Privacy Policy – Framework
- Responsible Entities
- Infina Ltd (UK) and InfinaTech Inc (USA) jointly process data.
- UK data (GDPR) processed under UK law; U.S. data processed under U.S. privacy laws (e.g. CCPA, COPPA where applicable).
- Data Collected
- Personal info: name, email, phone number, payment details, cohort activity.
- Behavioral data: video watches, quiz results, GitHub repo metrics.
- Optional data: job outcome for job-guarantee cohorts.
- Legal Bases
- Contractual necessity: to deliver services you signed up for.
- Legitimate interest: for platform improvements and analytics.
- Consent: for marketing—opt-in only, with opt-out line in every email.
- Use Cases
- Deliver course content, manage bookings, and enforce terms.
- Marketing (only if opted in), automated recommendations, and feedback surveys.
- Alumni validation (permission-based project showcases).
- Sharing Data
- We do not sell your data.
- We may share with:
- Affiliate or partner organizations for pilot programs (e.g. client POC sponsors).
- Analytics & infrastructure providers on a subprocessor basis (Google, Stripe, AWS).
- All subprocessors bound by strict data protection terms.
- Data Storage & Retention
- Retained for as long as you are an active learner, then archived for 5 additional years (for alumni, employability tracking).
- Data stored in UK or U.S.-based AWS servers (ISO 27001 certified) with encryption in transit and at rest.
- Your Rights
- UK Clients (under GDPR): right to access, rectification, erasure, restriction, data portability, objection.
- US Clients (under CCPA): right to access, deletion, “do not sell.”
- Opt-out by emailing hello@joininfinatech.com.
- Lawful requests handled within 30 days.
- Children & Minors
- Not intended for minors. Applicants under 18 must have written guardian consent. No unaccompanied minor enrollments.
- Security
- Infina employs industry-standard security: MFA, annual penetration tests, quarterly code audits, and logging.
- In the event of a breach, you’ll be notified within 72 hours in compliance with GDPR/CCPA.
- Updates to Policy
- We may update this policy. You’ll be notified by email 45 days prior to any material changes requiring opt-in again.