Infloww.com
Privacy Policy

INFINNI is committed to protecting your privacy. This Privacy Policy applies to the personal data

we collect and process in the course of our business. INFINNI acts in different ways when

processing data:

(i) INFINNI acts as a controller of your personal data when you sign up for our products and

services, visit our websites or interact with us through other channels (for example in person

events). We use this data for a variety of purposes, including to provide our products and

services to you, contact you about relevant content, and improve and promote our products and

services.

(ii) INFINNI acts as a processor when our customers use our products and services to collect

and process personal data in connection with their sales and other business activities. In this

case, we act as a processor (or service provider) on behalf of our customers (who are

controllers of personal data) under the INFINNI Data Processing Agreement

For the purposes of this Privacy Policy "Personal Data" means any information relating to an

identified or identifiable individual. This Privacy Policy describes your choices and rights with

respect to your Personal Data, including your rights of access and correction.

(i) For information about how to exercise your privacy rights when INFINNI acts as a controller

of personal data, please see the “Your Privacy Rights and Choices” section.

(iii) If you wish to exercise your privacy rights regarding Personal Data we process on behalf of

a customer, please refer to the customer policies and contact the customer directly.

We update this Privacy Policy from time to time and encourage you to review this Privacy Policy

periodically. We will post any Privacy Policy changes on this page and, if the changes are

material, notify you directly (for example, by sending you an email notification). Terms not

otherwise defined in this Privacy Policy have the meaning given to them in the INFLOWW Terms

of Service.1. What Information We Collect and Process

2. How We Use Personal Data

3. How We Share Personal Data

4. How We Transfer Personal Data Internationally

5. How We Store and Secure Personal Data

6. Cookies and Similar Technologies

7. Your Privacy Rights and Choices

8. Other Important Privacy Information

9. Contact Us1. WHAT INFORMATION WE COLLECT AND PROCESS

1.1 Information You Provide to INFINNI.

When you interact with us, including via our websites or any sites or services that link to this

Privacy Policy (such as infinni.io, infloww.com, etc.), with our representatives, at events, or when

you use the Subscription Service, we may collect Personal Data and other information from you,

as further described below.

1.1.1 When You Visit Our Websites. We collect Personal Data from you when you submit web

forms or interact with our websites, for example creating an INFLOWW account, booking a

demo or interacting with our support chatbot. We may ask for your email address, first and last

name, and other similar business information. You are free to explore some of our websites

without providing any Personal Data about yourself.

1.1.2 INFINNI Events. When you register for any INFINNI event, we collect information such as

name and email address. We use this information to communicate with you and in some cases

facilitate your registration. Additionally, we may share your registration data with third party

service providers in order to provide event information and improve your experience at the event

or future INFINNI events. Please see the events’ registration terms and conditions for additional

information.

1.1.3 Account and User Information. We collect Personal Data when you sign-up for an

INFLOWW account, create or modify user information, set preferences, or provide any other

related information to access or utilize our Subscription Service.

1.1.4 Payment Information. We collect payment and billing information when you register for or

purchase paid products or services. For example, we may ask you to provide a billing address,

or a billing contact for your INFLOWW account. If you give us payment information, we use it

solely as authorized by you in accordance with this Privacy Policy. We use secure third-party

payment service providers to process personal and financial data.

1.2 Information We Process on Behalf of Customers When They Use the Subscription Service.

Our product, or the Subscription Service, is a Customer Relationship Management (CRM)

platform that allows our customers to manage and centralize their operations across multiple

platforms. When customers use our product, they may process Personal Data such as first and

last name, email address, phone number, or other information about you. We call the

information that our customers submit or collect via the product ‘Customer Data’ under our

Terms of Service.

We generally store and process information about and on behalf of our customers on our

servers as a processor (or service provider) based on a customer’s instructions and in

accordance with our Terms of Service. Each customer controls and is responsible for the

information they process using the Subscription Service and for complying with any regulationsor laws that require providing notice, disclosure, and/or obtaining consent prior to transferring

the Personal Data to INFINNI for processing purposes.

If you have questions about the Personal Data we process on behalf of a customer, please

contact the customer directly and refer to their policies.

1.3 Information We Collect and Process When You Use the Subscription Service.

1.3.1 Usage Data.

We collect usage data when you or your users in your INFLOWW account interact with the

Subscription Service. Usage data includes metrics and information regarding your use and

interaction with the Subscription Service such as what product features you use the most, when

an object (like a ticket) is opened and closed, and how often certain features are triggered in

your account.

1.3.2 Log Files.

Like most websites and technology services delivered over the Internet, we automatically collect

and store information about your computer hardware and software when you visit our websites,

use our product and services, or visit other sites or services that link to this Privacy Policy. This

information can include your IP address, browser type, domain names, and the files viewed on

our websites (e.g., HTML pages, graphics, etc.), your operating system, access times and

referring website addresses.

1.3.3 Third Party Integrations. You may connect third party integrations to your INFLOWW

account, which may ask for certain permissions to access data or send information to your

INFLOWW account. It is your responsibility to review any third party integrations you authorize.

We may collect information about what types of integrations you use in your INFLOWW

account.

Any permission(s) granted by you, grants these third parties access to your data, which may

include (but is not limited to) granting third party applications access to view, store, and modify

your INFLOWW account data. We are not responsible for the practices of third party

integrations, so please carefully review the permissions you grant to third party applications.

1.4 Information We Collect From Other Sources.

INFINNI does not collect data from other sources.

2. HOW WE USE PERSONAL DATA

2.1 To Communicate with You About the Product and Services.We use the account information you provide to INFINNI when signing up for our products and

services, to send you transactional emails or in-app notification about billing, account

management, and other administrative matters.

We also use your information to recommend new products and services and to provide

customer support, such as resolving technical issues you encounter and analyzing product

outages or bugs.

2.2 To Provide the Subscription Service.

We use your account information and Customer Data to provide the product and services to

you. For example, we use the email address you provide when signing up for the product to

create your user account, and we use your payment information to process payments for the

Subscription Service. We also use this information to authenticate you when you log in and to

provide customer support.

2.3 To Improve and Develop Our Communication, Product and Services.

We use the information you provide us, professional data, log files, and usage data about how

you or your users interact with our product and services to develop and improve our products,

services, and communications. For example, we use usage data to assess trends and usage

across the product to help us determine what new features or integrations our users may be

interested in.

We may publish data about how our product and services are being used across our customer

base. When we share statistical information externally in this way, the data will be aggregated

and we will not identify individual users or customers. For example, we may publish blog posts

on trends or insights into how users are interacting with our product.

2.4 To Secure and Protect our Product and INFLOWW Users.

We use your account information to investigate and help prevent security incidents. We may

also use this information to meet legal requirements. We use your information to verify user

accounts, new product sign-ups, and to detect and prevent product abuse.

We use log files to provide general statistics regarding use of the websites by you, including

how you use our websites, what country you are logging in from (for analytics, export control

and regulatory purposes) and to help improve the navigation experience. Your IP addresses are

also collected and logged for security and debugging purposes, for example to track access

patterns, investigate security events and incidents. For these purposes we associate

automatically-collected data to other personal data provided by you such as name, email

address, address, and phone number.

2.5 To Market and Promote the Subscription Service.We use Personal Data to advertise, market, and promote our products, services, and other

offerings. For example, we use information like your email to send information or INFINNI

content to you we think may be of interest to you. We may also send you marketing

communications relating to our business with your explicit consent.

You may opt out of receiving this promotional content by following the instructions contained in

each communication that we send to you. If you unsubscribe from our marketing lists, we will

continue to contact you regarding administrative matters, and to respond to your requests.

We may reach out to you via telephone to ask about other INFINNI products or services you

may be interested in. If you have a call scheduled with an INFINNI representative, we may

record and transcribe the call. You will be notified at the beginning of the call that the call is

being recorded, and you will be offered an opportunity to opt-out of having the call recorded. We

may also reach out to you via WhatsApp or Telegram.

Where required by law, we will only send marketing communications with your consent.

Otherwise, we will market and advertise our products and services on the basis of our legitimate

business interests.

2.6 Other Purposes if We Obtain Your Consent.

We may use your data for other purposes when you give us consent to do so.

2.7 Legal Basis for Processing Personal Data.

INFINNI's Data Protection Officer can be contacted at dpo@infinni.io.

Our legal basis for collecting and using the Personal Data described above will depend on the

Personal Data concerned and the specific context in which we collect it. However, we will

normally collect Personal Data from you only where we have your consent to do so, where we

need the Personal Data to perform a contract with you, or where the processing is in our

legitimate interests and not overridden by your data protection interests or fundamental rights

and freedoms. In some cases, we may also have a legal obligation to collect Personal Data

from you.

3. HOW WE SHARE PERSONAL DATA

3.1 Service Providers.

We may share Personal Data with our third party service providers to support our websites,

products, and services. For example, we use service providers for data hosting, application

development, marketing, sales support and customer support. We may need to share your

information with service providers to provide information about products or services to you.

Examples may include removing repetitive information from prospect lists, analyzing data or

performing statistical analysis on your use of the Subscription Service or interactions on ourwebsites, providing marketing assistance, processing credit card payments, supplementing the

information you provide us in order to provide you with better service, developing and improving

the product and services, and providing customer service or support. These service providers

are prohibited from using your Personal Data except for these purposes, and they are required

to maintain the confidentiality of your information. In all cases where we share your information

in this way, we explicitly require the third party service providers to acknowledge and adhere to

our privacy and data protection policies and standards.

3.2 Payment Services.

We use NetSuite to securely connect to financial institutions across the EEA. By entering online

banking credentials for payment and completing checkout, your banking credentials are sent to

NetSuite for validation. Your personal and financial data is processed by NetSuite in accordance

with their Privacy Policy.

3.3 Partners.

INFINNI does not share data with any Partner.

3.4 Advertising Partners.

If you would accept to receive marketing communications at the time of creating an account, we

may also share Personal Data, such as your email address, with our advertising partners to

deliver INFINNI’s personalized ads on other companies' sites or mobile apps. You can opt out of

having your data disclosed to our advertising partners by managing your preferences.

3.5 Company Acquisition.

If we (or our assets) are acquired by another company, whether by merger, acquisition,

bankruptcy or otherwise, that company would receive all information gathered by INFINNI on

the websites and the Subscription Service. In this event, you will be notified via email and/or a

prominent notice on our website, of any change in ownership, uses of your Personal Data, and

choices you may have regarding your Personal Data.

3.6 Compelled Disclosure.

We reserve the right to use or disclose your Personal Data if required by law or if we reasonably

believe that use or disclosure is necessary to protect our rights, protect your safety or the safety

of others, investigate fraud, or comply with a law, court order, or legal process.

4. HOW WE TRANSFER PERSONAL DATA INTERNATIONALLY

For more information about how we may transfer personal data internationally, please refer to

our DPA Template.5. HOW WE STORE AND SECURE PERSONAL DATA

5.1 Data Storage and Security.

We use a variety of security technologies and procedures to help protect your Personal Data

from unauthorized access, use or disclosure. We secure the Personal Data you provide on

computer servers in a controlled, secure environment, protected from unauthorized access, use

or disclosure. All Personal Data is protected using appropriate physical, technical and

organizational measures.

5.2 Retention of Personal Data.

How long we keep information we collect about you depends on the type of information and how

we collect and store it. After a reasonable period of time, we will either delete or anonymize your

information or, if this is not possible, then we will securely store your information and isolate it

from any further use until deletion is possible.

We retain Personal Data that you provide to us where we have an ongoing legitimate business

need to do so (for example, as needed to comply with our legal obligations, resolve disputes

and enforce our agreements).

When we have no ongoing legitimate business need to process your Personal Data, we

securely delete the information or anonymize it or, if this is not possible, securely store your

Personal Data and isolate it from any further processing until deletion is possible. We will delete

this information at an earlier date if you so request, as described in the "Privacy Rights and

Choices" section.

If you have elected to receive marketing communications from us, we retain information about

your marketing preferences for a reasonable period of time from the date you last expressed

interest in our content, products, or services, such as when you last opened an email from us or

ceased using your INFLOWW account. We retain information derived from cookies and other

tracking technologies for a reasonable period of time from the date such information was

created.

The data we process on behalf of customers in connection with the Subscription Service is

stored and secured according to the INFLOWW Terms of Service and Data Processing

Agreement.

6. COOKIES

6.1 Cookies.

To find out more about how we use cookies on our websites and how to manage your cookie

preferences please see the INFINNI Cookie Policy as updated by us from time-to-time, without

additional notice.7. YOUR PRIVACY RIGHTS AND CHOICES

7.1 Personal Data Requests.

Depending on your location and applicable laws, you may have the following data protection

rights:

(i) Right of access. You may request a copy of the personal data we hold about you and

information on how it is processed.

(ii) Right to rectification. You may request correction of inaccurate or incomplete personal data.

(iii) Right to erasure. You may request deletion of your personal data where it is no longer

necessary, where you withdraw consent, or where processing is unlawful, among other grounds.

(iv) Right to restriction of processing. You may request that we limit the processing of your

personal data in certain circumstances.

(v) Right to data portability. You may request to receive your data in a structured, commonly

used, machine-readable format or have it transmitted to another controller.

(vi) Right to object. You may object to processing based on legitimate interests or carried out for

direct marketing purposes.

(vii) Right not to be subject to solely automated decision-making, including profiling. You have

the right not to be subject to a decision based solely on automated processing that produces

legal or similarly significant effects on you.

(viii) Right to withdraw consent. Where processing is based on consent, you may withdraw it at

any time without affecting the lawfulness of processing carried out prior to withdrawal.

(ix) Right to lodge a complaint. You have the right to lodge a complaint with a supervisory

authority, in particular in the Member State of your habitual residence, place of work, or the

place of the alleged infringement.

To exercise any of these rights, contact us at dpo@infinni.io.

Please note that to protect Personal Data, we may verify your identity by a method appropriate

to the type of request you are making. Depending on where you reside, you may be entitled to

empower an “authorized agent” to submit requests on your behalf. We will require authorized

agents to confirm their identity and authority, in accordance with applicable laws. You are

entitled to exercise the rights described above free from discrimination.We will respond to your request to change, correct, or delete your data within a reasonable

timeframe and notify you of the action we have taken. In some instances, your rights may be

limited, such as where fulfilling your request would impair the rights of others, our ability to

provide a service you have requested, or our ability to comply with our legal obligations and

enforce our legal rights. Depending on your location, and applicable laws, you may have the

right to complain to a data protection authority about our collection and use of your Personal

Data. Contact details for data protection authorities in the EEA are available on the European

Data Protection Board website.

If you are a customer, prospect, or otherwise interact with an INFINNI customer that uses our

Subscription Service and would like to access, correct, amend or delete your data controlled by

the customer, please contact the relevant customer directly.

7.2 To Unsubscribe From Our Communications. You may unsubscribe from our marketing

communications through the following methods:

(i) by clicking on the "unsubscribe" link located on the bottom of our e-mails;

(ii) updating your communication preferences;

Customers cannot opt out of receiving transactional emails related to their INFINNI Account or

the Subscription Service.

8. OTHER IMPORTANT PRIVACY INFORMATION

8.1 Information About Children.

INFINNI's websites, products, and services are not intended for or targeted at children under 18,

and we do not knowingly or intentionally collect Personal Data about children under 18. If you

believe that we have collected Personal Data about a child under 18, please contact us, so that

we may delete the information.

9. CONTACT US

If you have any questions about this Privacy Policy or our privacy practices, or if you have a

disability and need to access this notice in a different format:

(i) By email at dpo@infinni.io

(ii) You may also contact us by postal mail at:

Attn: Data Protection Officer

Infinni Innovations S.A.Calle Maria Zambrano 42, Club de Campo Abama Parcela 4-B1

Santa Cruz de Tenerife, 38687, Spain