We at InfiniGrow Ltd. (“InfiniGrow”, “us”, “we”, or “our”) recognize and respect the importance of maintaining the privacy of our customers (“Customers”) and their end users and of visitors to our website (“Site”). This Privacy Notice describes the types of information we collect from you when you visit our Site or use our revenue marketing platform (“Platform”) and the services available thereon (“Services”). This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at http://infinigrow.com/terms . “You” means any adult visitor to the Site or Platform and/or user of the Services.

If you are an individual located in the European Union (“EU Individual”), some additional terms and rights may apply to you, as detailed herein. InfiniGrow is the data controller in respect of the processing of Personal Data (as defined below) of visitors to the Site. Our registered office is Yavne 40, Tel Aviv – Yafo, Israel and our company number is 515531382.

If you have specific requests under European or UK law, you can also contact us, by way of our representative in those jurisdictions, at: https://prighter.com/q/18359593978. Our representative in the EU is PrighterGDPR-Rep by Maetzler Rechtsanwalts GmbH & Co KG c/o Infinigrow Ltd with address: Schellinggasse 3/10, 1010 Vienna, Austria. Our representative in the UK is PrighterUK-Rep by Prighter Ltd c/o Infinigrow Ltd with address:20 Mortlake Mortlake High Street, London, SW14 8JN, United Kingdom. Please add the following subject to all correspondence: ID-18359593978. 

When we process Personal Data relating to our Customers’ employees and end users in the context of providing Services to our Customers, the applicable Customer serves as the data controller with respect to such Personal Data and we serve as the data processor on its behalf. For more information about the Personal Data we handle as a data processor on behalf of our Customers, please see the sections on Customers’ End Users and Customer Personnel below.

“Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details the Personal Data collected by us in connection with provision of the Services.

Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section in order to find out more information about any topic. These key points do not substitute the full Privacy Notice.

1. Personal Data We Collect, Uses and Legal Basis.

2. Additional Uses.

3. Sharing the Personal Data We Collect.

4. International Transfer.

5. Security.

6. Your Rights – How to Control Our Use of Your Personal Data.

7. Data Retention.

8. Cookies and Similar Technologies.

9. Third-Party Services.

10. Children.

11. Changes to the Privacy Notice.

12. Comments and Questions.

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1. Personal Data We Collect, Uses and Legal Basis. 

Depending on your usage, we collect different types of data and we and any of our third-party subcontractors and service providers use the data we collect for different purposes, as specified below. You have no legal obligation to provide us with certain Personal Data, but if you refuse to provide such Personal Data we may not be able to provide you with the Services or part thereof.

1.1. Visitors to our Site

1.1.1. Contact Information. If you contact us via email, we will collect your email address and the content of your inquiry. If you contact us through the “Contact Us” or “Request a Demo” forms on the Site, we collect your name, company name, work e-mail, phone number (as required by such forms) and the information contained in your message.

How we use this data: To respond to your request or inquiry.

Legal Basis: We process this Personal Data based on performance of a contract when we respond to your inquiry.

1.1.2. Automatically Collected Data. When you visit the Site, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system, and Personal Data such as your IP address, device ID, as well as your browsing history and any information regarding your viewing, use of our Site. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section “Cookies and Similar Technologies” below.

How we use this data: (1) to review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and the Platform; (2) to prevent fraud, protect the security of our Site and Platform and address any problems with the Site or Platform; and (3) to provide you with customized content, targeted offers, and advertising related to our products and Services based on your viewing history on the Site or on other third-party websites you may visit or use.

Legal Basis: We process this Personal Data for our legitimate interests to develop our products, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights to market our own products and services.

1.2.  Customers’ End Users. We collect and process certain Personal Data of end users of our Customers’ services and/or visitors to their websites in the context of providing Services to our Customers. The types of Personal Data processed are determined by the applicable Customer, at its sole discretion. We collect and use this Personal Data as a data processor, solely for the purpose of providing Services to the applicable Customer, at its instruction, and on its behalf.

1.3.  Customer Personnel. We collect and process certain Personal Data of our Customers’ employees and other personnel in the context of providing Services to our Customers. In particular, when Customer personnel register accounts to use the Platform, they are required to provide the following Personal Data: last name, position, email address, and phone number. We collect and use this data as a data processor solely for the purpose of providing Services to the applicable Customer, at its instruction, and on its behalf.

2. Additional Uses

2.1. Statistical Information and Analytics. We and/or our service providers use analytics tools, including “Google Analytics” to collect and analyze information about the use of the Site, Platform and/or Services, such as how often users visit the Site and Platform, what pages they visit when they do so, and what other websites and mobile applications they used prior to visiting the Site. 

By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Site, Platform and Services, understand trends and customer needs and consider new products and services, and tailor existing products and services to customer desires. 

The information we collect is anonymous and aggregated and we will not link it to any Personal Data. We may share such anonymous information with our partners, without restriction, on commercial terms that we can determine in our sole discretion. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.

2.2. Direct Marketing. As described above, we may use Personal Data to let you know about our products and services that we believe will be of interest to you. We may contact you by email, or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with respect to you. To protect privacy rights and to ensure you have control over how we manage marketing with you:

2.2.1.We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.

2.2.2.You can ask us to stop sending email marketing by following the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively, you can contact us at [email protected].

2.2.3.You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below. If our marketing activities are based upon your consent, you may withdraw this consent at any time.

We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your account with us.

3. Sharing the Personal Data We Collect. We share your data, including Personal Data, as follows:

3.1. Service Providers and Sub-contractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Site, Platform and/or Services; (2) aid in their understanding of how users are using our Site, Platform and/or Services; and (3) for the purpose of direct marketing (see above for more details).

Such service providers and sub-contractors provide us with IT and system administration services, data backup, cloud services, user authentication, CRM systems, data analysis and help us serve advertisements and provide other marketing services.

3.2. Change of Ownership. If we are looking to sell our company, liquidate assets, or merge with another, we may share your Personal Data with other interested parties as part of negotiations toward that transaction. In such case, or where we do sell our company, your Personal Data shall continue to be subject to the provisions of this Privacy Notice.

3.3.  Law Enforcement Related Disclosure. We may share your Personal Data with government agencies or other relevant parties, such as a law office or independent auditor: (i) if we believe that such disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice) or those of a third party; (ii) if required by law or court order; or (iii) as is necessary to comply with any legal and/or regulatory obligations, such as audit requirements.

3.4.  Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

3.5.  Advertisers. When you click on an ad, whether or not it’s on our Site, the relevant advertiser will be alerted that someone has visited the page on which the relevant advertisement was displayed, and may be able to identify that it was you by using certain mechanisms, like cookies. We share Personal Data with such advertisers as follows: (i) with your consent (ii) hashed IDs and/or device identifiers. Advertisers are able to combine the Personal Data they collect independently with the Personal Data we share.

4. International Transfers. Some of our service providers are located in countries other than your own. When we transfer your Personal Data internationally, we will do so safely and securely and in accordance with applicable law.

4.1. If you are located in the EU, when we share your Personal Data with third parties based outside of the European Economic Area (“EEA”), we will ensure that they sign on agreements that require them to comply with applicable law, keep your data secure at similar levels to the level described in this Privacy Notice, and make sure that your data protection rights are protected. We will also implement the following safeguards:

4.1.1.When we transfer your Personal Data to Israel or the UK, we rely on the decision by the European Commission that says that those countries are considered to provide an adequate level of data protection.

4.1.2.Where we transfer your Personal Data to other countries, we (i) take additional security measures to protect the data and (ii) use specific contracts approved by the European Commission, known as the Standard Contractual Clauses, to give your Personal Data the same protection it has in the EEA.

4.2. Please contact us at [email protected] if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

5. Security. 

The security of your Personal Data is our highest priority. We work hard to make sure that your Personal Data will be held securely and that it will not be shared or lost accidentally. However, it is impossible to guarantee absolute security. The security of your data also depends on the security of the devices you use and the way in which you protect your user IDs and passwords. The measures we take include:

5.1.  Technical Measures. The electronic safeguards we employ to protect your Personal Data include secure servers, firewalls, and antivirus protections. We encrypt data in transit using secure HTTPS protocols.

5.2.  Access Control. We limit access to your Personal Data only to authorized personnel who have a need to know, including account managers, customer support staff, and software developers. We review these permissions regularly and revoke an employee’s access immediately after his/her termination.

5.3.  Internal Policies. We maintain and regularly review and update our privacy related and information security policies.

5.4.  Personnel. We require employees to sign non-disclosure agreements according to applicable law and industry customary practice.

5.5.  Standards and Certifications. We have been certified as compliant with ISO 27001 (Information Security Management) and have conducted a SOC 2 Type II security audit.

5.6.  Database Backup. Our databases are backed up and verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity.

6. Your Rights – How to Control Our Use of Your Personal Data. 

Depending on which laws apply, you have certain legal rights over your Personal Data. Below is some general information about rights that may apply to you but we recommend checking the law or consulting with a lawyer to understand what applies in your specific case. To exercise your rights, please contact us at [email protected]. If you want to exercise your rights regarding your Personal Data held by other controllers you can contact the applicable controller directly. We may ask for reasonable evidence to verify your identity before we can comply with any request.

6.1.  Right of Access. You may have a right to know what Personal Data we collect about you. We may charge you with a fee to provide you with this information, if permitted by law. If we are unable to provide you with all the information you request, we will do our best to explain why. See Article 15 of the GDPR for more details, if your Personal Data is subject to GDPR.

6.2.  Right to Correct Personal Data. You may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data. See Article 16 of the GDPR for more details, if your Personal Data is subject to GDPR.

6.3.  Deletion of Personal Data (“Right to Be Forgotten”). If you are located in the EU, you may have the right to request that we delete your Personal Data. Note that we cannot restore information once it has been deleted. Even after you ask us to delete your Personal Data, we may be allowed to keep certain data for specific purposes under applicable law. See Article 17 of the GDPR for more details, if your Personal Data is subject to GDPR.

6.4.  Right to Restrict Processing. If you are located in the EU, you may have the right to ask us to stop processing your Personal Data. See Article 18 of the GDPR for more details, if your Personal Data is subject to GDPR.

6.5.  Right to Data Portability. If you are located in the EU, you may have the right to request that we provide you with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format. See Article 20 of the GDPR for more details, if your Personal Data is subject to GDPR.

6.6.  Right to Object. If you are located in the EU, you may have the right object to certain processing activities. See Article 21 of the GDPR for more details, if your Personal Data is subject to GDPR.

6.7.  Withdrawal of Consent. If we are processing your data based on your consent, you are always free to withdraw your consent, however, this won’t affect processing we have done from before you withdrew your consent.

6.8.  Right to Lodge a Complaint with Your Local Data Protection Authority. If you are located in the EU, you have the right to submit a complaint to the relevant data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.

7. Data Retention.
   
   7.1.  We retain your Personal Data as long as necessary to fulfill each of the purposes we described above.
   
   7.2.  When deciding how long to store Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized access, the purposes for which the Personal Data was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business’s retention policy.
   
   7.3.  In some circumstances, we may store your Personal Data for longer if required to do so by law (e.g. to fulfill tax or audit requirements), or to keep accurate records of our interactions in case there is a prospect of litigation relating to your Personal Data. In such cases, we will maintain the same security measures as described above.
   
   7.4.  Please contact us at [email protected] if you would like details about the retention periods for each type of Personal Data we process.
   
   

8. Cookies and Similar Technologies.
   
   8.1.  What are Cookies? A cookie is a small piece of text that is sent to your browser by a website you visit. This piece of text acts as a sort of tag, letting the website know that it’s you (really, your device) that’s visiting. There are other technologies that act similarly, like web beacons, and pixel tags, but for simplicity’s sake we’ll refer to them all as “cookies”.
   
   8.2.  Websites can place their own cookies (called “first-party cookies”) but can also place cookies from other sites (called “third-party cookies”). If your browser holds both first and third-party cookies for a given website, both the website and the third party are notified when you visit the site. We may place both first and third-party cookies on our Site.
   
   8.3.  How We Use Cookies. While the specific names and types of cookies we use may change from time to time, they generally fall into one of the categories listed below. We will not place any cookies on your browser that are not strictly necessary unless you have first consented to receive them.
   
   

9. Third-Party Services. You may have access to third-party services through our services. Please note that all use of third-party services is at your own risk and subject to such third party’s terms and privacy policies. We do not take any responsibility for the performance of other services.
   
   

10. Children. We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has registered without parental permission, please advise us immediately.
    
    

11. Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version.
    
    

12. Comments and Questions. If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at [email protected].

Last updated: July 2023