PRIVACY POLICY

 

 

 

 

Thank you for choosing to be part of our community at Xungible LTD, ("Company," "we," "us," or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at support@xungible.com.

 

The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it.

 

Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect.

 

TABLE OF CONTENTS

 

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

4. HOW LONG DO WE KEEP YOUR INFORMATION?

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

6. DO WE COLLECT INFORMATION FROM MINORS?

7. WHAT ARE YOUR PRIVACY RIGHTS?

8. CONTROLS FOR DO-NOT-TRACK FEATURES

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

10. DO WE MAKE UPDATES TO THIS NOTICE?

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

1. WHAT INFORMATION DO WE COLLECT?


Personal information you disclose to us

 

In Short:  We collect personal information that you provide to us.

 

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you participate in activities on the Webapp or otherwise when you contact us.

 

The personal information that we collect depends on the context of your interactions with us and the Webapp, the choices you make and the features you use. The personal information we collect may include the following:

 

Personal Information Provided by You. We collect email addresses, usernames, dates of birth and other similar information.

 

Information automatically collected

 

In Short:  Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Webapp.

 

We automatically collect certain information when you visit, use or navigate the Webapp. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Webapp and other technical information. This information is primarily needed to maintain the security and operation of our Webapp, and for our internal analytics and reporting purposes.

 

 

2. HOW DO WE USE YOUR INFORMATION?

 

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

 

We use personal information collected via our Webapp for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

 

We use the information we collect or receive:

 

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

 

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

 

We may process or share your data that we hold based on the following legal basis:

More specifically, we may need to process your data or share your personal information in the following situations:

 

4. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

 

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Webapp is at your own risk. You should only access the Webapp within a secure environment.

 

6. DO WE COLLECT INFORMATION FROM MINORS?

 

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Webapp, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Webapp. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us via email at support@xungible.com.

 

7. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short:  In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

 

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

 

GENERAL DATA PROTECTION REGULATION (GDPR)

 

If you are from the European Economic Area (EEA), Xungible LTD legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

 

Xungible LTD may process your Personal Data because:

•        We need to perform a contract with you

•        You have given us permission to do so

•        The processing is in our legitimate interests and it’s not overridden by your rights

•        For payment processing purposes

•        To comply with the law

 

Retention of Data

 

Xungible LTD will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

Xungible LTD will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

 

Transfer of Data

 

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

 

Xungible LTD will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

Disclosure of Data. Legal Requirements

 

Xungible LTD may disclose your Personal Data in the good faith belief that such action is necessary to:

•        To comply with a legal obligation

•        To protect and defend the rights or property of Xungible LTD

•        To prevent or investigate possible wrongdoing in connection with the Service

•        To protect the personal safety of users of the Service or the public

•        To protect against legal liability

 

Security of Data

 

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

 

Your rights under the GDPR

 

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Xungible LTD aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

 

In certain circumstances, you have the following data protection rights:

 

•        The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

•        The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

•        The right to object. You have the right to object to our processing of your Personal Data.

•        The right of restriction. You have the right to request that we restrict the processing of your personal information.

•        The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

•        The right to withdraw consent. You also have the right to withdraw your consent at any time where Xungible LTD relied on your consent to process your personal information.

 

Please note that we may ask you to verify your identity before responding to such requests.

 

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice. 

 

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

 

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

 

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

 

If you are under 18 years of age, reside in California, and have a registered account with the Webapp, you have the right to request removal of unwanted data that you publicly post on the Webapp. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Webapp, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).


CCPA Privacy Notice

 

The California Code of Regulations defines a "resident" as:

 

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

 

All other individuals are defined as "non-residents."

 

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

 

How do we use and share your personal information?

 

More information about our data collection and sharing practices can be found in this privacy notice.

 

You may contact us at support@xungible.com.

 

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

 

Will your information be shared with anyone else?

 

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

 

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

 

Your rights with respect to your personal data

 

Right to request deletion of the data - Request to delete

 

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) if another consumer exercises his or her right to free speech, if we need to comply with a legal obligation or if we need to process your data to protect against illegal activities.

 

Right to be informed - Request to know

 

Depending on the circumstances, you have a right to know:

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

 

We will not discriminate against you if you exercise your privacy rights.

 

Verification process

 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

 

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

 

Other privacy rights

To exercise these rights, you can contact us at support@xungible.com. If you have a complaint about how we handle your data, we would like to hear from you.  

 

10. DO WE MAKE UPDATES TO THIS NOTICE?     

 

In Short:  Yes, we will update this notice as necessary to stay compliant with relevant laws.

 

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?     

If you have questions or comments about this notice, you may email us at support@xungible.com.