Privacy Policy Infocoin Limited

Infocoin Limited takes customer privacy very seriously. We are currently doing our best to comply with Regulation 2016/679, the General Data Protection Regulation (hereinafter referred to as GDPR), which sets the world’s highest privacy and information protection standards. This Privacy Policy sets out the types of information we collect, why we collect it, how we use it, and whom we may disclose it to. In addition, it outlines the rights that users have as data subjects and how they can be implemented.

This privacy policy applies to all cases of data processing performed by us in connection with the provision of our services through Internet sites, mobile versions of Internet sites (hereinafter — the «Website»), mobile applications for iOS and Android (hereinafter – the App and other Internet portals owned, operated, operated under the trademark INFOCOIN or accessed by Infocoin Limited, identified by the unified index of the resource Infocoin.online and any other sites on our domain with anyone under the domain).

Who we are

Our company Infocoin Limited (a company incorporated in the Republic of Cyprus, registration number HE 433674, Anexartisias & Athinon, NORA COURT, 2nd floor, Flat/Office 203, 3040 Limassol, Cyprus) and is the Operator of Personal Data.

Terms used in this privacy policy

Personal Data is any information related to a directly or indirectly identified or identifiable natural person. If our company has the means to identify the client and even their device, any information in our possession related to this client is considered Personal Data.

Personal Data operator – a person who determines the purposes and means of processing Personal Data. For instance, our company acts as a Personal Data Operator, processing Customers’ Personal Data for the purposes set out in this Privacy Policy. During the use of our website or application, we share the user’s Personal Data with another Personal Data Controller, whether it be an advertiser or other service provider, who in turn uses the customer’s Personal Data for their own purposes. All Personal Data Controllers are required to have a Privacy Policy similar to this one to inform customers about how their Personal Data is processed. The following will provide general information about the Personal Data Controllers to whom we may disclose Personal Data.

The Personal Data Processor is a third party who only helps to achieve the goals set by the Personal Data Operator. As a Personal Data Controller, our company uses the services of numerous third parties, entrusting them with certain activities we do not carry out for one reason or another (for example, for reasons of economic efficiency). The Personal Data Processor is only permitted to process your Personal Data following our written instructions.

Third countries are countries that are not subject to the legal regime of the GDPR. For the time being, under Third countries, we mean all countries outside the European Economic Area.

Personal Data we collect

We receive your Personal Data directly from you when you provide us with your Personal Data or collect them themselves when you use our services or interact with us. Depending on the processing purpose, we can process the following Personal Data categories.

Personal Data Category	Description
Identification information	Information used to identify you as a natural person, such as your first name, last name, gender, nationality, billing address and date of birth, as well our artificially created online identifier, e.g., identifier in Infocoin Limited systems.
Contact information	Information used to contact you, such as email address or phone number.
Your behavior when interacting with us online	Your behavior on our Website and in our Application: what you visited, for how long you stayed there, what clicked on, etc. We also monitor your response to emails and notifications we send – for example, whether you open emails and click the links they contain.
Devices and networks metadata	Information about the device you use to access our Website or the device where our App is installed; metadata related to your network connection, and information flowing from these data. Such information includes, in particular, information about your operating system, web browser, permission screen, IP address, etc.
Account information	Settings and other data you create while using Infocoin Account, such how notifications, history search, specific settings, image profile, account data you use to log in to your Infocoin account, namely, email address and password (we never store unencrypted passwords), preferences, and others data stored in Infocoin Account.
Payment information	The information you provide for payment. Usually, this is bank cards data. We never store unencrypted bank cards data.
Information about your requests and interactions with us	All correspondence between you and Infocoin Limited associated with your requests (for example, client support tickets), metadata, and notes created by our systems and specialists.
Your settings	Some from your settings relating to the Website or Application – for example, language settings, currency preferences, destination and other, as well as settings regarding files cookie.

Purposes of data use

Purposes of using User data. Every time you access our Website or our App, we process your Personal Data for the purposes set out below.

Name	Description	Category of Personal Data	Legal basis
Ensuring the Website and App functionality	We process your Personal Data to provide you with the functionality of our Website and App.	Your behavior when interacting with us online; Device and network metadata; Your settings.	Article 6 paragraph 1 (f) – for the purposes of realizing the legitimate interests of Infocoin (providing product functionality).
Product development, service improvement, and business development	We strive to continuously improve our products and services. To do this, we need accurate data about your interactions with us. Therefore, we collect data about your device and your network identifiers, as well as your behavior on our Website and our App. We analyze all this data and use it to create or modify our functionality and processes. We also use data to grow our business. Every time we need to make a business decision, we look at the data generated by the most important part of our business – our customers.	Your behavior when interacting with us online; Device and network metadata.	Article 6 paragraph 1 (f) – for the purposes of realizing the legitimate interests of Infocoin (design and development of products, services, and business).
InfoCoin account	When you create an Infocoin Account, we process your Personal Data to provide you with all of its functionality in accordance with the Terms of Use. The amount of Personal Data processed varies depending on what data you store.	Contact Information; Account Information; Identification information; Payment information.	Article 9 paragraph 1 (b) – the need to conclude and implement a contract (Terms of Use).
Direct Marketing	We process Customers’ Personal Data for direct marketing purposes to match the most relevant offers to customers and maximize marketing effectiveness (including email offers and related information processing activities). This is done if you have signed up to receive our offers (based on your consent) or used our services and have not rejected our offers (have not opted out of our offers). In addition to your contact information, we also store the following data: transaction history, preferences, and other data about your interactions with us, which helps us segment customers and personalize offers. Based on the history of feedback and interaction, we can approach the Client with an individual personally tailored offer. In addition, we may send emails to customers who provide their details. We only store the Personal Data collected in this way for 30 days. We do not, under any circumstances, disclose the Client’s contact information to other Personal Data Operators without their knowledge and address clients only with the offers related to our primary business. To ensure you don’t miss out on our offers, in addition to direct messages, we send push notifications through our Website and App (with your consent).	Your behavior when interacting with us online; Account Information; Device and network metadata; Identification information (if entered in the fields); Contact details (if entered in the fields); Your settings.	Article 6 paragraph 1 (f) – for the purposes of realizing the legitimate interests of Infocoin (direct marketing). Article 6, paragraph 1 (a), consent. The Client can always unsubscribe from the mailing list (exercise their right to opt out of receiving direct marketing communications or withdraw consent) and check the subscription status by clicking on one of the links provided at the bottom of each email sent as part of the email newsletter.
Online advertising	Also, to provide you with the best offers and maximize our marketing activities’ effectiveness, we display advertisements on the site Infocoin.online and third-party websites that, based on your Personal Data, are most relevant to you. Therefore, there is a chance that you will see Infocoin business on other resources on the Internet.	Your behavior when interacting with us online; Account information; Device and network metadata; Your settings.	Article 6 paragraph 1 (f) – for the purposes of realizing the legitimate interests of Infocoin (direct marketing).
Marketing Analytics	For the overall improvement of our marketing campaigns, we provide analysis to track the performance of campaigns and their impact on our advertising performance metrics. We also analyze your interaction with Infocoin and send you offers that are relevant to you.	Your behavior when interacting with us online; Device and network metadata.	Article 6 paragraph 1 (f) – for the purposes of realizing the legitimate interests of Infocoin (direct marketing).
Substantiation and presentation of claims and lawsuits, as well as defense against claims and lawsuits	We save your Personal Data for at least four years from the time you use our Website or App to allow us to bring claims or lawsuits in connection with your use of the Website or App in violation of our Terms of Use or in violation of certain legal obligations, and to be able to defend against claims or claims brought by you.	Identification information; Your behavior when interacting with us online; Device and network metadata; Account information Contact details (if they are entered in the fields); Your settings.	Article 6 paragraph 1 (f) – for the purposes of realizing the legitimate interests of Infocoin (protection of our legal rights).
Data protection	We need to protect ourselves from various threats that try to exploit vulnerabilities in our security system and harm our business. To do this, in certain cases, we need to process the Personal Data of our users.	Your behavior when interacting with us online; Device and network metadata.	Article 6, paragraph 1 (f), for the purposes of implementation legitimate interests Infocoin (security).

— Purposes of using the data of the person who posts the content . When you order services from us, we continue to process your Personal Data for the purposes described above. Personal Data processed for these purposes also includes information about your order(s), your requests, and information related to communications between us. In addition, we process your Personal Data for the following purposes.

Name	Description	Personal Data Category	Legal basis
Services order and provision	The main reason for our collection and use of your Personal Data is the conclusion of a contract with you and the subsequent provision of the ordered services. Depending on the volume of our services used by the client, we process Personal Data following the need dictated by the conclusion and execution of agreements on the provision of services concluded by using the site’s functionality, pressing the appropriate keys, filling in blocks of information. In the process of placing an order, the client receives a request to express consent to the processing of the specified Personal Data. The client always has the right to withdraw his consent by contacting the support service at the following links: https://business.infocoin.online/support https://view.infocoin.online/help. At the same time, please keep in mind that after the withdrawal of consent to the processing of Personal Data, we will not be able to provide the client with further support related to current services. If necessary, we process your Personal Data to conclude an agreement with you and provide ordered services; sometimes, third-party Operators can process Personal Data, in compliance with all the mentioned obligations for their preservation and conservation, under our strict control and with written consent. A complete list of third-party Personal Data Controllers to whom we may disclose customer Personal Data is available upon written request.	Identification information; Contact Information; Information about your order(s); Information about the submitted documents; Payment information; Documents required for the provision of services entrusted to third parties; Licenses and other documents related to the order.	Paragraph 1 (b) of article 6 – the need to conclude and implement a contract.
Fraud Prevention	Moreover, to prevent fraudulent chargebacks, if a client reports a fraudulent purchase through their bank account, we may examine their information on social networks to check the client for any connection with the person who ordered advertising or other services to make sure that there are no fraudulent attempts to return funds spent on advertising and other services. We process only a limited amount of information necessary to verify the client’s relationship with the person who ordered advertising or other services and publish any data related to a particular case.	Identification information; Contact Information; Information about your order(s); Information about travel documents; Payment Information; Your behavior when interacting with us online; Device and network information; Public information related to your order.	Article 6 paragraph 1 (f) – for the purposes of realizing the legitimate interests of Infocoin and the e-commerce and e-advertising industry in general (fraud prevention).
Customer Support	Customer support is an integral part of our services. To provide customers with the services they request, we capture all information in the course of communication with customers through any channels, including email, chat, and telephone.	Identification information; Contact Information; Information about your order(s); Information about travel documents; Information about your requests and interactions with us.	Article 6 paragraph 1 (b), the need to conclude and perform a contract
Substantiation and presentation of claims and lawsuits, as well as defense against claims and lawsuits	We store and process Customer Personal Data to establish, assert, and defend claims. Each time you use the site, we keep all relevant data in the event of possible claims or lawsuits that you or us may bring, in particular in the context of litigation and other proceedings, as well as in the exercise or sale of claims transferred by you to us, for at least four years from the date of creation of the relevant order. When we receive data protection requests from customers, we also store all the data provided by the customers and all information about working with the request for the specified purpose.	Identification information; Contact information Information about your order(s); Payment information; Your behavior when interacting with us online; Device and network information; Public information related to your order; Information about your requests and interactions with us.	Article 6 paragraph 1 (f) – for the purposes of realizing the legitimate interests of Infocoin (protection of our legal rights).
Compliance with legal obligations	Where applicable, we must process specific Customer Personal Data to comply with our legal obligations. We do not need to obtain customer consent for such processing, as it is a legal requirement. To this end, we process each client’s identification and contact information, and information about the transactions made. The main norms that oblige us to perform these actions are contained in the law: the Civil Code, the Consumer Rights Protection Law, VAT acts, and tax reporting. If a customer sends us a request to exercise rights relating to their Personal Data, we ask them to provide certain Personal Data and then process it to comply with applicable law. If the legislation that applies to our relationship with you does not expressly require the collection of such data, we will not collect them.	Information about your order(s); Information about your requests and interactions with us.	Article 6 paragraph 1 (c) – the need to comply with legal obligations that apply to Infocoin.

To whom and why we disclose Personal Data

— Disclosure of data to other Personal Data Operators

In some cases, we disclose Personal Data to third persons who use them for their purposes.

Thus, Clients’ Personal Data may be opened up to certain advertisers and service providers in Third countries.

All advertisers use Personal Data according to their Privacy Policies (published on advertisers’ websites). Disclosure of Personal Data to other service providers is carried out according to current regulatory legal acts concerning Personal Data.

In case of giving you consent through our file cookies settings, we transfer some of your data to our partners for marketing purposes.

Recipient category	Examples
Advertisers To fulfill our own purposes, such as targeting, your Personal Data is processed accordingly.	An advertiser who purchases impressions of their ad
Other service providers Third-party organizations related to the main activity of the site that process your personal information following their privacy policies, as well as under accepted norms of international law.	Service providers
Operators receiving and processing payments Executing payment orders on the merchant’s website is just the beginning of a long chain of technical operations required for admission payment to your (bank) account and directions confirmation seller. The information must go through various payment operators and acquiring banks. These subjects act as Personal Data operators because they fully control this data.	PayPal
Communication and social platforms To send you communications related to our services or allow you to log in to InfocoinAccount through third-party platforms, we need to transmit your Personal Data to the supplier platform of your choice.	Facebook Ireland Ltd. Google Ireland Limited
Persons providing legal services We may use the services of other entities to protect our legal rights and present claims.	Lawyers, collection agencies

— Disclosure to Personal Data Processors

Our company requires numerous activities that we cannot carry out independently. To execute them, we use the services of third-party partners to whom we disclose Customer Personal Data, as they often cannot proceed without it. However, in such cases, our company retains the status of a Personal Data controller, and third-party partners act as processors.

Therefore, they may only process Personal Data for our purposes, and we are always responsible for the information. Under no circumstances may they use the data for their own purposes or in a manner contrary to our agreement.

Moreover, we cooperate only with partners who give us sufficient guarantees to comply with legal requirements and fully ensure the security of customer information.

Recipient Category

Examples

Persons providing enforcement services

When representing you in disputes with carriers, we may use the services of third parties to protect your rights and interests.

Lawyers, collection agencies.

Online advertising services.

Thanks to these services, we can show your personal advertising on the Internet.

Facebook Ireland Ltd. (Facebook for Business)

Google Business

Criteo SA

CityBusiness Media, LLc.

Analytical tools.

We use data analysis and logging software tools from third-party vendors to provide a comprehensive view of our customer base and improve the convenience of our services.

Exponea s.r.o.

Facebook Ireland Ltd.

Google LLC.

Keboola s.r.o.

GoodData Corporation.

Datadog Inc.

Logmole

Loggly, Inc. (SolarWinds Worldwide, LLC)

Functional Software, Inc. dba Sentry

Smartsupp.com, s.r.o.

Mapbox, Inc.

FullStory, Inc.

Software Development

We may occasionally share your Personal Data with our developers who help build our technologies.

We are currently working with many software developers. We do not share their Personal Data to respect their privacy.

Duration of Personal Data storage

Usually, we process your Personal Data for as long as it is no longer necessary for us to use it for the purposes set out in this Privacy Policy. We generally process your Personal Data for the statutory limitation period, which is typically three years, and an additional one year due to the margin required due to delayed notifications and our further actions.

To comply with legal obligations, we process your Personal Data for as long as required by applicable law, such as the 10-year account holding period.

To keep the Infocoin client’s Account, we store Personal Data for five years from the date of the last action you took while logged in to the Account.

We periodically send e-mails to customers for personalized offers, each of which offers a simple and straightforward way to unsubscribe and thereby opt-out of this type of processing. We store and use Customer Personal Data for this purpose until you unsubscribe from the mailing list.

Gaining access to and control of your Personal Data

It is our concern to let the Clients always control their Personal Data. Clients have certain rights in this regard. Clients may, under certain conditions:

— get acquainted with the comprehensive information about what data we process and receive its copy;

— send us removal requests for their data;

— edit their data if they encountered mistakes in it;

— limit processing data;

— object against the processing;

— receive Personal Data in a standard, machine-readable format and transmit it to their other supplier.

To implement your rights, You can contact support at the following links https://business.infocoin.online/support or https://view.infocoin.online/help.

Please note that in order to protect your Personal Data, we only process requests sent from the account with the email address used during registration. If you wish to change your email address, please provide additional information to verify that the customer is the owner of the Personal Data.

— Access to your Personal Data

You can at any time send a request to the support service at the following links: https://business.infocoin.online/support or https://view.infocoin.online/help to find out if we process your personal data and receive the following information:

— The purposes for which we process your Personal Data;

— The categories of Personal Data we process;

— A list of third parties to whom we share your Personal Data, primarily if third parties are located in third countries;

— The duration of the processing of your Personal Data or the time of their storage;

— Your rights as a data subject under the GDPR (General Data Protection Regulation);

— Your right to file complaints with supervisory authorities;

— Where we received your data if we did not receive it directly from you;

— Any information about automated decision making (if any) that may apply to you;

— When the data was transferred to a third country and what security measures are applied under the GDPR;

Also, upon your request, we will provide a complete copy of all Personal Data we process. The first copy of the data is provided free of charge. However, subsequent copies are subject to an administrative fee.

You can also request data to be provided in a commonly used format for data portability.

— Deletion of Personal Data

You also have the right to complete deletion of Personal Data (or, more precisely, their complete and irrevocable anonymization) if one of the following cases applies to you:

— We no longer need your Personal Data for the purposes identified in this Privacy Policy;

— You have successfully objected to the processing of Personal Data pursuant to Article 21 of the GDPR, and we have no other purposes for processing your Personal Data;

— We unlawfully processed your Personal Data, or there is a legal obligation obliging us to delete your Personal Data;

However, you do not have the right to request the deletion of Personal Data if the processing is necessary for:

— exercising the right to freedom of expression and information;

— compliance with a legally binding obligation obliging us to store Personal Data;

— we need our Personal Data for the establishment and implementation of claims, as well as defense against them.

— Correction of Personal Data

If you believe that any of your Personal Data that we process is incorrect, you can report it, and we will do our best to update it.

— Restriction of the processing of your Personal Data

Under certain conditions, we restrict the processing of your Personal Data. It means that we will ensure that it is not processed for any other purpose than archiving or moving to a secure archive. You have the right to demand a restriction if:

— you have disputed the accuracy of your Personal Data (we will continue to process it after the issue has been resolved);

— we unlawfully processed your Personal Data, but instead of deletion, you requested restriction of their processing;

— the sole remaining purpose of the processing of your Personal Data is the establishment and implementation of claims, as well as defense against them;

— you object to the processing of data following Art. 21 para. 1 GDPR, and we estimate the validity of your request.

— Objection to the processing of your Personal Data

You may object to any purpose for which we process your Personal Data based on a legal basis of a legitimate interest. If you object to data processing for marketing purposes, we will immediately stop using your Personal Data for these purposes.

If you object to any other purpose based on a legal interest, we will stop processing your Personal Data for the purposes in question unless we can demonstrate that our legitimate grounds for processing it override your personal interests, rights, and freedoms.

— Ensuring the portability of your Personal Data

Finally, you have the right to receive your Personal Data processed (based on consent, or the need to enter into a contract or the need to fulfill obligations under it) in a commonly used and machine-readable format, and you have the right to transfer this data to other Personal Data controllers according to your choice.

Cookies and similar technologies

Cookies are small text files placed on your device that allow us to remember certain information about you for various purposes, such as providing the Website and App functionality, developing products, improving the service and business development, ensuring the work of the Infocoin Account, online advertising, marketing analytics, information security, fraud prevention.

Our website uses (or migh be using) three types of cookies:

— cookies strictly necessary for the operation of the website and the provision of services (they cannot be disabled);

— so-called «performance» cookies, used to obtain statistical data to improve our services;

— cookies used for marketing purposes.

Cookies used to obtain statistical data and for marketing purposes can be disabled using the settings.

You can learn more about cookies, including how to manage or delete them, at www.aboutcookies.org, www.allaboutcookies.org, or www.civicuk.com/cookie-control/browser-settings. However, please note that some site features may not work if cookie files are deleted.

DON’T TRACK: We currently do not respond to your browser’s Do Not Track settings.

Cookies _	Goal
__business.infocoin.online	Files are needed for administration, statistics and other indicators important to our developers
__view.infocoin.online	Files are needed to display the architecture, code, and other metrics our developers need
helpcrunch-widget	The SameSite attribute of the Set-Cookie HTTP response header allows you to specify whether your cookies should be restricted to the visited site, third parties, or subdomains of the site.
_ga	User identification (Google Analytics 4)
_gid	User identification (Google Analytics 4)
_ga_<container-id>	Save session state (Google Analytics 4)
_ga	Universal Analytics User ID (analytics.js)
_gid	Universal Analytics User ID (analytics.js)
_gat	Limits the number of requests. If Google Analytics support is implemented using Google Tag Manager, the file will be named _dc_gtm_<property-id>
AMP_TOKEN	contains a token that can be used to get the Client-ID from the AMP service
_gac_<property-id>	Contains information about the user’s company. After establishing a connection between the Google Analytics and Google Business accounts, the Google Business conversion tags placed on the site will receive data from the cookie file.

Transfer of your data outside the European Economic Area

If needed, we can transfer your Personal Data outside European Economic Area. This happens when a customer wants to buy advertising from a Third country or orders any of the services from a third country. A need to transmit customers’ information to such third persons is natural because providing services would be impossible without it. Also, we can transfer your Personal Data outside European economic zones to the Personal Data Processors located in third countries.

When transferring data to countries where we cannot rely on the corresponding level of protection according to Article 45 of the GDPR and sufficient measures to ensure security under Article 46 of the GDPR, we transfer Personal Data based on the exception provided in Art. 49 Paragraph 1 Subparagraph b of the GDPR. All service providers use Personal Data according to their Privacy Policies (published on their websites). Disclosure of Personal Data to other service providers takes place according to current regulatory legal acts concerning Personal Data.

Complaints to supervisory authorities

Data protection is a serious issue, and implementing the rules is quite tricky. Nobody is perfect, and it may happen that we make a mistake. If you discover that we have misused your Personal Data, don’t hesitate to get in touch with us first, and we will do our best to fix the problem. You can always contact us with any questions regarding data protection by contacting support at the following links: https://business.infocoin.online/support or https://view.infocoin.online/help, or email to our office, the address of which is listed on the website.

However, you have the right to file complaints with the supervisory authorities under any circumstances. A person from the European Union may file a complaint with power in the EU Member State where they reside, in the EU Member State where they work, and in the EU Member State where the alleged infringement occurred.

How to contact us and exercise your rights

To clarify all privacy and security issues data, you can contact support at the following links: https://business.infocoin.online/support or https://view.infocoin.online/help.

Special conditions for persons residing in certain countries

Regardless of where you live, we guarantee your Personal Data protection. This Privacy Policy contains specific terms that differ from or supplement the rest of the terms and may apply to persons residing in certain countries and states under the terms of this Privacy Policy.

— For persons residing in California

These exceptional provisions apply to you if you reside in California.

We comply with the California Consumer Privacy Act (CCPA), which sets the highest privacy standards in the United States. You can review this Privacy Policy at any time for information about our processing of your Personal Data.

You have the right to request information about how we process your Personal Data and receive a copy of it. For 12 months, we provide the first two copies of the data free of charge. You also have the right to request your Personal Data to be deleted. For more information about your rights and how you can exercise them, see this Privacy Policy (sections «Access and control your Personal Information» and «How to contact us and exercise your rights»).

If you choose to exercise any of your rights, you will be required to verify your identity, for instance, by verifying that you are the owner of your email address. If you exercise your rights through an authorized agent, we will require your written authorization and proof of your identity and that of the agent. Under no circumstances will we discriminate against you or treat you unfavorably because you have exercised any of your rights.

In exchange for your subscription to marketing communications, we may offer you financial rewards in the form of coupons, credit points, or other forms of discounts. Details of the specific promotion will be presented to you as part of the subscription offer. We consider the estimated value of your subscription to be equal to the value of the promotion provided, based on our calculation of additional costs. After accepting our offer, you can cancel it at any time without any limitation of your rights. For more information, see this Privacy Policy (in the «Purposes of using Personal Data» section).

We do not sell your Personal Information within the meaning of the CCPA.

In addition, you can contact our data protection representative with any questions related to the processing of your Personal Data and the exercise of your rights about Personal Data.

Changes to this Privacy Policy

Methods work with Personal Data may change as it develops our business. If such changes come, we supplement this Politics confidentiality to comply with the principles of transparency. These rules are subject to change at any time without notice.

This edition Privacy Policy valid from 09.12.2022.

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