Privacy Notice - InfraFund
Last updated: 15 Jun 2024
InfraFund (“InfraFund”, “we”, or “us”) is committed to protecting the privacy of our customers, and we take our data protection responsibilities with the utmost seriousness.
This Privacy Notice describes how InfraFund collects and processes your personal data through the InfraFund websites and applications that are referenced in this Privacy Notice. InfraFund refers to an ecosystem comprising InfraFund websites (whose domain names include but are not limited to www.InfraFund.net), mobile applications, clients, applets and other applications that are developed to offer InfraFund Services, and includes independently-operated platforms, websites and clients within the ecosystem (e.g., InfraFund’s Open Platform, InfraFund Launchpad, InfraFund Labs, InfraFund Charity, InfraFund DEX, InfraFund X, JEX, and fiat gateways).
This Privacy Notice applies to all Personal data processing activities carried out by us, across platforms, websites, and departments of InfraFund.
To the extent that you are a customer or user of our services, this Privacy Notice applies together with any terms of business and other contractual documents, including but not limited to any agreements we may have with you.
To the extent that you are not a relevant stakeholder, customer, or user of our services, but are using our website, this Privacy Notice also applies to you together with our Cookie Notice.
This Notice should therefore be read together with our Cookie Notice, which provides further details on our use of cookies on the website. Our Cookie Notice can be accessed here.
1. What Personal Data does InfraFund collect and process?
Personal data is data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.
Information you provide to us. To open an account and access our services, we'll ask you to provide us with some information about yourself. This information is either required by law (e.g., to verify your identity and comply with “Know Your Customer” obligations), necessary to provide the requested services (e.g., you will need to provide your email address in order to open your account), or is relevant for certain specified purposes, described in greater detail below. In some cases, if we add services and features you may be asked to provide us with additional information.
Failure in providing the data required implies that InfraFund will not be able to offer you our services.
We may collect the following types of information from you:
Category of Personal Data / Types of Personal Data :
- Personal Identification Data.
Full name, e-mail address, gender, home address, phone number, date of birth, nationality, signature, utility bills, photographs, and a video or voice recording of you
- Sensitive and Biometric Personal Data
InfraFund may also collect sensitive personal data when permitted by local law or with your consent, such as biometric information, for example to verify your identity by comparing the facial scan data extracted from your selfie or video with the photo in your government issued identity document
- Government Identifiers
Government issued identity documents such as passport, national identification number, national identity card details, drivers licence numbers
- Online Identifiers
Social media domains/ profiles (such as Telegram, X, etc.)
- Institutional Information
Proof of legal formation, personal identification data for all material beneficial owners, personal data about the board of directors senior persons responsible for the operations of the body corporate
- Financial Information
Bank account information, payment card information, source of funding, source of wealth, InfraFund account information, InfraFund user ID and pay ID
- Wallet Information
Wallet address, wallet ID, and other information related to integrations that you select
- Transaction Information
Information about the transaction you make on our services, such as the name of the recipient, your name and e-mail
- Information from Cookies
See our Cookie Notice for more information.
- Employment Information
Job title, salary wage rate, and company
- Communications
Surveys responses, information contained in the Survey. Communications with us including call recordings with our customer services team.
- Contact Information
E-mail address, country, region,
Information we collect from you automatically. To the extent permitted under the applicable law, we may collect certain types of information automatically, for example whenever you interact with us or use the services. This information helps us address customer support issues, improve the performance of our sites and services, maintain and or improve your user experience, and protect your account from fraud by detecting unauthorized access.
Information collected automatically includes:
Category of Personal Data / Types of Personal Data:
- Browsing Information
Device ID, browsing information such as name and version, Internet Protocol (“IP”) address , internet connectivity data, operator and carrier data, login data, browser type and version, device type category and model, time zone setting and location data, language data, application version. browser plug-in types and versions, operating system and platform, other information stored on or available regarding the devices you allow us access to when you visit our Platforms
- Usage Data
Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies or similar technologies.
Information about how our Services are performing when you use them, e.g., error messages you receive, performance of the site information, other diagnosis data.
- Marketing and Research Information
Identifiers – the IP address, or other online identifiers of a person, e-mail address if used for direct marketing, and name and address
Demographic data - (e.g., income, family status, age bracket, gender, interests, etc)
Browser/web history data and preferences expressed through selection/viewing/purchase of goods, services and content, information about your mobile device including (where available) type of device, device identification number, mobile operating system.
Analytics and profiles of the individuals based on the data collected on them. For more information about this please see our Cookie Policy.
Interests or inferred interests and marketing preferences.
Information we collect from our affiliates and third parties.
From time to time, we may obtain information about you from our affiliates or third parties sources as required or permitted by applicable law.
Category of Personal Data / Type of Personal Data:
- Affiliates
In accordance with applicable law, we may obtain information about you from the group of companies related to us by common control or ownership (“Affiliates”) as a normal part of conducting business, so that we may offer our Affiliates’ Services to you.
We may obtain information about you such as Personal Identification Data, Transactional Information, Institutional Information, Usage Information. For example, if you want to convert cryptocurrency into fiat and make withdrawals into your bank account, we might need to exchange information with InfraFund Connect. For more information about how InfraFund Connect processes this information you can check its Privacy Notice here.
- Blockchain Data
We may analyze public blockchain data, such as transaction ID’s, transaction amounts, wallet address, timestamps or transactions or events.
- Retail Merchant Information
When conducting a transaction with a third-party merchant, the merchant may provide us with personal data about you such as name, contact information, transaction information.
2. Why does InfraFund process my personal data? Which legal bases are we relying on for our collection and processing of your personal data?
Our primary purpose in collecting personal data is to provide our services in a secure, efficient, and smooth way. We generally use your personal data to deliver, provide, operate, our services, and for content and advertising, and for loss prevention and anti-fraud purposes. Below you’ll find an explanation on how we use Automated individual decision-making, including profiling. InfraFund does not rely solely on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk.
Why does InfraFund process my Personal Data? / Legal Basis for our use of personal data (EEA and Switzerland EU GDPR):
- Managing our contractual relationship with you. To create and maintain your account.
This includes when we use your personal data to take and handle orders and process payments.
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Contact Information, Financial Information. The consequences of not processing your personal data for such purposes is the inability to open an account with us or the termination of your account where one is already open.
Processing is necessary for the performance of a contract of which you are a party.
- To maintain legal and regulatory compliance
Most of our core services such as the exchange services are subject to strict and specific laws and regulations requiring us to collect, use and store certain personal data and process Personal Identification identity information and in some cases Sensitive Personal Data[(including biometrics) (as detailed in section I) For example to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and in particular to comply with Anti-Money Laundering laws and regulations.
The Category of Personal Data is Personal Identification Data , Institutional Information, Sensitive and Biometric information, Government Identifiers, Contact Information, Financial Information. If you do not provide personal information required by law, you may be unable to open an account, or we may have to close your account where it is already opened.
Processing is necessary to comply with our legal obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations.
Processing is necessary for reasons of substantial public interest based on EU or EU Member State law. We are subject to EU Anti-Money Laundering Directives and the relevant EU Member States' law implementing them which require us to process for instance information from your ID documents including a photographic picture of you and a visual image of your face (the so called "liveness check").
- Communicate with you on service and transaction- related matters.
We use your personal data to communicate with you in relation to InfraFund Services on administrative or account-related information. We will communicate with you to keep you updated about our Services for example, to inform you of relevant security issues, updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.
Processing is necessary for the performance of a contract of which you are a party.
- To provide customer services:
We process your personal data when you contact us in order to provide support with respect to questions, disputes, complaints, troubleshoot problems, etc.
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Communications, Contact Information, Financial Information, Browsing Information, Usage Data.
Without processing your personal data for this purpose, we can’t respond to your requests.
Processing is necessary for the performance of a contract of which you are a party.
Processing is necessary for the purpose of the legitimate interest pursued by us to improve our services and enhance our user experience.
- To promote safety, security, and integrity of our platform.
We process your personal data in order to enhance security, monitor and verify identity or service access, combat malware or security risks and to comply with applicable security laws and regulations.
We process your personal data to verify accounts and related activity, find and address violations of our Terms and Conditions, investigate suspicious activity, detect, prevent and combat unlawful behaviour, detect fraud, and maintain the integrity of our Services.
The Category of Personal Data processed is Personal Identification Information, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, Usage Data.
Without processing your personal information, we may not be able to ensure the security of our Services.
We use your personal data to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of InfraFund Services.
Processing is necessary for the performance of a contract of which you are a party.
- To promote safety, security, and integrity of our Services.
Fraud prevention and detection and credit risks.
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, Usage Data.
We process Personal Identification Data to prevent and detect, prevent and mitigate fraud and abuse of our services and in order to protect you against account compromise or funds loss and in order to ensure the security of our users, InfraFund services and others. We may also use scoring methods to assess and manage credit risks. Please note that we may engage in automated decision-making for purposes of risk and fraud detection. When we do, we implement suitable measures to safeguard your rights and freedoms and legitimate interests, including the right to obtain human intervention, to express your point of view and to contest the decision.Please refer below to Section 10 for more information.
Processing is necessary for the purpose of the legitimate interests pursued by us and the interests of our users when, for example, we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others;
- To provide InfraFund services.
We process your personal data to provide the services to you , process your orders, facilitate transactions and to complete the transactions the Users require. For example, when you want to use the exchange service on our platform, we ask for certain information such as your identification, contact information, and payment information.
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, Usage Data.
We cannot provide you with services without such information.
Processing is necessary for the performance of a contract of which you are a party.
Processing is necessary for the purpose of our legitimate interest and your interest in providing better documentation for your transactions.
-To use the services of social media platforms or advertising platforms for purposes including marketing
-The category of personal data processed is Usage Data, Browsing Information.
We rely on your consent to process your personal data to use the services of advertising platforms. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- To improve our services.
We process personal data to improve our services and for you to have a better user experience;
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Browsing Information, Usage Data.
Processing is necessary for the purpose of the legitimate interest pursued by us to improve our services and enhance our user experience.
- To provide you with promotions
We use your information to provide you with promotions, including offers, rewards, and other incentives for using our Services. This would also include to enable you to partake ina prize draw, competition or complete a survey.
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Browsing Information, Usage Data and Online Identifiers.
For non-users, processing is necessary for the purpose of our legitimate interest and your interest to reward your customer loyalty.
For users, we rely on your consent to process your personal data to provide you with promotions. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- To do research and innovate.
We carry out surveys to learn more about your experience using our Services. We also use your information to support research and development and drive innovations of our Services and products. This information will also be used for Marketing purposes.
Processing is necessary for the purpose of our legitimate interest to improve and run our Services through information obtained from these surveys.
-For internal business purposes and record keeping.
The Category of Personal Data processed is Personal Identification Data, Financial Information, Transaction Information and Browsing Information.
Processing is necessary for the purpose of the legitimate interest pursued by us to keep records to ensure that you comply with your contractual obligations pursuant to the agreement (“Terms and Conditions”) governing our relationship with you.
Processing is necessary to comply with our legal obligations to keep certain records for internal business and research purposes as well as for record keeping purposes.
- Recommendations and personalisation.
We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalise your experience with InfraFund services;
Processing is necessary for the purpose of our legitimate interest to provide a personalised service to our customers.
Processing is necessary for the performance of a contract of which you are a party.
- To provide marketing communications to you.
We use your information based on your consent to send you targeted marketing communications through email, mobile, in-app, and push notifications.
We also use your information to carry out profiling for marketing purposes.
The Category of Personal Data processed is Personal Identification Information, Institutional Information, Transactional Information, Browsing Information, Usage Data, Marketing and Research Information, Communications.
Where required by applicable law, we rely on your consent to process your personal information for marketing purposes. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Where we carry out profiling for marketing purposes, for example to establish what Services or promotions you may be interested in, this processing is based on legitimate interest.
Transactional account messages and communications regarding our business relationship will not be affected even if you opt-out from marketing communications.
-Events
(i) To host, and/or organise and events.
InfraFund hosts many live, in-person events throughout the year. These include events like the Blockchain week, for example. If you register for one of our events and you are a user, we will access the information in your account to provide you with information and services associated with the event. You may be asked to provide more information when signing up for an event.
If you are not a user and you sign up for one of our events, we will collect the following information: name, email, company, title, industry, address, phone number, whether meal preferences, social media domain and the like.
(ii) in some cases you might pay to attend an Event. In such cases we will access the information in your account to provide you with information, services associated with the event and facilitating the ticketing process. You may be asked to provide more information when signing up for an event.
(iii) if you are a presenter at one of our events, we will collect information about you including your name, employer and Contact Information, and photograph, and we may also collect information provided by event attendees who evaluated your performance as a presenter. We may also make and store a recording of your voice and likeness in certain instances.
(iv) Some of our events are sponsored. InfraFund may provide an attendee list to sponsors, co-sponsors and exhibitors of our events. InfraFund may also allow sponsors, co-sponsors, exhibitors or other third parties relevant for the organisation of the event to send you material by mail once per sponsored event, in which case InfraFund engages a third-party mailing house and does not share your mailing address directly with the sponsor/exhibitor. If you do not wish to have your information included in an attendee list or to receive information from sponsors, co-sponsors and/or exhibitors, you can express your preferences when you register for events. We do give attendees a choice not to receive marketing messages from the sponsor or from InfraFund.
(iv) To provide you with information about the event(s) which you have registered, such as event updates and possible changes, cancellations or similar information.
(v) To fulfil and monitor our legal responsibilities for example under public safety legislations
(vi) In accordance with your preferences, to communicate with you about the other events, news and services we provide
(vii) To plan better future events and attendee experience.
Processing is necessary for the purpose of our legitimate interest to produce, organise and host events.
In the case where you pay to participate to an Event, the processing is necessary for the performance of a contract of which you are a party.
Processing is necessary for the purpose of our legitimate interest to promote the events, inform about the Event or to evaluate the performance of the Event.
We rely on your consent to process your personal data for marketing purposes. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Further details may be as follows:
When you decide to participate in an event or act as a presenter for the event, we rely on your consent to process your personal data for attendance to an event. When you consent to processing your personal data for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal data for that purpose. If you are a presenter at one of our events, we may also like to take photographs, and make and store a will collect recording of your voice and likeness in certain instances. In these situations InfraFund relies on a legitimate interest basis for collecting, storing and processing this personal data. When we organise events and work with sponsors, co-sponsors and exhibitors and send material, we rely on your consent to send you material about the event or direct marketing email. When you consent to processing your personal data for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal data for that purpose.
Cookies: where we use cookies and similar technologies as part of our Service. The Category of Personal Data processed is Information from Cookies.
Where required by applicable law, we rely on your consent to place cookies and similar technologies. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose.
The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal
To comply with other legal and regulatory obligations.
We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, government, and other legal requests, court orders, or disclosure to tax authorities in line with the detailed information set forth under Section 6.
The Category of Personal Data processed is Personal Identification Information, Institutional Information, Financial Information, Transactional Information, Browsing Information, Usage Data, Blockchain Data.
Processing is necessary to comply with our legal obligations under applicable laws and regulations
We may also rely on legitimate interests in responding to legal requests where we are not compelled by applicable law but have a good faith belief it is required by law in the relevant jurisdiction.
3. Can Children Use InfraFund Services?
InfraFund does not allow anyone under the age of 18 to use InfraFund Services and we do not knowingly request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any personal information to InfraFund Services.
If a User or Customer submitting personal information is suspected of being younger than 18 years of age, InfraFund will require the relevant Customer or User to close his or her account, and will take steps to delete the individual’s information as soon as possible.
4. What About Cookies and Other Identifiers?
We use cookies and similar tools to enhance your user experience, provide our services, enhance our marketing efforts and understand how customers use our services so we can make improvements. Depending on applicable laws in the region you are located in, the cookie banner on your browser will tell you how to accept or refuse cookies. A copy of our cookie policy is available here.
5. How and Why We Share your Personal Data?
We may share your Personal Data with third parties (including other InfraFund entities) if we believe that sharing your Personal Data is in accordance with, or required by, any contractual relationship with you (including InfraFund Terms & Conditions) or us, applicable law, regulation or legal process. When sharing your Personal Data with other InfraFund entities, we will use our best endeavours to ensure that such entities are either subject to this Privacy Notice, or follow practices at least as protective as those described in this Privacy Notice. For example, depending on where you reside and the entity responsible for running KYC checks. For more information please refer to Section 1.
We may also share personal data with the following persons or in the following circumstances:
Affiliates: Personal data that we process and collect may be transferred between InfraFund companies as a normal part of conducting business and offering our Services to you. See Section 1 “InfraFund Relationship with you” and Section 1. “What Personal Data does InfraFund collect and process?”.
Third parties: We employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. The third-party service providers only have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws. In accordance with and as far as provided by applicable law, your personal data may also be shared by third parties (i.e. another data controller) upon exercising your right to data portability. Please refer to Section 10 for more information on data portability. When you use third-party services (like when you connect your InfraFund account with your bank account) or websites that are linked through our Services, the providers of those services or products may receive information about you that InfraFund, you, or others share with them. Please note that when you use third-party services or InfraFund affiliate services which are not governed by this Privacy Policy, their own terms and privacy policies will govern your use of those services and products.
Legal Authorities: We may share your information with courts, law enforcement authorities, regulators, attorneys or other third parties: (a) to comply with laws and legal obligations; (b) for the establishment, exercise, or defence of a legal or equitable claim; (c) to respond to law enforcement and regulatory requests, including (1) when we are compelled to do so by a subpoena, court order, search or seizure warrant, or similar legal procedure, or (2) for international law enforcement requests, pursuant to a mutual legal assistance treaty (MLAT) or letters of request; (d) to comply with one or more forms of “travel rules” that require our transmitting of your information to another financial institution, regulatory authorities or other industry partners; (e) when we believe in good faith that the disclosure of personal information is necessary to protect the rights, property or safety of our customers, InfraFund, or others, including to prevent imminent physical harm or material financial loss; (f) to investigate violations of our Terms of Use or other applicable policies; or (g) to detect, investigate, prevent or address fraud or credit risk, other illegal activity or security and technical issues, to report suspected illegal activity or to assist law enforcement in the investigation of suspected illegal or wrongful activity.
Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). Also, in the unlikely event that InfraFund or substantially all of its assets are acquired by a third party, user information will be one of the transferred assets.
With your Consent: We also may disclose your Personal Data as may be described in a notice to you at the time the information is collected or before it is shared, or in any other manner to which you consent.
6. International transfers of Personal Information
To facilitate our global operations, InfraFund may transfer your personal information outside of the European Economic Area (“EEA”), UK and Switzerland. The EEA includes the European Union countries as well as Iceland, Liechtenstein, and Norway. Transfers outside of the EEA are sometimes referred to as “third country transfers”.
We may transfer your personal information to our Affiliates, third-party partners, and service providers based throughout the world. In cases where we intend to transfer personal information to third countries or international organisations outside of the EEA, InfraFund puts in place suitable technical, organizational and contractual safeguards (including Standard Contractual Clauses), to ensure that such transfer is carried out in compliance with applicable data protection rules.
We also rely on decisions from the European Commission where they recognise that certain countries and territories outside of the European Economic Area ensure an adequate level of protection for personal information. These decisions are referred to as “adequacy decisions”.
7. How Secure is My Information?
We design our systems with your security and privacy in mind. We have appropriate security measures in place to prevent your information being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We work to protect the security of your personal data during transmission and while stored by using encryption protocols and softwares. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
Our security procedures mean that we may ask you to verify your identity to protect you against unauthorised access to your account. We recommend using a unique password for your InfraFund account that is not utilized for other online accounts and to sign off when you finish using a shared computer.
8. What About Advertising?
In order for us to provide you with the best user experience, we may share your personal data with our marketing partners for the purposes of targeting, modelling, and/or analytics as well as marketing and advertising. You have a right to object at any time to processing of your personal data for direct marketing purposes (see Section 10 below).
9. What Rights Do I Have?
Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your personal data. You have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances. In addition, when you consent to our processing of your personal data for a specified purpose, you may withdraw your consent at any time. If you want to exercise any of your rights please contact us using the webform available here. These rights may be limited in some situations - for example, where we can demonstrate we have a legal requirement to process your personal data.
Right to access: you have the right to obtain confirmation that your personal data are processed and to obtain a copy of it as well as certain information related to its processing. Please follow the FAQ for further information on how to access your account statement yourself. You can also check your device and IP address login’s via the dedicated “Account Activity Records” page located here. Please note that you have to login to your account first to obtain access;
Right to rectify: you can request the rectification of your personal data which are inaccurate, and also add to it. You can also change your personal data in your account at any time.
Right to delete: you can, in some cases, have your personal data deleted. Please follow the FAQ for further self-help information on how you can request that your account is deleted yourself. Please note that personal data may still be retained in the event of account deletion to comply with our legal obligations.
Right to object: you can object, for reasons relating to your situation, to the processing of your personal data For instance, you have the right to object where we rely on legitimate interest or where we process your data for direct marketing purposes;
Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your personal data by us, provided there are valid grounds for doing so. We may continue to process your personal data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law;
Right to contest to a decision based solely on automated processing: You have the right to require that decisions be reconsidered if they are made solely by automated means, without human involvement; we use automated tools to make sure that you are eligible to be our customer taking into account our interests and legal obligations; if these automated tools indicate that you do not meet our acceptance criteria, we will not onboard you as our customer;
Right to portability: in some cases, you can ask to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, that we communicate your personal data on your behalf directly to another data controller;
Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter;
Right to lodge a complaint with the relevant data protection authority: We hope that we can satisfy any queries you may have about the way in which we process your personal data. However, if you have unresolved concerns, you also have the right to complain to the data protection authority in the location in which you live, work or believe a data protection breach has occurred.
If you have any questions or objection as to how we collect and process your personal data, please contact us using the webform available here.
10. How Long Does InfraFund Keep My Personal Data?
We keep your personal data to enable your continued use of InfraFund Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Notice, and as may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or to resolve disputes and/or legal claims or as otherwise communicated to you.
While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal data are described below.
Personal Identifiable Data collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as is required under such laws.
Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis and until you (a) unsubscribe, or we (b) delete your account. Thereafter we will add your details to an unsubscribed list to ensure we do not inadvertently market to you.
Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes.
Recording of voice calls with you may be kept for a period of up to six years, for audit/ compliance purposes and to resolve disputes and/or legal claims.
Information collected via cookies, web page counters and other analytics tools is kept for a period of up to one year from the date of the collection of the cookie of the relevant cookie.
11. Notices and Revisions
If you have any concerns about privacy at InfraFund, please contact us, and we will try to resolve it. You also have the right to contact your local Data Protection Authority.
Our business changes regularly, and our Privacy Notice may change also. You should check our websites frequently to see recent changes. We will update the “Last Updated” date accordingly at the beginning of this Privacy Notice. We will announce any material changes to this Privacy Notice on our Platform or by sending an email that you have provided under your account. Your continued use of InfraFund after the changes to this Privacy Notice means that you understand and agree to such changes.
Unless stated otherwise, our most recent Privacy Notice applies to all information that we have about you and your account.
12. Languages
This Privacy Policy may be published in different languages. In case of any discrepancy, this English version shall prevail.
13. Contact Information
Our data protection officer can be contacted using the webform available below, or via email and will work to address any questions or issues that you have with respect to the collection and processing of your personal data.
If you have a question about your account management, or InfraFund products or services the Data Protection Officer will not be able to assist you. In that case, please contact our Customer Support team using the following link.
InfraFund (“InfraFund”, “we”, or “us”) is committed to protecting the privacy of our customers, and we take our data protection responsibilities with the utmost seriousness.
This Privacy Notice describes how InfraFund collects and processes your personal data through the InfraFund websites and applications that are referenced in this Privacy Notice. InfraFund refers to an ecosystem comprising InfraFund websites (whose domain names include but are not limited to www.InfraFund.net), mobile applications, clients, applets and other applications that are developed to offer InfraFund Services, and includes independently-operated platforms, websites and clients within the ecosystem (e.g., InfraFund’s Open Platform, InfraFund Launchpad, InfraFund Labs, InfraFund Charity, InfraFund DEX, InfraFund X, JEX, and fiat gateways).
This Privacy Notice applies to all Personal data processing activities carried out by us, across platforms, websites, and departments of InfraFund.
To the extent that you are a customer or user of our services, this Privacy Notice applies together with any terms of business and other contractual documents, including but not limited to any agreements we may have with you.
To the extent that you are not a relevant stakeholder, customer, or user of our services, but are using our website, this Privacy Notice also applies to you together with our Cookie Notice.
This Notice should therefore be read together with our Cookie Notice, which provides further details on our use of cookies on the website. Our Cookie Notice can be accessed here.
1. What Personal Data does InfraFund collect and process?
Personal data is data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.
Information you provide to us. To open an account and access our services, we'll ask you to provide us with some information about yourself. This information is either required by law (e.g., to verify your identity and comply with “Know Your Customer” obligations), necessary to provide the requested services (e.g., you will need to provide your email address in order to open your account), or is relevant for certain specified purposes, described in greater detail below. In some cases, if we add services and features you may be asked to provide us with additional information.
Failure in providing the data required implies that InfraFund will not be able to offer you our services.
We may collect the following types of information from you:
Category of Personal Data / Types of Personal Data :
- Personal Identification Data.
Full name, e-mail address, gender, home address, phone number, date of birth, nationality, signature, utility bills, photographs, and a video or voice recording of you
- Sensitive and Biometric Personal Data
InfraFund may also collect sensitive personal data when permitted by local law or with your consent, such as biometric information, for example to verify your identity by comparing the facial scan data extracted from your selfie or video with the photo in your government issued identity document
- Government Identifiers
Government issued identity documents such as passport, national identification number, national identity card details, drivers licence numbers
- Online Identifiers
Social media domains/ profiles (such as Telegram, X, etc.)
- Institutional Information
Proof of legal formation, personal identification data for all material beneficial owners, personal data about the board of directors senior persons responsible for the operations of the body corporate
- Financial Information
Bank account information, payment card information, source of funding, source of wealth, InfraFund account information, InfraFund user ID and pay ID
- Wallet Information
Wallet address, wallet ID, and other information related to integrations that you select
- Transaction Information
Information about the transaction you make on our services, such as the name of the recipient, your name and e-mail
- Information from Cookies
See our Cookie Notice for more information.
- Employment Information
Job title, salary wage rate, and company
- Communications
Surveys responses, information contained in the Survey. Communications with us including call recordings with our customer services team.
- Contact Information
E-mail address, country, region,
Information we collect from you automatically. To the extent permitted under the applicable law, we may collect certain types of information automatically, for example whenever you interact with us or use the services. This information helps us address customer support issues, improve the performance of our sites and services, maintain and or improve your user experience, and protect your account from fraud by detecting unauthorized access.
Information collected automatically includes:
Category of Personal Data / Types of Personal Data:
- Browsing Information
Device ID, browsing information such as name and version, Internet Protocol (“IP”) address , internet connectivity data, operator and carrier data, login data, browser type and version, device type category and model, time zone setting and location data, language data, application version. browser plug-in types and versions, operating system and platform, other information stored on or available regarding the devices you allow us access to when you visit our Platforms
- Usage Data
Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies or similar technologies.
Information about how our Services are performing when you use them, e.g., error messages you receive, performance of the site information, other diagnosis data.
- Marketing and Research Information
Identifiers – the IP address, or other online identifiers of a person, e-mail address if used for direct marketing, and name and address
Demographic data - (e.g., income, family status, age bracket, gender, interests, etc)
Browser/web history data and preferences expressed through selection/viewing/purchase of goods, services and content, information about your mobile device including (where available) type of device, device identification number, mobile operating system.
Analytics and profiles of the individuals based on the data collected on them. For more information about this please see our Cookie Policy.
Interests or inferred interests and marketing preferences.
Information we collect from our affiliates and third parties.
From time to time, we may obtain information about you from our affiliates or third parties sources as required or permitted by applicable law.
Category of Personal Data / Type of Personal Data:
- Affiliates
In accordance with applicable law, we may obtain information about you from the group of companies related to us by common control or ownership (“Affiliates”) as a normal part of conducting business, so that we may offer our Affiliates’ Services to you.
We may obtain information about you such as Personal Identification Data, Transactional Information, Institutional Information, Usage Information. For example, if you want to convert cryptocurrency into fiat and make withdrawals into your bank account, we might need to exchange information with InfraFund Connect. For more information about how InfraFund Connect processes this information you can check its Privacy Notice here.
- Blockchain Data
We may analyze public blockchain data, such as transaction ID’s, transaction amounts, wallet address, timestamps or transactions or events.
- Retail Merchant Information
When conducting a transaction with a third-party merchant, the merchant may provide us with personal data about you such as name, contact information, transaction information.
2. Why does InfraFund process my personal data? Which legal bases are we relying on for our collection and processing of your personal data?
Our primary purpose in collecting personal data is to provide our services in a secure, efficient, and smooth way. We generally use your personal data to deliver, provide, operate, our services, and for content and advertising, and for loss prevention and anti-fraud purposes. Below you’ll find an explanation on how we use Automated individual decision-making, including profiling. InfraFund does not rely solely on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk.
Why does InfraFund process my Personal Data? / Legal Basis for our use of personal data (EEA and Switzerland EU GDPR):
- Managing our contractual relationship with you. To create and maintain your account.
This includes when we use your personal data to take and handle orders and process payments.
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Contact Information, Financial Information. The consequences of not processing your personal data for such purposes is the inability to open an account with us or the termination of your account where one is already open.
Processing is necessary for the performance of a contract of which you are a party.
- To maintain legal and regulatory compliance
Most of our core services such as the exchange services are subject to strict and specific laws and regulations requiring us to collect, use and store certain personal data and process Personal Identification identity information and in some cases Sensitive Personal Data[(including biometrics) (as detailed in section I) For example to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and in particular to comply with Anti-Money Laundering laws and regulations.
The Category of Personal Data is Personal Identification Data , Institutional Information, Sensitive and Biometric information, Government Identifiers, Contact Information, Financial Information. If you do not provide personal information required by law, you may be unable to open an account, or we may have to close your account where it is already opened.
Processing is necessary to comply with our legal obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations.
Processing is necessary for reasons of substantial public interest based on EU or EU Member State law. We are subject to EU Anti-Money Laundering Directives and the relevant EU Member States' law implementing them which require us to process for instance information from your ID documents including a photographic picture of you and a visual image of your face (the so called "liveness check").
- Communicate with you on service and transaction- related matters.
We use your personal data to communicate with you in relation to InfraFund Services on administrative or account-related information. We will communicate with you to keep you updated about our Services for example, to inform you of relevant security issues, updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.
Processing is necessary for the performance of a contract of which you are a party.
- To provide customer services:
We process your personal data when you contact us in order to provide support with respect to questions, disputes, complaints, troubleshoot problems, etc.
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Communications, Contact Information, Financial Information, Browsing Information, Usage Data.
Without processing your personal data for this purpose, we can’t respond to your requests.
Processing is necessary for the performance of a contract of which you are a party.
Processing is necessary for the purpose of the legitimate interest pursued by us to improve our services and enhance our user experience.
- To promote safety, security, and integrity of our platform.
We process your personal data in order to enhance security, monitor and verify identity or service access, combat malware or security risks and to comply with applicable security laws and regulations.
We process your personal data to verify accounts and related activity, find and address violations of our Terms and Conditions, investigate suspicious activity, detect, prevent and combat unlawful behaviour, detect fraud, and maintain the integrity of our Services.
The Category of Personal Data processed is Personal Identification Information, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, Usage Data.
Without processing your personal information, we may not be able to ensure the security of our Services.
We use your personal data to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of InfraFund Services.
Processing is necessary for the performance of a contract of which you are a party.
- To promote safety, security, and integrity of our Services.
Fraud prevention and detection and credit risks.
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, Usage Data.
We process Personal Identification Data to prevent and detect, prevent and mitigate fraud and abuse of our services and in order to protect you against account compromise or funds loss and in order to ensure the security of our users, InfraFund services and others. We may also use scoring methods to assess and manage credit risks. Please note that we may engage in automated decision-making for purposes of risk and fraud detection. When we do, we implement suitable measures to safeguard your rights and freedoms and legitimate interests, including the right to obtain human intervention, to express your point of view and to contest the decision.Please refer below to Section 10 for more information.
Processing is necessary for the purpose of the legitimate interests pursued by us and the interests of our users when, for example, we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others;
- To provide InfraFund services.
We process your personal data to provide the services to you , process your orders, facilitate transactions and to complete the transactions the Users require. For example, when you want to use the exchange service on our platform, we ask for certain information such as your identification, contact information, and payment information.
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, Usage Data.
We cannot provide you with services without such information.
Processing is necessary for the performance of a contract of which you are a party.
Processing is necessary for the purpose of our legitimate interest and your interest in providing better documentation for your transactions.
-To use the services of social media platforms or advertising platforms for purposes including marketing
-The category of personal data processed is Usage Data, Browsing Information.
We rely on your consent to process your personal data to use the services of advertising platforms. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- To improve our services.
We process personal data to improve our services and for you to have a better user experience;
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Browsing Information, Usage Data.
Processing is necessary for the purpose of the legitimate interest pursued by us to improve our services and enhance our user experience.
- To provide you with promotions
We use your information to provide you with promotions, including offers, rewards, and other incentives for using our Services. This would also include to enable you to partake ina prize draw, competition or complete a survey.
The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Browsing Information, Usage Data and Online Identifiers.
For non-users, processing is necessary for the purpose of our legitimate interest and your interest to reward your customer loyalty.
For users, we rely on your consent to process your personal data to provide you with promotions. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- To do research and innovate.
We carry out surveys to learn more about your experience using our Services. We also use your information to support research and development and drive innovations of our Services and products. This information will also be used for Marketing purposes.
Processing is necessary for the purpose of our legitimate interest to improve and run our Services through information obtained from these surveys.
-For internal business purposes and record keeping.
The Category of Personal Data processed is Personal Identification Data, Financial Information, Transaction Information and Browsing Information.
Processing is necessary for the purpose of the legitimate interest pursued by us to keep records to ensure that you comply with your contractual obligations pursuant to the agreement (“Terms and Conditions”) governing our relationship with you.
Processing is necessary to comply with our legal obligations to keep certain records for internal business and research purposes as well as for record keeping purposes.
- Recommendations and personalisation.
We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalise your experience with InfraFund services;
Processing is necessary for the purpose of our legitimate interest to provide a personalised service to our customers.
Processing is necessary for the performance of a contract of which you are a party.
- To provide marketing communications to you.
We use your information based on your consent to send you targeted marketing communications through email, mobile, in-app, and push notifications.
We also use your information to carry out profiling for marketing purposes.
The Category of Personal Data processed is Personal Identification Information, Institutional Information, Transactional Information, Browsing Information, Usage Data, Marketing and Research Information, Communications.
Where required by applicable law, we rely on your consent to process your personal information for marketing purposes. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Where we carry out profiling for marketing purposes, for example to establish what Services or promotions you may be interested in, this processing is based on legitimate interest.
Transactional account messages and communications regarding our business relationship will not be affected even if you opt-out from marketing communications.
-Events
(i) To host, and/or organise and events.
InfraFund hosts many live, in-person events throughout the year. These include events like the Blockchain week, for example. If you register for one of our events and you are a user, we will access the information in your account to provide you with information and services associated with the event. You may be asked to provide more information when signing up for an event.
If you are not a user and you sign up for one of our events, we will collect the following information: name, email, company, title, industry, address, phone number, whether meal preferences, social media domain and the like.
(ii) in some cases you might pay to attend an Event. In such cases we will access the information in your account to provide you with information, services associated with the event and facilitating the ticketing process. You may be asked to provide more information when signing up for an event.
(iii) if you are a presenter at one of our events, we will collect information about you including your name, employer and Contact Information, and photograph, and we may also collect information provided by event attendees who evaluated your performance as a presenter. We may also make and store a recording of your voice and likeness in certain instances.
(iv) Some of our events are sponsored. InfraFund may provide an attendee list to sponsors, co-sponsors and exhibitors of our events. InfraFund may also allow sponsors, co-sponsors, exhibitors or other third parties relevant for the organisation of the event to send you material by mail once per sponsored event, in which case InfraFund engages a third-party mailing house and does not share your mailing address directly with the sponsor/exhibitor. If you do not wish to have your information included in an attendee list or to receive information from sponsors, co-sponsors and/or exhibitors, you can express your preferences when you register for events. We do give attendees a choice not to receive marketing messages from the sponsor or from InfraFund.
(iv) To provide you with information about the event(s) which you have registered, such as event updates and possible changes, cancellations or similar information.
(v) To fulfil and monitor our legal responsibilities for example under public safety legislations
(vi) In accordance with your preferences, to communicate with you about the other events, news and services we provide
(vii) To plan better future events and attendee experience.
Processing is necessary for the purpose of our legitimate interest to produce, organise and host events.
In the case where you pay to participate to an Event, the processing is necessary for the performance of a contract of which you are a party.
Processing is necessary for the purpose of our legitimate interest to promote the events, inform about the Event or to evaluate the performance of the Event.
We rely on your consent to process your personal data for marketing purposes. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Further details may be as follows:
When you decide to participate in an event or act as a presenter for the event, we rely on your consent to process your personal data for attendance to an event. When you consent to processing your personal data for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal data for that purpose. If you are a presenter at one of our events, we may also like to take photographs, and make and store a will collect recording of your voice and likeness in certain instances. In these situations InfraFund relies on a legitimate interest basis for collecting, storing and processing this personal data. When we organise events and work with sponsors, co-sponsors and exhibitors and send material, we rely on your consent to send you material about the event or direct marketing email. When you consent to processing your personal data for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal data for that purpose.
Cookies: where we use cookies and similar technologies as part of our Service. The Category of Personal Data processed is Information from Cookies.
Where required by applicable law, we rely on your consent to place cookies and similar technologies. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose.
The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal
To comply with other legal and regulatory obligations.
We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, government, and other legal requests, court orders, or disclosure to tax authorities in line with the detailed information set forth under Section 6.
The Category of Personal Data processed is Personal Identification Information, Institutional Information, Financial Information, Transactional Information, Browsing Information, Usage Data, Blockchain Data.
Processing is necessary to comply with our legal obligations under applicable laws and regulations
We may also rely on legitimate interests in responding to legal requests where we are not compelled by applicable law but have a good faith belief it is required by law in the relevant jurisdiction.
3. Can Children Use InfraFund Services?
InfraFund does not allow anyone under the age of 18 to use InfraFund Services and we do not knowingly request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any personal information to InfraFund Services.
If a User or Customer submitting personal information is suspected of being younger than 18 years of age, InfraFund will require the relevant Customer or User to close his or her account, and will take steps to delete the individual’s information as soon as possible.
4. What About Cookies and Other Identifiers?
We use cookies and similar tools to enhance your user experience, provide our services, enhance our marketing efforts and understand how customers use our services so we can make improvements. Depending on applicable laws in the region you are located in, the cookie banner on your browser will tell you how to accept or refuse cookies. A copy of our cookie policy is available here.
5. How and Why We Share your Personal Data?
We may share your Personal Data with third parties (including other InfraFund entities) if we believe that sharing your Personal Data is in accordance with, or required by, any contractual relationship with you (including InfraFund Terms & Conditions) or us, applicable law, regulation or legal process. When sharing your Personal Data with other InfraFund entities, we will use our best endeavours to ensure that such entities are either subject to this Privacy Notice, or follow practices at least as protective as those described in this Privacy Notice. For example, depending on where you reside and the entity responsible for running KYC checks. For more information please refer to Section 1.
We may also share personal data with the following persons or in the following circumstances:
Affiliates: Personal data that we process and collect may be transferred between InfraFund companies as a normal part of conducting business and offering our Services to you. See Section 1 “InfraFund Relationship with you” and Section 1. “What Personal Data does InfraFund collect and process?”.
Third parties: We employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. The third-party service providers only have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws. In accordance with and as far as provided by applicable law, your personal data may also be shared by third parties (i.e. another data controller) upon exercising your right to data portability. Please refer to Section 10 for more information on data portability. When you use third-party services (like when you connect your InfraFund account with your bank account) or websites that are linked through our Services, the providers of those services or products may receive information about you that InfraFund, you, or others share with them. Please note that when you use third-party services or InfraFund affiliate services which are not governed by this Privacy Policy, their own terms and privacy policies will govern your use of those services and products.
Legal Authorities: We may share your information with courts, law enforcement authorities, regulators, attorneys or other third parties: (a) to comply with laws and legal obligations; (b) for the establishment, exercise, or defence of a legal or equitable claim; (c) to respond to law enforcement and regulatory requests, including (1) when we are compelled to do so by a subpoena, court order, search or seizure warrant, or similar legal procedure, or (2) for international law enforcement requests, pursuant to a mutual legal assistance treaty (MLAT) or letters of request; (d) to comply with one or more forms of “travel rules” that require our transmitting of your information to another financial institution, regulatory authorities or other industry partners; (e) when we believe in good faith that the disclosure of personal information is necessary to protect the rights, property or safety of our customers, InfraFund, or others, including to prevent imminent physical harm or material financial loss; (f) to investigate violations of our Terms of Use or other applicable policies; or (g) to detect, investigate, prevent or address fraud or credit risk, other illegal activity or security and technical issues, to report suspected illegal activity or to assist law enforcement in the investigation of suspected illegal or wrongful activity.
Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). Also, in the unlikely event that InfraFund or substantially all of its assets are acquired by a third party, user information will be one of the transferred assets.
With your Consent: We also may disclose your Personal Data as may be described in a notice to you at the time the information is collected or before it is shared, or in any other manner to which you consent.
6. International transfers of Personal Information
To facilitate our global operations, InfraFund may transfer your personal information outside of the European Economic Area (“EEA”), UK and Switzerland. The EEA includes the European Union countries as well as Iceland, Liechtenstein, and Norway. Transfers outside of the EEA are sometimes referred to as “third country transfers”.
We may transfer your personal information to our Affiliates, third-party partners, and service providers based throughout the world. In cases where we intend to transfer personal information to third countries or international organisations outside of the EEA, InfraFund puts in place suitable technical, organizational and contractual safeguards (including Standard Contractual Clauses), to ensure that such transfer is carried out in compliance with applicable data protection rules.
We also rely on decisions from the European Commission where they recognise that certain countries and territories outside of the European Economic Area ensure an adequate level of protection for personal information. These decisions are referred to as “adequacy decisions”.
7. How Secure is My Information?
We design our systems with your security and privacy in mind. We have appropriate security measures in place to prevent your information being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We work to protect the security of your personal data during transmission and while stored by using encryption protocols and softwares. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
Our security procedures mean that we may ask you to verify your identity to protect you against unauthorised access to your account. We recommend using a unique password for your InfraFund account that is not utilized for other online accounts and to sign off when you finish using a shared computer.
8. What About Advertising?
In order for us to provide you with the best user experience, we may share your personal data with our marketing partners for the purposes of targeting, modelling, and/or analytics as well as marketing and advertising. You have a right to object at any time to processing of your personal data for direct marketing purposes (see Section 10 below).
9. What Rights Do I Have?
Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your personal data. You have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances. In addition, when you consent to our processing of your personal data for a specified purpose, you may withdraw your consent at any time. If you want to exercise any of your rights please contact us using the webform available here. These rights may be limited in some situations - for example, where we can demonstrate we have a legal requirement to process your personal data.
Right to access: you have the right to obtain confirmation that your personal data are processed and to obtain a copy of it as well as certain information related to its processing. Please follow the FAQ for further information on how to access your account statement yourself. You can also check your device and IP address login’s via the dedicated “Account Activity Records” page located here. Please note that you have to login to your account first to obtain access;
Right to rectify: you can request the rectification of your personal data which are inaccurate, and also add to it. You can also change your personal data in your account at any time.
Right to delete: you can, in some cases, have your personal data deleted. Please follow the FAQ for further self-help information on how you can request that your account is deleted yourself. Please note that personal data may still be retained in the event of account deletion to comply with our legal obligations.
Right to object: you can object, for reasons relating to your situation, to the processing of your personal data For instance, you have the right to object where we rely on legitimate interest or where we process your data for direct marketing purposes;
Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your personal data by us, provided there are valid grounds for doing so. We may continue to process your personal data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law;
Right to contest to a decision based solely on automated processing: You have the right to require that decisions be reconsidered if they are made solely by automated means, without human involvement; we use automated tools to make sure that you are eligible to be our customer taking into account our interests and legal obligations; if these automated tools indicate that you do not meet our acceptance criteria, we will not onboard you as our customer;
Right to portability: in some cases, you can ask to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, that we communicate your personal data on your behalf directly to another data controller;
Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter;
Right to lodge a complaint with the relevant data protection authority: We hope that we can satisfy any queries you may have about the way in which we process your personal data. However, if you have unresolved concerns, you also have the right to complain to the data protection authority in the location in which you live, work or believe a data protection breach has occurred.
If you have any questions or objection as to how we collect and process your personal data, please contact us using the webform available here.
10. How Long Does InfraFund Keep My Personal Data?
We keep your personal data to enable your continued use of InfraFund Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Notice, and as may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or to resolve disputes and/or legal claims or as otherwise communicated to you.
While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal data are described below.
Personal Identifiable Data collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as is required under such laws.
Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis and until you (a) unsubscribe, or we (b) delete your account. Thereafter we will add your details to an unsubscribed list to ensure we do not inadvertently market to you.
Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes.
Recording of voice calls with you may be kept for a period of up to six years, for audit/ compliance purposes and to resolve disputes and/or legal claims.
Information collected via cookies, web page counters and other analytics tools is kept for a period of up to one year from the date of the collection of the cookie of the relevant cookie.
11. Notices and Revisions
If you have any concerns about privacy at InfraFund, please contact us, and we will try to resolve it. You also have the right to contact your local Data Protection Authority.
Our business changes regularly, and our Privacy Notice may change also. You should check our websites frequently to see recent changes. We will update the “Last Updated” date accordingly at the beginning of this Privacy Notice. We will announce any material changes to this Privacy Notice on our Platform or by sending an email that you have provided under your account. Your continued use of InfraFund after the changes to this Privacy Notice means that you understand and agree to such changes.
Unless stated otherwise, our most recent Privacy Notice applies to all information that we have about you and your account.
12. Languages
This Privacy Policy may be published in different languages. In case of any discrepancy, this English version shall prevail.
13. Contact Information
Our data protection officer can be contacted using the webform available below, or via email and will work to address any questions or issues that you have with respect to the collection and processing of your personal data.
If you have a question about your account management, or InfraFund products or services the Data Protection Officer will not be able to assist you. In that case, please contact our Customer Support team using the following link.