personal data are collected.

Direct marketing.

We may also use your electronic contact details for marking purposes, i.e. to inform you about
our services which may be derived from your past usage of Services. These communication shall strictly adhere to
applicable legal regulations. You may opt out from marketing communication via disabling his option on your
Account.

Personal data sharing.

Your personal data shall not be shared or provided to any third party without your
consent except for in cases we are obliged to provide personal data on the basis of law or an order of public
authority; or if personal data sharing is specifically allowed by applicable legal regulations. Should the
applicable legal regulations prohibit that, your personal data shall never be shared with any third party.

Data security.

We will ensure that your data are stored securely. Therefore, we have introduced adequate
physical, technical and organisational measures and plans protecting and securing data collected from you
(which, however, do not deprive you from your duties to undertake proper steps in order to secure your data
especially for data transmission to our Account). The aim is to eliminate unauthorised or unlawful processing of
your personal data, or accidental, unauthorised or unlawful access, use, transferring, processing, copying,
transmitting, alteration, loss or damage of your data. Despite all efforts and meeting all rules set out by
applicable legal regulations, it is not possible to ensure the security of your data, if they are transferred or
transmitted in an unsecured way. We will protect your data in the following ways:

  • Using cryptography, where necessary;
  • Using password protection, where necessary; and
  • Restricting access to your data (i.e. access to your personal data is granted only to those from our employees or
    contractors for whom the access is indispensable).

Changes of Privacy Policy.

We may, from time to time, change and/or update the terms of this Privacy Policy and
you shall be notified hereof via your Account.

Right to access.

You have a right to be provided with details of personal details processed by us and require
correction or deletion of your personal data. You may contact us at privacy@infinario.com, should you have any such request.

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