PRIVACY POLICY

1. Introduction

Inflow Network LLC (hereinafter also “Inflow”, “we”, “us”), incorporated and registered in 112 Capitol Trail STE A987 Newark, DE 19711, operates “inflowtoken.io” website (“collectively referred to as the “Service”).

While providing our Service, we recognize the importance of your privacy and carry out our activities in line with the applicable data protection regulation including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the California Consumer Privacy Act (“CCPA”) and other relevant laws and regulations.

This Privacy Policy (“Policy”) aims to explain how we collect, use, store, share, dispose of and protect personal data you have chosen to share with us when you access our website or any pages or any tablet or mobile phone applications bearing ‘Inflow’ brand that we are owned and/or operated by us or whenever we otherwise connect with you. By means of this Privacy Policy, we fulfil our obligation under Articles 13 and 14 GDPR to provide information on our processing activities to the relevant data subjects.

2. Personal Data We Collect

We collect the personal data which you provide directly to us or which we generate when you open an account, perform any transactions on our platforms or browse our website. This may include: 

• Identity information such as, name, surname, nationality, date of birth; 

• Account information, such as username, password, account settings and preferences;

• Contact information such as e-mail address;

• Location information such as your country of residence, postal code and last physical address information;

• Identity verification information, such as images of your government-issued ID, passport, national ID card or driving licence;

• Transaction Information including your crypto currency wallet address, Ethereum address public blockchain data;

• Store Preferences including your safe search settings, notification settings, and favorite widgets;

• Photos that you share with us;

• Risk management information that is collected in accordance with the know-your-customer, anti-money landering and counter terrorism financing legislation;

• Computer or mobile device information, including IP address, operating system, network system, browser type and settings, device and browser metadata such as IP addresses, operating system type and version, date and time of access, domain name, URLs of visited pages, any referrer URL, interactions with user interface, access provider, and analytics information IP address, domain name, unique device identifiers, type of mobile device, operating system type and version, browser meta data, browser version, clickstream information;

• Marketing Information including cookies, pixel tags, clear gifs, web bugs, single pixel gifs, and personally submitted preferences, resettable device identifiers;

• Website or mobile application usage information;

• Communications and correspondences that you made with us, whether through our website or via e-mail, over the phone or via any other medium;

• Information regarding our services you used and the way in which you use our Services.

3. Collection Method of Your Personal Data

We collect your personal data in several ways, including:

• Directly from you via our website and mobile application as well as e-mail, telephone, printed form, and other physical and electronic environment;

• From publicly available sources of information;

• From our own records of how you use our services;

• From third party companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Service.

4. Use of Your Personal Data

We may use your personal data to:

• Process your subscription and create your account;

• Identify you as a user in our system, carry out the identification processes in accordance with the law;

• Verify your identity and inform the public authorities and institutions in accordance with applicable know-your-customer, anti-money laundering, counter terrorism financing legislation or regulations as well as our Terms of Use and other legislations and regulations applicable to our firm;

• Provide and maintenance our product and our services;

• Develop, comply and undertake the purchase contract for the products, items or services you have purchased or of any other contract with us through the service and perform our contractual responsibilities;

• Provide our services and process your transactions on our platforms;

• Contact you via email, phone call, SMS, or other equivalent forms of electronic communication;

• Conduct marketing activities and marketing analysis and send newsletters, surveys, offers, and other promotional materials related to our services;

• Improve our website and website offerings thorugh analysing your website usage, and enhance a great user experience by personalizing our services based on your experience;

• Track advertising tailored to your interests on the services and other websites;

• Review your questions, recommendations and opinions and respond your customer service requests and support needs;

• Detect, prevent, or investigate security breaches, fraud, and other unauthorized or illegal activity and evaluate system security and stability;

• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our services users is among the assets transferred;

• Comply with applicable laws. 

5. Legal Basis for Processing of Your Personal Data

We collect and process your personal data on the following bases which are stated in Article 6(1) of the GDPR:

• You have given consent to the processing of your personal data for one or more specific purposes,

• Processing is necessary for the performance of our contract,

• Processing is necessary for compliance with a legal obligation to which we are subject,

• Processing is necessary for the purposes of our legitimate interests pursued by the controller or by a third party, provided always that such interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.

We have a legitimate interest in improving and personalizing our services based on your needs, requests and suggestions, retaining and evaluating information on your recent visits to our website and how you move around different sections of our website, and contacting you for marketing purposes and promote our services (Recital 47 GDPR), without affecting your fundamental rights and freedoms.

We collect and process your special categories of personal data on the following bases which are stated in Article 9(2) of the GDPR:

• You have explicitly given us your consent to process your personal data,

• Processing relates to personal data which are manifestly made public by you,

• Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

6. Disclosure of Your Personal Data

The data collected by us may be transferred to third parties in order for the purposes set out in this Privacy Policy. This may, for instance, include our representatives, suppliers, business partners, legally authorized persons and institutions, public authorities and any other relevant roles. 

We may disclose your personal data to: 

• Our service providers for business or commercial purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising and marketing, network infrastructure, storage, monitoring and analyzing the use of our services, transaction monitoring;

• Our business partners and solution partners for the purposes specified in Section 4;

• Our professional advisors, including legal, accounting, or other consulting services, for purposes of audits, complying with our legal obligations;

• Our suppliers, for marketing and sales activities, mailing activities, sending newsletters, targeting activities, serving relevant ads for you, improving our website;

• Public authorities, legally authorized persons and institutions, regulators, government officials for meeting legal and regulatory requirements, or protecting or defending our rights or property in accordance with applicable laws.

For the compliance with the GDPR, we ensure our suppliers and business or solution partners whether they are located outside the EEA or not, to take appropriate technical and organizational security measures in accordance with applicable data protection laws and use it solely for the purposes specified by us.

7. Retention of Your Personal Data

We take all the necessary measures to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organisation or a country unless stated in this Privacy Policy and there are adequate controls in place including the security of your data and other personal information.

We will retain your personal data only for as long as they are necessary for the purposes set out in this Privacy Policy. If we no longer have a legal basis or a purpose for processing your personal data, we delete such personal data.

8. Marketing

We may occasionally communicate news, updates, promotions and information relating to our products and services. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under the data protection laws in pursuit of our legitimate interests.

We may share personal data with third parties to help us with our marketing and promotional projects or sending marketing communications.

If you want to opt out of receiving promotional and marketing emails, text messages, posts and other forms of communication from us (or our promotional partners), which you might receive in accordance with this section, you can choose one of the following ways:

• Click “unsubscribe” at the bottom of an email we sent you; or

• Contact us at support@inflowtoken.io and request to opt out. 

If you do opt out of receiving promotional and marketing messages, we will no longer use or transfer your personal data to third parties for direct marketing purposes. We would like to remind you that we may continue to send transactional or administrative e-mails (e.g. account status and activity updates, respond to your inquiries or complaints etc.) related to our services or your requests for information or materials, even you opt out.

9. Your Rights

You may benefit from various rights as a "data subject". 

You may, at any time, exercise any of the above rights, by contacting us via  support@inflowtoken.io together with a proof of your identity, i.e. a copy of your ID card, or passport, or any other valid identifying document.

Please note that we may reject requests that are excessive or a misuse of the relevant right or we may not be able to give you access to your personal data that we hold, if making such a disclosure would breach our legal obligations to other data subjects or if prevented by any applicable law or regulation.

1. If you are from the European Economic Area or in certain countries, you are also entitled (with some exceptions and restrictions) to:

• Access: You have the right to request information about how we process your personal data and to obtain a copy of that personal data.

• Rectification: You have the right to request the rectification of inaccurate personal data about you and for any incomplete personal information about you to be completed.

• Objection: You have the right to object to the processing of your personal information, which is based on our legitimate interests.

• Deletion: You can delete your account by using the corresponding functionality directly on the service.

• Automated decision-making: You have the right to object a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.

• Restriction: You have the right to ask us to restrict our processing of your personal data, so that we no longer process that personal data until the restriction is lifted.

• Portability: You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and to have that personal data transmitted to another organization in certain circumstances.

• Complaint: You have a right to lodge a complaint with the authorized data protection authority if you have concerns about how we process your personal data. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established. 

10. Additional Information for Residents of the State of California (USA)

Under the California Consumer Privacy Act of 2018 (“CCPA”), specific disclosures are required and California residents have additional rights regarding their personal information. 

1. Categories of Personal Information We Collect

2. Your Rights

Access

You may request access to the personal information that we have collected and maintained about you (along with information regarding its use and disclosure) over the past twelve (12) months upon appropriate verification. You may only make such requests twice (2) per every twelve (12) months.

Deletion 

You have the right to request that we delete personal information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.

Your California Privacy Rights under the "Shine the Light" Law

If you are a California resident, you have the right to request certain information from us regarding our information-sharing practices with third parties for direct marketing purposes. To the extent that we share your personal information for direct marketing purposes, you may receive the following information: (1) the categories of information and sources of information that we disclosed to third parties for direct marketing purposes during the preceding year; and (2) the names and address information of third parties that received such information, or if the nature of their business cannot be determined from the name, the examples of the products or services marketed.

To the extent that we sell your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You also have the right to direct us not to sell your personal information.

Verifying Your Request

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request.

Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf (e.g., previous transactions of person to whom request relates).

We will only use the personal information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.

Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded

You may also designate an authorized agent to make a request to access or delete on your behalf. Your authorized agent must submit proof that you have provided them with power of attorney pursuant to Probate Code sections 4000 through 4465. We may deny a request from a purported authorized agent who does not provide proof of authorization to act on your behalf.

Non-Discrimination

We will not discriminate against any consumer that asserts their rights under the CCPA. We will not: (1) deny you goods or services; (2) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (3) provide you a different level of qualify of goods or services; or (4) suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

11. Right to withdraw consent

If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. To withdraw your consent please follow the opt-out links on any message sent to you or contact us via  support@inflowtoken.io .

Once we have received the notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

12. Collection Of Children’s Personal Data

We do not knowingly collect personal data from children under the age of 13. We encourage parents and legal guardians to monitor their children's internet usage and to help enforce our Privacy Policy by instructing their children to never provide us personal data without their permission. If you have any concerns about your child’s privacy with respect to our services, or if you believe that your child may have provided his/her personal data to us, please contact us via  support@inflowtoken.io. We ensure to delete such personal data from our records immediately.

DISCLAIMER: When processing open data from social networks, it might be reasonably impossible to recognize the real age of users. Our verification of the age of users is limited to technically available and reasonable treatment of the information openly provided by the social networks from which we collect the data. In case of fallacious, erroneous or missing age data, the social networks shall be solely responsible for violation of requirements of the GDPR and other data protection laws in relation to the personal data of children.

13. Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our website and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Strictly Necessary Cookies. We use Session Cookies to operate our website and deliver it to you.

Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

Analytics Cookies. We use Analytics Cookies to collect information about how you interact with the website and help us analyze and improve the website.

Advertising Cookies. We use Advertising Cookies to make advertising messages more relevant to you. They help to display advertisements that are based on your inferred interests, prevent the same ad from appearing too often and ensure that ads are properly displayed.

Security Cookies. We use Security Cookies for security purposes.

14. Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We may use such third-party Service Providers for the following purposes:

1. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service. Such third-party Service Providers:

• help us to understand how our users experience our website by tracking their movements around our website;

• track and monitor website traffic and use of our website;

• collect usage and behavioral information about our users and provide financial analysis to make profitable decisions that enhance our website.

15. Links to Third Party Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

16. Changes to our Privacy Policy

We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or push notification. Please check back frequently to see any updates or changes to our Policy. 

17. Contact us

If you have any questions or concerns about our privacy practices or our data collection or processing practices, or if you want to report any security violations to us, please contact us via  support@inflowtoken.io .