1. Important Information and Commitment
In this Privacy Policy, we delineate how INFX, a product of LEADING ("INFX," "We," "Us"), collects and processes personal data for our current and potential customers. INFX, consisting of various legal entities, is committed to ensuring fair and legal use of customer data. This policy applies to individuals providing personal data through INFX's Electronic Services, including its website, trading platform, software applications, and social media.
Confidentiality and Security Commitment
We recognize the significance of the confidentiality and security of your personal data. INFX is dedicated to safeguarding your information through specific policies and practices. To ensure a high level of data protection, we implement appropriate technical and organizational measures. This Privacy Policy undergoes periodic reviews and revisions to align with new obligations, ensuring compliance with applicable laws and regulations. Significant revisions will be communicated through usual channels.
Encouragement to Review
We encourage you to carefully read this privacy policy. In specific cases of data collection or processing, additional privacy statements or notices may be provided. Understanding this policy is crucial for a comprehensive grasp of the logistics related to your personal data. Note that this Privacy Policy supplements other notices provided by INFX and does not override them.
2. Who We Are and Personal Data Responsibility
INFX Entity and Personal Data Collection:
INFX, represented by various entities, including Exinity UK Limited and Exinity Capital East Africa Limited, is responsible for collecting your personal data. For inquiries regarding your personal data use, please contact [insert contact information].
Types of Personal Data We Collect and Process:
After registration with INFX, we collect your personal data to fulfill legal obligations such as KYC and regulatory requirements. Understanding your background and requirements enables us to provide fair services, relevant information, and process your requests effectively.
1.Identity Data: First name, maiden name, surname, proof of identity, username, title, date and place of birth, gender, country of residence, and citizenship.
2.Contact Data: Billing address, shipping address, email address, phone number, and address proof.
3.Professional Data: Education level, occupation, employer name, work experience, financial awareness, and trading experience.
4.Tax Data: Tax country of residence, tax identification number.
5.Financial Data: Annual income, net assets, sources of funds, expected account turnover, bank accounts, bank statements, payment card details and their copies, e-wallet information.
6.Transaction Data: Payment details, information about purchased products and services, method of deposit, purpose of transaction.
7.Technical Data: Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in type and version, operating system and platform, and other technical and electronic services on the device used to access the INFX website.
8.Personal Data: User name, password, purchase or order information, interests, preferences, feedback, survey responses.
9.Usage Data: Information about how you use our website, products, and services.
10.Marketing and Communications Data: Preferences in receiving marketing from us and any third-party companies on our behalf, and communication preferences.
Sensitive Personal Information:
We may also collect, store, and use sensitive personal information, including details about criminal convictions and crimes.
Information about Criminal Convictions and Crimes:
We also collect, use, and share summary data, such as statistics or demographics. Non-personal data may come from your personal data but is not considered personal data for legal purposes, as it does not directly or indirectly reveal your identity. For example, we might aggregate your usage data to calculate the percentage of users who visit specific websites and e-service features. However, if summary data can directly or indirectly identify you or is connected with your personal data, we will treat it as personal data and use it in accordance with the privacy policy.
3. How We Collect Your Personal Information
We use different methods to collect your personal data, such as:
Direct Interaction: You can provide your identity, contact information, and financial data by filling in required forms on our website, electronic service registry, or through phone, email, or other contact methods. This includes, but is not limited to, circumstances such as applying for our products or services, creating an account on our website, and subscribing to our services.
Automation Techniques or Interactions: When you interact with our e-services, we may automatically collect technical data about your devices, browsing operations, and patterns. This is done through the use of cookies, server logs, and similar technologies.
Third-Party or Public Sources: We may receive personal data from various third-party and public sources related to your identity, contact data, and other information. This may include data from technical analysis providers, payment service providers, and open-source identity verification sources.
Data Generated in the Course of Providing Services: We process personal data generated during the provision of services, such as transaction data.
4. Purposes of Using Your Personal Data
Based on legal bases, we may use your personal data for the following purposes ("Permitted Purposes"):
Signing or Executing Our Agreement:
Provide services according to the service agreement.
Offer brokerage services and process client requests.
Respond to information requests and provide follow-up support.
Abide by Our Legal Obligations:
Comply with applicable laws in countries/regions of operation.
Prevent and detect money laundering, terrorism, fraud, or other crimes.
Fulfill legal and tax reporting obligations.
Pursue Our Legitimate Interests:
Administrative and operational procedures.
Statistical purposes, market research, and product analysis.
Business or operation monitoring and analysis.
Protection of property, rights, and defense against potential claims.
With Your Consent for Marketing Purposes:
Communicate information about INFX services, products, and technologies.
Conduct customer surveys, marketing campaigns, and market analysis.
Collect information about preferences to personalize and improve communication.
Monitoring and Surveillance:
Monitor through various methods for compliance and security purposes.
Use automated monitoring tools, random monitoring systems, specific monitoring systems, data tracking, aggregation and analysis tools, and other monitoring techniques.
Automatic Decision-Making:
In case of legal requirements, we will not use your personal information for decisions that significantly affect you automatically.
5. Sharing Your Personal Information and Under What Circumstances
We may share your personal information in the following cases:
Among INFX Entities: Sharing personal information within INFX entities based on confidentiality agreements.
Service Providers: Instructing internal or external service providers to process personal data on our behalf, subject to agreements ensuring data protection.
Fraud and Crime Prevention Services: Sharing data with companies providing fraud and crime prevention services.
Various Services: Sharing personal data with providers of IT services, trading platform management, customer support, marketing, and other relevant services.
Business Transfers: Sharing personal data in the context of selling, transferring, merging, or acquiring parts of our business or assets.
Financial Transactions: Disclosing information to institutions, stock exchanges, clearing systems, and other participants in related transactions.
Legal Compliance: Sharing personal data with courts, law enforcement, regulatory authorities, or legal representatives for legitimate claims or dispute resolution.
International Transmission: Some INFX entities and third parties are located
outside your country/region, involving data transfer with appropriate protective measures.
6. International Transmission of Personal Data
Transmitting personal data outside your country/region may occur for licensing purposes. Protective measures include transferring data only to countries with adequate protection or implementing legal safeguards.
7. Safety and Protection
INFX employs security measures to prevent unauthorized or illegal processing, loss, destruction, alteration, disclosure, or damage to customer personal data. Measures include encryption, two-factor authentication, access management, clean desktop policies, and disaster recovery procedures.
8. Phone Conversations and Electronic Records
INFX records, monitors, and processes telephone conversations and electronic communications for service transactions. The content may be recorded in minutes or notes for meetings and can be provided to customers upon request.
9. How Long We Retain Your Personal Data
We retain your personal data for as long as necessary to fulfill the purposes for which we collected it, considering legal, accounting, and reporting requirements.
10. Your Legal Rights
Under Data Protection law, you have rights related to your personal data:
Request access to your personal information.
Request correction of your personal information.
Request deletion of your personal data.
Object to processing based on legitimate interests.
Request restrictions on processing.
Exercise data portability rights.
To exercise these rights, contact us via email. No fees are required, unless requests are unfounded or excessive.
11. Personal Data Leakage
We have procedures to address suspected breaches of personal data and will notify affected parties and regulatory authorities as required by law.
12. Protection of Minors' Information
We do not collect personal information from minors under 18. If discovered, we take immediate action to remove it.
13. Modification of Privacy Policy
We reserve the right to amend this policy. Material changes will be communicated through our website or other channels.
14. Our Information
INFX is provided by LEADING. For inquiries or concerns, contact us at [insert contact information].
15. Supplement: Reading Mobile Phone Information
As of May 4, 2023, INFX will read user mobile phone information for security verification purposes. User-uploaded information is encrypted and not shared with third parties.
LEADING
Address: 1312 17th Street Suite 600
Email: [email protected]
We will respond promptly to your requests and work diligently to resolve issues.