Privacy Policy

Updated 04.28.25

Infinity⁹ (“Infinity⁹,” “we,” “our,” or “us”) is committed to protecting the personal data of our investors, prospective clients, partners, and visitors (“you” or “your”). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you engage with us—whether through our website, digital communications, or as part of our investment and advisory activities.

We adhere to applicable privacy and data protection laws in the United States, as well as in Latin American jurisdictions, including (but not limited to) Ecuador’s Ley Orgánica de Protección de Datos Personales, Mexico’s Ley Federal de Protección de Datos Personales en Posesión de los Particulares, Colombia’s Ley 1581 de 2012, Chile’s Law 19.628, and others, as relevant to our operations and your residency.

1. Who We Are

Infinity⁹ is a U.S.-based investment management firm that structures, manages, and co-invests in institutional-grade real estate opportunities across the United States. We serve international clients—particularly from Latin America and the Middle East—who seek trusted access to U.S. private market investments.

2. Information We Collect

a. Personal Information You Provide Directly

We may collect and process the following personal data:
• Full name
• Email address
• Phone number
• Country and city of residence
• Citizenship and/or tax residency
• Professional background and investment profile
• Investment qualifications (e.g., accredited investor status)
• Identity verification documents, such as passports or government-issued IDs (as required for Know Your Customer / AML compliance)
• Any other data you choose to provide through forms, onboarding portals, or direct communications

b. Information We Collect Automatically

When you interact with our website, we may automatically collect:
• IP address and geolocation
• Browser type and device information
• Session duration, page views, and referring URLs
• Cookie and tracking technology data (see Section 7 below)

3. Legal Basis for Processing

Our collection and processing of your data is based on one or more of the following legal grounds:
• Your express consent (e.g., when subscribing or submitting a form)
• Performance of a contract or steps prior to entering into one
• Compliance with legal obligations, including AML, KYC, and regulatory disclosures
• Legitimate interest in managing our business, improving our services, and ensuring secure operations

Where required under local regulations, we will obtain your explicit consent prior to processing your data.

4. How We Use Your Information

We use your personal information to:
• Evaluate your eligibility to access investment opportunities
• Comply with legal and regulatory obligations (AML/KYC, OFAC screening, etc.)
• Maintain contact and provide investment-related updates
• Provide onboarding, transactional, and client support services
• Improve website functionality, content performance, and user experience
• Send educational materials, thought leadership content, and relevant announcements (only if you opt-in)

We do not use your data for profiling or automated decision-making without human review.

5. Data Sharing and Disclosure

We do not sell or rent your personal information.

We may share your data with the following third parties, under strict confidentiality and data protection obligations:

  • Fund administrators, compliance partners, and legal advisors
  • Technology service providers (e.g., CRM, analytics, document management platforms)
  • Banking and custodial partners for transaction processing
  • Regulatory bodies or law enforcement, where legally required

In cross-border scenarios, we ensure that transfers of personal data from Latin America to the United States or other jurisdictions are made in compliance with local legal requirements, including the use of standard contractual clauses, adequacy decisions, or lawful exceptions.

6. Data Subject Rights

You may have the following rights under applicable law:

  • Right to access the personal data we hold about you
  • Right to rectify inaccurate or incomplete data
  • Right to withdraw consent at any time
  • Right to object to or restrict processing under certain conditions
  • Right to request deletion (“right to be forgotten”) where applicable
  • Right to data portability (where applicable)

To exercise any of these rights, please email: privacy@infinity9.com

We will respond within the time frame required by law in your jurisdiction (typically 15–30 days).

7. Cookies and Analytics

We use cookies and third-party analytics tools (such as Google Analytics) to improve our website’s performance and understand user behavior. These cookies may track:

  • Session identifiers
  • Language preferences
  • User interactions and navigation flow
  • Referring sources

You can control or delete cookies via your browser settings. Some functionality may be affected if cookies are disabled.

8. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this policy, or as required by law, including record-keeping and regulatory obligations. This may include retention periods beyond the termination of a relationship or contract.

9. Security and Safeguards

Infinity⁹ employs industry-standard security practices to protect your data, including:

  • Encrypted storage and secure access protocols
  • Multi-factor authentication on sensitive systems
  • Strict internal access controls and confidentiality agreements
  • Regular audits and third-party assessments

While no system is completely immune to risk, we take our responsibility seriously and actively mitigate potential vulnerabilities.

10. Minors and Sensitive Data

Our services are intended for individuals over 18 years of age. We do not knowingly collect information from minors or process sensitive personal data (e.g., health, religion, political views) unless legally required to do so.

11. Third-Party Websites

Our website may include links to third-party platforms. This Privacy Policy does not apply to those sites. We recommend reviewing their policies before submitting any personal data.

12. International Data Transfers

As a U.S.-based firm serving international clients, we may transfer your information across borders. Where applicable, we will implement safeguards in accordance with the data protection laws of your country (e.g., transfer mechanisms permitted under Latin American laws modeled on GDPR).

13. Changes to This Policy

We reserve the right to modify this Privacy Policy at any time to reflect changes in law, regulation, or business practices. When we do, we will update the “Effective Date” at the top of this page. Significant changes will be communicated to you directly where feasible.

14. Contact Us

For any questions about this Privacy Policy or to exercise your rights, please contact us:

Infinity⁹ Compliance Office

Email: legal@infinity9.com

Address: 801 Brickell Ave. Suite 800, Miami FL, 33131

Website: www.infinity9.com