Effective Date: January 1, 2023
Last Updated: October 17, 2025

Thank you for choosing to be part of the Infraway community. Infraway LLC, doing business as Infraway (“Infraway,” “we,” “us,” or “our”), is committed to protecting your personal information and your right to privacy.

If you have any questions or concerns about this privacy notice or how we handle your data, please contact us at hello@theinfraway.com.

This Privacy Policy explains what information we collect, how we use it, who we share it with, how we protect it, and the rights you have. It applies to all information collected through:

• our website www.theinfraway.com (the “Website”),
  
  

• our mobile application (the “App”), and
  
  

• any related services, sales, marketing, or events (collectively, the “Services”).

By using our Services, you agree to the terms described here. If you do not agree, please discontinue use immediately.

1. Who We Are

For users in the European Economic Area (“EEA”) and the United Kingdom (“UK”), Infraway LLC acts as the data controller responsible for your personal information under this Privacy Policy.

If required by law, we will designate an EU and/or UK representative for data protection matters. You may contact that representative using the information provided at the end of this notice once appointed.

2. Definition of Personal Information

“Personal information” or “personal data” means any information that identifies, relates to, describes, or can reasonably be linked, directly or indirectly, to an identified or identifiable individual.

This includes, for example, your name, contact details, device identifiers, and any data that could reasonably be connected to you.

3. What Information Do We Collect?

a. Information You Provide

We collect personal information that you voluntarily provide when you register, request information, purchase a product, participate in activities, or contact us.
Examples include your name, email address, shipping address, payment details, or communication preferences.

We may also allow you to register or log in using a social-media account (e.g., Facebook, Twitter). If you choose to do so, we collect information from that service consistent with your privacy settings there.

You are responsible for ensuring the information you provide is accurate and kept up to date.

b. Information Collected Automatically

When you visit or use our Services, we automatically collect certain data such as:

• IP address, browser type, operating system, language settings, device identifiers, referring URLs, usage data, and location (country or region).
  This helps maintain security, improve performance, and support analytics.
  
  

Like many companies, we use cookies and similar technologies (such as pixels and web beacons). Details about cookies are provided in Section 12 below.

c. Information Collected Through Our App

When using the Infraway App, we may collect:

• Geolocation data (if you enable it) to provide location-based features.
  
  

• Device data (model, OS version, identifiers, carrier).
  
  

• Device movement data (e.g., step count, motion patterns) used internally to enhance performance, improve features, and troubleshoot.
  
  

• Push-notification preferences (if you enable them).
  
  

You can change permissions in your mobile-device settings at any time.

d. Sensitive Data Clarification

We do not intentionally collect or process sensitive personal information such as health data, biometric identifiers, or genetic information. Movement and location data collected through the App are used only for functionality and analytics and cannot reasonably be used to infer medical or health conditions.

e. Data Minimization

We only collect the personal information necessary to deliver our Services and limit data collection to what is relevant and proportionate.

4. What Is Our Legal Basis for Processing (EEA & UK Users)?

If you are located in the EEA or UK, we process personal information only when a lawful basis applies:

• Contract: to perform our agreement with you (e.g., fulfilling an order or enabling app functions).
  
  

• Legal obligation: to comply with laws (tax, accounting, consumer rights).
  
  

• Legitimate interests: to operate, improve, and secure our business (provided your rights do not override those interests).
  
  

• Consent: when you have given clear permission (e.g., for marketing emails or analytics). You may withdraw consent at any time.
  
  

5. How Do We Use Your Information?

We use personal data to:

• Provide, operate, and maintain the Services.
  
  

• Process orders and transactions.
  
  

• Communicate with you (service updates, customer support, marketing where permitted).
  
  

• Analyze usage to improve performance and develop new features.
  
  

• Detect, prevent, and address fraud or security issues.
  
  

• Comply with legal obligations.
  
  

6. Will Your Information Be Shared with Anyone?

We share personal information only when necessary and in accordance with this notice:

• With service providers and processors that perform work on our behalf (e.g., hosting, analytics, customer support, payment processing).
  Each partner is contractually required to protect your data and may not use it for their own purposes.
  
  

• Business partners or affiliates to offer integrated products or promotions.
  
  

• Legal requirements to comply with law, regulation, or valid legal process.
  
  

• Business transfers in connection with mergers, acquisitions, or financing.
  
  

• Third-party links: Our Services may contain links to third-party websites or applications. We are not responsible for their privacy or data-handling practices.
  
  

We do not sell or share your personal information for cross-context behavioral advertising as defined under the CCPA/CPRA.

7. International Data Transfers

Because Infraway is headquartered in the United States, your personal information may be transferred to and processed there.
When data from the EEA or UK is transferred outside those regions, we rely on safeguards such as the EU–U.S. Data Privacy Framework and Standard Contractual Clauses approved by the European Commission to ensure equivalent protection.

8. How Long Do We Keep Your Information?

We keep personal data only as long as necessary to achieve the purposes described or to meet legal requirements.
When you request deletion, we will anonymize your data within 30 days, retaining only non-identifiable information for internal analytics and operational continuity.
If information is contained in backups, it will be isolated until securely overwritten.

9. How Do We Keep Your Information Safe?

We implement appropriate technical and organizational safeguards—including encryption, access controls, secure servers, and employee confidentiality commitments—to protect your data from unauthorized access, loss, or misuse.
However, no online transmission or storage system is completely secure, and we cannot guarantee absolute security.

10. Do We Collect Information from Minors?

We do not knowingly collect or market to:

• individuals under 18 years old (in the U.S.), or
  
  

• individuals under 16 (in the EEA or UK) without parental consent.
  If we discover we have unintentionally collected such data, we will promptly delete or anonymize it.
  
  

11. What Are Your Privacy Rights?

a. General Rights

You may request to access, correct, delete, or restrict processing of your personal information, or withdraw consent where applicable.
If you previously gave consent to processing (for example, for marketing communications), you may withdraw that consent at any time by clicking “unsubscribe” in our emails or contacting hello@theinfraway.com.
We will verify and respond to valid requests within 30 days and will not discriminate against anyone for exercising these rights.
To protect your data, we may request reasonable information to verify your identity before processing any rights request.

b. GDPR / UK Rights

Residents of the EEA or UK have additional rights to:

• Data portability (receive your data in a structured, machine-readable format).
  
  

• Object to certain processing (including direct marketing).
  
  

• Lodge a complaint with a supervisory authority.
  
  

• EU contacts: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
  
  

• UK contacts: https://ico.org.uk/global/contact-us/
  
  

• Switzerland: https://www.edoeb.admin.ch/edoeb/en/home.html
  
  

c. California (US) Residents

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), you have the right to:

• Know what categories of personal information we collect and why.
  
  

• Access and delete your personal information.
  
  

• Correct inaccurate information.
  
  

• Limit use of sensitive personal information (e.g., precise location).
  
  

• Opt out of sale or sharing of data (Infraway does not sell or share personal information).
  
  

You may make these requests by emailing hello@theinfraway.com.

12. Cookies and Tracking Technologies

We use cookies and similar tracking technologies (like web beacons and pixels) to operate our Services, improve functionality, analyze usage, and personalize content. This section explains what cookies are, how we use them, and how you can control them.

a. What Are Cookies?

Cookies are small text files stored on your device (computer, phone, tablet) when you visit a website or use an app. They help remember your preferences, enable certain features, and gather analytical data to improve performance.

There are two main types:

• Session cookies: Deleted automatically when you close your browser.
  
  

• Persistent cookies: Remain stored until deleted or they expire.
  
  

b. Types of Cookies We Use

c. Third-Party Cookies

Some cookies may be placed by third parties acting on our behalf — for example:

• Google Analytics (to understand traffic and usage patterns)
  
  

• Shopify or Stripe (to process transactions)
  
  

• Apple or Android SDKs (for app functionality)
  
  

These third parties may use cookies according to their own privacy policies. We review these providers to ensure they maintain appropriate safeguards.

d. How to Manage or Disable Cookies

You can manage cookie preferences through:

• Browser settings: Accept, refuse, or delete cookies.
  
  

• Device settings: Mobile operating systems may offer “Limit Ad Tracking” or similar privacy controls.
  
  

• Cookie consent banner: When visiting our website from certain regions (e.g., EU/UK), you’ll see a banner to manage preferences or withdraw consent at any time.
  
  

If you disable cookies, some features of the Website or App may not function properly.
If you provide consent through our cookie banner, we store that preference for 12 months (or as required by law) before asking you again.

e. How Long Cookies Are Stored

Cookies remain active for different periods depending on their type and purpose — typically from a few minutes to two years. You can manually clear them at any time.

f. Updates to This Cookie Policy

We may update this Cookie section to reflect changes in technology or legal requirements. The “Last Updated” date at the top of this Privacy Policy will reflect the most recent change.

g. Questions

If you have any questions about our cookie practices or how your preferences are handled, please contact us at hello@theinfraway.com.

13. Automated Decision-Making and Profiling

We may analyze aggregated motion or activity data to improve performance and features. This analysis does not produce legal or significant effects on individual users.

14. Data Breach Notification

If a data breach occurs that affects your personal information, we will notify you and relevant authorities as required by law.

15. Data Processing Addendum (Business Partners)

For business customers or partners who require a Data Processing Addendum (DPA) consistent with Article 28 of the GDPR or other applicable law, please contact hello@theinfraway.com to request a copy.

16. Do-Not-Track Signals

Because no uniform standard for recognizing Do-Not-Track (DNT) signals exists, we do not currently respond to DNT browser signals. If a standard emerges, we will update this notice accordingly.

17. Accessibility Statement

We are committed to ensuring that this Privacy Policy is accessible to individuals with disabilities. If you need it in an alternative format, please contact us at hello@theinfraway.com.

18. Changes to This Notice

We may update this policy periodically. The “Last Updated” date indicates the latest revision.
If we make material changes, we will notify you via email, in-app alert, or prominent notice on our Website.
Continuing to use the Services after changes become effective means you accept the revised policy.

19. Governing Law

This Privacy Policy is governed by the laws of the State of California, United States, without regard to conflict-of-law rules.
If you reside in the EEA or UK, your local laws may provide additional rights that supersede certain provisions.

20. Contact Us

Infraway LLC
447 Sutter Street Suite 405 #401
San Francisco, CA 94108 USA
hello@theinfraway.com

For privacy questions in the EEA or UK, you may contact our privacy team at the same email or, once appointed, our local representative for data protection matters.
You also have the right to lodge a complaint with your local data-protection authority if you believe your rights have been violated.

21. How to Review, Update, or Delete Your Data

To access, update, or delete the personal information we hold about you—or to exercise any privacy rights—email hello@theinfraway.com with your request.

Upon verified request, we will deactivate your account and anonymize all associated data within 30 days.

Policy last reviewed internally on: October 17, 2025
Policy Version: v3.0