Infloww.com
Privacy Policy

INFINNI is committed to protecting your privacy. This Privacy Policy applies to the personal data
we collect and process in the course of our business. INFINNI acts in different ways when
processing data:
(i) INFINNI acts as a controller of your personal data when you sign up for our products and
services, visit our websites or interact with us through other channels (for example in person
events). We use this data for a variety of purposes, including to provide our products and services
to you, contact you about relevant content, and improve and promote our products and services.
(ii) INFINNI acts as a processor when our customers use our products and services to collect and
process personal data in connection with their sales and other business activities. In this case,
we act as a processor (or service provider) on behalf of our customers (who are controllers of
personal data) under the INFINNI Data Processing Agreement
For the purposes of this Privacy Policy "Personal Data" means any information relating to an
identified or identifiable individual. This Privacy Policy describes your choices and rights with
respect to your Personal Data, including your rights of access and correction.
(i) For information about how to exercise your privacy rights when INFINNI acts as a controller of
personal data, please see the “Your Privacy Rights and Choices” section.
(iii) If you wish to exercise your privacy rights regarding Personal Data we process on behalf of a
customer, please refer to the customer policies and contact the customer directly.
We update this Privacy Policy from time to time and encourage you to review this Privacy Policy
periodically. We will post any Privacy Policy changes on this page and, if the changes are material,
notify you directly (for example, by sending you an email notification). Terms not otherwise defined
in this Privacy Policy have the meaning given to them in the INFLOWW Terms of Service.

1. What Information We Collect and Process
2. How We Use Personal Data
3. How We Share Personal Data
4. How We Transfer Personal Data Internationally
5. How We Store and Secure Personal Data
6. Cookies
7. Your Privacy Rights and Choices
8. Other Important Privacy Information
9. Contact Us

1. WHAT INFORMATION WE COLLECT AND PROCESS
1.1 Information You Provide to INFINNI.
When you interact with us, including via our websites or any sites or services that link to this
Privacy Policy (such as infinni.io, infloww.com, etc.), with our representatives, at events, or when
you use the Subscription Service, we may collect Personal Data and other information from you,
as further described below.
1.1.1 When You Visit Our Websites. We collect Personal Data from you when you submit web
forms or interact with our websites, for example creating an INFLOWW account, booking a demo
or interacting with our support chatbot. We may ask for your email address, first and last name,
and other similar business information. You are free to explore some of our websites without
providing any Personal Data about yourself.
1.1.2 INFINNI Events. When you register for any INFINNI event, we collect information such as
name and email address. We use this information to communicate with you and in some cases
facilitate your registration. Additionally, we may share your registration data with third party
service providers in order to provide event information and improve your experience at the event
or future INFINNI events. Please see the events’ registration terms and conditions for additional
information.
1.1.3 Account and User Information. We collect Personal Data when you sign-up for an
INFLOWW account, create or modify user information, set preferences, or provide any other
related information to access or utilize our Subscription Service.
1.1.4 Payment Information. We collect payment and billing information when you register for or
purchase paid products or services. For example, we may ask you to provide a billing address,
or a billing contact for your INFLOWW account. If you give us payment information, we use it
solely as authorized by you in accordance with this Privacy Policy. We use secure third-party
payment service providers to process personal and financial data.
1.2 Information We Process on Behalf of Customers When They Use the Subscription Service.
Our product, or the Subscription Service, is a Customer Relationship Management (CRM)
platform that allows our customers to manage and centralize their operations across multiple
platforms. When customers use our product, they may process Personal Data such as first and
last name, email address, phone number, or other information about you. We call the information
that our customers submit or collect via the product ‘Customer Data’ under our Terms of Service.
We generally store and process information about and on behalf of our customers on our servers
as a processor (or service provider) based on a customer’s instructions and in accordance with
our Terms of Service. Each customer controls and is responsible for the information they process
using the Subscription Service and for complying with any regulations or laws that require

providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to
INFINNI for processing purposes.
If you have questions about the Personal Data we process on behalf of a customer, please contact
the customer directly and refer to their policies.
1.3 Information We Collect and Process When You Use the Subscription Service.
1.3.1 Usage Data.
We collect usage data when you or your users in your INFLOWW account interact with the
Subscription Service. Usage data includes metrics and information regarding your use and
interaction with the Subscription Service such as what product features you use the most, when
an object (like a ticket) is opened and closed, and how often certain features are triggered in your
account.
1.3.2 Log Files.
Like most websites and technology services delivered over the Internet, we automatically collect
and store information about your computer hardware and software when you visit our websites,
use our product and services, or visit other sites or services that link to this Privacy Policy. This
information can include your IP address, browser type, domain names, and the files viewed on
our websites (e.g., HTML pages, graphics, etc.), your operating system, access times and
referring website addresses.
1.3.3 Third Party Integrations. You may connect third party integrations to your INFLOWW
account, which may ask for certain permissions to access data or send information to your
INFLOWW account. It is your responsibility to review any third party integrations you authorize.
We may collect information about what types of integrations you use in your INFLOWW account.
Any permission(s) granted by you, grants these third parties access to your data, which may
include (but is not limited to) granting third party applications access to view, store, and modify
your INFLOWW account data. We are not responsible for the practices of third party integrations,
so please carefully review the permissions you grant to third party applications.
1.4 Information We Collect From Other Sources.
INFINNI does not collect data from other sources.
2. HOW WE USE PERSONAL DATA
2.1 To Communicate with You About the Product and Services.
We use the account information you provide to INFINNI when signing up for our products and
services, to send you transactional emails or in-app notification about billing, account
management, and other administrative matters.

We also use your information to recommend new products and services and to provide customer
support, such as resolving technical issues you encounter and analyzing product outages or bugs.
2.2 To Provide the Subscription Service.
We use your account information and Customer Data to provide the product and services to you.
For example, we use the email address you provide when signing up for the product to create
your user account, and we use your payment information to process payments for the
Subscription Service. We also use this information to authenticate you when you log in and to
provide customer support.
2.3 To Improve and Develop Our Communication, Product and Services.
We use the information you provide us, professional data, log files, and usage data about how
you or your users interact with our product and services to develop and improve our products,
services, and communications. For example, we use usage data to assess trends and usage
across the product to help us determine what new features or integrations our users may be
interested in.
We may publish data about how our product and services are being used across our customer
base. When we share statistical information externally in this way, the data will be aggregated
and we will not identify individual users or customers. For example, we may publish blog posts
on trends or insights into how users are interacting with our product.
2.4 To Secure and Protect our Product and INFLOWW Users.
We use your account information to investigate and help prevent security incidents. We may also
use this information to meet legal requirements. We use your information to verify user accounts,
new product sign-ups, and to detect and prevent product abuse.
We use log files to provide general statistics regarding use of the websites by you, including how
you use our websites, what country you are logging in from (for analytics, export control and
regulatory purposes) and to help improve the navigation experience. Your IP addresses are also
collected and logged for security and debugging purposes, for example to track access patterns,
investigate security events and incidents. For these purposes we associate automatically-
collected data to other personal data provided by you such as name, email address, address, and
phone number.
2.5 To Market and Promote the Subscription Service.
We use Personal Data to advertise, market, and promote our products, services, and other
offerings. For example, we use information like your email to send information or INFINNI content
to you we think may be of interest to you. We may also send you marketing communications and
surveys relating to our business with your explicit consent.

When we send you marketing communications, we may use tracking technologies (such as
tracking pixels and tracked links) to detect whether you have opened our emails and whether you
have clicked on the links they contain. We use this information to measure engagement, assess
the effectiveness of our campaigns, and make our future communications more relevant to you.
Where required by law, we will only use these tracking technologies with your consent, which you
can withdraw at any time.
You may opt out of receiving this promotional content by following the instructions contained in
each communication that we send to you. If you unsubscribe from our marketing lists, we will
continue to contact you regarding administrative matters, and to respond to your requests.
We may reach out to you via telephone to ask about other INFINNI products or services you may
be interested in. If you have a call scheduled with an INFINNI representative, we may record and
transcribe the call. You will be notified at the beginning of the call that the call is being recorded,
and you will be offered an opportunity to opt-out of having the call recorded. We may also reach
out to you via WhatsApp or Telegram.
Where required by law, we will only send marketing communications with your consent.
Otherwise, we will market and advertise our products and services on the basis of our legitimate
business interests.
2.6 Other Purposes if We Obtain Your Consent.
We may use your data for other purposes when you give us consent to do so.
2.7 Legal Basis for Processing Personal Data.
INFINNI's Data Protection Officer can be contacted at dpo@infinni.io .
Our legal basis for collecting and using the Personal Data described above will depend on the
Personal Data concerned and the specific context in which we collect it. However, we will normally
collect Personal Data from you only where we have your consent to do so, where we need the
Personal Data to perform a contract with you, or where the processing is in our legitimate interests
and not overridden by your data protection interests or fundamental rights and freedoms. In some
cases, we may also have a legal obligation to collect Personal Data from you.
3. HOW WE SHARE PERSONAL DATA
3.1 Service Providers.
We may share Personal Data with our third party service providers to support our websites,
products, and services. For example, we use service providers for data hosting, application
development, marketing, sales support and customer support. We may need to share your
information with service providers to provide information about products or services to you.

Examples may include removing repetitive information from prospect lists, analyzing data or
performing statistical analysis on your use of the Subscription Service or interactions on our
websites, providing marketing assistance, processing credit card payments, supplementing the
information you provide us in order to provide you with better service, developing and improving
the product and services, and providing customer service or support. These service providers are
prohibited from using your Personal Data except for these purposes, and they are required to
maintain the confidentiality of your information. In all cases where we share your information in
this way, we explicitly require the third party service providers to acknowledge and adhere to our
privacy and data protection policies and standards.
3.2 Payment Services.
We use NetSuite to securely connect to financial institutions across the EEA. By entering online
banking credentials for payment and completing checkout, your banking credentials are sent to
NetSuite for validation. Your personal and financial data is processed by NetSuite in accordance
with their Privacy Policy.
3.3 Partners.
INFINNI does not share data with any Partner.
3.4 Advertising Partners.
If you would accept to receive marketing communications at the time of creating an account, we
may also share Personal Data, such as your email address, with our advertising partners to
deliver INFINNI’s personalized ads on other companies' sites or mobile apps. You can opt out of
having your data disclosed to our advertising partners by managing your preferences.
3.5 Company Acquisition.
If we (or our assets) are acquired by another company, whether by merger, acquisition,
bankruptcy or otherwise, that company would receive all information gathered by INFINNI on the
websites and the Subscription Service. In this event, you will be notified via email and/or a
prominent notice on our website, of any change in ownership, uses of your Personal Data, and
choices you may have regarding your Personal Data.
3.6 Compelled Disclosure.
We reserve the right to use or disclose your Personal Data if required by law or if we reasonably
believe that use or disclosure is necessary to protect our rights, protect your safety or the safety
of others, investigate fraud, or comply with a law, court order, or legal process.
4. HOW WE TRANSFER PERSONAL DATA INTERNATIONALLY
For more information about how we may transfer personal data internationally, please refer to our
DPA Template.

5. HOW WE STORE AND SECURE PERSONAL DATA
5.1 Data Storage and Security.
We use a variety of security technologies and procedures to help protect your Personal Data from
unauthorized access, use or disclosure. We secure the Personal Data you provide on computer
servers in a controlled, secure environment, protected from unauthorized access, use or
disclosure. All Personal Data is protected using appropriate physical, technical and organizational
measures.
5.2 Retention of Personal Data.
How long we keep information we collect about you depends on the type of information and how
we collect and store it. After a reasonable period of time, we will either delete or anonymize your
information or, if this is not possible, then we will securely store your information and isolate it
from any further use until deletion is possible.
We retain Personal Data that you provide to us where we have an ongoing legitimate business
need to do so (for example, as needed to comply with our legal obligations, resolve disputes and
enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Data, we securely
delete the information or anonymize it or, if this is not possible, securely store your Personal Data
and isolate it from any further processing until deletion is possible. We will delete this information
at an earlier date if you so request, as described in the "Privacy Rights and Choices" section.
If you have elected to receive marketing communications from us, we retain information about
your marketing preferences for a reasonable period of time from the date you last expressed
interest in our content, products, or services, such as when you last opened an email from us or
ceased using your INFLOWW account. We retain information derived from cookies and other
tracking technologies for a reasonable period of time from the date such information was created.
The data we process on behalf of customers in connection with the Subscription Service is stored
and secured according to the INFLOWW Terms of Service and Data Processing Agreement.
6. COOKIES
6.1 Cookies.
To find out more about how we use cookies on our websites and how to manage your cookie
preferences please see the INFINNI Cookie Policy as updated by us from time-to-time, without
additional notice.
7. YOUR PRIVACY RIGHTS AND CHOICES

7.1 Personal Data Requests.
Depending on your location and applicable laws, you may have the following data protection
rights:
(i) Right of access. You may request a copy of the personal data we hold about you and
information on how it is processed.
(ii) Right to rectification. You may request correction of inaccurate or incomplete personal data.
(iii) Right to erasure. You may request deletion of your personal data where it is no longer
necessary, where you withdraw consent, or where processing is unlawful, among other grounds.
(iv) Right to restriction of processing. You may request that we limit the processing of your
personal data in certain circumstances.
(v) Right to data portability. You may request to receive your data in a structured, commonly used,
machine-readable format or have it transmitted to another controller.
(vi) Right to object. You may object to processing based on legitimate interests or carried out for
direct marketing purposes.
(vii) Right not to be subject to solely automated decision-making, including profiling. You have the
right not to be subject to a decision based solely on automated processing that produces legal or
similarly significant effects on you.
(viii) Right to withdraw consent. Where processing is based on consent, you may withdraw it at
any time without affecting the lawfulness of processing carried out prior to withdrawal.
(ix) Right to lodge a complaint. You have the right to lodge a complaint with a supervisory
authority, in particular in the Member State of your habitual residence, place of work, or the place
of the alleged infringement.
To exercise any of these rights, contact us at dpo@infinni.io .
Please note that to protect Personal Data, we may verify your identity by a method appropriate to
the type of request you are making. Depending on where you reside, you may be entitled to
empower an “authorized agent” to submit requests on your behalf. We will require authorized
agents to confirm their identity and authority, in accordance with applicable laws. You are entitled
to exercise the rights described above free from discrimination.
We will respond to your request to change, correct, or delete your data within a reasonable
timeframe and notify you of the action we have taken. In some instances, your rights may be
limited, such as where fulfilling your request would impair the rights of others, our ability to provide

a service you have requested, or our ability to comply with our legal obligations and enforce our
legal rights. Depending on your location, and applicable laws, you may have the right to complain
to a data protection authority about our collection and use of your Personal Data. Contact details
for data protection authorities in the EEA are available on the European Data Protection Board
website.
If you are a customer, prospect, or otherwise interact with an INFINNI customer that uses our
Subscription Service and would like to access, correct, amend or delete your data controlled by
the customer, please contact the relevant customer directly.
7.2 To Unsubscribe From Our Communications. You may unsubscribe from our marketing
communications through the following methods:
(i) by clicking on the "unsubscribe" link located on the bottom of our e-mails;
(ii) updating your communication preferences;
Customers cannot opt out of receiving transactional emails related to their INFINNI Account or
the Subscription Service.
8. OTHER IMPORTANT PRIVACY INFORMATION
8.1 Information About Children.
INFINNI's websites, products, and services are not intended for or targeted at children under 18,
and we do not knowingly or intentionally collect Personal Data about children under 18. If you
believe that we have collected Personal Data about a child under 18, please contact us, so that
we may delete the information.
9. CONTACT US
If you have any questions about this Privacy Policy or our privacy practices, or if you have a
disability and need to access this notice in a different format:
(i) By email at dpo@infinni.io
(ii) You may also contact us by postal mail at:
Attn: Data Protection Officer
Infinni Innovations S.A.
Calle Maria Zambrano 42, Club de Campo Abama Parcela 4-B1
Guia de Isora, 38687, Spain