for Users of Infleum website
Last modified: July 12, 2018
Users of INFLEUM, a company incorporated in the Cayman Islands under registration
number 341937 (“Company”) are processed and what rights the Users of the Company,
users of the website infleum.io (collectively with all of its subdomains and all their
respective pages, “Website”), the online services at the Website (“Services”), or when
you otherwise interact with us (the “Users”) retain in relation to their personal data
being in the possession of the Company.
1.2. The European General Data Protection Regulation (“GDPR”) that comes into force on
the 25th of May 2018 regulates the manner in which the personal data are collected,
provisions of the GDPR.
2.1.1. “Users” has the meaning ascribed to it in Section 1.1;
2.1.2. “Controller” means the natural person or legal person acting alone or jointly
with others, who determines the purposes and means of the processing of personal data;
2.1.3. “Data” means the information that is collected in relation to your use of the Website and the Services.
2.1.4. “Data subject” means the natural person to whom the Personal data refer.
2.1.5. “Employees” means the employees of the Company from time to time;
2.1.6. “Company” has the meaning ascribed to it in Section 1.1;
2.1.7. “GDPR” has the meaning ascribed to it in this Section 2.1.6 “Personal data”
means any information relating to an identified or identifiable natural person;
2.1.9. “Processor” means a natural or legal person, public authority, agency or other
body which processes personal data on behalf of the Controller; and
2.1.10. “Terms and Conditions of the Website” means the document describing the
terms and conditions of the Website available on the Website (as may be amended from time to time).
2.1.11. “User Account” means an account which may be provided to you by Company
for the purpose of improving your experience at the Website and use of the Services, as well as obtaining
access to specific additional other products, utilities and offerings provided by Company Parties
3. DATA CONTROLLER
3.1. The Company is the data controller. The contact details of the Company are as follows:
3.1.1. Email: firstname.lastname@example.org
3.1.2. Address: P.O. Box 31119 Grand Pavilion, Hibiscus Way,
802 West Bay Road, Grand Cayman, KY1-1205 Cayman Island
3.2. The Company treats data protection and privacy issues with utmost care. In addition
the Company strives to apply such policies and mechanisms which ensure high standard of security.
Appropriate electronic and procedural measures are used in order to make sure that the personal data
being in the Company’s possession are not accessible by any unauthorised person.
The Employees are trained how to handle and process personal data strictly limited within the course of business,
while the methods and electronic systems used for processing and sharing of
personal data, where permitted, provide sufficient guarantees of protection.
4. TYPES OF PERSONAL DATA PROCESSED
4.1. In order to perform the Services and the functionality of the Website, we are entitled
to ask you to provide Company Parties with your personal identification information,
including but not limited to your name, e-mail address, phone number, date of birth, a
scanned copy of a valid government-issued passport or ID number, information about
the used cryptocurrency wallet addresses.
4.2. The Personal data may be collected either directly by the Data subject or indirectly
through intermediaries and other third parties acting on behalf of the User, such as
employees, agents or other service providers.
4.3. Company may collect the Data from you in a variety of ways and circumstances.
Company Parties shall be entitled to combine Data collected in the course of your
interaction with different sections of the Website or the Services with any other
relevant available information.
4.4. Data collected by or transmitted to Company Parties, in the course of accessing,
interaction and operation of the Website and provision of the Services may include, without limitation, the following Data:
4.4.1. Internet Protocol (IP) address and location;
4.4.2. cookie information;
4.4.3. browser identification information;
4.4.4. information on the computer or mobile device you use to access the Website and the Services,
including the hardware model, operating system and version, your web browser,
and device identifiers (including a network ID used to communicate with other nodes on the platform);
4.4.5. information contained in or relating to any communication that you send to us or send through the Website,
and metadata associated with the communication;
4.4.6. date and time of accessing the Website and the Services;
4.4.7. information of third parties websites referred the Website or the Services;
4.4.8. information related to your activity in the course of the Services use, including, without limitation,
search queries history, search results provided to you in response to your query, web pages you visited by reference from the search results;
4.5. You may always refuse to supply Data, though this may prevent you from engaging in certain Website-related activities.
4.6. Data collected hereunder in the course of operation of the Website and provision of the
Services may differ depending on whether you access the Website and the Services
logged in to your User Account or without logging in.
5. PURPOSES OF COLLECTING AND PROCESSING
5.1. Company collects and process the Data as part of the operation of the Website and the
Services, including, but not limited to, for the following purposes:
5.1.1. administration and development of the Website and the Services;
5.1.2. enhancement of user experience, including the provision of personalized Services and improvement of the Website and the Services;
5.1.3. development of new products, utilities, and offerings;
5.1.4. detection, investigation, and prevention of fraudulent transactions and other illegal activities and protection of your rights and rights of Company Parties;
5.1.5. collection, processing and performing statistical and other research and analysis of information for enhancement of the Website and the Services;
5.1.6. communication with you about products, services, promotions, events and other news and information we think will be of interest to you; and
5.1.7. verifying compliance with the Terms and Conditions of the Website.
6. POTENTIAL RECIPIENTS OF PERSONAL DATA
6.1. The Company may share the Personal data processed by the Company with the physical and legal persons listed below:
6.1.1. in the context of provision of Services by the Company;
6.1.2. employees who are properly informed about the provisions of the GDPR and are bound by the confidentiality agreement executed with the Company;
6.1.3. IT centers which provide outsourced IT and communication support, backup and other IT services with whom the Company
has entered into confidentiality agreements while the Personal data shared are always encrypted;
6.1.4. courts, upon receipt of a court order or judicial or administrative order;
6.1.5. governmental bodies and public authorities, including tax authorities, who have legitimate interest on such Personal data; and
6.1.6. to any other person for which the Data subject has given his/her consent.
7. LEGAL BASIS FOR COLLECTION OF PERSONAL DATA
7.1. The Company processes the User’s Personal data based on the below legal grounds:
7.1.1. the Company obtains the consent of the User. Such consent is required to be obtained when
(i) the Company collects the Personal data for advertising and marketing purposes or
(ii) for a purpose which is not related to the services provided to the User by the Company;
7.1.2. for the entry into/performance of the contractual obligations under a contract entered
into between the Company and the Data subject regarding the provision of Services;
7.1.3. compliance by the Company with its legal obligations imposed by any applicable legislation; and
7.1.4. to pursue the legitimate interests of the Company, the Users and the Employees, provided that
such legitimate interests shall not override the right of the Data subject.
8. TERM OF RETENTION
The Company processes the Personal data only for such period which is necessary in relation to the purpose for which they are processed.
The Users are entitled to have their Personal data collected by the Company erased and no longer processed where
(i) such Personal data are no longer necessary for the purpose they are collected or processed,
(ii) the User’s consent has been withdrawn or
(iii) the User objects to the processing of the Personal data. Irrespective of the latter, the Company reserves its legal rights for further retention
of the User’s Personal data in order to comply with its obligations under the relevant provisions of the Cayman Islands laws.
9. SECURITY OF STORAGE
9.1. The Company implemented specific organizational and technical mechanisms which
ensure high level of security of the Personal data. The Company strives to use physical
and electronic filing systems which provide for the protection of the Users’ Personal
data against unlicensed or unlawful processing, accidental loss, destruction or damage.
9.2. In addition to the security policy undertaken by the Company, the Data subjects are
highly recommended to use only secured emails and secured networks when
transmitting their Personal data to the Company.
10. RIGHTS OF THE DATA SUBJECTS
10.1. The Data subjects have certain rights under the GDPR, including amongst others:
10.1.1. the right of access to the Personal data, including the purpose of the
processing, the categories of Personal data concerned, the recipients to whom
the Personal data have been disclosed, the proposed period of retention of
such Personal data;
10.1.2. the right to rectification of inaccurate Personal data concerning the Data subject
10.1.3. the right to erasure – “right to be forgotten”;
10.1.4. the right to the restriction of processing;
10.1.5. the right to data portability under which the User is entitled to receive his/her
Personal data in a structured, commonly used and machine-readable format
and to transmit those data to another controller;
10.1.6. to withdraw their consent where processing relies on consent; and
10.1.7. to lodge a complaint before the Data Protection Commissioner of the Cayman Islands.
12. CONTACT US
Grand Pavilion, Hibiscus Way, 802 West Bay Road Grand Cayman, KY1 – 1205