Privacy Policy

Privacy highlights

Your privacy is very important to us. For that reason, we have provided you the highlights of our Privacy Policy, with clear indicators of our privacy practices and references to the full privacy policy.

Collection and sale of data

Do we sell your personal information? (sec 13)

With your consent, do we share or sell aggregated information? (sec 13)

With your consent, do we share your data with third party API partners? (sec 13)

Do we use sensitive categories of data, like carbon activities?

Do we use your contact list if you allow us access? (sec 6)

Do we delete your data when you request account deletion?

Do we retain your data for as long as we need it unless you request deletion?

Privacy tools and controls

Can you delete your data? (sec 15.4)

Are your activity and profile privacy controls set to “Everyone” by default? (sec 14.2)

Can you control who sees your activity and content? (sec 14.2)

Do all users worldwide have the same suite of tools and controls? (sec 16)

Communications

Do we give you advance notice when we make important changes to our Privacy Policy?

Do we send you marketing communications with opt out?

Do we send you push notifications with opt out?

Recording and tracking

Do we use cookies? (sec 10)

Do we track your device location to provide Infini to you? (sec 4)

Do we track your device location while you are not using the app? (sec 4)

Do we track your browsing activities on other sites?

Do we listen to you using your device microphone?

Privacy policy details

1.      Introduction

Our Privacy Policy (“Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy controls and your rights in connection with our mobile applications and the related website and services (collectively, the “Services”). Please also read our Terms of Use which sets out the terms governing the Services.

Infini Green Pty Ltd (“Infini”) is headquartered in Brisbane, Australia and our Services are provided to you by Infini Green Pty Ltd. If you are a resident of the European Economic Area (“EEA”), Infini Green Pty Ltd. is the controller of your personal data for the purposes of EEA data protection law.

This policy is written in English. To the extent a translated version conflicts with the English version, the English version takes precedence. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.

Questions or comments about this Privacy Policy may be submitted to us at hello@infini.green.

2.     Infini collects

Infini collects information about you, including information that directly or indirectly identifies you, if you or your other members choose to share it with Infini. We receive information in a few different ways, including when you record, track, complete or input activities using the Services. Infini also collects information about how you use the Services. There are also several opportunities for you to share information about yourself, your family and friends, and your activities with Infini.

3.     Account, profile, activity, and use information

We collect basic account information such as your name, email address, location, household data, username and password that helps secure and provide you with access to our Services.

Profile, activity and use information is collected about you when you choose to record an activity, step, or offset (including dates, amounts spent, providers, lifestyle habits, and quantity information) or share, post, join a challenge, view others’ activities or steps, or otherwise use the Services.

We use your contact information so we can respond to your support requests and comments.

4.    Location information

We collect and process location information when you register for and use the Services. We do not track your device location while you are not using Infini, but in order to provide Infini’s core Services, it is necessary for us to track your device location while you use Infini. If you would like to stop the device location tracking, you may do so at any time by adjusting your device settings.

5.     Content you share with Infini

We gather information from the inputs, records, photos, posts, comments, kudos, ratings, reviews, and other content you share on the Services, including when you participate in partner events or create activities or steps.

6.     Contacts information

You can choose to add your contacts’ information by connecting your contacts from your mobile device or social networking accounts to Infini. If you choose to share your contacts with Infini, Infini will, in accordance with your instructions, access and store your contacts’ information in order to identify connections and help you connect with them. 

7.     Carbon footprint information

Infini may collect or infer carbon footprint information. Certain carbon footprint information may be inferred from sources such as spend or other measurements or other indicators. Before you can input or upload carbon footprint information to Infini, you must give your explicit consent to the processing of that carbon footprint information by Infini. You can withdraw your consent to Infini processing your carbon footprint information at any time.

8.    Payment information

When you make a payment on Infini, you may provide payment information such as your payment card or other payment details. We use payment card Industry compliant third-party payment services and we do not store your credit card information.

9.     Third party accounts

Infini allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Facebook, Instagram, LinkedIn, Google, or Apple (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences. This information is collected by the Third-Party Account provider and is provided to Infini under their privacy policies. You can generally control the information that we receive from these sources using the privacy controls in your Third-Party Account.

10.  Technical information and log files

We collect information from your mobile device, computer, or browser, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information. Learn more about how we use cookies and manage your preferences by visiting our Cookies Policy.

The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyse trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses may be linked to session IDs, user IDs and device identifiers.

11.    Other information

We may collect information from you through third parties, such as when we collect your feedback through surveys.

We may also collect information about you from other members such as when they make posts, give you kudos or comment on your activities.

12.   How Infini uses information

Infini uses the information we collect and receive as described below.

12.1    To provide the Services

We use the information we collect and receive to provide the Services, including providing you with the ability to:

  • Record your activities and analyse your performance. For example, to compare your footprint, analyse your activities, and plan steps.

  • Interact with other users. For example, to share carbon goals, participate in challenges, or events, follow other users, and use features that help users interact with one another, such as group activities.

  • Manage your footprint and goals. For example, to set goals and use your footprint dashboard.

  • To visualise your activities in new ways.

Subject to your privacy controls, your information, including parts of your profile, username, posts, photos, users you follow and who follow you, your activities, the devices you use, and kudos and comments you give and receive will be shared on Infini so that you may be able to participate in the Services. Certain information (e.g., your name, and some profile information) is also available to non-users on the web. Your location information may also be shared on Infini or to non-users, in accordance with your privacy controls.

12.2   To customise your experience

We use the information we collect about you, your followers, and your activities to customise your experience. For example, we may suggest steps, projects, or brands that may interest you, users that you may want to follow, or new features that you may want to try.

12.3   To protect you and the Services

We use the information we collect to protect users, enforce our Terms of Use and community standards and promote safety. For example, we find and remove content that violates our terms, such as hate speech or spam, as well as suspend or terminate accounts that share such content.

12.4   To improve our Services

We also use the information we collect to analyse, develop, and improve the Services. To do this, Infini may use third-party analytics providers to gain insights into how our Services are used and to help us improve the Services.

12.5   To communicate with you

We use the information we collect to provide support in response to your requests and comments.

We may also use the information we collect to market and promote the Services, activities and events on Infini, and other commercial products or services. This includes marketing and push communications, where you have not opted out of receiving such messages and notifications.

12.6   To process your subscription or licence

We use the information we collect to process your subscription or licence.

13      Aggregate information

We do not sell your personal information. Infini may aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties. Examples of the type of information we may aggregate include information about carbon footprints, work-related activities, brands selected, demographics, goals, and performance. Infini may use, sell, license, and share this aggregated information with third parties for research, business, or other purposes such as to reduce global carbon emissions or to help our partners understand more about users, including the people who use their products and services. Please visit your privacy controls if you object to Infini using your information for these purposes.

14      How Information is shared

In addition to sharing aggregated data about our users as described above, we also share personal information in accordance with your preferences, as needed to operate our business and provide the Services, and where required for legal purposes, as stated below.

14.1   Service providers

We may share your information with third parties who provide services to Infini such as supporting, improving, promoting, and securing the Services, processing payments, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf, so that we or they may promote Infini or display information that may be relevant to your interests on the Services or other websites or services.

14.2   Publicly available information

When you join the Infini community, your profile and your activities are set to be viewable by everyone by default. Your name and other profile information is viewable by other Infini members and the public and, subject to your privacy controls, additional information, and content you share may also be viewable. For example, your photo and steps may be accessed by other Infini users and non-users or viewable on publicly accessible Infini pages or in search engine results. We provide a variety of tools to control the sharing of your information and encourage our users to adjust their controls to align with their desired experience.

14.3   Sharing information and activities

As a lifestyle social network, we share your information with other Infini users and the public in accordance with your privacy controls. You can change the visibility of the activities you upload to Infini. You can also connect and share your activities with your contacts via text, email, or on social media applications like Facebook, Instagram, and Linkedin. If you link your Infini account to other social networks and share your activities, they will be viewable on such third-party platforms, including your location information. You should use caution when sharing information via third parties and you should carefully review the privacy practices of such third parties.

14.4  Third party business via API or other integrations

We enable you to share your information and content with third party apps, plugins, or websites that integrate with the Services, as well as with third parties who work with Infini to offer an integrated feature. You can choose to share your profile data and activity data (including private activities). Information collected by these third parties is subject to its’ terms and policies. Infini is not responsible for the terms or policies of third parties.

14.5   Affiliates and acquirers of our business or assets

We may share your information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regard to your information. If Infini becomes involved in a business combination, securities offering, bankruptcy, reorganisation, dissolution, or other similar transaction, we may share or transfer your information in connection with such transaction.

14.6  Legal requirements

We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that this is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Use or fraud or abuse of Infini or its members, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.

14.7  How we protect information

We take several measures to safeguard the collection, transmission, and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity. The Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. Infini engages providers that are industry leaders in online security, including Services verification, to strengthen the security of our Services. The Services are registered with site identification authorities so that your browser can confirm Infini’s identity before any personal information is sent. In addition, Infini’s secure servers protect this information using advanced firewall technology.

15      Managing your settings

15.1    Privacy controls

Infini offers several features and settings to help you manage your privacy and share your activities. Most privacy controls are located in your privacy controls page, but some are specific to individual activities, or users. Infini provides you the option to make your activities private.

15.2   Adjust notification and email preferences

Infini offers various ways to manage the notifications you receive. You can choose to stop receiving certain emails and notifications by indicating your preferences with Infini. You may also unsubscribe by following the instructions contained at the bottom of marketing or promotional emails. Any administrative or service-related emails (to confirm a purchase, or an update to this Privacy Policy or our Terms of Use, etc.) generally do not offer an option to unsubscribe as they are necessary to provide the Services you requested.

15.3   Updating account information

You may correct, amend, or update profile or account information at any time by adjusting that information in your account settings. If you need further assistance correcting inaccurate information, please contact us at hello@infini.green.

15.4   Deleting information and accounts and downloading your data

You can delete your account using our self-service tools. To request that your account is deleted, or download your data including your activity files, contact Infini at hello@infini.green.

After you make a deletion request, we permanently and irreversibly delete your personal data from our systems, including backups. Once deleted, your data, including your account, and activities cannot be reinstated. Following your deletion of your account, it may take up to 90 days to delete your personal information and system logs from our systems. Additionally, we may retain information where deletion requests are made to comply with the law and take other actions permitted by law.

You should be aware that content you have shared with others, such as photos, or that others have copied may also remain visible after you have deleted your account or deleted specific information from your own profile. Your public profile may be displayed in search engine results until the search engine refreshes its cache.

Infini also provides you the option to remove individual activities you have posted without deleting your account. Once removed, the activities may remain on Infini’s systems until you delete your account.

16      Your rights and our legal bases

We provide the same suite of privacy tools and controls to all of our members worldwide. Particular rights may be available to you if you reside in certain locations, such as the EEA, UK or Brazil. See section 19 below to learn about your location specific rights and how to exercise them.

16.1   Your legal rights in the EEA

If you are habitually located in the EEA, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. Learn more at section 19 below.

16.2   Our legal bases

Infini relies on several legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

  • as necessary to provide the Services and fulfill our obligations pursuant to the Terms of Use. For example, we cannot provide the Services unless we collect and use your location information;

  • where you have consented to the processing;

  • where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;

  • to protect your vital interests, or those of others, such as in the case of emergencies; and

  • where necessary for the purposes of Infini’s or a third party’s legitimate interests, such as our interests in protecting our members, our partners’ interests in collaborating with our members, and our commercial interests in ensuring the sustainability of the Services.

16.3   Transfers

The Services are operated from Australia. If you are located outside of Australia and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in Australia, as it is necessary to provide the Services and perform the Terms of Use. Australian privacy laws may not be as protective as those in your jurisdiction.

16.4  Retention of information

We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until your account is deleted. In addition, you can delete some items of information (e.g., profile information) and you can remove individual activities from view on the Services without deleting your account. Following your deletion of your account, it may take up to 90 days to fully delete your personal information and system logs from our systems. Additionally, we may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Use and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to Infini, such as statistics of the use of the Services. For example, we may retain publicly available activities, brands or steps to continue to improve the Services and we use aggregated information in Infini Licences. This information will be de-associated with your name and other identifiers.

17      Other Infini sites

Infini maintains certain websites and platforms that can be accessed outside of www.infini.green  (the “Other Sites”). The Other Sites maintain the look and feel of the Services but are hosted by outside service providers with their own terms and privacy policies. If you interact with the Other Sites, your information may be stored, processed, or shared outside of the Services. If you interact with the Other Sites, you acknowledge that you may be subject to the terms and conditions and policies applicable to such Other Site. Please be aware that any personal information you submit to the Other Sites may be read, collected, or used by other users of these forums indefinitely, and could be used to send you unsolicited messages. Infini is not responsible for the personal information you choose to submit via the Other Sites.

18      Privacy Policy information

Infini reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Infini makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account.

Location specific disclosures

19      Location specific disclosures

19.1   Residents of European Economic Area (“EEA”)

19.1.1 Your Rights and how to exercise them

If you are habitually located in the European Economic Area ("EEA") or the United Kingdom ("UK"), you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We summarise these rights below:

Object

Where we process your information based on our legitimate interests as explained below, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

Access and porting

You can access much of your information by logging into your account. If you require additional access or if you are not a Infini user, contact us at hello@infini.green.

Rectify, restrict, limit, delete

You can also rectify, restrict, limit or delete much of your information by logging into your account, such as to edit your profile, delete photos you have posted, remove individual activities or steps from view, or delete your account. If you are unable to do this, please contact us at hello@infini.green.

Revoke consent

Where you have previously provided your consent, you have the right to withdraw your consent to the processing of your information at any time. For example, you can withdraw your consent by updating your settings. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.

Complain

Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

19.1.2 EEA Members: Our legal bases for processing your information

Data protection law (for example, in the EEA or Brazil) requires organisations to have legal bases to collect, use, share and otherwise process information about you. While some of your rights apply generally, certain rights only apply depending on the legal bases we rely on to process data. We’ve summarised these legal bases and your rights below.

To provide the Infini Services

As described in the Terms of Use, the core Infini Services cannot be provided, and the Terms of Use cannot be performed, without Infini processing data including for the following purposes:

  • Create your account and provide you with access to the Services.

  • Record your activities, brands, steps, and offsets including your measurement and location data.

  • Help you analyse your activities and steps. For example, to compare your past activities and analyse your steps.

  • Help you record, monitor, track and analyse your carbon footprint, goals and offsets.

  • Process your Infini subscription or licence.

  • Respond to your support requests and comments.

Since we process data you provide to us which is necessary to perform our contract with you, you have the right to port or transfer that data if you are habitually resident in the EEA or the UK.

With your consent

We ask for your permission to process your information for certain purposes, and you have the right to withdraw your consent at any time. We ask for your consent to: 

  • Collect or infer carbon footprint information which may include information inferred from sources such as expenditure or other indicators. We use your carbon footprint information to provide helpful statistics and visualisations.

  • Send you marketing communications.

  • Collect and process information from third-party products and services, such as Instagram, Facebook or Google.

  • Access photos, location, and contacts information through your device-based settings so we can provide the services described when you enable the settings.

When we process data you provide to us based on your consent, you have the right to withdraw your consent at any time via your settings. You also have the right to port or transfer the data.

Legal obligation or for the establishment, exercise or defence of legal claims

We process data where we have a legal obligation to do so, for example, where we're responding to valid and binding legal process from law enforcement agencies for certain data. See section 14.6 above for more information. In addition, processing may be needed for us to establish, exercise or defend civil or criminal claims in connection with actual or potential litigation including to protect the Infini Services, our property or other legal rights, including those of our members or partners.

To protect vital interests

We process data where it is necessary to protect an interest which is essential to someone’s life or protect any person from serious bodily injury. This includes processing information to combat harmful conduct both on and off of our Services.

Carrying out a task in the public interest

Where laid down by EU law or the law in an EU Member State, we may process your data to perform processing in the public interest. This may include protecting against harm and undertaking research for social good. You have the right to object to, and seek restriction of, our processing of your personal data when we process data using this legal basis.

In furtherance of legitimate interests

We process your information for our legitimate interests, and those of third parties, while applying appropriate safeguards that protect your privacy, rights and interests. We do this to:

  • Market the Services, activities on Infini and other commercial products or services to provide you with better Services and to enable you to use the full range of our Services. For example, our partners may pay us to promote their products and services on Infini. This is one of the ways we are able to provide the Services on a sustainable basis.

  • Maintain our business by conducting research and continuously improving the Services so as to offer innovative and customised offerings to our users and partners.

  • Convert your information into aggregated form for use by us and our partners. Our partners may use this information to reduce carbon emissions or for other commercial purposes including developing useful insights.

  • Keep the Services safe and secure by using information to prevent or detect violations of our Terms of Use, community standards, fraud or abuse, and other harmful or illegal conduct. We may also share information with third parties, including law enforcement agencies for this purpose.

  • Promote the Services, including email and in-product marketing campaigns to inform you about our Services.

  • Enable you to find new ways to interact by using the Services. For example, challenges, or events, follow other users, and use features that help users interact with one another, such as group activities.

  • Enable you to visualise your activities in new ways.

  • Customise the Services for you. We may suggest activities, brands, or steps that may interest you, users that you may want to follow, or new features that you may want to try. We rely on our legitimate interest in retaining users when ensuring that we offer new opportunities, such as showing brands or steps of interest to our community, and we may use location information when suggesting such opportunities.

You have the right to object to, and seek restriction of, our processing of your personal data based on legitimate interests. Visit your privacy controls to object to the processing of your personal data. If you have questions about objections, please contact us at hello@infini.green.

19.2 Residents of Argentina

You can access much of your information by logging into your account. If you require additional access or if you are not a Infini user, contact us at hello@infini.green.

We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the right to lodge a complaint to the Agency of Access to Public Information, in its function of controlling agency responsible.

19.3   Residents of Australia, New Zealand or Hong Kong

Infini takes steps to keep your information accurate and up to date. If you reside in Australia, New Zealand or Hong Kong, you may request access to or correction of the information that we have collected about you. To access your information, please contact us at hello@infini.green. We may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

If you have any complaints regarding how we handle your information, please contact us at hello@infini.green with a detailed description of the complaint. We will respond to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

19.4  Residents of Brazil

A Brazilian Data Protection Authority ("DPA") will be established and will provide guidelines on how to interpret and implement the LGPD’s requirements. As those guidelines are not yet established, our approach is subject to change.

If you are habitually located in Brazil, you have rights under the Lei Geral de Proteção de Dados ("LGPD"), including the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. You can find more information about how to exercise these rights in section 19.1 above.

If you have questions about your rights, please contact us at hello@infini.green.

The LGPD requires us to have legal bases to collect, use, share and otherwise process information about you. You can find a description of the legal bases we rely on by reviewing the above section 19.1.2.

19.5 Residents of Germany

If you reside in Germany, you have a right to report content that you believe is unlawful under the Network Enforcement Act ("NetzDG"). To submit a report, please contact us at hello@infini.green and include the heading NetzDG in your email.

Please note that Infini separately maintains community standards that prohibit certain types of content, including hate speech. You can report content which you believe violates our community standards by using our reporting or flagging tools in our app or on our website, or contacting us at hello@infini.green.

19.6. Residents of Indonesia, Malaysia, Philippines, Thailand, Singapore or Mexico

Infini takes steps to keep your information accurate and up to date. If you reside in Indonesia, Malaysia, Philippines, Thailand or Singapore, you may request access to, and modification, opposition, and deletion of the information that we have collected about you. To access your information, please contact us at hello@infini.green. Subject to applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

19.7. Residents of South Korea

Infini takes steps to keep your information accurate and up to date. If you reside in South Korea, you may request access to, and modification, opposition and deletion of the information that we have collected about you. To access your information, please contact us at hello@infini.green. Subject to the applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

If you have any complaints regarding how we handle your information, please contact us at hello@infini.green with a detailed description of the complaint. We will respond to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

Data retention and destruction

Under applicable South Korean law, your information must be retained for the following periods:

  • Records regarding contracts or the cancellation of contracts, and records on payment and provision of goods:

    • Reason of retention: Act on Consumer Protection in Electronic Commerce Transactions, etc.

    • Retention period: five years

  • Records on customer complaints or dispute resolution:

    • Reason of retention: Act on Consumer Protection in Electronic Commerce Transactions, etc.

    • Retention period: three years

  • Communications confirmation data

    • Reason of retention: Communications Privacy Protection Act

    • Retention period: three months

  • Records on electronic financial transactions:

    • Reason of retention: Electronic Financial Transaction Act

    • Retention period: five years

Method and procedure for the destruction of information

Infini retains your information (i) for as long as you maintain an account or as needed to provide you the Services and/or (ii) as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. information is destroyed when it is no longer necessary for these purposes. The specific destruction process and method are as follows: (i) information printed on the paper is shredded; and (ii) information stored in electronic form is deleted using technology designed to prevent the recovery of the information.