1. INTRODUCTION

This General Infinity Stones Privacy Policy (also referred to as the ‘Privacy Policy’) provides information on the collection, use, sharing and processing of personal information by Infinity Stones  and its affiliates (“Infinity Stones”, “we” or “us”) in connection with your use of Infinity Stones websites, mobile applications, and social media pages that link to this Privacy Policy, your interactions with Infinity Stones during in-person meetings or at Infinity Stones events, and in the context of other offline sales and marketing activities. This Privacy Policy also explains the choices you have in relation to these processing activities.

This Privacy Policy was last updated on October 8th, 2018. However, the Privacy Policy can change over time, for example, to comply with legal requirements or to meet changing business needs. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example via a pop-up notice or statement of changes on our website).

As used in this Privacy Policy, ‘personal information’ or ‘personal data’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, business contact details, or information gathered through your interactions with us via our websites or at events. Personal information is also referred to as information about you.

2. SCOPE

This Privacy Policy applies to the processing of personal information by Infinity Stones of:

  • visitors and users of the various Infinity Stones sites, including our websites on infinitystons.io, computer or mobile software applications and our social media pages that link to this Privacy Policy (collectively referred to as the sites);
  • attendees of Infinity Stones events;
  • customers and prospective customers and their representatives;
  • suppliers and business partners and their representatives.

When interacting with our websites, you also have the ability to link or connect with non-Infinity Stones websites, social media networks, applications or other features. Enabling these features will lead to other parties than Infinity Stones processing information about you. Infinity Stones does not have any control over these features of other parties. We encourage you to review the privacy policies of these parties before using these features.

3. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

Infinity Stones and its affiliated entities are responsible for processing your personal information described in this Privacy Policy.

4. WHICH TYPES OF PERSONAL INFORMATION DO WE PROCESS AND FROM WHICH SOURCES?

Infinity Stones can process information about you collected both offline and online.

  • Offline information about you originates from our interactions with you during in-person meetings or at Infinity Stones events, conferences, workshops or gatherings;
  • Online information about you originates from your activities on our sites, for example, in relation with your Infinity Stones accounts, (pre-)sales inquiries or subscription to our sites, or from your interactions with Infinity Stones via electronic communication tools such as email or telephone. Information about you may also be provided by third-party sources, such as data aggregators who may not have a relationship with you. Online information about you may also originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our sites or sites of third parties.

Information about you that Infinity Stones may be collect and process include:

  • name and physical address, email addresses, and telephone numbers;
  • demographic attributes, when tied to personal information that identifies you;
  • photographs and testimonials;
  • transactional data, including products and services ordered, financial details and payment methods;
  • company data such as the name, size, and location of the company you work for and your role within the company;
  • data from surveys and publicly available information, such as social media posts;
  • unique IDs such as your mobile device identifier or cookie ID on your browser;
  • IP address and information that may be derived from IP address, such as geographic location;
  • information about a device you use, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, and the preferred language;
  • behavioral data of the internet connected computer or device you use when interacting with the sites, such as advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a site.

Please note that Infinity Stones does not control the content that you may post to Infinity Stones social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit personal information to these social networks and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.

5. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?

We may use personal information for the following purposes:

  • to communicate and respond to your requests and inquiries to Infinity Stones;
  • to deliver functionality on our sites and for their technical and functional management;
  • to market our products and services or related products and services, and to tailor our marketing and sales activities to your or your company’s interests;
  • to engage in transactions with customers, suppliers and business partners and to process orders for Infinity Stones products and services;
  • to analyze, develop, improve and optimize the use, function, and performance of our sites and products and services;
  • to manage the security of our sites, networks, and systems;
  • to comply with applicable laws and regulations and to operate our business;

These purposes are described below in further detail.

To communicate and respond to your requests and inquiries to Infinity Stones

If you get in touch with us (such as by submitting contact forms on our sites, attending Infinity Stones events or other occasions, sending an email or by visiting social media platforms), we process information about you to communicate with you and to respond to your requests or other inquiries. We can also process personal information to interact with you on third-party social networks.

To deliver functionality on our sites and for their technical and functional management

When you choose to register with us (such as to make use of our communities), we need to process the personal information provided by you so that we can create and manage a personal account for you. Upon creating your account, we will send you your personal login information. This personal information enables us to administer your account, for example by changing your password for you.

To market our products and services or related products and services and to tailor marketing and sales activities

Infinity Stones may use information about you to notify you about new product releases and service developments, events, alerts, updates, prices, terms, special offers and associated campaigns and promotions (including via newsletters). Infinity Stones may also use personal information to advertise Infinity Stones’ products and services or related products and services, and also to have our distributors, resellers or partners notify you about our products or services or their related products or services (such as via joint sales or product promotions). We do our best to tailor your website visit, marketing experience and our communications to your expressed interests.

If you attend an event, Infinity Stones may process information about you gathered in relation to the event and can share information about your attendance with your company. Infinity Stones may also permit designated event partners or conference sponsors to send you up to two communications related to your event attendance. Please note that our partners or conference sponsors may directly request information about you at their conference booths or presentations, and their use of your information that you provide to them will be subject to their privacy policies.

We may also process your personal information to post testimonials on our sites, but will first obtain your consent to use your name and testimonial.

To analyze, develop, improve and optimize the use, function, and performance of our sites and products and services

We may process personal information in order to analyze, develop, improve and optimize the use, function, and performance of our sites and products and services. In case the sites permit you to participate in interactive discussions, create a profile, post comments, opportunities or other content, or communicate directly with another user or otherwise engage in networking activities, Infinity Stones may process personal information when moderating these activities.

To manage the security of our sites, networks, and systems

We may collect site usage data for security and operations management to help keep our sites, networks, and systems secure, or to investigate and prevent potential fraud, including ad fraud and cyber-attacks and to detect bots.

To comply with applicable laws and regulations and to operate our business

In some cases, we have to process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the performance and operation of our business, such as to conduct internal audits and investigations or for finance and accounting and archiving and insurance purposes.

6. WHAT IS OUR BASIS FOR PROCESSING INFORMATION ABOUT YOU?

For personal information collected about you in the EU, our basis for processing is the following:

  • In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing this information.
  • In order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you.
  • We process personal information for marketing and sales activities based on your consent where so indicated on our sites at the time your personal information was collected, or further to our legitimate interest to market and promote our products and services.
  • We rely on our legitimate interest to analyze, develop, improve and optimize our sites, products, and services, and to maintain the security of our sites, networks and systems.
  • In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.

7. FOR WHAT PERIOD DO WE RETAIN PERSONAL INFORMATION

Infinity Stones maintains personal information for the following retention periods:

  • Information about you we collect to engage in transactions with our customers, suppliers and business partners, and to process purchases of our products and services, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.
  • If you have registered for an Infinity Stones account, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for 18 consecutive months. Infinity Stones retains records of that deletion for 90 days.
  • If you have registered for our newsletters and blogs, your subscription data will be retained for as long as you are subscribed to our distribution lists. Infinity Stones retains records of that deletion for 30 days.
  • Contact information such as your email address or phone number collected online on our sites or offline from our interactions with you at Infinity Stones events and workshops, and used for direct marketing and sales activities will be retained for as long as we have an active (customer) relationship with you. We treat you as an active contact if (i) you have interacted with Infinity Stones or updated your contact details and preferences in the past 18 months; and (ii) you have not made a deletion request.
  • Personal information needed to retain your opt-out preferences is retained for 20 years (or longer as necessary to comply with applicable law).

8. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?

Sharing within Infinity Stones

As a business with global reach, information about you may be shared globally throughout Infinity Stones’ worldwide offices.

Infinity Stones employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Sharing with third parties

We may share personal information with the following third parties:

  • Third-party service providers (for example, credit card processing services, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on behalf of Infinity Stones;
  • Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
  • As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.

9. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?

Infinity Stones is a company with global reach in the Blockchain industry. If personal information is transferred to an Infinity Stones recipient in a country that does not provide an adequate level of protection for personal information, Infinity Stones will take measures designed to adequately protect information about you, such as ensuring that such transfers are subject to the terms of the EU Model Clauses.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Infinity Stones is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission and commits to cooperate with EU data protection authorities.

10. HOW IS YOUR PERSONAL INFORMATION SECURED?

Infinity Stones has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.

11. WHAT COOKIES AND SIMILAR TECHNOLOGIES DO WE USE ON OUR SITES?

Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Infinity Stones and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in Section 5 above.

When do we use cookies and similar technologies?

Cookies are small text files that contain a string of characters and uniquely identify a browser on a device connected to the Internet. Any browser visiting our sites will receive cookies from us. We also place cookies in your browser when you visit non-Infinity Stones sites that host our plugins or tags. We use cookies and other technologies on all our sites to ensure the best possible and secure experience on our sites and to provide you with tailored information on products and services. Infinity Stones also uses cookies or similar technologies on its sites to collect online information such as your mobile device ID, IP address, and other information about your device, as well as behavioral data of your device usage on our sites (e.g. pages viewed, links clicked, documents downloaded).

If you do not want to receive cookies, you can change your browser settings on your computer or other device you are using to access our services. Most browsers also provide functionality that lets you review and erase cookies, including Infinity Stones cookies.

12. WHAT ARE YOUR CHOICES?

We provide multiple choices in respect of the information we process about you:

  • Opt-out of our use of your personal information
    You may withdraw consent you have previously provided for the processing of information about you, including for email marketing by Infinity Stones.
  • Delete personal information
    You can ask us to erase or delete all or some of the information about you.
  • Change or correct personal information
    You can edit some of the information about you by. You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate.
  • Object to, or limit or restrict use of personal information
    You can ask us to stop using all or some of the information about you (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if the information about you is inaccurate).
  • Right to access and/or have your information provided to you
    You can also ask us for a copy of information about you and can ask for a copy of information about you provided in machine-readable form if you reside in the EU or other countries that provide you this right as a matter of law.

13. DO YOU COLLECT SENSITIVE INFORMATION AND INFORMATION FROM CHILDREN?

Sensitive personal information

We ask that you do not send us, and do not share any sensitive personal information (for example, government-issued IDs, information related to the racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).

Children’s privacy

As a company focused on serving the needs of businesses, Infinity Stones’ sites are not directed to minors and Infinity Stones does not promote or market its services to minors, except in very limited circumstances as part of specific educational outreach programs with parental permission. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our sites without appropriate consent, please notify us so that we may immediately delete the information from our servers and make any other necessary corrections. Please note that such requests may not ensure complete or comprehensive removal of the content or information, as, for example, some of the content may have been reposted by another user.

14. HOW TO CONTACT INFINITY STONES IF YOU HAVE QUESTIONS, COMMENTS OR COMPLAINTS?

Please email us at: contact@infinitystones.io

15. DISPUTE RESOLUTION OR FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law.