This Privacy Policy shall be effective starting on May 25th, 2018.

Last updated: 27.07.2018

Infinito Solutions Pte Ltd. is a private limited company incorporated in Singapore with the company number 201900666E and the registered office in 80 Robinson Road, #08-01, Singapore 068898. Infinito Solutions Pte Ltd., formally known as Infinito Solutions, aims to create a perfect blockchain experience for users, applications, and developers through its product Ecosystem which includes Infinito Wallet, Infinito App Square, Infinito Blockchain Platform, and InfinitoPAY.

Infinito Solutions Pte Ltd. (“Infinito Solutions”, “us”, “we”, and “our”) issues Infinito Wallet (“IW”, “our Product”, “our Services”) and operates https://www.infinitowallet.io/ (“the Website”, “our Website”). This Privacy Policy informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of our website and our product. We are committed to respect and protect our clients and visitors’ privacy so your personal information will never be compromised or monetized.

Please take a moment to carefully and thoroughly read this updated Privacy Policy. If you have any questions about this new policy, please feel free to contact us at [email protected] zendesk.com.

ACCEPTANCE OF PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. Infinito Solutions. may provide additional "just-in-time" disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may supplement or clarify Infinito Solutions. ’s privacy practices or may provide you with additional choices for how Infinito Solutions processes your data.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue your access/use of our Services.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Services prior to the change becoming effective.

FULL PRIVACY POLICY

This Privacy Policy applies to all websites and web applications which link to this policy and are published by Infinito Solutions Pte Ltd., 80 Robinson Road, #08-01, Singapore 068898. The Website may contain links to other websites for your convenience and information. We are not responsible for the privacy practices or the content of those sites. If you wish to amend any of the personal information that we hold about you, or update your marketing preferences, you can do so at any time through your account. If you have any queries about how we use your personal information, please contact us at [email protected]

INFORMATION WE COLLECT

This section details the information we may collect about you. We explain why and how we use it in later sections.

ACCOUNT INFORMATION If you decide to create an account or inquire about one of our products or services, we’ll ask you to provide us with some specific information, for example:

• Basic personal details – such as your first name and last name;

• Personal details – such as address, and proof of residency, phone number, mobile phone number, and email address;

• Work details – such as job title, department, company name, company address, work email address and office phone number;

• Log in details – such as username and password;

• Payment details – such as your billing address and credit card information.

• Passport and KYC contact details: Such as Passport, Proof of Residency, Selfie /Photo Verification

ADDITIONAL INFORMATION

On occasion, we will ask you to voluntarily provide additional information, for example:

• Your opinion of our products and services;

• Your preferences, including newsletters or web alert topics;

• Information we obtain from partners and public sources;

In some circumstances, we collect information about you from our partners or from publicly available websites to help us better understand our audience and enhance the relevance of our content.

COOKIES Our website uses technology to collect information about its use, to distinguish between users, to help us provide you with a good experience and to allow us to improve the site and the service we offer. This means that when you visit our website, cookies or similar technologies will be placed on your computer or other device.

For more information, please see our Cookie Policy (Insert link to Cookie Policy).

LAWFUL BASIS FOR PROCESSING

We only process personal information where we have a lawful basis for doing so, such as the following:

• User consent – This is where you have given us explicit permission to process personal information for a given purpose. For example, if you requested to receive information about a particular product and service, we would ask for your consent if we wanted to use your personal information for any other purpose. You have the right to withdraw this consent at any time. You can manage your preferences within your account or by contacting customer service.

• Legitimate business purposes– This is where we have a legitimate interest, as a business, to process personal information. For example, where we are aware of copyright infringements on our Site, it is in our legitimate interests as a business to identify those responsible. We take due care to balance our interests against your right to privacy.

• Contractual necessityThis is where we have to process personal information to meet our contractual obligations.

• Legal obligation– This is where we must process personal information in compliance with the law. For example, we process and retain customer invoice information to comply with financial regulations.





HOW WE USE YOUR PERSONAL INFORMATION

• We collect personal information for eight main reasons:

• To provide our service– We require some of your basic personal information so our services work as you would expect, for example, providing access to our digital content, notifying you of changes to our services and dealing with customer services queries.

• To improve and maintain performance– In order to provide you with the best possible user experience, we need to make sure that our products and services work as they should. Using personal information helps us understand how our readers use our Sites so we can make improvements. This includes testing proposed developments on our Sites, reaching out to our customers with market research surveys and hosting subscriber focus groups.

• To bill our customers– We, along with our authorized payments processors, securely process your payment information to take payments, give refunds and to detect and prevent fraudulent activity.

• To monitor compliance with our policies and terms– We monitor for breaches of our terms and conditions and copyright policies.

• To personalize our products and services – We improve your experience of our products and services by personalizing parts of our Sites and apps with the information you give us and what we learn about you. This includes showing you articles you may be interested in and recommending emails you may wish to sign up to. Where our Sites have such functionality, you can manage elements of personalization in your account.

• To communicate product changes and offers– We want you to get the most out of our products and services, including showcasing our latest content and newsletters. We will contact you with carefully-curated Infinito Solutions offers and promotions, exclusive event invitations and feature announcements. For example, if there are no updates on topics you follow in your web alerts, we will send you articles on other topics that we think you might be interested in. You are able to change your preferences at any time through your account or by contacting customer services. We also personalize our communications for strategic purposes.

• To understand our users– We perform statistical, demographic and marketing analyses of Site users and their purchasing patterns for product development purposes. Infinito Solution uses this information for analysis purposes, including analysis to improve customer relationships.

• For the purposes of advertising– We rely on advertising revenue in part to support our journalism. We need to process your information to understand the effectiveness of the advertising we serve to you and others, and to deliver relevant personalized advertising. We use the information you give us and the information we collect about you to serve you with the most appropriate advertisements.





WHO WE SHARE YOUR PERSONAL INFORMATION WITH

• We disclose personal information to facilitate the running of our business or to provide specific services you have requested. Commonly, we will disclose information to:

• Service providers – We engage service providers who help to support our business and improve our products. These service providers include, for example, fulfilment providers for delivery of our digital content and marketing; customer service agencies; organizations that host our Sites or databases; and providers of online surveys.

• Advertisers – We, and our advertising partners, use cookies to collect personal information and serve you with advertisements that we believe are relevant to you and your interests. There is more specific information about our advertising partners and data sharing in our Cookie Policy.

• Social media providers – We share the information of our subscribers with social media partners for the following reasons:

• To create lookalike audiences - For the purposes of targeted advertising on social media platforms

• Other users – Our Sites are publicly accessible and anyone around the world who accesses our Sites will be able to see anything you post, such as comments about an article. We encourage you to use a pseudonym when commenting on our Sites if you do not wish to be identifiable to other readers.

• Legal processes and successors in title – We may transfer or disclose your personal information to any entity which takes over or acquires the relevant Infinito Solutions business. We also share aggregated, non-identifiable information with third parties. Before sharing this information, we ensure that it cannot identify you as an individual. For example, we regularly release information about the size and growth of our audiences.

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We retain the majority of your personal information for as long as your account is active and therefore open; this allows you to continue accessing our content, products and services.

If you become inactive and are not a subscriber, we may delete elements of the information associated with your account. We will normally warn you if your access is going to be withdrawn and give you the opportunity to retain your account.

Where we don’t need to keep all of your information in full, we will obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that we do not retain your information for any longer than is necessary. It is sometimes necessary for us to keep your personal information for longer periods of time, for example:

• If there is a statutory requirement to retain it;

• If we require the information for legal reasons or there is a legitimate business need for us to retain it;

• To ensure we do not contact you if you have asked us not to.

HOW WE KEEP YOUR PERSONAL INFORMATION SECURE

We have appropriate technical and administrative security measures in place to help ensure that our users’ information is protected against unauthorized or accidental access, use, alteration, or loss. We use encryption technology, such as Transport Layer Security (TLS), to protect your personal information when you order products or services from us. More information about our approach to cyber security can be found in our Cyber Security Statement.

Since we operate a global business, your personal information may be processed and stored outside of the EU. For example, our global customer services team may need to access information about you in order to respond to your queries. Such transfers of data are undertaken in accordance with applicable laws and regulatory obligations.

Additionally, we may use international web hosting facilities and cloud server services. In all cases, we will ensure your personal information is maintained with the tightest security standards available.

YOUR RIGHTS

Under EU data protection laws, you have rights as an individual in relation to the personal data we hold about you. These rights include:

• The right to object to direct marketing – your preferences, including in relation to direct marketing, can be found in your account;

• The right to access the personal data that we process about you;Upon request, we will provide you with a copy of all the personal data we have on you.

• The right to request the deletion of your personal data - Upon request, we will delete all of your personal data stored on our servers. Please be aware that given the immutable nature of blockchain technology, we may not be able to fully delete every piece of personally identifiable information (such as public keys, transaction records, etc.). However, we will do everything possible to fully comply with every request, and we will design future products with the right to deletion in mind.

• The right to request the rectification of your personal data – you can manage some of this information in your account. For everything else, please contact us.

You can exercise these rights through your account or by contacting customer services.

These rights to not extend to processing and collection of personal data by journalists or for journalistic purposes.

WHERE THIS PRIVACY POLICY APPLIES

Personal information is collected by Infinito Solutions Pte Ltd. which is considered the “data controller” of your personal information under European Union and UK data protection law. Our address is 80 Robinson Road, #08-01, Singapore 068898.

Our Sites are not intended for children under 16 years of age. We do not intentionally collect or use any information from children.

Our Sites may contain links to third party websites which are not subject to this privacy policy. We are not responsible for their content, use of personal information, or security practices.

If you have any queries in regards to the processing of your personal information, please contact customer service directly at [email protected]

Infinito Solutions Pte Ltd.

Registered Office: 80 Robinson Road, #08-01, Singapore 068898.

Changes to this Privacy Policy

Any changes we may make to this privacy policy will be posted on this page. If changes are significant, we may choose to notify you by email or to clearly indicate on our home page that the policy has been updated.

This policy is effective from May 25, 2018.