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Data Privacy Policy

The Data Privacy Policy (“Policy”) of xiQ, Inc. (“xiQ”, “we,” or “us”) and xiQ Service (“Service”), including the xiQ mobile and tablet application (“App”), is incorporated into and is subject to the xiQ Terms of Use.

This Policy covers information that we collect when you use our Service and information that we have on people who are featured in our platform. We describe how we use and disclosesuch information, steps we take to protect such information and the choices you have in connection with this. By using the Service, you consent to the privacy practices described in this Policy.

A) Users of Our Service

The information we collect on the Service:

  • User-provided Information. When you use the Service, you may provide and we may collect what is generally called “personally identifiable” information, or “personal information,” which is information that specifically identifies an individual. We may only collect the following information Full name, Email address, Job title and Organization name. You may provide us with personal information when you register for an account, or use the Service.

  • “Automatically Collected” Information. When you use the Service, we may automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This “automatically collected” information may include your IP address or other device address or ID (including any ID accessible from your device), web browser and/or device type, the web pages or sites that you visit just before or just after you use the Service, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service.

  • Analytics. We may work with different companies who offer services that can assist us in better understanding how users of our Services interact with and use our Services. For example, we currently use and may continue to use a product called Flurry Analytics within one or more versions of our App. You can learn more about Flurry Analytics at www.flurry.com, as well as review Flurry’s privacy policy. As of the date of this Policy, Flurry offers an “End User Opt-Out of Flurry Services” at www.flurry.com/user-opt-out.html.

  • Information from Other Sources. We may obtain information, including personal information, from third parties and sources other than the Service, such as our partners, advertisers, and Integrated Services. If we combine or associate information from other sources with personal information that we collect through the Service, we will treat the combined information as personal information in accordance with this Policy.

How we use the information we collect:

We use information we collect on the Service in a variety of ways in providing the Service and operating our business, including the following:

  • We use the information that we collect on the Service to operate, maintain, enhance, and provide all features of the Service, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time on the Service.

  • We use the information that we collect on the Service to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, feature, and functionality.

  • We may use your email address (if it’s been provided to us) or other information we collect on the Service (a) to contact you for administrative purposes such as customer service, to address intellectual property infringement, privacy violations or defamation issues related to information or materials posted through your account on the Service or (b) to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. Generally, you have the ability to opt-out of receiving any promotional communications as described below under “Your Choices”.

  • We also may use your information as may be described in a notice to you at the time the information is collected, or in any other manner to which you consent.

When we disclose information.

Except as described in this Policy, we will not disclose your information that we collect on the Service to third parties without your consent. We may disclose information to third parties in the following circumstances:

  • Any information that you voluntarily choose to include in a publicly accessible area of the Service, such as a public profile (if we offer one), will be available to anyone who has access to that content, including other users.

  • We work with third party service providers to provide website or application development, hosting, maintenance, and other services for us. For example, we use and may continue to use Amazon Web Services (AWS) to host and store much of the backend functionality of our Service. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions.

  • We may make certain automatically collected, aggregated, or otherwise non-personally-dentifiable information available to third parties for various purposes, including (a) compliance with various reporting obligations; (b) for business or marketing purposes; or (c) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.

  • We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

  • We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (a) take precautions against liability, (b) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (c) investigate and defend ourselves against any third-party claims or allegations, (d) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (e) protect our property or other legal rights (including, but not limited to,enforcement of our agreements), or the rights, property, or safety of others.

  • Information about our users, including personal information, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

  • We also may disclose your information as may be described in a notice to you at the time the information is collected, or in any other manner to which you consent.

B) People Featured on our Platform

xiQ provides predictive DISC on individuals. DISC is a behavior assessment tool which categorizes a person’s personality as being Dominant (D), Influencing (I), Steady (S) or Conscientiousness (C). To provide these predictive behavioral traits, xiQ utilizes publicly available digital footprint of a person.

xiQ’s DISC Personality Analysis are predictive. As such:

  • A) Insights have not been collected for, and is not intended to be indicative of, any person’s employability, credit worthiness, credit standing, credit capacity, or other characteristics related to such person’s manner or mode of living, as listed in Section 603(d) of the Fair Credit Reporting Act (“FCRA”), 15 USC Section 1681a.

    and

    B) Customer shall not use any Insights as a factor in establishing any person’s eligibility for:
    1. Credit or insurance used primarily for personal, family or household purposes,
    2. Employment purposes, or
    3. Other purposes authorized under Section 604 of the FCRA, 15 USC Section 1681b or any similar statute.

xiQ may also provide public social media information, public news, videos, and other information on executives of various private and public sector enterprises.

Your Rights to Your Information

Right of Access:

You have the right to request what personal information we have collected, used, and disclosed about you.

Right to Correct:

You have the right to correct, update or modify the personal data we hold about you.

Right to Erasure of Data:

You have the right to request deletion of your personal data. We will comply with any such request within 2 business days.

Right to Non-Discrimination:

You have a right not to receive discriminatory treatment by xiQ if and when you exercise your privacy rights. To exercise any of your privacy rights, you may submit a request to us via email at [email protected] or may write to us at the address given at the end of this Policy.

Children’s Privacy

Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13 without obtaining parental consent. If you are under 13 years of age, then please do not use or access the Service at any time or in any manner. If we learn that personally identifiable information has been collected on the Service from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an account on the Service, then you may alert us at [email protected] and request that we delete that child’s personally identifiable information from our systems.

Data Security

  • 1. We use specific physical, administrative, and technical safeguards designed to improve the integrity and security of your personally identifiable information. While we strive to protect the security of information you transmit to us or store in the service, we cannot guarantee or warrant the security of any information you transmit to us or store in the service. Additionally, we cannot guarantee that your information will not be accessed, disclosed, altered, or destroyed by a breach of our physical, technical, or administrative safeguards.

    2. If we become aware of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the service in the event of a security breach. Depending on your location, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach, please contact us at [email protected].

    3. For information on security related to Amazon’s AWS services, please refer to the AWS Security Center or similar AWS security pages that Amazon may provide from time to time.

Privacy Settings

We are responsible for circumvention of any privacy settings or security measures on the Service. We cannot control the actions of other users or third parties with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service.

International Visitors

The Service is hosted in the United States and is intended for visitors located within the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including personal information, on or to the Service, you consent to such transfer, storage, and processing.

Changes and Updates to this Policy

Please revisit this Policy periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed tothe current version of the Policy.

Our Contact Information

Please contact us with any questions or comments about this Policy, your personal information, our use and disclosure practices, or your consent choices by email at [email protected].

xiQ, Inc.

100 Redwood Shores Parkway, Suite 100

Redwood City, CA 94065

USA

Last updated: 28/05/2024