Effective date: September 30, 2019
A. Personally Identifiable Information.
Personally identifiable information (“PII”) is information belonging to an individual and identifying that individual such as an individual’s full name, mailing address, e-mail address, social security number, government identification number (such as a driver’s license number of passport number), or account number for a credit or debit card or for another financial product or service. Also included in PII is information about the computer or mobile device that you use to access our Website.
1. PII that you submit to the Website. We collect information that you submit when visiting the Website, which may include your name and email address, contact information if you contact us with an inquiry (such as your mailing address and phone, telephone number), and, if we provide Website registration for you, any other information you include in your personal registration profile.
a. How we use PII that you submit. We may use your information to allow you to set up a user account and profile and to personalize your experience on our Website. We will neither rent nor sell your PII to anyone, but we may use the collected PII for our general commercial purposes, such as to improve our Website and our Services, and to grow our business. We will use your contact information to respond to your inquiries and/or to provide information to you.
b. Your control over how we use your PII. You have the right to control the use of your PII by Infiot. If you do not want to receive general communications from us, you may opt-out of receiving such communications, and we ask that you please contact us at email@example.com. You can add, update or delete your personal information by contacting us at firstname.lastname@example.org. Please know that when you opt to update or delete your information, we may maintain a copy of the unrevised information in our records, but never in a manner that would identify you personally.
2. PII that we gather automatically. We automatically collect some information which gets recorded in our server logs when you visit the Website. This PII includes your device’s IP address, location, browser and operating system, and statistics about how you use the Website. If you connect to our Website using a mobile device, we may also collect information about your device including the operating system and browser used and a unique device identification number. We also collect “cookie” information. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Website are visited and by how many people.
a. How we use PII that we automatically gather. We generally use the automatically gathered PII only in quantified, anonymous, and aggregate form, and not in a manner that would identify you personally (“non-PII”), because its value lies in allowing us to do quantitative analyses of the behavior and activities of large numbers of users, not in identifying particular users. For example, non-PII aggregate data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services more efficient, and to make them as useful to as many users as possible. We also use non-PII to improve our platform and to improve and test the features and functions of our Website.
3. Other uses of PII. We may, from time to time, use PII in a variety of other ways that relate to our business purposes:
a. Marketing and Events: We may use PII to deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, and online via our Website. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. Please remember that even if you opt out of receiving marketing emails, we may still send you important information related to your account or to the Services.
b. Surveys: We may invite you to participate in a survey or take a questionnaire relating to some aspect of our business. If you choose to participate in an Infiot survey, any PII you provide may be used in anonymous or non-PII form for marketing or market research purposes.
c. Social Media: Some of our Services may include social media features for information exchange purposes. Depending upon the Service component, the PII you choose to post, share, upload, or make available is and will be public, non-confidential, and visible to others who use those Services. You should never post or share any information that is confidential or about others unless you have permission to do so. We may use information you provide in social media contexts to personalize your experience on our Website.
d. Legal obligations: We may be required to use and retain PII for legal compliance reasons, such as the following: to prevent, detect, or investigate a crime such as fraud or identity theft; to prevent loss of confidential information; to meet our internal and external audit requirements; to provide security; to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities; to enforce our terms and conditions; to respond to any other necessary compliance circumstances under applicable laws; and, to protect our rights, privacy, safety, or property, or those of other persons. To help us achieve these lawful purposes, we reserve the right to access, read, preserve, and disclose any information that we believe is necessary for us to comply with law or with an order from a court or regulatory agency, to enforce our agreements, or to protect the rights, property, or safety of our employees, our visitors and subscribers, or others.
B. PII and Children.
The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13. We do not knowingly collect or solicit PII from children under 13. If you are a child under 13, please do not attempt to register with Infiot (if we provide personal registration on the Website), and please do not send any personal information about yourself to us through our Website. If we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible as may be required by COPPA and other laws. If you believe that a child under 13 may have provided us personal information without parental consent, please contact us at
C. PII and Third Parties.
As indicated above, we will neither rent nor sell your PII to anyone. However, we may share your PII with third parties as described in this section:
1. Contracts with our Vendors. We may enter into contracts with other companies and people to perform tasks on our behalf, and so we may need to share your PII with them to provide products or services to you; for example. These vendors do not have any right to use the PII we share with them beyond what is necessary to assist us, and their agreements bind them to confidentiality obligations in regard to your PII.
2. Our Marketing and California’s Shine the Light Law. We may engage with a service provider for marketing and promotional purposes, and effective marketing may require us to provide some PII to the marketing service provider. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of PII which we share with any third parties for marketing purposes and to ask us for contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to
3. Transfers of Business Assets. We may choose to buy or sell business assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, PII could be one of the assets transferred to or acquired by a third party. In any transaction of this sort, strict confidentiality and non-disclosure provisions would bind the parties to an obligation to preserve the confidentiality of your PII.
4. Transfers of Aggregate Non-PII. We may anonymize your PII so that you are not individually identified, combine it with anonymized information of many other Website visitors, and then provide that non-PII information in anonymous and aggregate form to our partners, who may perform various analytics on our Website or may use the aggregated information to develop their own marketing for their own business purposes. In such circumstances, we never disclose aggregate information to a partner in a manner that would identify you personally, as an individual.
D. The California Online Privacy Protection Act and “Do Not Track” Signals.
E. Website Visitors from Outside the United States
2. If you are an individual within the European Economic Area, you have certain rights under the European Union General Data Protection Regulation (“GDPR”). In certain circumstances, you have the right to:
a. Request access to any of your PII which we have collected; and/or
b. Request prompt correction of any inaccurate PII; and/or
c. Request the deletion of your PII, provided that its retention is not required by Infiot for compliance with a legal obligation under European or EU Member State law, or for establishing, exercising, or defending a legal claim; and/or
d. Prevent or restrict processing of your PII, except to the extent processing is required by Infiot for establishing, exercising, or defending a legal claim; and/or
e. Request that your PII be transferred to a third party, provided that such transfer is technically available; and/or
f. File a complaint with an EU Data Protection Authority if you believe that Infiot has not complied with its obligations under the GDPR.
F. Additional Policy Information.
1. No Guarantee of Complete Security. Although we use commercially reasonable efforts consistent with industry standards to keep your PII secure, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.