In force from 21/09/20
Infinex Partners Limited (“Infinex”) is committed to protecting and respecting your privacy. We want to tell you how we use and protect your personal information. This includes informing you of your rights regarding your personal information that we hold.
This Privacy Notice sets out how we may use, process and store your personal information. We may get that information from you or our partners, through contracts or other legal arrangements you have with us or our partners on behalf of us in order to deliver contractual/legal obligations. In other cases, we will get that information from you with your permission and consent, or we may receive your personal information from third parties who you have given consent to pass this information on to us.
The Laws and Regulations
The laws that govern personal data in the IOM are:
The Data Protection Act 2002
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”).
The independent authority that upholds information rights in the public interest in the Isle of Man is the Isle of Man Information Commissioner. Further information can be found at https://www.inforights.im/
Who is Infinex Partners Limited?
This is Infinex’s trading address, company number and contact information:
Infinex Partners Limited
34 North Quay
Isle of Man
Company Registration Number: 133522C
Phone: +44 (0) 1624 604270
Infinex’s Website: https://www.infinexpartners.com
Information we may collect from you
Infinex collects personal information about you whenever you use our services. Some of it is information you give us directly when, for example, you email us. Other information is collected as you interact with us, such as online chats with our customer services team.
Information we may collect from your device
We collect information from the devices you use to receive Infinex’s content, products and services. This includes, but is not limited to the following: your IP address (a number that identifies a specific device on the internet and is required for your device to communicate with websites), hardware model, operating system and version, software, preferred language, serial numbers, mobile network information and location data.
Information you give us
You may give us information about you with your consent, for example:
· By filling in a form or sending us an e-mail
· Applying for a job at Infinex
This information may be personal, financial, educational, or related to your employment history.
Why does Infinex collect personal information?
Infinex collects information for some or all of the following reasons:
· To provide services to you after you have registered an account
· To employ you or consider you for employment
· For legal or regulatory reasons, for example, if you have entered into a contract with us
· Things we do with your consent for marketing purposes
What legal basis does Infinex have for processing my information?
Infinex may process your information because:
· We have a contract with you
· You have given us permission to do so
· We must provide services to you after you have registered an account
· To comply with the law.
All of these reasons are reasons Infinex may legally process the information we have about you.
Who might Infinex share your information with?
We share your personal information with external organisations that carry out a range of services on behalf of Infinex. We carry out checks to ensure that the companies we work with will give your information the same level of care and protection as we do. Both we and they are obliged to handle your information in accordance with data protection law, and we are also required to put in place contractual measures reinforcing those obligations.
The main functions that are or may be carried out, fully or in part, by third parties are listed below:
· Account set-up and registration
· Management and execution of marketing campaigns
· Customer services
· Payment processing and verification
· Anti-fraud and -money laundering checks and ID verification
· Checks to detect unfair use of our products and services
· Web hosting, online content services and data storage
· Management of competitions, contests and offers
· Data analytics and data cleansing
· Market research and collecting or analysing customer feedback
· IT services and support
· Audit-, Legal- & Compliance- related services
Where we store your personal data
We primarily store and process your personal data in the Isle of Man. If we do transfer your personal data outside the EEA it will be because you have consented or because we have a legal reason to do so.
Some examples of reasons your data may be processed outside of the EEA include:
· Services fulfilment
· Verification processing
· Payment processing
· Technical support services.
If your personal data cannot be processed within the EEA, we will:
· Comply with all other data protection principles
· Where possible, be to a country that is on the list of the EU Commissions’ countries that provide adequate protection for the rights and freedoms of data subjects
· If the transfer is to the United States of America, we will use reasonable endeavours to make sure they participate in the Privacy Shield program
· Make sure we have assessed the adequacy of protections in all other cases.
Access to your stored personal data via password
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Transmission and storage of your personal data
Unfortunately, the transmission of information via the internet is not completely secure. Although we use best practice to ensure your data is encrypted to the standard required in the GDPR to protect your personal data, we cannot guarantee the security of your data as it is transmitted and stored.
How long will you keep my personal information?
Infinex will not retain your personal information for longer than required. We will keep your personal information:
· For as long as required by law
· Until we no longer have a valid reason for keeping it
· Until you request us to stop using it.
· We may keep just enough of your personal information to ensure that we comply with your requests to not use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until such time as you are no longer our customer.
If you have questions about our Data Retention Policy, we can provide you with a copy. Please contact: email@example.com
What if I chose not to give you my personal information?
If the personal information is necessary in order to supply services to you under a contract between you and Infinex, then we will not enter into that contract or provide the services if you do not give us your personal information.
Infinex will respect your legal rights to your data.
Below are the rights that you have under law, and what Infinex does to protect those rights:
The right to be informed - Infinex is publishing this Privacy Notice to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data.
The right to access - You have the right to access your information. Please email Infinex’s Data Protection Officer at firstname.lastname@example.org if you wish to request a Subject Access Request which shows all information Infinex holds about you. This information will be provided to you within 30 days of your request.
The right to rectification - If the information Infinex holds about you is inaccurate or not complete, you have the right to ask Us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact our Data Protection Officer if you need us to rectify your information: email@example.com
The right to erasure - This is sometimes called ‘the right to be forgotten’. If you want Infinex to erase all your personal data and we do not have a legal reason to continue to process and hold it, please contact our Data Protection Officer: firstname.lastname@example.org
The right to restrict processing - You have the right to ask Infinex to restrict how we process your data. This means We are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. If you want us to restrict the processing of your data, please contact our Data Protection Officer: email@example.com
The right to data portability - Infinex must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this affecting the usability of your data. Please contact our Data Protection Officer if you want information on how to port your data elsewhere: firstname.lastname@example.org. This right only applies to personal data that you have provided to Us as the Data Controller. The data must be held by Us by consent or for the performance of a contract.
The right to object - You have the right to object to Infinex processing your data even if it is based on Our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purposeless of statistics. If you wish to object please contact our Data Protection Officer: email@example.com
The right to withdraw consent - If you have given Us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and Infinex must stop processing your data. If you want to withdraw your consent, please contact our Data Protection Officer: firstname.lastname@example.org
The right to complain to a Supervisory Authority - You have the right to complain to the ICO if you feel that Infinex has not responded to your requests to solve a problem. You can find their contact details here: https://www.inforights.im/
Links to Other Websites
From time to time, our website may contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites may have their own privacy notices and that we do not accept any responsibility or liability for any such notices. Please check these notices, where available, before you submit any personal data to these websites.
Changes to Our Privacy Notice
Infinex may change this notice from time to time in the future. Any such changes will be posted here and, where appropriate, notified to you in writing. We advise you to check back frequently to see any updates or changes.
This notice was last updated in September 2020.