This is the privacy policy (“Privacy Policy”) that governs how we, Xpolog (“Xpolog”, “we”, “our” or “us”), use Personal Information (defined below) that we collect, receive and store about individuals in connection with the use of: (i) the website http://wiki.xpolog.com and http://www.xpolog.com, and any other website that we operate (each, together with its sub-domains, content and services, a “Site”); and (ii) the Xpolog analytics software and any Xpolog branded products or services offered through the Site (each individually, and collectively, the “Software”). The Site and the Software are individually and collectively referred to herein as the “Services”. 

The Services may not be hosted by us – all or some of the hosting is done by third party service providers that we engage. This means that data you provide us or that we or third parties collect from you (including any Personal Information, as defined below) is hosted with such third party service providers on servers that they own or control. Regardless of where such third party service providers are located (and some are located in the US), their servers may be located anywhere in the world (including the US). Your data may even be replicated across multiple servers located in multiple countries. So please be aware that you are consenting to your data being transferred to various third party service providers around the world (including the US) for such hosting purposes.   [we should add specific (check the box) consent in order to transfer PII outside the EU] 

  1. Introduction. We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Services. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information.
  2. Terms of Use and EULA. This Privacy Policy forms part of our Terms of Use which is available at [http://xpolog.com/terms_and_conditions-xpolog_ltd.html/] (“Terms”) and the Software’s license agreement which you accepted prior to downloading, installing and/or using the Software for first time] (“EULA”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.
  3. Consent and Modification.  You are not legally obligated to provide us Personal Information, and you hereby confirm that providing us Personal Information is at your own free will. By using the Services, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Site, and your continued use of the Services thereafter means that you accept those changes.
  4. What Personal Information We Collect and How We Collect It. We do not currently require you to provide Personal Information in order to have access to general information available on the Site. But, we do receive and/or collect Personal Information from you in the following ways: 
    1. Account.  In order to use certain services that we offer via the Service, you may be required to create an account (“Account”).  If you create an Account you will be required to provide us with certain information, such as your name, email address, business name , as well as username and a password that you will use for your Account (“Account Information”). You may also choose to provide additional Personal Information as part of the Account registration process and in connection with your ongoing use of your Account. We may send you a text message to your mobile phone or an e-mail to the e-mail address you submit to confirm your registration. If you choose not to create an Account, you may not be able to access or use certain features of the Service.
    2. ‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online form that we make available or by sending an email to an email address that we display, you may be required to provide us with certain information such as your name and/or phone and email address.
    3. Share with Others. The Services may offer features enabling you to invite others to use the Services, for example by sending an invitation email from the Site to the recipient’s external email address. If you send or post an invitation, you will be providing us with Personal Information about the recipient such as his/her email address or online account user name and id. 
    4. Location Data. We may provide certain location-based services (“Location Services”) in connection with the Software that are dependent on data related to the geographic location of your device on which the Software is installed (“Location Data”). If you choose to participate in these Location Services, you agree that we may collect or obtain your Location Data. You should be able to use the settings on your device to turn off location-sharing features. 
    5. Purchases. The Site and/or Software may include the option to purchase certain products or services from us. If you choose to make a purchase we will require sufficient information from you to complete the transaction. Such information could include a credit card number and related account and billing information, invoice related information, and other data required to process the order. We may also update such data should you grant us permission to bill you or your credit card for recurring charges, such as monthly or other types of periodic payments. We may use the tools, software or services of third-party service providers to process transactions on our behalf, in which case you acknowledge and agree to review and be bound by the terms of use and privacy policy of said third-party service provider. 
    6. Blogs, Newsletters, Surveys and Promotions. The Site may contain a blog forum displaying information about Xpolog and some of its products and services. The Services may also offer you the opportunity to subscribe to newsletters and participate in surveys and other promotional activities. In each of the foregoing cases, your interaction (such as responding on the blog forum, subscribing to a newsletter, or participating in a survey) may require you to provide certain Personal Information such as your name and email address
    7. Log Files, Device and Usage Data. We may make use of log files but also by deploying tracking technologies within the Services, and we may also associate this information with your Account. We do this to analyze trends, track user movement around the Services, gather demographic information, and to generally collect information that we may find insightful or helpful. The information inside the log files includes internet protocol (IP) addresses, MAC address, type of browser, operating system type, Internet Service Provider (ISP), date/time stamp of Services use, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Services, track users’ movement around the Services, and gather demographic information.
    1. Cookies and Other Tracking Technologies. A cookie is text file placed on your hard drive and stored by your browser. We use cookies to administer, and provide you with access to, the Services; but we also use cookies to improve the user experience of the Services (for example, cookies and other technologies may serve to recall an IP address previously indicated by a user) and to collect statistical or aggregated data about how you and other users use and interact with the Services, which may include for the purpose of serving advertisements and other marketing content. Some of the cookies are set by us, and some may be set by third parties, in which case the third party hosts it (for example, social plug-ins, such as a “Like” button, involve the setting of cookies by the applicable third party). If you do not want to receive cookies, consult your respective browser settings. This may allow you to receive notifications when cookies are set, or to otherwise block cookies altogether. You may also be able to delete cookies that have already been set. If you do block or restrict cookies, various features and functionality of the Services may be impaired. 
    2. Google Analytics.  We are using a tool called “Google Analytics” to collect information about use of the Service. Google Analytics collects information such as how often users visit the Service, what pages they visit when they do so, and what other sites they used prior to coming to the Service. We use the information we get from Google Analytics to maintain and improve the Service and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Service is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/
  1. Reserved
  2. The Way We Use Personal Information. In addition to the uses of Personal Information described elsewhere in this Privacy Policy, if you submit or we collect Personal Information through the Services, then we may use such Personal Information in the following ways, via any applicable communication channel, including e-mail, SMS, etc.:
    1. We will use Personal Information to: (a) administer and provide the Services to you (including connecting you with other users); (b) further develop and improve the Services; (c) send you updates, promotions, offerings, or other news of/about the Services and/or Xpolog; (d) respond to communications with you; (e) identify or authenticate your access and use of the Services; and/or (f) send you updates and marketing information related to our products and services.
    2. If you choose to send your friend an invitation email or message we will use the contact information that you provide, or make available, to automatically send your friend an invitation email or message. Your name and email address may be included in the invitation email or message. 
    3. We may transfer your Personal Information to our local or foreign subsidiaries or affiliated companies for the purpose of storing or processing such information on our behalf. Such information may be transferred to other countries. We require that these parties agree to process such information in compliance with our Privacy Policy. 
    4. We may share your Personal Information with our third party service providers and partners, but only to assist us with our business operations and to provide our Services to you and other users and to develop and improve them. These third parties may have their own privacy policies that they adhere to, so they won’t necessarily adhere to this Privacy Policy; however, we use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Information. Also, just as with our third party hosting providers, these third parties may be based (and their servers may be located) anywhere in the world.
    5. We may disclose your Personal Information or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms and EULA, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Xpolog, our users, yourself or the public.
  1. Use of Anonymous Information. We may use Anonymous Information (as defined below) or disclose it to third parties (such as advertisers and marketing partners)for any purpose whatsoever (including, in order to improve our Services and enhance your experience with the Services), with our without compensation or other monetization. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Services.
  2. Opting Out. You may choose not to receive future promotional, advertising, or other Services-related emails from us by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Services.
  3. Choice. At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Services but you may be unable to access certain options, programs, offers, and services that involve our interaction with you. 
  4. Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to support@xpolog.com. Your email should include adequate details of your request.
  5. Links to and Interaction with Third Party Products. The Services may enable you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.
  6. Children’s Privacy. The Services are not structured to attract children under the age of 13 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13 years. If we learn that we have collected Personal Information from a child under 13 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at xplg.privacy@xpolog.com. 
  7. Security. We use administrative, physical and technical safeguards to protect Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we try to use reasonably acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Site or an Application, you can contact us at xplg.security@xpolog.com. 
  8. Merger, Sale or Bankruptcy. In the event that XpoLog is acquired by, or merged with, a third party entity, we may (and hereby reserve the right to) transfer or assign the Personal Information and other information we have collected or received. In the event of a bankruptcy, insolvency, receivership, or comparable event, we may not be able to control how your Personal Information is treated, transferred, assigned, or used. 
  9. California Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to xplg.privacy@xpolog.com. Please note that we are only required to respond to one request per customer each year.
  10. Our California Do Not Track Notice.

We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

  1. Deletion of Content from California Residents.  If you are a California resident under the age of 18 and a registered user of certain parts of the Services, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted.  If you wish to remove such content or Personal Information, please contact xplg.privacy@xpolog.com, and provided you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law.  Please be aware that after removal you will not be able to restore removed content or Personal Information. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require (or allow) us to enable removal. 
  1. Commitment. Protecting your privacy online is an evolving area, and we try to evolve our Services to meet these demands. If you have any comments or questions regarding this Privacy Policy, please contact us at xplg.privacy@xpolog.com. 

Last updated: January 26, 2017