Last updated: September 1, 2026
This Privacy Policy explains how Init Capital Limited ("INFINIT", "we", "us") handles personal information in connection with the INFINIT marketplace.
It covers:
the website at infinit.tech
the marketplace application at app.infinit.tech
the documentation site at docs.infinit.tech
correspondence with us by email or through our community channels
applications from prospective vault curators
Init Capital Limited is the data controller for the information described in this Policy. It should be read together with our Legal Disclaimer, Terms of Use and Risk Disclosure.
This Policy does not cover the practices of vault curators, exchanges, wallet providers or blockchain networks, each of which is an independent party with its own policies.
The marketplace is designed to operate with as little personal information as possible. We do not require depositors to open an account, submit identity documents, or provide proof of address. Access is by wallet connection.
Prospective curators are treated differently. A curator applying to list a vault is a business counterparty and is subject to business verification checks, described in section 6.
| Information | How we get it | Why we have it |
|---|---|---|
| Wallet address | You connect a wallet, or you transact with a vault contract | Required to operate the marketplace: to display your position, to attribute deposits and redemptions, and to issue and redeem receipt tokens |
| On-chain transaction data | Public blockchain records associated with your wallet address | To calculate balances and settle redemptions, and for sanctions and illicit-activity screening |
| IP address and approximate location derived from it | Automatically, when you load the site | To apply the jurisdictional access restrictions described in section 4, and to protect the site against abuse |
| Device and browser information, including browser type, operating system, language and referring page | Automatically, when you load the site | Site security, error diagnosis and basic availability monitoring |
| Email address and message content | Only when you choose to write to us or to subscribe to updates | To answer you, and to send updates you have asked for |
| Social handle and message content | Only when you choose to contact us on X, Discord or Telegram | To answer you |
We do not collect government-issued identity documents, proof of address, or other identity verification material from depositors.
Where you apply to operate a vault on the marketplace, we collect, from you and from our verification provider:
corporate registry information for the applicant entity, including registration number, registered address, directors and shareholding
identity information for beneficial owners and controlling persons
sanctions, adverse media and politically exposed person screening results
corporate documents you submit, such as constitutional documents and ownership charts
business, contact and commercial information exchanged during onboarding
We do not sell personal information. We do not share it with advertisers, and we do not use it to build advertising profiles.
The marketplace is not available to persons located in the United States, in Singapore, or in any territory subject to comprehensive sanctions administered by the U.S. Office of Foreign Assets Control.
To apply those restrictions we determine an approximate location from your IP address at the point you load the site, and block access where the result falls in a restricted territory. We use the IP address for that purpose and for site security. We do not use it to identify you personally, and we do not combine it with your wallet address to build a profile of you.
Where a vault or an applicable law requires it, wallet addresses interacting with the marketplace may be screened against sanctions lists, including OFAC and United Nations lists, and against datasets of addresses associated with illicit activity. Screening is carried out through established blockchain analytics providers.
A screening hit may result in a deposit being refused, a redemption being delayed, or a report being made to the relevant authority where we are required to make one.
Screening operates on public blockchain data and on the wallet address you present. It does not require you to give us any identity information.
Applicants to operate a vault on the marketplace are verified before they are listed. Verification covers the applicant entity, its beneficial owners and its controlling persons, and is carried out through a specialist verification provider engaged by us.
The provider collects the supporting material directly from the applicant, performs the checks, holds the underlying records, and returns to us the verification outcome and the review record. It acts on our instructions and may not use the material for any other purpose. Applicants are given the provider's own privacy notice at the point they are asked for information.
Verification does not apply to depositors. Where a check carries an ongoing monitoring obligation, the entity and the individuals concerned are re-screened periodically for as long as the curator relationship continues.
We do not link a wallet address to an email address, a social handle or a real-world identity. Those records are held separately and are only connected if you connect them yourself, for example by writing to us from an email address and identifying the wallet you are asking about.
| Purpose | Basis |
|---|---|
| Operating the marketplace, displaying positions, issuing and redeeming receipt tokens | Performance of the contract between you and us under our Terms of Use, and our legitimate interest in running the service |
| Applying jurisdictional access restrictions | Compliance with legal obligations, and our legitimate interest in restricting access to permitted jurisdictions |
| Sanctions and illicit-activity screening | Compliance with legal obligations, and our legitimate interest in preventing financial crime |
| Curator business verification and beneficial owner checks | Compliance with legal obligations, and our legitimate interest in verifying counterparties before they are given control of a vault |
| Answering your correspondence | Our legitimate interest in responding to you |
| Sending updates you have subscribed to | Your consent, which you may withdraw at any time |
| Site security, error diagnosis and abuse prevention | Our legitimate interest in keeping the service available and secure |
| Responding to lawful requests from authorities, and establishing or defending legal claims | Compliance with legal obligations, and our legitimate interest in defending claims |
The marketplace uses browser storage that is strictly necessary for the site to function, including retaining your wallet connection state and your interface preferences between visits. These are not used for advertising and are not shared.
We do not run advertising cookies or third-party tracking pixels.
We share personal information with:
Our verification provider, for the curator checks described in section 6.
Blockchain analytics providers, for any screening described in section 5.
Infrastructure and service providers who process information on our instructions, including hosting and content delivery providers, blockchain node and RPC providers, monitoring and error reporting providers, and communications providers. Each is engaged under terms that restrict use of the information to the services provided to us.
Professional advisers, including legal, audit and accounting advisers, where reasonably required.
Authorities and law enforcement, where we are required to disclose by applicable law or valid legal process, or where disclosure is necessary to establish or defend legal claims.
A successor entity, in connection with a reorganisation, merger or transfer of the business, subject to this Policy continuing to apply.
Vault curators do not receive depositor personal information from us.
We and our providers operate across multiple jurisdictions, and your information may be processed in a country other than the one you are in. Where information is transferred internationally, we require the receiving party to be bound by contractual terms that oblige it to protect the information to the standard set out in this Policy and to process it only on our instructions.
| Category | Retention |
|---|---|
| Curator verification records, including screening results and the review record | Five years after the curator relationship ends, or longer where a specific legal obligation or an open investigation requires it |
| Screening records relating to wallet addresses | Five years from the date of the screen |
| Server and security logs, including IP address | Twelve months, except where a record is retained for a specific investigation |
| Correspondence | Two years from the last message, unless it relates to a dispute or a legal claim |
| Subscription email address | Until you unsubscribe, and then a suppression record so that we do not contact you again |
| Wallet addresses and transaction data recorded on a blockchain | Permanent, and outside our control. See section 12 |
Deposits, redemptions and receipt token movements are recorded on a public blockchain. Those records are maintained by the network, not by us. They are public, permanent and replicated across independent nodes.
We cannot amend, erase or restrict blockchain records, and no deletion request we receive can change them. Anyone can inspect a wallet address and its full transaction history, and a wallet address may be linked to your identity by a third party using information we neither hold nor control. Consider this before connecting a wallet that is associated with your identity elsewhere.
Subject to applicable law, you may ask us to:
confirm whether we hold information about you, and give you a copy of it
correct information that is inaccurate or incomplete
delete information we no longer have a lawful reason to keep
restrict how we use information, or object to our use of it where we rely on a legitimate interest
provide information you gave us in a portable format
withdraw consent, where our use rests on consent, without affecting anything done before you withdrew it
Two limits apply. We cannot delete or amend blockchain records, for the reasons in section 12. And we cannot delete verification and screening records that we are required to retain, for the periods in section 11.
To make a request, contact us at privacy@infinit.tech. We will respond within thirty days. We may ask you to demonstrate control of the wallet address concerned, by signing a message from it, before we act on a request relating to that address. Where the records are held by a provider on our behalf, we will pass your request to that provider.
If you consider that we have not handled your information properly, you may complain to the data protection authority in your jurisdiction.
We restrict access to personal information to those who need it, hold operational keys in a multi-signature arrangement with hardware-backed signers, and require our providers to maintain appropriate security controls.
No system is fully secure. We do not guarantee that our security measures will prevent every unauthorised access, and you connect a wallet and transact at your own risk, as set out in our Terms of Use.
The marketplace is not available to anyone under 18, or under the age of majority in their jurisdiction if that age is higher. We do not knowingly collect information from children. If you believe a child has provided information to us, contact us and we will delete it.
We may update this Policy. Where a change is material, we will post the updated Policy with a new "Last updated" date and give notice through the marketplace interface not less than seven days before it takes effect. Continued use of the marketplace after that date means you accept the updated Policy.
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