Privacy Policy

Influencio Privacy Policy

Your privacy is important to us. Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Information.

The consent you give us under this Privacy Policy shall be in addition to any other consents you may have previously given to us in respect of your Personal Information.

We may update this Privacy Policy from time to time to ensure its consistency with our business operations, future development, industry trends and/or changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on this website. Please check back regularly for updated information on the handling of your Personal Information.

1. GENERAL Data Protection ACT REGULATION (EU) 2016/679 (“GDPR”)

1.1 For the purposes of this Agreement “Personal Data” shall mean data, whether true or not, about an individual who can be identified:

1.1.1 From that data; or

1.1.2 From that data and other information to which the Company has or is likely to have access; and/or any other personal data, as defined under the GDPR.

1.2 The way in which your Personal data shall be collected, processed, handled and/or stored will be governed by the GDPR, and all the ancillary corresponding laws and regulation applicable to data handling as governed under the GDPR will be complied with.

2. Scope and consent

By signing up for, accessing, or using any product, services, content, features, technologies or functions offered on the Influencio website and all related sites, you consent to the collection, use, storage, processing, both electronically and manually, and disclosure of your Personal Data, including without limitation, Personal Data already disclosed by you or on your behalf prior to the date hereto; any Personal Data which may subsequent hereto be furnished by you or on your behalf; as well as any other alteration to such data in the future, for the purposes of using Influencio’s Services.

The term “Services” in this Privacy Policy shall be defined to include all the interactions you have with us, from the registration of your Influencio account, to your usage of the Influencio platform.

By using our Services, you are also consenting to our collection, use, disclosure and retention of your personal information as described in this Privacy Policy and in our member’s Terms and Conditions.

You may withdraw your consent to any use of your Personal Information as set out in this Privacy Policy by contacting us at [email@influencio.io] However, please note that we may have to limit your Influencio Account or decline to offer you certain Services if you withdraw your consent.

3. How we collect your personal information

In this Privacy Policy, “Personal Information” means any information that can be associated with a specific person and which can be used to identify that specific person (whether from that data alone or from that data in combination with other information that Influencio has access to). We do not consider Personal Information to include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person.

We collect Personal Information from you and the devices (including mobile devices) you use to access or use our Services. You should ensure that all Personal Information submitted to us is complete, accurate, true and correct. If you fail to do so, we may be unable to provide you with the products and services you have requested.

The Personal Information we collect includes, but is not limited to, information of the kinds described below:

4. Information that we collect automatically

We collect information about your interaction with our sites and Services, advertising, mobile notifications or e-mail communications. This is typically information we receive from your computer or other devices, including your mobile devices, and includes:

● Device ID or unique identifier, device type, unique device token;

● Geo-location information, including location information from your mobile device (However, do keep in mind that most devices allow you to control or disable the use of location services in the device’s settings menu);

● Computer and connection information; and

● Statistics on page views, traffic to and from the sites, referral URL, IP address and web log information, blockchain wallet address;

You may also be presented with an additional notice when using our Services explaining any additional information we may collect from you that is not listed in this Privacy Policy.

4.1 Information that you give us when you use our Services

Such types of information include:

● Identity-related information that you provide us when you register a Influencio Account, including your name, physical address, email address, telephone and/or mobile phone number, business seller information, and unique identification number (e.g. NRIC or passport number), and identity-related information of the directors and executive officers of your corporate body authorised to operate your Influencio Account;

● Financial information such as your [bank account information, credit card, or debit card];

● E-mail address, Telegram username, Twitter handle;

● Transactional information based on your activities conducted on our sites and through our Services (such as information on your buying and selling activity and other content you generate or that relates to your Account);

● Information provided through chats, dispute resolution, referral services, or added to a web form or when adding/updating your Account information, or provided when you correspond through our sites and Services, or when corresponding with our customer service team; and

● Any additional information that Influencio may ask you to provide in order to verify your Account or listings.

4.2 Information from other sources

We may combine information you give us with information we collect from other sources and use it for the purposes disclosed in this Privacy Policy.

● We may also obtain information about you from third parties. This may include:

● publicly available demographic information;

● additional contact information, User information or account information (including third-party account information) and other information required to verify you or your business’s identity or User information to assess fraud;

● credit check information;

● information from credit bureaus and financial institutions; and

● analytics data from your usage of our Services.

● You may choose to provide us with access to certain Personal Information stored by third parties such as social media sites (e.g., Facebook, Twitter, Medium, YouTube, LinkedIn and many others). The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your Influencio Account and authorising Influencio to have access to this information, you agree that Influencio may collect, use and share this information in accordance with this Privacy Policy.

● If you give us Personal Information relating to a third party (e.g. information of your customers and/or employees), you must do so only with their consent. By submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Information for the respective purposes. In addition, you agree to inform them that we have collected their Personal Information and tell them how we collect, use and disclose the Personal Information.

5. cookies, web beacons, and other similar technologies

Cookies are small amounts of data that are sent to your browser and stored on your computer’s hard drive to collect standard internet log information and visitor behavior information. When you visit Influencio, we can automatically collect information from you through cookies or similar technologies.

5.1 How we use cookies

When you sign up for, access, or use any product, service, content, features, technologies or functions offered on the Influencio website and all related sites in utilising our Services, we or our authorised service providers may use cookies, web beacons, and other similar technologies for storing information to help us provide you with a better, faster, and safer experience. Service providers are companies that help us with various aspects of our business, such as site operations, customer support, services, applications and tools.

Accordingly:

● We and/or our authorised service providers may employ cookies in order for our server to recognise a return visitor as a unique User including, and not limited to, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s clickstream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

● The cookies are also used to link your device to your Influencio Account so that you do not have to re-connect your address each time you click on a link in the Influencio platform or query or access to our Services.

● Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser or device settings. However, you may be required to re-enter your password more frequently during your use of our Services, or may not be able to enter certain part(s) of our website.

● Where possible, security measures are set in place to prevent unauthorised access to our cookies and similar technologies. A unique identifier ensures that only we and/or our authorised service providers have access to cookie data.

We use cookies in a range of ways to make your experience of our Influencio Services more enjoyable, including but not limited to:

● to keep you signed in; and

● to record your habits and preferences when browsing Influencio; and to record our performance and verify the effectiveness of online advertising through Google Stats with cookies.

5.2 The types of cookies we use

We use different types of cookies, including but not limited to:

5.2.1 Functional Cookies

We use such cookies to help us identify you and remember your previous preferences and settings, which may include your device, your operating system, your preferred language, your location, and other session data. We use a mix of first-party and third-party cookies.

5.2.2 Marketing Cookies

We use these cookies to collect information about your visit to Kashi, the content you view, the links you follow, and other information about your browsers, devices, your IP addresses and referral URLs. We sometimes share certain parts of the collected information with third parties for marketing purposes. We may also share online data collected through cookies with our marketing partners. This means that when you visit another website, you may also be shown advertisements based on your browsing patterns on Influencio.

5.3 How we manage our Cookies

Most browsers are preset to accept cookies. You can adjust your browser setting to prevent cookies or to notify you as soon as cookies are loaded. However, stopping all cookies might mean that you cannot access or use some Influencio features.

6. How we use your personal information

We use the Personal Information we collect to operate, improve and personalise our Services; to contact you and provide you customer service; to detect, prevent and mitigate fraudulent or illegal activities; and for all other such purposes as described in paragraph 4.5 of this Section. You agree that we may use your Personal Information as follows:

6.1 Operate, improve, and personalise our Services

● Provide you use of and access to our Services;

● Process your application for Influencio products and services;

● Process transactions and send notices about your transactions;

● Verify your identity, including during Account creation and password reset processes;

● Responding to your queries, feedback, complaints and requests, and to resolve disputes, collect fees, and troubleshoot problems;

● Give you access to a history of your usage of the Services;

● Customise, measure and improve our Services; and

● Provide other services requested by you as described when we collect the information.

6.2 Operate, improve, and personalise our Services Contact you and provide you customer service

● Provide you with customer support in relation to the use of our Services;

● Contact you via postal mail, email, or phone (including using auto-dialled or pre-recorded messages and text messages) in order to provide you with information regarding your activity of the Services where it requires your attention, and for such other purposes as authorised by law and is consistent with this Privacy Policy.

6.3 Detect, prevent and mitigate fraudulent or illegal activities

● Prevent, detect, investigate and report fraud, security breaches, potentially prohibited or illegal activities;

● Protect the security and integrity of our sites and Services;

● Compare the Personal Information you provide for accuracy, and verify it with information provided by third parties where necessary.

6.4 Others

● Detect, prevent, remediate breaches or attempted breaches of or otherwise enforce our policies, applicable law, or any agreement that we may have with you;

● Perform creditworthiness and solvency checks, and compare information for accuracy and verify it with third parties where necessary;

● Provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences;

● For accounting, audit or litigation purposes.

7. How we share your personal information with other Influencio users

The protection of your Personal Information is very important to Influencio. We will share selected Personal Information with other Influencio Users in order to facilitate your transactions and to help resolve a dispute between you and another Influencio User.

● When you transact with other Influencio Users, we may provide those Users with your Personal Information necessary to complete the transaction. Such information includes your blockchain wallet address or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction.

● Should we choose to partner with larger merchant Influencio Users (including marketplace platforms or sites), we retain the rights to integrate our Services into their sites or apps to enable them to transact through Influencio’s Services.

● Following up on the above, if you choose to “link” your Influencio Account with these third party sites, we may provide them with your Influencio Account information, including your Personal Information. By “linking” your Influencio Account, you will also authorise them to interact with your Influencio Account, without any further action or confirmation on your part. To streamline your interactions and to save you time in avoiding having to re-enter all your Personal Information into these third party sites, we may also disclose your Personal Information (including your passport or national identity documents) directly to these merchant Influencio Users to the extent required by them to remain in compliance with the laws and regulations applicable to them.

● We will not disclose your credit card number or bank account number to anyone you have paid or who has paid you using Influencio, or with the third parties that offer or use our Services, unless we have your express permission, or where we are required to do so to comply with our obligations under credit card rules, a subpoena, or any other legal process or investigation.

Our policies and Terms and Conditions expressly prohibits a receiving party from using any Personal Information that we may share with them for unrelated purposes, such as to directly market to you, unless you have agreed to it. Contacting Users with unwanted or threatening messages is also against our policies and constitutes a violation of our Terms and Conditions.

Please note that merchants and other Influencio Users you buy from or contract with have their own privacy policies, and although Influencio’s Terms and Conditions does not allow the other transacting party to use this information for anything other than providing Services, we are not responsible for their actions, including their information protection practices.

8. How we share your personal information with other third parties

Subject to any applicable law, we may also share your Personal Information with the following third parties for the purposes listed below:

● Members of the Influencio corporate family, to provide joint content, products, and services (such as registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of Influencio policies, and to guide decisions about their products, services, and communications. Members of our corporate family will use this information to send you marketing communications if you have requested their services.

● Credit bureaus and collection agencies to report Account information, as permitted by law.

● Banking partners (a) to comply with the requirements of credit card association rules for inclusion on their list of Users (in the event that you meet their criteria which includes having Influencio close your Account due to your breach of our Terms and Conditions); (b) to comply with their anti-money laundering and countering the financing of terrorism requirements; or (c) if we believe that disclosing your information is necessary to help us or our banking partners prevent fraud or assess and manage operational or financial risk.

● Third party payment service providers to facilitate their provision of services to you through our platform.

● Companies that we plan to merge with or acquire or are acquired by. (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your Personal Information. If your Personal Information could be used contrary to this policy, you will receive prior notice.)

● Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to us or one of our affiliates; when we need to do so to comply with the law or credit card rules; or when we believe, at our sole discretion, that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our Terms and Conditions.

● Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise notified and consent to when using a specific service).

● Other unaffiliated third parties, for the following purposes:

● Fraud Prevention and Risk Management: to help them prevent fraud or assess and manage risk. As part of our fraud prevention and risk management efforts, we also may share necessary account information with third parties in cases where we have placed a hold or other restriction on your Account based on disputes, claims, chargebacks or other scenarios regarding your use of the Services

● Customer Service: for customer service purposes, including to help service your Accounts or resolve disputes (e.g., billing or transactional).

● Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing requirements.

● Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.

● KYC (Know Your Customer) service partners, such as [name of KYC service provider], for more information on [KYC service provider] and their privacy policy, please refer to: [KYC Service Provider URL];

Please note that some of these third parties may be based in other countries where the laws on the processing and protection of Personal Information are less stringent than the laws in your country.

Additionally, if you open a separate account directly on a third party website or via a third party application, and/or share any information about your Influencio account on such third party websites, any information that you enter on that website or application (and not directly on a Influencio website) will be shared with the owner of the third party website or application. These sites are governed by their own privacy policies, and you are encouraged to review their privacy policies before providing them with your Personal Information. We are not liable or responsible for the actions or information practices of such third parties.

9. you may access and correct your personal information

We take steps to ensure the Personal Information we collect from you is accurate and up to date, and that you have the ability to access or update/correct it.

9.1 Accessing your Personal Information

● At any time, you may access your Personal Information by connecting your wallet in the Influencio platform and clicking on the KYC status button.

9.2 Accessing/ Updating/ Correcting your Personal Information

It is your responsibility to ensure all Personal Information that you submit to us is complete, accurate, true and correct.

● Please update your personal data immediately if it changes or is inaccurate.

● If you wish to update/correct your Personal Information, please contact us at [email@influencio.io]. We reserve the right to reject your update/correction request if we have reasonable grounds to believe that such an update/correction should not be made.

10. Storage, Security and Retention of Your Personal Information

10.1 Storage

We[A1] store and process your Personal Information in a GDPR compliant data centre operated by Amazon Web Services (AWS), a company of Amazon Web Services Inc.

For more information on the GDPR compliant storage and processing of your data and/or personal information please refer to the official AWS GDPR DATA PROCESSING ADDENDUM: https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf

Further you can find the privacy policy of AWS here: https://aws.amazon.com/privacy/

10.2 Security

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Our data centres and platforms are provided and hosted by Amazon Web Services.

Despite our security precautions, we cannot fully guarantee the security of your Personal Information because of the inherent risks of data transmission over the internet. At all times, you assume the risks associated with the transmission of your Personal Information over the internet and the possibility of malware present on your device used for our Services. Therefore, you should ensure that you only enter or upload your Personal Information on a secure device within a secure environment.

10.3 Retention

We retain your Personal Information for as long as you continue to have a Influencio Account.

● If your Influencio Account is terminated (either by your request or by us), we will retain your Personal Information for at least 5 years after Account termination in order to comply with the regulatory requirements under the laws and regulations applicable to our Services.

● Under certain circumstances we may retain Personal Information from closed Accounts to prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms and Conditions, comply with applicable legal data retention obligations and take other actions permitted by law.

● After it is no longer necessary for us to retain your Personal Information, we will dispose of it in a secure manner according to our data retention and deletion policies.

11. contact us about privacy questions

If you have any questions or concerns regarding this Privacy Policy, please contact us via email at [email@influencio.io]

[A1]Client to confirm storage services. This is a template for AWS.