INTRODUCTION AND GENERAL TERMS
This Privacy Policy covers the processing of personal data by Prominent Contact LTD, trading as InFynd ("InFynd""," " We”, "us", or "our" in this policy), when providing its services to clients. If you have any questions or comments about this Privacy Policy, please contact us at:
Address: Gateshead International Business Centre, Mulgrave Terrace, Gateshead NE8 1AN
Email: [email protected]
InFynd is committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal data collected from you or from public sources will be processed by us. When we determine the purpose or means for processing this personal data, we act as the “data controller.” We will comply with all applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the European Union's General Data Protection Regulation (GDPR) and ICO Guidelines. You have the right to object to us processing your personal data for direct marketing purposes; refer to paragraph 7 below for details on how to do this.
This Privacy Policy explains the following:
WHAT INFORMATION WILL INFYND COLLECT ABOUT ME?
We collect and process the following data, which may include your personal data.
InFynd’s Website:If you contact us about our services or request a demo on our website, the forms you complete or the emails you send may include information about you, such as your full name, email address, the organisation on behalf of whom you are contacting us, and your inquiry.
InFynd’s Online Client Platform: To provide an InFynd Client with access to our platform and enable them to access our services, we collect the full name, email address, and password of each individual authorized by such client to access the platform.
Analytics on the Website and the Platform: Our website and online client platform use cookies and other mechanisms to collect and log analytical information, help analyse usage, compile statistical reports on the use of our website, and improve both our website and marketing efforts.
The following data may be collected:
InFynd Database: InFynd gathers current and historic business contact data. The data collected about individuals on the InFynd Database comprises:
We also hold data regarding your employer company, such as its name, alias, size, industry, website, and industry. In some cases, we estimate individuals’ net worth based on publicly available data(For example, the individual's employment history or whether such an individual has previously sold shares in a company). Where you change jobs, we may hold your previous employers and titles.
To facilitate specific aspects of its services, InFynd requires a business email address to be recorded for profiles in our database. If not available, we may generate one based on the email address structure known to be employed by the respective employer company.
We also retain hashed personal email addresses. Hashing is a method of encryption, that involves the transformation of the actual email address into a unique reference known as a hash. A Hash is one of the means used to locate the same individual on social networking platforms. It's important to note that we do not reverse the hash or use the personal email address to contact you.
The majority of the personal data collected about you is sourced from publicly available channels, including business and employment-oriented social networks, recruitment websites, and company websites.
Information is also acquired through correspondence with you (via email or phone), from our clients, our affiliate’s services, recruiters, and other premium data providers. InFynd does not aim to collect any non-business-related data, such as date of birth, home address, personal email, or telephone number, and InFynd does not collect sensitive personal data.
When our clients utilize our service to send marketing emails, they may include cookies (or similar technologies) in the emails. This enables them to determine whether an email bounced back and was not delivered, whether an email was opened and whether links in the email were followed.
GROUNDS OF PROCESSING
Consent: On some occasions, InFynd processes your data with your consent, which may be obtained by third parties on InFynd’s behalf. You have the right to withdraw such consent at any time, and we will cease processing the data after consent is withdrawn.
Legitimate interest:InFynd process your personal data when it is in our or our clients' legitimate interest to do so, and when these interests are not overridden by your rights. Our and our clients' legitimate interests include: organising information about potential business customers in a searchable database, accessing up-to-date and complete information, identifying individuals in specific roles within B2B leads, identifying individuals with a certain estimated net worth, enabling clients to reach out only to relevant contacts, generate and contact potential B2B leads for B2B marketing, and having access to aggregated statistical insights for understanding patterns and trends.
Legal obligation:InFynd may process your data to comply with our legal and regulatory obligations, such as preventing, investigating, and detecting crime, fraud, or anti-social behaviour, and prosecuting offenders, including working with law enforcement agencies.
Contractual obligation:InFynd may process your data when there is a contractual relationship with the individual, and it is necessary to process their personal data to comply with our obligations under the contract.
DATA SHARING
We will share your information with the following:
Our companies: Access to personal data within the InFynd and our group of companies is restricted to individuals who have a legitimate need to access the information for our business purposes.
InFynd clients: We may share personal data with our clients or our reseller clients including Experian LTD (https://experian.co.uk/business-information/marketing-transparency-notice.html) or their customers as part of the offering of our services. InFynd provides limited access to its database. InFynd clients or reseller clients or their customers may use the data to contact individuals on their business telephone, business address, and business email address through other electronic mail or through targeted display ads on social networks in order to market products and/or services.
Please note that in providing data to its clients, InFynd is processing such data as a processor on behalf of the client, who is acting as the controller. Clients are likely to have their own privacy policies and opt-out options, and we recommend that you review them. Where InFynd has made personal data available to its clients, the client's privacy policy should include InFynd as a data source.
Suppliers, subcontractors, and service providers: We maintain your information confidentially but may disclose it to suppliers or subcontractors as far as reasonably necessary for the purposes outlined in this privacy policy. However, such disclosure is contingent on their agreement to safeguard this information.
This includes external third-party service providers, such as accountants, auditors, experts, lawyers, and other professional advisors external to our organization. It also includes IT systems, support, and hosting service providers, technical engineers, data storage and cloud providers, and similar third-party vendors and outsourced service providers that assist us in conducting our business activities.
Data management platform: A Data Management Platform (DMP) is a technology platform utilized for collecting and managing data, primarily for digital marketing purposes. InFynd provides DMPs with data, enabling the DMP to create audience segments, which are used by advertisers to target specific types of users in online advertising campaigns.
Government authorities: Additionally, we may disclose your information to the extent required by law, including to government bodies and law enforcement agencies. This disclosure may also occur in connection with any legal proceedings or prospective legal proceedings, as well as to establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention.
Potential acquirers or investors: If we are engaged in a merger, acquisition, or sale of all or part of our assets, you will be informed via email, account message, and/or a prominent notice on our website of any change in ownership or the uses of this information. Additionally, you will be provided with any choices you may have regarding this information.
HOW WE WILL USE INFORMATION WE COLLECT ABOUT YOU
InFynd Website and InFynd Client Platform:
We may process your personal data for the following purposes for InFynd’s own:
If you would like to find out more about the way these third parties collect and process your information, please refer to their respective privacy policies.
We may use your personal data on the InFynd Database for the following purposes:
Additionally, we process personal data to comply with necessary legal and regulatory obligations. These obligations include preventing, investigating, and detecting crime, fraud, or anti-social behaviour, as well as prosecuting offenders, which may include working with law enforcement agencies.
All content, if you send us objectionable content or behave disruptively on our website, we may process personal data included in your messages to respond to and stop such behaviour. In cases where we reasonably believe you are or may be in breach of the law (e.g., if the content you send amounts to harassment or is defamatory), we may use your personal data to inform relevant third parties, such as your email/internet provider or law enforcement agencies, about the content.
MARKETING OPT-OUT OPTIONS
If you do not wish for your personal data to be used in the InFynd Database for the specified purposes, please fill in your details here or contact us using the provided contact details.
If you receive a marketing email from us and wish to be removed from our mailing list, please inform us by clicking the "unsubscribe" link located at the bottom of any marketing email you receive from us.
THE APP
Additional Limits on the Use of Your Google User Data:
Notwithstanding any other provisions in this Privacy Policy, if you grant the App access to the following types of your Google data, the App's use of that data will be subject to the following additional restrictions:
YOUR RIGHTS WITH PERSONAL DATA THAT WE PROCESS RELATING TO YOU
You have the following rights regarding the way we process personal data about you. We aim to comply without undue delay and within one month at the latest.To make a request, please contact us using the above contact details, addressed to the Data Protection Officer.
DATA RETENTION
We will hold your personal data for as long as is necessary for the relevant purpose.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
CHILDREN
We do not knowingly solicit data from or market to children under the age of 13 as per UK GPDR and under the age of 16 as per EU GDPR. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information from our files within a reasonable time.
SECURITY
InFynd is committed to ensuring the safety and security of your personal data, guarding against unauthorized access, alterations, disclosure, or destruction of the information we hold. We will take all reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal data.
Our security measures include:
It's important to note that, despite our efforts to provide reasonable security for the information we process and maintain, no security system can entirely eliminate the possibility of potential security breaches.
CHANGES
We will notify you of any changes to this Privacy Policy by email and/or notice on the website, as appropriate.
INTERNATIONAL DATA TRANSFERS
Your personal data, which you provide to us, is primarily stored and maintained within the European Economic Area (EEA). However, given the global nature of our business and the technological requirements required, your personal data may be transferred to third-party service providers outside the EEA, in countries where there may be a lower legal level of data protection.
When we transfer your data outside the EEA, we take measures to ensure that only the minimum amount of necessary data is transferred. We also strive to anonymize the data whenever possible. Additionally, we have established agreements with these third-party service providers, incorporating standard data protection clauses. These clauses are designed to guarantee that appropriate safeguards are in place, aligning with the principles outlined in this Privacy Policy and complying with European levels of data protection.
If you wish to obtain more information about the specific safeguards implemented for the international transfer of your personal data, please do not hesitate to contact us.
CALIFORNIA RESIDENTS & CCPA
If you are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in respect of the personal information we hold about you.
If you have questions or concerns about our privacy policies and practices, please contact us at the details provided at the top of this Policy. This Policy was last updated on 3 February 2021.
Please refer to the information above for:
You have the right to:
To make a verifiable request, please contact us using the above contact details, addressed to the Data Protection Officer. We may verify your request by asking for proof of identity.