Privacy Policy

Last Updated as of 20 AUGUST 2025

At Infini Labs (referred to here as "Infini", "we", "us" or "our"), we respect and protect the privacy of the users ("you" and "your" or "Users", as relevant) who explore and use our products through the website, the applications or any other tools we operate (collectively, the "Services").


This Privacy Policy describes how we collect, use, process, manage and disclose your personal data when you use our Services. This Privacy Policy includes:

  • the types of personal data which we will collect or process;
  • how personal data will be used, disclosed and protected; and
  • your rights in relation to personal data.

We may modify this Privacy Policy from time to time in which case we will update the "Last Updated" date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on our website (the "Site") or our application (the "APP"), or by other means consistent with applicable law) and will take additional steps as required by applicable law. After the publication of the new version of this Privacy Policy, your continued use of the our Site or APP or your continued relationship with us shall be deemed to be acceptance of and consent (to the extent that consent is the relevant legal basis of processing your personal data) to this updated Privacy Policy, as amended from time to time.


Infini will take reasonable and practicable steps to ensure the security of your personal data and to avoid unauthorised or accidental access, erasure or use for other purposes. This includes physical, technical, and procedural security methods, where appropriate, to ensure that your personal data may only be accessed by authorised personnel.


Please note that if you do not provide Infini with personal data (or relevant personal data relating to persons appointed by you to act on your behalf), we may not be able to provide the information, products or services you have asked for or process your requests, applications, subscriptions or registrations, as applicable.


Please note that Infini do not control websites, applications, or services operated by third parties, and we are not responsible for their actions. We encourage you to review the privacy policies of the other websites, decentralized applications, and services you use to access or interact with our Services.


If you have any questions about this Privacy Policy or how Infini uses your personal data, please contact us through the communication channels set out in the "Contact Us" section below.

1、OUR COLLECTION OF PERSONAL DATA

Personal data may be collected from you on a voluntary basis for particular purposes or services. Sometimes we collect your personal data automatically when you interact with our services, and sometimes we collect your personal data directly from yourself. At times, we may collect personal data about you from other sources and third parties, even before our first direct interaction.

2、WHAT PERSONAL DATA WE COLLECT

We may collect your following personal data in connection with our services:

1）Information you provide during "Know Your Customer" ("KYC") and Anti-Money Laundering ("AML") processes, which includes personal identifying information. This may include:

Basic Information: name, address, date of birth, nationality, country of residence, phone number, email address.

Identification Information: utility bills (or other proof of address), photographs, Government-issued identification (such as identification cards, passports, driver's licenses, etc.), tax ID number, employment information, proof of residency, visa information, organizational documents, and information regarding ultimate beneficial owners.

Financial Information: income/net assets/treasury verification statements,on-chain asset balances (e.g., holdings of USDT/USDC), transaction records (including deposits, consumption, redemptions), and return details (such as annualized returns and commission rebates).

Payment Information: consumption records (including the amount, time, and merchant details); preferred payment methods (such as integration with Apple Pay).

2）If you are a company or other legal entity, the information may include :

Basic Information of Your Shareholders or Directors : name, address, date of birth, nationality, country of residence, phone number, email address.

Identification Information of Your Shareholders or Directors: utility bills (or other proof of address), photographs, Government-issued identification (such as identification cards, passports, driver's licenses, etc.), tax ID number, employment information, proof of residency, visa information, organizational documents, and information regarding ultimate beneficial owners.

Corporate Information: Company name, address, business type, registration details.

Financial Data: Asset scale (such as AUM details), transaction records (payments, investment redemptions), income details (strategy yield rates, profit-sharing data).

Payment and Billing Data: API integration parameters, payment order details (amount, time, customer information), invoice content (such as payer memo).

Operational Logs: Account activities (such as strategy selection, redemption requests), device logs.

3) Information collected automatically

Browser and Device Information

IP address/derived location information

Device type (mobile/desktop), operation log (e.g., account management)

Other device characteristics or identifiers (e.g. plugins, the network you connect to)

4）Information we obtain from third parties

Information from Analytics Providers: We receive information about your website usage and interactions from third party analytics providers. This includes browser fingerprint, device information, and IP address.

Error Tracking Data: We utilize information from third party service providers to provide automated error monitoring, reporting, alerting and diagnostic capture for Service and Site errors to allow Users to build more effectively.

3、OUR USE OF PERSONAL DATA

From time to time, where personal data is provided to Infini, we may use the personal data as explained below and such personal data may be transferred to a place outside your jurisdiction.

In general, for all external parties, we use your personal data for the purpose directly related to the function or activity of Infini, to comply with legal requirements, to carry out obligations arising from the contracts entered between you and us (if any). We have specified the purposes of use of your personal data in this "OUR USE OF PERSONAL DATA" section. We may also notify you of other purposes at the time of collection of the personal data.

We use the personal data we collect to:

  • Manage your account and its day-to-day operations;
  • Process your applications, subscriptions and registration for our products and services.
  • Administer your accounts and provide you with our products and services.
  • Provide you with the online services available at through our Site and/or through other telecommunication channels.
  • Market our services to you, including through in-person events, social media, email, and other online venues, based on your interests and interactions with us;
  • Administer, provide, maintain, improve, and personalize our products and services, including by recognizing you and remembering your personal data when you return to our services;
  • Help us to facilitate transactions and individual benefits and services, including customer support, contests, sweepstakes, and promotions;
  • Identify and analyze how you use our services;
  • Help us to monitor and analyze trends, usage, and activities in connection with our services;
  • Help us to improve and customize our services to address the needs and interests of our user base and other individuals we interact with;
  • Help us to test, enhance, update, and monitor the services, or diagnose or fix technology problems;
  • Help us to maintain the safety, security, and integrity of our services, technology assets, and business;
  • Help us to detect, prevent, investigate, or provide notice of malicious, deceptive, fraudulent, unlawful or criminal activity;
  • Comply with legal obligations.

If your jurisdiction includes countries or regions with special requirements for the use or protection of personal data, we will comply with those requirements unless permitted otherwise by applicable law.

4、OUR DISCLOSURE OF YOUR PERSONAL DATA

Infini may be required to retain, process and/or disclose your personal data to agents, contractors or other third-party service providers, to which we do not assume any liability for any loss or damage that you may sustain, in order to:

  • comply with a court order, subpoena or other legal process (whether in which jurisdiction); comply with applicable laws and regulations;
  • comply with a request by a government authority, law enforcement agency or similar body (whether in which jurisdiction);
  • provide to the third-party database for submitting behaviors concerning anti-money laundering, terrorism financing, and evading trade and economic sanctions;
  • provide to a third party which provide services (such as legal, financial, management, operation, market surveillance, analytic or technical services) or is associated or acting as a nominee to Infini;
  • provide to any third party to whom our businesses or any part of our businesses will be sold, assigned or transferred to, if applicable; or

Infini may need to retain, process and/or disclose your personal data in order to enforce any agreement with you, protect our rights, property or safety, or the rights, property or safety of our employees.

5、COOKIES AND RELATED TECHNOLOGIES

If you access Infini's information or services through the Site or the APP, you should be aware that cookies are used. We and our third-party providers may use (i) cookies or small data files that are stored on your computer and (ii) other, similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, "cookies") to automatically collect your information and use or disclose your information for the purposes described in the sections above. For example, our services use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to collect and view reports about the traffic on our website. You can obtain more information on the use of Google Analytics by visiting Google's privacy policy here and you can view Google's currently available opt-out options here.

6、CHOICE RELATING TO THE USE OF COOKIES ON OUR PLATFORM SERVICES

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receives a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our website, as some features and offerings may not work properly or at all. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

The legal basis for the setting of cookies are legitimate interests under Art. 6 para. 1 letter f) GDPR and, if applicable, Your consent in accordance with Art. 6 (1) (b) GDPR. In the case of the initiation of a contract or an ongoing contractual relationship, the legal basis also follows from Art. 6 para. 1 sentence 1 letter b) GDPR.

7、PUBLIC INFORMATION OBSERVED FROM BLOCKCHAINS

We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding holdings, purchases, sales, or transfers of tokens, which may then be associated with other data you have provided to us.

8、CHILDREN'S PERSONAL INFORMATION

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

9、LINKS TO THIRD-PARTY WEBSITE OR SERVICES

Our services may include links to third-party websites, plug-ins, and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

10、THIRD-PARTY WALLET EXTENSIONS

Certain transactions conducted through our services require you to connect your wallet to our services. By using such third-party wallets for transactions, you agree that your interactions with such third-party wallets are governed by their privacy policies. We expressly disclaim any responsibility for any actions arising from the use of third-party wallets, including but not limited to any consequences arising from the use or disclosure of personal information by third-party wallets.

11、OUR TRANSFER OF YOUR PERSONAL DATA

For one or more of the purposes specified above, we may transfer your personal data outside your jurisdiction to any agents, contractors or other third-party service providers who provide administrative, telecommunications, computer, payment, debt collection, data processing, data storage, data analytics or other services to us in different countries or regions, and other third parties as notified at the time of collection.

We may also share your personal data within our group of companies for providing the products and services sought by you for the same purpose or directly related to the purposes at the time of collection.

We may rely on your consent for data transfer or adopt contractual and/or other means to ensure the agents, contractors or other third-party data processors who process personal data on behalf of us will take all reasonable steps to (i) protect the personal data they hold against unauthorized or accidental access, processing, erasure, loss or use; and(ii) ensure that personal data will not be kept longer than necessary.

12、PROTECTION OF PERSONAL DATA

All personal data provided to us will be securely stored with restricted access by authorized personnel only. We utilize encryption/security software for data transmission so as to protect your data via encrypting it in a secure format to ensure its privacy and security from unauthorised access or disclosure, accidental loss, alteration or destruction.

In addition, we may rely on your consent or adopt contractual or other means to prevent any personal data transferred to our data processors (i) from being kept longer than is necessary for processing of the data; and (ii) from unauthorized or accidental access, processing, erasure, loss or use, if we are to engage any data processor. For those located in the EU or the UK, we are required to impose the mandatory contractual obligations on our data processors in compliance with EU GDPR and UK GDPR.

Nevertheless, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our Site. Once your personal data is received, we will use strict procedures and security features to try to prevent unauthorized access.

If you suspect any misuse, loss of, or unauthorised access to your personal data, please let us know immediately following the details set out in the Section "Contact Us" below.

13、RETENTION OF YOUR PERSONAL DATA

We aim to retain your personal data no longer than is necessary for the fulfilment of the purposes of collection unless a longer retention period is required or permitted by applicable laws, rules and regulations. The precise length of time will depend on the type of data, our legitimate business needs, and other legal requirements that may require us to retain it for certain minimum periods.

We may be required to retain certain data for the purposes of tax reporting or responding to tax queries. In other instances, there may be some other legal or risk management requirements to retain data, including where certain data might be relevant to any potential litigation (bearing in mind the relevant limitation periods).

In determining the appropriate retention period for different types of personal data, we always consider the amount, nature, and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition of course to ensuring that we comply with our legal and risk management obligations, as described above).

Once we have determined that we no longer need to hold your personal data, we will delete it from our systems.

We will take commercially reasonable steps to ensure the accuracy of your personal data held by us. If we become aware that the personal data is inaccurate, we will not use such data and will notify any third party to which such personal data has been transferred regarding the same.

14、YOUR RIGHTS

Under applicable data privacy laws, you may have the right to request for access to your personal data, to obtain a copy of the personal data, to correct any personal data that is inaccurate and to delete or cease the collection, processing or use of any personal data. You can also request us to inform you of the type of personal data held by us.

Request for access and correction of personal data or for information regarding policies and practices and kinds of data held by us should be addressed in writing and sent to us by post or by email following the details set out in the Section "Contact US" below.

In accordance with the terms of applicable laws, we have the right to charge a reasonable fee for the processing of any data access request.

In addition, the EU GDPR and UK GDPR offer various protections and clarify the rights of citizens and individuals in the EU or the UK, with regard to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us.

15、INFORMATION FOR CALIFORNIA RESIDENTS

In addition to the information and rights described in this Privacy Policy, residents of California have additional rights and access to specific information under the California Consumer Privacy Act ("CCPA") concerning their personal information. This section of the Privacy Policy applies to you if you are a California resident (referred to as a "Consumer" as defined by the CCPA). If you are not a Consumer, this section does not apply to you, and you should not rely on it.

1） Information Collection and Usage

The following is a summary of the personal information (as defined by the CCPA) we collect and use in connection with our Services for commercial and business purposes. For more details, please refer to the relevant sections of this Privacy Policy.

Categories of Personal Information we may collect and use for commercial and business purposes:

  • Contact and account registration information: When you register for an account or get in touch with us, you may provide us with your name, email address, physical address, phone number, account username and password, electronic signature, and other relevant details.
  • Financial or payment information: We collect information related to the payment methods you provide, billing details, and information about the products or services you purchase.
  • Transaction information: When you use our Services for transactions, we may collect the names and email addresses of transaction participants, subject lines, the history of actions taken within a transaction (e.g., reviews, signatures, enabling features), and personal information of individuals involved or their devices, such as names, email addresses, IP addresses, and authentication methods.
  • Customer service information: We gather information regarding your customer service interactions with us, including any questions or messages you send us directly through online forms, email, phone, or mail.
  • Information about your web browser, mobile device, or internet connection: When you access our Services online, we may automatically collect your IP address, device identifiers, device attributes (including cookie IDs and mobile advertising IDs), data on how you interact with our online Services (usage data), location information (such as city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation), and, with your permission based on your mobile device settings, precise geolocation information obtained from GPS functionality on your mobile device.

Commercial and Business Purposes for Using Collected Personal Information:

  • Providing requested products and services to you and processing payments.
  • Creating and managing your account, and maintaining our relationship with you (e.g., communication, providing requested information).
  • Sending you transaction records, including those related to purchases or other events.
  • Marketing features, products, or special events via email or phone, and sending you marketing communications about third-party products and services we believe may interest you.
  • Conducting sweepstakes, contests, and refer-a-friend programs.
  • Selecting and delivering tailored content and advertising, and supporting marketing and advertising efforts for our Services.
  • Generating and analyzing data about our users and their usage of our Services.
  • Testing changes and developing new features and products for our Services.
  • Addressing issues you may encounter with our Services, including providing support and resolving disputes.
  • Managing the Services platform, including support systems and security.
  • Preventing, investigating, and responding to fraud, unauthorized access or use of our Services, violations of terms and policies, or other inappropriate activities.
  • Complying with legal obligations and applicable retention periods.
  • Establishing, exercising, or defending our rights in legal claims.

2）The Right to Opt Out of Personal Information Sales

Consumers have the right to opt out of the "sales" of their personal information as defined by the CCPA. According to the CCPA, with certain exceptions, a "sale" occurs when a business sells, rents, releases, discloses, disseminates, makes available, transfers, or otherwise communicates orally, in writing, or electronically, a consumer's personal information to another business or a third party in exchange for monetary or other valuable consideration.

As explained in more detail in other part of this Privacy Policy, we share personal information with other companies. Consumers can submit requests to opt out of such sharing using the following methods:

  • Adjusting cookie settings and selecting the option to opt out of respective cookie activities.
  • Clicking the "unsubscribe" link at the bottom of any Project marketing communication.

3）The Right to Access

Consumers have the right to request specific details about the personal information we have collected about them within the past 12 months. This includes the right to request:

  • The specific pieces of personal information and categories of personal information we collected about them.
  • The categories of personal information we sold or disclosed for business purposes and the categories of third parties to whom we sold or disclosed that information for a business purpose.
  • The categories of sources from which we collected personal information.

4）The Right to Deletion

Consumers have the right to request the deletion of personal information we have collected from them. However, the CCPA allows us to retain information in certain circumstances (e.g., legal obligations, specific exceptions outlined by the CCPA).

5）How to Exercise Access and Deletion Rights

Consumers can submit requests for accessing or deleting their personal information by accessing and reviewing personal information associated with your account by contacting us via contact@infini.money.

For security purposes, we will verify your identity before fulfilling your request. If you have an account with us, we may verify your identity by having you log in. If you don't have an account, we may need to contact you or request additional information (such as your name, email address, or telephone number) to verify your identity.

Once your identity is verified, we will respond to your request to the extent permitted by law. If we're unable to verify your identity, we may ask for more information or deny your request. If we can't fulfill your request completely, we will provide you with further details explaining why.

Please note that certain personal information may be exempt from these requests under applicable law. Additionally, we require certain types of personal information to provide our products and services. If you request deletion of such information, you may no longer be able to access or use our products and services.

6）The Right to Nondiscrimination

Consumers have the right to be free from discrimination for exercising their CCPA rights.

We will not deny, charge different prices for, or provide a different level of quality of goods or services with respect to Consumers who choose to exercise their CCPA rights.

7）Authorized Agents

If you designate an agent to make CCPA requests on your behalf, we will verify both your identity and your agent's authorization to act on your behalf. We may request a signed written authorization or a copy of a power of attorney to verify the agent's authority.

8）"Shine the Light"

If you are a California resident, you have the right to request a list of third parties that received your personal information for direct marketing purposes in the previous year. This list will include the types of personal information shared. We provide this list at no cost. To request this information, please contact us via the Site.

16、ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area ("EEA"), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

  • To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
  • When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
  • To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of communications).
  • When we have your consent to do so (e.g., when you opt in to receive communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please contact us at contact@infini.money.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

  • For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
  • For individuals in the UK: https://ico.org.uk/global/contact-us/
  • For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

17、UPDATES TO THIS PRIVACY POLICY

We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you by email to your registered email address, by prominent posting on our services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

18、CONTACT US

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to contact@infini.money.