PRIVACY POLICY

Last updated: May 10th, 2019

XEEPP Inc. ("XEEPP", "we", "us" or "our", as appropriate) respects an individual's privacy and will only collect, use or disclose your personally identifiable information (personal information) in accordance with its Privacy Policy. We recognize every individual's right to privacy and acknowledge our obligation to preserve the confidentiality of personal information. This Privacy Policy governs the collection, use, storage and disclosure of the personal information of the users ("User(s)" or "you") of our website https://XEEPP.com ("Website"), products, and services, including our applications available on the Shopify platform https://apps.shopify.com/partners/XEEPP (“Apps”). XEEPP is responsible for how we collect, handle and use this information.

XEEPP reserves the right to update its Privacy Policy at any time and such modifications shall be effective immediately, unless otherwise stated.

Please note that this Privacy Policy constitutes an integral part of the terms and conditions of use of our Website, in addition to any terms and conditions specific to the use of our Apps, as applicable.

PERSONAL INFORMATION COLLECTION AND CONSENT

XEEPP may collect personal information that can identify you when you (i) access our Website, (ii) download and subscribe to our Apps, (iii) order or request information about our Apps or our services. The types of personal information collected include your name, mailing address, email address, phone number and payment details.

XEEPP will collect personal information from Users only if they consent to submit such information to us. Please however note that you are under no obligation to provide personal information, with the caveat that your refusal to do so may prevent you from using certain portions of the Website or our Apps.

By providing their personal information or by using our Website, Users are consenting to XEEPP’s collection, use, storage, and disclosure of your personal information in accordance with this Privacy Policy and all applicable laws.

For personal information of Users located in the European Union ("EU") or using our Website tools which are offered to EU residents, the collection, use, storage, and disclosure of your personal information will be made in accordance with this Privacy Policy and in compliance with the applicable requirements of the General Data Protection Regulation (EU 2016/679) ("GDPR"). If you think GDPR may apply to you, please refer to the appropriate section of this Privacy Policy for more details about the processing of your personal information and your rights with respect to such processing.

AUTOMATIC INFORMATION COLLECTION

Whenever you interact with our Website, XEEPP automatically collects, receives and records information on our server logs from your browser including browsing actions and patterns. The information includes your internet protocol (IP) address, cookie information, the page you requested and test data results

We also use cookies and other standard web technology to collect information about the use of our systems. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

PURPOSES OF COLLECTION

XEEPP may collect your personal information from you for the following purposes:

To provide you with our Apps and services and to process all related payments; To manage our Apps and your log-in accounts in our Apps; To manage and improve our customer service to our Apps; To operate and manage our Website; To enable you to use our Website tools; and To send you notification emails about our Website, Apps and other products or services, as the case may be. If you would like to opt out of future electronic communications from XEEPP, you may indicate this preference by selecting the unsubscribe instructions at the end of our electronic communications. Please note that if you opt out of messages from us, we may continue to send you account-related updates so as to continue to support your account in our Apps or Website.

XEEPP will identify the purposes for which personal information is collected at or before the time it is collected. If XEEPP seeks to use personal information that has been collected for a purpose not previously identified, it will seek your consent prior to use, unless otherwise permitted or required by law.

DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES

We do not sale or trade your personal information to third parties. XEEPP may however disclose your Personal Information to third parties such as suppliers, service providers, contractors or agents that perform services on our behalf, such as processing and delivery of our Apps, information technology and/or data hosting or processing services or similar services, or otherwise to use, store or process Personal Information on our behalf for the purposes described in this Privacy Policy.

INFORMATION SECURITY

XEEPP makes reasonable efforts to ensure that any personal information you provide is maintained in a secure environment. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. While we strive to protect your personal information, XEEPP cannot warrant the security of any personal information you transmit to us or from our on-line services, and you do so at your own risk.

XEEPP has implemented and maintains reasonable and appropriate security measures, procedures and practices to protect against the loss and unauthorized access, use, modification, destruction or disclosure of your personal information while it is in our custody or under our control. For example, we use SSL encryption, firewalls, anti-virus and system security monitoring.

We also limit access to your personal information to those employees, contractors and agents who have a business need to know.

CROSS-BORDER TRANSFER

XEEPP processes and stores personal information using our server(s) based in the United States.

If you are located outside of the United States, note that your personal information and other information that we collect through this Website may be transferred to the United States, for the purposes described above. By accepting this Privacy Policy, using this Website or providing us with any personal information, you agree to the transfer of information to the United States.

CHILDREN'S ONLINE PRIVACY PROTECTION

XEEPP understands the importance of protecting children's privacy, especially in an online environment. The Website is not designed for or directed at children. It is our policy not to knowingly collect or maintain information about anyone under the age of 18.

ACCESS TO AND DELETION OF YOUR PERSONAL INFORMATION

If your Personal Information changes, or if you no longer desire to use our Apps, you may correct, update, amend, delete/remove your information by making the change within your personal profile on the Apps or you can contact us through our Privacy Officer, whose contact details are provided below.

We may require that you provide us with acceptable verification of your identity before providing access to such information.

General and anonymous data related to the terminated account may be retained to ensure consistency of our databases and to allow retrieving historical data about services provided.

DATA RETENTION

XEEPP will retain the personal information collected only for such period as is reasonably necessary for the fulfillment of the purposes for which it was collected and listed above or to comply with any legal requirements, including statutory retention periods.

THIRD PARTY WEBSITES

Our Website, including Apps, products or services available therein, may contain hyperlinks or other "computer" links to website from third parties ("Third Parties websites") that can cause leaving the Website currently browsed. XEEPP provides these links only for convenience, and the inclusion of any link does not imply endorsement by XEEPP of the website linked to. Accordingly, any personal information that is transmitted by use of Third Party websites is subject to the privacy policy of the relevant Third Party websites. It is the responsibility of the Users to consult these policies in order to ensure that their personal information is being protected.

CONTACT

XEEPP is responsible for personal information under its control and has designated a Privacy Officer who is accountable for this Privacy Policy and applicable european governing laws. Should you have any questions, concerns or claims about your personal information or XEEPP privacy practices, please contact our Privacy Officer at the information below.

NOTICES

EUROPEAN ECONOMIC AREA (EEA) NOTICE Transfers of Personal Information

XEEPP is a data controller and is responsible for your personal information, which the XEEPP processes and stores in the United States We may use the following safeguards when transferring your personal information t to a country, that is not within the EEA:

a. Only transfer your personal data to countries that have been deemed by the European Commission to provide an adequate level of protection for personal information; b. Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in the EU.

Opt-in

If you are an EU resident, we may only collect your data using cookies and similar devices, and then track and use your personal information where you have first consented to that. We will not automatically collect personal information from you unless you have consented to us doing so. If you consent to our use of cookies and similar devices, you may at a later date disable them.

Your Legal Rights



Under certain circumstances, as an EU resident, you may have rights in relation to your personal information, including the right to:

Request access to your personal information This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Request correction of your personal information This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us. Request erasure of your personal information This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request. Object to processing of your personal information You may exercise this right in the event that we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms. Request restriction of processing your personal information This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal information Upon your request, we will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Right to withdraw (revoke) consent

You may exercise this right where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of these rights, please contact our Privacy Officer. Please also note that the following will apply:

No Fee Usually Required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we my charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.