GDPR

INTRODUCTION AND GENERAL TERMS

This Privacy Policy covers the processing of personal data by ProminentContact LTD, trading as Infynd.com, a private limited company under the laws of England and Wales with company number 12150394 whose registered office is at Lily Hill House, Lily Hill Road, Bracknell, England, RG12 2SJ and ICO Registration Number ZA599278 ("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: Lily Hill House, Lily Hill Road, Bracknell, England, RG12 2SJ
• Email: compliance@infynd.com

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 personal data we may collect about you;
• Why our processing is lawful;
• Who we may share your information with;
• How we will use that information;
• Who we may disclose that information to; and
• Your rights regarding the information.

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 organization 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:

• number of visitors to our website;
• pages visited and time spent per page;
• page interaction information, such as scrolling, clicks and browsing methods;
• Websites tracking the origins of visitors and their subsequent destinations;
• page response times and any download errors; and
• other technical information relating to end user device, such as IP address or browser plug-in.

InFynd Database:

InFynd gathers current and historic business contact data. The data collected about individuals on the InFynd Database comprises:

• Name
• Employer Company & Company Details
• Office Location (Country & City)
• Business Telephone Number
• Business Email Address
• Job TitlePage response times and any download errors; and
• Social profiles such as LinkedIn

We also hold data regarding your employer company, such as its name, alias, size, industry, website, social handles and industry. 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 processes your personal data when it is in our 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 platform:

• to administer platform log-ins (where applicable) and deliver our services to our clients or their customers under the agreed terms of service;
• to process your enquiries to reply and provide support, including providing you and/or your organisation with information about the services InFynd offers;
• to keep you updated via our mailing list with information on news, offers, and updates about InFynd (see below for how to unsubscribe);
• to compile reports on how visitors use the InFynd website and improve the website;
• to conduct remarketing for InFynd, which allows us to show InFynd ads to people who’ve previously visited our website;
• to conduct advertising on social networks for InFynd, meaning that if you link to one of our social media platforms you may be subject to targeted marketing displaying InFynd ads via that site.

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.

InFynd Database:

We may use your personal data on the InFynd Database for the following purposes:

• to build our sales intelligence database to empower our clients or their customers to generate and manage sales leads for businesses and high net worth individuals;
• to enable our clients or their customers to deliver relevant display ads on social networks (such as Facebook, LinkedIn and Instagram) and other services;
• to empower our clients or their customers to enrich their existing customer relationship management records and receive timely updates of changes;
• to undertake research and compile statistical aggregated reports based on data held in InFynd’s sales intelligence database;
• to supply data management platforms;
• to run our own marketing campaigns and promote our services.

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:

• App’s use and transfer to any other app of information received from Google Accounts will adhere to Google API Services User Data Policy, including the Limited Use requirements, which is available at the following link: https://developers.google.com/
  . It's important to note that these are policies are governed by Google, and InFynd does not have any control or interference in this regard. We recommend you to visit Google´s policies directly for further details on their procedures and future updates.
• The App will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing it is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
• The App will not use this Gmail data for serving advertisements.
• The App will not permit humans to read this data unless we have your affirmative agreement for specific messages. Reading is only done when necessary for security purposes, such as investigating abuse, complying with applicable law, or for the App's internal operations. Even in these cases, access is granted only when the data has been aggregated and anonymized.

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 for free of charge and within one month at the latest.

Under data protection law, you have rights including :

• Your right of access - you have the right to access the personal data we hold on you in certain circumstances.
• Your right to rectification - you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure - you have the right to ask us to erase your personal information in certain circumstances.
• Your right to restrict processing - you have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing - you have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability - you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. Upon a request, InFynd will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
• Your right to withdraw consent - you have the right to withdraw consent in relation to our processing of your personal data at any time.
• Your right to not be part of automated decision making - you have the right to not be subject to decision based on solely automated means.
• Your right to make a complaint to a Supervisory Authority – please let us know if you are unhappy with the way InFynd is processing your personal data. If you do not agree with the way we have processed your data or responded to your concerns, or if you do not think we are handling your personal data adequately, you have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk

If you want to exercise any of your rights, please contact us using the above contact details, and provide a specific date and time, proof of your identity or a description of yourself.

You are not required to pay any charge for exercising your rights. If you make a request, we will normally respond to you within one month. We will notify you if this period must be extended by two months in certain circumstances.

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 compliance@InFynd.com. 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:

• hashing and encryption of our services and data;
• regular review of information collection practices;
• encryption of our services and data;
• restricted access of data to employees, contractors and agents; and
• internal policies outlining our data security. 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 UK and 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 UK and EEA, in countries where there may be a lower legal level of data protection.

When we transfer your data outside the UK and 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 appropriate legal mechanisms to transfer data, such as the UK International Data Transfer Agreement. These clauses are designed to guarantee that appropriate safeguards are in place, aligning with the principles outlined in this Privacy Policy and complying with UK and 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 August 2024.

Please refer to the information above for:

• the date on which this Policy was last updated (see paragraph 1)
• categories of personal information collected about you in the last 12 months (see paragraph 2)
• categories of sources from which the personal information was collected (see paragraph 2)
• categories of third parties with whom we share personal information (see paragraph 4)
• where you have a profile on our database, a list of categories of personal information sold about you in the last 12 months (see paragraph 2)
• We have disclosed and sold personal information to third parties within the last 12 months.
• We do not sell the personal information of minors under 16 years of age without affirmative authorization.
• You can designate an authorised agent to make a request under the CCPA on your behalf. The authorized agent must submit proof that they have been authorized by you to act on your behalf and proof of their own identity.

You have the right to:

• request access to your personal information and request that InFynd disclose what personal information we collect, uses, discloses, and sells;
• request deletion of your personal information collected or maintained by us;
• opt-out of the sale of your personal information fill in your details here: https://infynd.com/do-not-sell-my-info/

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.

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