Privacy

Policy

Our Privacy Policy was last updated on [June 10, 2024].

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • "Company" (referred to as either “IC” "the Company", "We", "Us" or "Our" in this Agreement) refers to Infinity Capital W.L.L For the purpose of the PDPL (Bahrain Personal Data Protection Law), the Company is the Data Controller.

  • "Country" refers to [Kingdom of Bahrain].

  • "Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

  • "Data Controller", for the purposes of the PDPL (Bahrain Personal Data Protection Law), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

  • "Device" means any device that can access the Website such as a computer, a cell phone or a digital tablet.

  • "Do Not Track" (DNT)” Because there is not yet a consensus on how companies should respond to web browser-based “do-not-track” (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please note that not all tracking will stop even if you delete cookies.

  • "Personal Data" is any information that relates to an identified or identifiable individual. a. For the purposes of PDPL (Bahrain Personal Data Protection Law), Personal Data refers to any information that can be used to identify you, or that can be linked to you, as an individual. b. Personal information about you: personal information that you provide to us (if may require) when you apply to open an account (e.g. personal/identification information, name, date of birth, nationality residential address, gender, country of residence, accredited investor status, tax residential status, tax identification numbers, income and wealth information, annual income, net worth, source of funds and wealth, employment activity, investment risk appetite, passport, national ID (or equivalent documents), bank details, IBAN details, and proof of address, etc), as well as any additional information provided by or through Our Website, or submitted through a question, such as your e-mail address, or submitted through the uploading of personal documents in order to comply with KYC checks requirements in the jurisdictions where we operate;

  • "Service" refers to the Website.

  • "Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the PDPL (Bahrain Personal Data Protection Law), Service Providers are considered Data Processors.

  • "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • "Website" refers to[Infinity Capital], accessible from [infinitycapital.bh]

  • "You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

  • While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to: Email address

  • First name and last name

  • Phone number

  • Address

  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

Our Website uses cookies to collect and store certain information about you, and to distinguish you from other users of this Website. This helps us provide you with a good experience when you browse our Website and also allows us to improve our Website. A cookie is a small text file which is sent by a Website, accepted by a web browser and then placed on your hard drive. The information collected from cookies lets us know that you visited our Website in the past, and helps you avoid having to re-enter information on each visit in order to use some of our products or services, among other things. We use a variety of cookies in this Website:

Strictly Necessary: These cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but if you do so, some parts of the site will not work. These cookies do not store any personal information.

Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Functional Cookies: These cookies enable the Website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, some or all of these services may not function properly.

Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Social Media Cookies: These cookies are set by a range of social media services that we may have added to the site to enable you to share our content with your friends and social or professional networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

  • To manage Your requests: To attend and manage Your requests to Us.

  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.

  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

We may transfer your personal information to third parties and statutory authorities only if you have given us your consent to do so by sharing your information with us and agreeing to and accepting this policy, or if there is an obligation to do this on the basis of statutory regulations or due to an enforceable official or judicial order.

Transfer of personal information to other responsible parties may include:

a. third parties in order to deliver our services to you;

b. Judicial and regulatory authorities whom we are obliged to share information with, as required or permitted by law; and

c. Banks and payment providers, to process and authorize payments.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation

  • Protect and defend the rights or property of the Company

  • Prevent or investigate possible wrongdoing in connection with the Service

  • Protect the personal safety of Users of the Service or the public

  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service. Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Change to the Privacy Policy

In the future, we may need to make more modifications. All subsequent modifications will be reflected in the most recent Privacy Policy published on this Website, ensuring that you are constantly aware of our current practices regarding the information we collect, how we may use that information, and disclosures of such information to third parties. The date at the bottom of the Privacy Policy indicates when it was last updated. Infinity Capital W.L.L maintains the right, at its sole discretion, to change, revise, or update this Privacy Policy at any time. Any changes will take effect only after the effective date of the change and will have no bearing on any disputes that arose prior to that date.

Confidentiality

You understand that any information or materials provided on the Website are confidential ("Confidential Information"). You ensure to keep the Confidential Information confidential and to safeguard its confidentially with the same level of care as it protects its own confidential information, but no less than a reasonable degree of care. You may only disclose Confidential Information to your employees, agents, and consultants who need to know it, and only if they have agreed to the same confidentiality responsibilities.

Trademarks

Trademarks and service marks used on this Website are the property of IC or its owners. Nothing on this Website should be regarded as conferring a license or right to use any trademark without IC's prior written authorization. IC's name or logo may not be utilized in any way, including advertising or publicity related to the dissemination of materials on this Website, without prior written authorization. You are not authorized to use IC's logo as a hyperlink to this Website unless you acquire IC's prior written permission, while IC's does allow you to use certain defined aspects of the Website to use IC's logo as a hyperlink for specific purposes.

Governing Law and Dispute Resolution

This Privacy Policy and any use of this Website by such user will be governed and construed in accordance with the laws of the Kingdom of Bahrain. Without regard to conflict of laws principles, and such user irrevocably agrees that any legal action arising out of or relating to this Privacy Policy or such use may be brought by or on behalf of such user only in Bahrain's courts, and such user irrevocably submits to the jurisdiction of such courts.