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Infinia Mobile
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LEGAL NOTICE
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This website is owned by Infinia Mobile, S.L. (Infinia Mobile), a Spanish company with registered office at Avda. De la Industria, nº6, 2nd Floor, 28108, Alcobendas (Madrid), Spain, registered in the Commercial Registry of Madrid, in volume 33.992, sheet 23, section 8, page 611,685, with tax identification number B-8739342.

Contents and use

Infinia Mobile maintains this website to provide information about its activities, products and services in general. We do our best to include up-to-date and accurate information on this website, but it does not guarantee the accuracy, validity, timeliness or completeness of the information. Infinia Mobile will not be responsible for any damage or injury resulting from your access to or inability to access this internet site or from your reliance on any information provided at this site.

The information provided on this website is:

  • General Information only, and it is not intended to address the specific circumstances of any particular individual or entity.
  • It does not have to be complete, accurate, or updated.
  • Sometimes it is linked to external sites over which Infinia Mobile has no control and for which we assume no responsibility.

Copyright.

The user acknowledges and accepts that all copyrights, trademarks and all other intellectual property rights in all the material or content provided as part of this website shall remain at all times the property of Infinia Mobile. You can’t use this material without express authorization from Infinia Mobile and always mentioning the source.

Viruses, piracy and other cybercrimes

The user agrees not to misuse this website by knowingly introducing viruses, trojans, worms, logic bombs or other malicious or technologically damaging material. The user will not attempt to have any unauthorized access to the server that hosts this website or any other server, computer or database related to our website. You agree not to attack this website through a denial of service attack or distributed denial of service attack. By violating this provision, you may violate applicable civil and criminal regulations. We will report any breach to the applicable law enforcement authority and cooperate with the appropriate authority to disclose the identity of the hacker. In the event of such a breach, your right to use this website will cease immediately

We are not responsible for any loss or harm in relation of a service attack, virus or any other software or material that is malicious or technologically harmful to your computer, equipment, data or material because of the use of this website or of the download of its content or the contents to which this site redirects.

Contact

You can contact our customer service department via the phone number +34 913 62 39 86 or by sending an email to infinia@infiniamobile.com, using our contact form in the “Contact” section of our website

PRIVACY POLICY
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End User Privacy Notice

We at Infinia Mobile, S.L. (“Infinia”, “we”, “us” or “our”) respect your privacy and recognize the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data. The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you visit the digital properties (“Digital Properties”) such as websites or apps of the publishers using our technology which helps our clients to serve online ads. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing. This Privacy Notice applies whenever you visit the Digital Properties or use any of other services, all of which together we refer to as "Services".

Infinia participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Infinia’s identification number within the framework is 479.

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use the Services. For specific information with more details about our processing activities, please see the service specific information below.

1. Who is responsible for the processing of your Personal Data

We, Infinia Mobile S.L., based at Avda. de la Industria, nº6, 2nd Floor, 28108, Alcobendas (Madrid), Spain act as a data controller when we process your Personal Data within the Services.

2. What types of Personal Data do we process and how do we collect it?

When you use the Services, as further explained, we collect, use, store and transfer different kinds of Personal Data via third party service providers. For example, when you visit a website or app, the publisher sends its supply side partners a request. These requests are transferred to our demand side partners which provide us with your data. Also, we enrich this information via our technology to deduce additional data about you. As a general principle, we do not collect, generate, and do not ask you to provide any "special categories of Personal Data", which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation. The information we collect depends on which of the Services you use and how you use them. We process the following types of your Personal Data.

2.1. Personal Data we generate from your use of our Services

When we receive data from our partners, who collects it from the services provided to the users, we also process device-related information, including:

• Profiling information: We enrich the personal data we receive from our partners that help us serve you ads. Based on the data we received from them, which is detailed below, we estimate your sociodemographic profile including your gender, age and socioeconomic level, your area of interests and home/work locations.

2.2. Personal Data we collect from third parties

We obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations.

• Technical information: We collect information about your device and device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (such as IDFA or other unique identifiers provided by our service providers) and geolocation data (based on GPS information).

• Device matching information: We collect information about the ads that were shown, such as what type of ad, where in the page they appeared, and whether you interacted with them.

• Indoor tracking information: We collect information that identify your device in order to count people who visits the business establishments of our clients.

To learn more about which data is processed, please see the section with service specific information below.

3. Do we collect data from minors?

The Services are intended to be appropriate for general audiences. Therefore, we do not intentionally collect and/or categorize personal information from children. In the event that we learn that we have collected personal data from a user under 16 years of age within the scope of the Services explained in this Privacy Notice, we will delete that data as quickly as possible. If you believe that a user might be under the age of 16, please contact our DPO in the e-mail legal.sp@azerion.com.

4. For what purpose do we process your data?

As a data controller, depending on which Services you are using, we may process your Personal Data for the following purposes:

4.1. Provision and improvement of the Services

  • to intend to serve you ads
  • to ensure that our technologies function properly
  • to detect the unique end users using several devices to improve our services via unifying end user experience through different devices

4.2. Personalization of your experience

• to infer insights about your profiles including information about their sociodemographic profile (such as gender, age and socioeconomic level), psychological profile (such as your interest and apps you visit) and behavioral profile (such as home/work locations or life zone)

• to serve targeted ads to you on behalf of our clients based on the information inferred as mentioned above and, on the location.

4.3. Reporting

• to provide information and reports to our clients about the performance of the ads via DSPs (Demand Side Platforms) of the end users entering the stores we work with

4.4. Compliance with our legal or regulatory obligations

  • to comply with subpoenas, warrants, or other legal process.
  • to respond to requests from public and government authorities including public and government authorities outside an end user’s country of residence.
  • to protect our operations or those of any of our affiliates.
  • to protect our rights, privacy, safety or property, and/or that of our affiliates, end users, or others.
  • to allow us to pursue available remedies or limit the damages that we may sustain.

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.

5. Do we engage in profiling activities?

If you consent to this via the consent management platform provided by the publishers allowing us to serve you ads, we conduct profiling activities to show you ads that are more relevant to you. You can also go to your privacy settings to review and amend your privacy choices related to this type of processing at any time.

Please see for aditional information the section with service specific information below.

6. On which legal basis do we process your Personal Data?

As a data controller, we process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:

• Your consent: We process your Personal Data if you have provided your consent via a consent management platform available in the publisher’s page for a specific purpose. For example, when you visit a Digital Property for the first time, your consent is asked by the relevant publisher on behalf of us, for the data processing in the context of personalized advertising. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.

• Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations. for example, for tax and accounting purposes or legal disputes.

• Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we may process any privacy request you submit to us to be able to support our potential legal claims or transfer your Personal Data across all our group companies for administrative transfers as well as to determine the size of the user base of our services. We kindly remind you that you have the right to object to such processing of personal data.

Please see for aditional information the section with service specific information below.

7. With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments and technical support and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of the Services provided through our partners.

• Demand side partners: Demand partners are companies that integrate with our Services in order to bid for ad space of the publishers to serve personalized ads we provide to them. To be able to target end users, we transmit personal data to demand partners so that they have information about the device to bid for.

• External service providers: We share your Personal Data with external service providers who perform services on our behalf, like IT services, hosting, cross device matching, data analysis and indoor tracking services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.

• Law enforcement, government authorities or courts: We disclose your Personal Data in the event that we reasonably suspect malicious activity or fake traffic or in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.

• Affiliates and group companies: We share information with our affiliated companies, i.e. companies within our corporate family, which are also subject to this policy. We also share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group companies, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.

• Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

8. Where will my Personal Data be processed?

In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission's standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data. For further information on, or to receive a copy of, the adequate safeguards adopted by us for the international transfer of your Personal Data, please contact us by email at legal.sp@azerion.com. We will process any request in line with any local laws and our policies and procedures.

9. How do we protect your Personal Data?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

10. How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. You can consult more information about the data retention periods in the SPECIFIC SERVICE INFORMATION section.

11. What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

  • Access the Personal Data we hold about you, including information such as, for example, the source and categories of data, the processing purposes, the recipients (or categories thereof) and the respective retention period.
  • Request an update or correction of your Personal Data so that it is always accurate.
  • Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
  • Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
  • Restrict the processing of your Personal Data for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
  • Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
  • Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your Personal Data for profiling. In that case, we will stop processing your Personal Data for such purposes.

You can exercise these rights by sending a request to our DPO Office: legal.sp@azerion.com, providing your name, your email address as well as a description of your request. If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands or Spanish Data Protection Agency (AEPD) in Spain.

12. How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support via our Website or our Data Protection Officer via e-mail to legal.sp@azerion.com.

13. How often do we update this Privacy Notice?

We regularly review and update this Privacy Notice. Please regularly check this page to stay updated with the changes of this privacy notice.

This Privacy Notice was last updated on January 31, 2023.

14. Additional Information for California Residents

This section for California residents supplements the information provided in this Privacy Notice and applies solely to users, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.

We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

  • Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)
  • Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D – Commercial information (such as purchase history)
  • Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)
  • Category G – Geolocation data
  • Category H – Audio, electronic, visual, thermal, olfactory, or similar information

The CCPA provides consumers (California residents) with specific rights regarding their personal information. You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you. You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function. Finally, you have a right to not be discriminated against for exercising your rights under the CCPA. You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

Additional Information for Brazil Residents

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

Hosting

Infinia is hosted by external companies to provide its Services to its clients. For example, every time there is a data collection via our demand side partners, the information allowing this transfer (e.g., device information) as well as online identifiers (such as your IDFA) and geo location information will be sent to the external servers. This data is used to provide and improve our service and ensure its functionality.

Data retention period:

• 365 days except for services or treatments that have specific retention periods.

Cross-Device Matching

We also work with a service provider to whom we transfer the data we receive from our demand side partners for them to estimate the number of unique users we serve our ads on different devices. We process your Personal Data for this cross-device matching purposes based on your consent. You can adjust your preferences at any time in your privacy settings. If you choose not to allow us to pursue only this purpose, you may still see ads that are less personalized for you.

Data retention period:

• Maximum 90 days.

Profiling

Based on your consent, we infer insights from your Personal Data provided to us by our demand side partners combined with aggregated statistics we obtain from other service providers using our technology. Your profiles are then processed to show you relevant ads, based on your preferences and interests. You can adjust your preferences at any time in your privacy settings. If you choose not to give consent for this purpose, Infinia would not be able to show you personalized ads.

Data retention period:

• The data will be deleted within 30 days from the moment we stop receiving data from a specific user.

Indoor Tracking

Based on legitimate interest, we process technical information of your device (MAC address) along with the information related to the store, provided by our service provider through its devices located into the stores of the partners we work with. Based on legitimate interest, we are processing this data to be able to provide aggregated reports back to our clients on the performance of the campaigns run.

Data retention:

• Maximum 90 days.

WEB PRIVACY POLICY
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Infinia Mobile Website/Platform Privacy Notice

We at Infinia Mobile S.L. (“Infinia”, “we”, “us” or “our”) respect your privacy and recognize the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data. The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you use the platform (“Platform”), visit or use any other services available on our website: www.infiniamobile.com (“Website”). This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

This Privacy Notice applies whenever you create an account in our Platform or use any of other Website services, all of which together we refer to as "Services".

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.

1. Who is responsible for the processing of your Personal Data

We, Infinia Mobile S.L., based at Avda. de la Industria, nº6, 2nd Floor, 28108, Alcobendas (Madrid), Spain act as a data controller when we process your Personal Data within our Services.

2. What types of Personal Data do we process and how do we collect it?

When you use the Services, as further explained, we collect, use, store and transfer different kinds of Personal Data via third party service providers. For example, when you visit a website or app, the publisher sends its supply side partners a request. These requests are transferred to our demand side partners which provide us with your data. Also, we enrich this information via our technology to deduce additional data about you. As a general principle, we do not collect, generate, and do not ask you to provide any "special categories of Personal Data", which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

The information we collect depends on which of the Services you use and how you use them. We process the following types of your Personal Data.

2.1. Personal Data provided by you

When you use our Services, you provide or be asked to give us certain information, including:

• Your account information: On our Website, you need an account to access our Platform. The account is created by our tech team and to create this account, we collect your log-in data (username, first name, last name, your email address, country, language and password).

• Your contact information: On our website, we may also process your contact information (company, job title, phone number, workplace in addition to the account information such as email, name and surname) based on your consent to receiving newsletters through the contact forms or raffles.

• Information provided in relation to our customer service: When you contact support via our Website form we collect information about your request (subject and content of your request) and in addition to your contact information mentioned above details.

2.2. Personal Data we receive or generate from your use of our Services

When you receive our Services, we also process device-related information, including:

• Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (your IP address), geolocation data (based on your IP address), browser settings, screen resolution and other technical information.

• Cookie data: As further described in our Cookie Notice (“Cookie Notice”), we use cookies and similar technology and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, purposes and the scope of the data that may subsequently be processed is set out in our Cookie Notice.

2.3. Personal Data we collect from third parties

We will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data are provided by the following third parties, including:

• Your contact information: We collect your contact information specified above from third party data providers we work with as well to provide you with updates related to our services.

To learn more about which data is processed, please see the section with service specific information below.

3. Do we collect data from minors?

Our services are intended to be appropriate for general audiences. Therefore, we do not intentionally collect and/or categorize personal information from children. In the event that we learn that we have collected personal data from a user under 16 years of age within the scope of the Services explained in this Privacy Notice, we will delete that data as quickly as possible. If you believe that a user might be under the age of 16, please contact our support team sending an email to legal.sp@azerion.com.

4. For what purpose do we process your data?

As a data controller, depending on which Services you are using, we may process your Personal Data for the following purposes:

4.1. Provision and improvement of our Services

  • to allow you to use our services
  • to create and manage your account
  • to communicate with you in context of account activation, password management
  • to provide technical support and respond to your requests
  • to understand and improve your online experience

4.2. Marketing and Analytics

• to send you newsletters

4.3. Communication

• to provide you with customer support based on your questions, requests, or complaints

4.4. Compliance with our legal or regulatory obligations

  • to comply with subpoenas, warrants, or other legal process
  • to respond to requests from public and government authorities including public and government authorities outside an user’s country of residence
  • to protect our operations or those of any of our affiliates
  • to protect our rights, privacy, safety or property, and/or that of our affiliates, end users, or others
  • to allow us to pursue available remedies or limit the damages that we may sustain

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.

5. On which legal basis do we process your Personal Data?

As a data controller, we process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:

• Your consent: We process your Personal Data if you have provided your consent via a consent management platform available on our Website. For example, we may analyze your use of our Services via an external service provider or send you newsletters based on your consent. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.

• To carry out contract and pre-contractual measures: We process your Personal Data for the performance of a contract or pre-contractual measures to which you are a party, for example, in the context of customer service or to create an account for you to provide or to facilitate the delivery of requested service

• Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations. For example, for tax and accounting purposes or legal disputes.

• Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we may process any privacy request you submit to us to be able to support our potential legal claims. We kindly remind you that you have the right to object to such processing of personal data.

Please see for aditional information the section with service specific information below.

6. With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments and technical support and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services. This Policy does not apply to those parties, and Infinia is not responsible for their collection or use of information to the extent allowed by the applicable law.

• External service providers: We share your Personal Data with external service providers who perform services on our behalf, like IT services, hosting, data analysis and marketing. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.

• Law enforcement, government authorities or courts: We disclose your Personal Data in the event that we reasonably suspect malicious activity or fake traffic or in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.

• Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

7. Where will my Personal Data be processed?

In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission's standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data. For further information on, or to receive a copy of, the adequate safeguards adopted by us for the international transfer of your Personal Data, please contact us by email at legal.sp@azerion.com. We will process any request in line with any local laws and our policies and procedures.

8. How do we protect your Personal Data?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

9. How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. You can consult more information about the data retention periods in the SPECIFIC SERVICE INFORMATION section.

10. What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

• Access the Personal Data we hold about you, including information such as, for example, the source and categories of data, the processing purposes, the recipients (or categories thereof) and the respective retention period.

• Request an update or correction of your Personal Data so that it is always accurate.

• Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.

• Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.

• Restrict the processing of your Personal Data for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.

• Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.

• Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your Personal Data for profiling. In that case, we will stop processing your Personal Data for such purposes.

You can exercise these rights by sending a request to our DPO Office: legal.sp@azerion.com, providing your name, your email address as well as a description of your request. If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands or Spanish Data Protection Agency (AEPD) in Spain.

11. How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support via our Website or our Data Protection Officer via e-mail to legal.sp@azerion.com.

12. How often do we update this Privacy Notice?

We regularly review and update this Privacy Notice. Please regularly check this page to stay updated with the changes of this privacy notice. This Privacy Notice was last updated on January 31, 2023

13. Additional Information for California Residents

This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice. We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

  • Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)
  • Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D – Commercial information (such as purchase history)
  • Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)
  • Category G – Geolocation data
  • Category H – Audio, electronic, visual, thermal, olfactory, or similar information

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

Additional Information for Brazil Residents

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

Hosting

Infinia is hosted by external companies to provide its Services to its clients. For example, every time you visit our Website, your technical information will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Data retention period for the following processing activities related to Hosting:

  • Use of Website Cookies: Consult the Infinia Cookie Notice for more information on the duration of cookies and the retention of data for the use of cookies.
  • Creation of the Platform user account: Duration of the service contracted by the user. Suspension of the user account after 90 days of non-use.
  • Website contact form: The data will be stored for a maximum period of one (1) year after the end of the communications or the commercial relationships.
  • Performance of raffles: Raffles duration.

Analytics

We use analytics services to understand which features you like in our Services and to monitor traffic of our Website. For this purpose, we process information about your device and on how you use our Services, including your technical information. We also process your users full IP address to allow us to better understand how you use our Services and to improve our websites. By activating IP anonymization on this Website, the IP address is shortened prior to transmission within the EEA or in other states party to the Agreement on the EEA. We process this information based on your consent.

Data retention period for the following processing activities related to Analytics:

• Use of Website Cookies: Consult the Infinia Cookie Notice for more information on the duration of cookies and the retention of data for the use of cookies.

Newsletters

Based on your consent, we process your contact information including your name, surname, company name and job title to send you newsletters including information about our Services for marketing purposes via our third-party service providers. You can withdraw your consent at any time by contacting us.

Data retention period for the following processing activities related to Newsletters:

  • Newsletter subscription: Subscription duration. Once the subscription is canceled, the data will be blocked and stored for a maximum period of one (1) year.
  • Website contact form: The data will be stored for a maximum period of one (1) year after the end of the communications or the commercial relationships.
COOKIES POLICY
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Infinia Mobile Cookie Notice

This cookie notice (“Cookie Notice”) applies to Infinia Mobile S.L. (“Infinia”, “we”, “us” or “our”) services (internet sites and platform, "Services"). It explains what these technologies are, why we use them and the duration of their use as well as your rights to control our use of them. For more information about the ways in which Infinia handles personal data, please refer to our Privacy Notice.

What are cookies and similar techniques?

Cookies are small pieces of information (small files) stored within your browser or on your device. There are similar techniques as cookies such as Flash cookies, web beacons, small graphic files (pixels) and an additional HTML5 (local) storage in your browser. These techniques function in a similar manner as cookies. Where we refer to “cookies” in this Cookie Notice, we also mean similar techniques.

Cookie Parties

As Infinia, we place cookies when you visit our Services that are only readable for us (”1st Party Cookies”), as do the third parties (”3rd Party Cookies”). These cookies are Google Analytics cookies only readable for the third party, that is Google Ireland Limited.

Cookie Types

Cookies that are essential for the functionality of our Services (also known as “Strictly necessary” cookies):

Since these cookies are essential, they are always active in our Services. We respect your preferences and in order to make your choices valuable and effective, we keep strictly necessary cookies out of types of cookies that we ask for your consent. We use these cookies for activities such as recognising you when you sign-in to use our Services so that you do not have to log in manually the next time you visit www.infiniamobile.com.

Cookies that help to a better user experience (also known as “Functional” cookies):

For example, we use these cookies to remember information when you fill in forms or input fields on various pages and to keep track of your preferences such as language settings, location settings, etc.

Cookies that allow us to gather information about the way visitors use our Services (also known as “Performance” cookies):

The information we gather from these cookies is used to generate site statistics. These statistics provide us with insights, such as how often our Services are visited, which parts or features are mostly viewed, how often our Services are interacted with. We continuously try to measure which Services of us are the most popular that attracts most visitors and users. This allows us to make the structure, navigation, and content as user-friendly as possible.

Cookies on “www.infiniamobile.com”

We use cookies on our www.infiniamobile.com website on which you can find this Cookie Notice. You can find the detailed cookie information below.

Strictly Necessary Cookies

Host Cookie Name Purpose Lifetime
google.com _GRECAPTCHA This cookie is used to distinguish between humans and bots. This is beneficial to the web in order to produce valid reports on the use of the web. 6 months
google.com rc::c This cookie is used to distinguish between humans and bots. Session

Performance Cookies

Host Cookie Name Purpose Lifetime
infiniamobile.com _gat Google Analytics Cookies 30 minutes
infiniamobile.com _ga Google Analytics Cookies 2 years
infiniamobile.com _gid Google Analytics Cookies 24 hours
infiniamobile.com __utmb This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behavior and measure site performance. This cookie determines new sessions and visits and expires after 30 minutes. The cookie is updated every time data is sent to Google Analytics. Any activity by a user within the 30-minute life span will count as a single visit, even if the user leaves and then returns to the site. A return after 30 minutes will count as a new visit, but a returning visitor. 30 minutes
infiniamobile.com __utma This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behaviour and measure site performance. This cookie lasts for 2 years by default and distinguishes between users and sessions. It is used to calculate new and returning visitor statistics. The cookie is updated every time data is sent to Google Analytics. The lifespan of the cookie can be customised by website owners. 2 years
infiniamobile.com __utmz This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behavior measure of site performance. This cookie identifies the source of traffic to the site - so Google Analytics can tell site owners where visitors came from when arriving on the site. The cookie has a life span of 6 months and is updated every time data is sent to Google Analytics. 6 months

How cookies can be deleted?

If you do not want websites to place cookies on your devices, you can adjust the browser settings so that your browser refuses all cookies or only third-party cookies. You can also delete cookies that have already been placed. Note that you must adjust the settings separately for each browser and computer that you use. If you decide to disable all cookies, some parts of our Services may not function properly.

How you can adjust the settings differs per browser. If necessary, consult the help function of your browser, or click on one of the links below to go directly to the manual of that specific browser.

If you want to disable cookies from specific parties, you can do so via:

Furthermore, you can withdraw the consent you gave for non-essential cookies at any time under the link “Cookie Settings” or you can exercise your right to withdraw your consent by contacting us as described in our Privacy Notice.

Updates to this Cookie Notice

We will amend this Cookie Notice when we implement new technologies and functions. If we make significant changes, we will notify you of this. For example, by posting a notification on our websites and/or apps, through email, pop-ups (e.g., by requesting your consent again), or similar methods.

Questions or complaints regarding privacy or cookies can be sent to legal.sp@azerion.com.