Privacy Statement

Tracey

Updated 31 October 2022 12:45

Privacy Statement, effective as of July 15, 2022

This Privacy Statement describes how information relating to individuals is collected, used, shared or otherwise processed (“Personal data'') by companies that are responsible for processing Personal data on the Platform and the rights associated with that processing.

The type of company that will use Personal data depends on the kind of Services you use on the Platform. In general, Personal data for Services on the Platform are processed by Max Victory Limited (the Republic of Seychelles), and personal data for spot trading transactions in the European Union and the United Kingdom will be processed by Exechain OÜ (the Republic of Estonia). This means that your data controller as a counterparty for the purposes of this Privacy Statement will involve different companies, depending on your location and the types of services that you are accessing via the Platform.

If our services or products are provided through local operating subsidiaries or third-party service providers in alignment with the Terms of Services or other applicable rules, this means your data controller will be this subsidiary or provider in accordance with our global privacy standards, this Privacy Statement, as well as any applicable national laws.

Unless the context requires otherwise, the “Operator”, “we” or “us” for the purposes of these Terms shall mean the company with which you have a legal relationship. It also includes its relevant affiliates involved in the collection, use, sharing, or other processing of the Personal data. A list of The Operator’s affiliates can be found in the List of Subsidiaries.

This Privacy Statement uses some of the provisions of the Terms of Service.

A reference to websites shall include a reference to the mobile applications, clients, applets and other applications ( “Platform”)

Responsible Operator’s entity

1.1 The Operator and/or its affiliated entities are responsible for the processing of your Personal data as described in this Privacy Statement as part of our daily business operations, unless specified otherwise, and act as the controller of such Personal data.

1.2 This Privacy Statement sets out how our Platform and other products and services provided by the Operator, collects, uses and manages the personal information we receive from you, or a third party, in connection with our provision of services to you or which we collect from your use of the Platform. The Privacy Statement also informs you of your rights with respect to the processing of your personal information.

1.3 Please note that if you are an employee of the Operator, a contractor of the Operator or a third party supplier and you have a separate contract describing the processing of personal data, your personal information will be used in connection with your contract of employment or your contractual relationship, whichever is applicable.

1.4 If you provide us, our service providers or our affiliates with any Personal data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Statement. If you believe that your Personal data has been provided to us improperly, or want to exercise your rights relating to your Personal data, please contact us by using the information in the Section 17 below.

2. Processing activities covered

2.1 This Privacy Statement applies to the processing of Personal data collected by us when you:

visit our websites, applications and other places that display or link to this Privacy Statement;
visit our branded social media pages;
visit our offices;
receive communications from us or otherwise communicate with us, including but not limited to emails, phone calls, texts or faxes;
use our products and services where we act as a controller of your Personal data;
register for, attend or take part in our events, webinars, programs, trainings, certifications or contests;
act as or work for a service provider or supplier to the Operator, to the extent the Operator acts as a controller with respect to your Personal data if a separate contract describing the processing of personal data does not exist;
are employed by a customer of our products and services where your information has been shared with us in our capacity as a controller (for example, during the contracting process);
participate in surveys, research or other similar data collection facilitated by us.

2.2 When applications, connectors, extensions or other solutions are provided by us and they link to this Privacy Statement, this Privacy Statement applies. When these offerings are provided by third parties, a privacy policy of the third party applies and this Privacy Statement does not.

2.3 Our websites and services may contain links to other websites, applications, platforms and services maintained by third parties. The information practices of these third parties, including the social media platforms that host our branded social media pages, are governed by their privacy policy, which you should review to better understand their privacy practices.

2.4 In some circumstances, we also collect, or our partners provide us with, publicly available information which may contain Personal data that you have published or that has been made available online. The way in which our partners collect this is detailed in their own privacy policies, available on their websites.

3. What Personal data do we collect?

3.1 Personal data we collect directly from you

The Personal data we collect directly from you may include identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information, among others. We may collect such information in the following situations:

Situations	Categories of Personal data
If you express an interest in obtaining additional information about our services; request customer support (including accessing the Support Center); use our “Contact Us” or similar features; register to use our websites or to receive communications; sign up for an event, webinar or contest; participate in a program, training, certification or survey; use our products and services; download certain content; or are employed by a customer of our products and services where your information has been shared with us.	Contact information, such as your name, job title, company name, address, phone number, email address, username and password, other information you have voluntarily chosen to share.
If you make purchases via our websites, apps, Platform or register for an event or webinar.	Contact information, financial and billing information, such as: Full name, residential address and contact details (e.g. email address, telephone number, fax etc.); Date of birth, place of birth, gender, citizenship; Bank account information, credit card details, including details about your source of funds, assets and liabilities, and KYC information; Trading account balances, trading activity, your inquiries and our responses; Billing name and address, credit card number, bank account information; Information on whether you hold a prominent public function (PEP); Verification information, which includes information necessary to verify your identity such as a passport, driver’s license or government-issued identity card); Other Personal Information or commercial and/or identification information – Whatever information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (AML) obligations, such as under the European Union’s 4th AML Directive and the U.S. Bank Secrecy Act (BSA).
If you attend an event	Attendee badge information which may include name, title, company name, address, country, phone number and email address, image and video. During the Covid-19 pandemic, this may also include health status, including your temperature, COVID-19-related symptoms, exposure to COVID-19 positive individuals, vaccination status, testing results, and recent travel history.
If you register with us for a variety of purposes, including joining a community that we host or participating in a program.	Username, photo, video or other biographical information, such as your occupation, location, social media profiles or usernames, company name, areas of expertise and interests.
If you interact with our websites, apps, Platform, or emails.	Information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers), which may qualify as Personal data (please see the Section 4 below) using cookies, web beacons, or similar technologies.
If you use and interact with our products and services.	Information about your device and your usage of our services through log files and other technologies, some of which may qualify as the Personal data (including Usage Data) (please see the Section 4 below).
If you communicate with us via a phone call.	phone number, record of conversation.
If you visit our offices.	Name, email address, phone number, company name, time and date of arrival, image or video. During the Covid-19 pandemic, this may also include health status, including your temperature, Covid-19-related symptoms, exposure to Covid-19 positive individuals, vaccination status, testing results, and recent travel history.
If you voluntarily submit certain information to us, such as filling out a survey, responding to a questionnaire or participating in other forms of research.	Information you have provided as part of that request, which may include the Personal data and special categories of the Personal data, to the extent you voluntarily choose to provide it.
If you are a supplier or service provider to Us (or work for a supplier or service provider).	Contact information, payment and billing information.

3.2 We obtain information about you in a number of ways through your use of our services, including through any of our websites, the account opening process, webinar sign-up forms, event subscribing, news and updates subscribing, and from information provided in the course of on-going support service communications. We also receive information about you from third parties such as your payment providers and through publicly available sources. For example:

3.2.1 The banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;

3.2.2 Your business partners may provide us with your name and address, as well as financial information;

3.3 Credit reference agencies do not provide us with any personal information about you, but may be used to corroborate the information you have provided to us.

3.4 The Personal data we collect to provide our products and services may include information you have made publicly available online (such as when using social media sites) or that is published by third parties and contains information about you (such as news articles). For a select number of services, we collect this Personal data from partners who may receive this data when you visit or use their services or through the third parties they work with. We analyze this information to enable our customers to assess the success of their brands.

3.5 In addition, the Personal data we collect to provide our products and services may include location information from third parties, which helps us offer features like identity management and multi-factor authentication.

3.6 Advertising: The Personal data we collect from other sources for the purposes of tailored advertising includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. We, collect this from third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you.

4. What Usage Data do we process?

4.1 As is true of most websites, we gather certain information when individual users visit our websites. This information may include:

4.1.1 identifiers, such as user ID, organization ID, username, email address and user type;

4.1.2 commercial information; and

4.1.3 internet activity information such as IP address (or proxy server information), device and application information, identification numbers, location, browser type, Internet service provider or mobile carrier, user interactions such as the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system type and version, system configuration information, date and time stamps associated with your usage and details of which of our products and product versions you are using. This information is used for the purposes set out in the Section 5 of this Privacy Statement below.

4.2 In addition, we gather certain information automatically as part of your use of our products and services (“Usage Data”). This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, browser type, Internet service provider or mobile carrier, the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system type and version, system configuration information, date and time stamps associated with your usage and details of which of our products and product versions you are using. This information is used for the purposes set out in detail in the Section 5 of this Privacy Statement below. In addition, we may use the aggregate and de-identified Usage Data for other internal business purposes, such as to identify additional customer opportunities and to ensure that we are meeting the demands of our customers and their users. Please note that this Usage Data is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals), but as we and our Users deal with Digital Assets and Fiat it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers.

5. Cookies, web beacons and other tracking technologies on our website and in email communications

5.1 We use technologies such as web beacons, pixels, tags, and JavaScript, alone or in conjunction with cookies, to gather information about the use of our websites and how people interact with our emails. For more information you may visit our Cookie Notice.

5.2 As described in the Cookie Notice, we or one of our authorized partners may place or read cookies on your device when you visit our websites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). To learn more about targeted advertising and advertising networks, please visit our Cookie Notice.

6. Purposes for which we process Personal data and the legal bases on which we rely

Purpose	Description	Legal basis
Websites and social media branded pages
Providing our websites or apps (including our social media pages)	We process your Personal data to operate and administer our websites and to provide you with the content you access and request	Our legitimate interest in providing online content to our customers and prospective customers regarding our service offering and related information
Improving our websites or apps	We process your Personal data to analyze overall trends and help us improve the user experience on our websites	Our legitimate interest in providing a relevant and well-functioning website for the benefit of our website visitors
Promoting the security of our websites or apps	We process your Personal data by tracking use of our websites or apps and verifying and investigating activity	Our legitimate interest in promoting the safety and security of our websites and in protecting our rights and the rights of others
Displaying personalized advertisements and content	We process your Personal data to conduct market research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests	Our legitimate interest in advertising our products and services or, where necessary, to the extent you have provided your prior consent Please see 11 below, to learn how you can control the processing of your Personal data by us for personalized advertising purposes
Office visitors and events
Registering visitors	We process your Personal data, including registration information and associated non-disclosure information, for security reasons	Our legitimate interest in protecting our offices, staff, visitors and our confidential information against unauthorized access
Managing event registrations and attendance	We process your Personal data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you	Performance of a contract or where we receive your consent
Ensuring the health and safety of our visitors and employees	We process your Personal data (which may include special categories of Personal data) (where legally permitted) during office visits and at events during the Covid-19 pandemic to ensure the health and safety of our visitors and employees	Consent and explicit consent or in our legitimate interest to ensure the health of our employees and visitors where necessary for reasons of public interest in the area of public health
Communications
Sending communications	We process your Personal data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS or push notifications, information about our products, news or events) about us, our affiliates and partners	Our legitimate interest in conducting direct marketing or where you have provided your prior consent (please see the Section 13 below to learn how you can control the processing of your Personal data by the Operator for marketing purposes)
Recording phone calls	We process your Personal data, including recording phone calls (in accordance with applicable laws) for training, quality assurance, and administration purposes If required under applicable law, we will give you the option to object to a call being recorded	Consent or our legitimate interest in maintaining the high quality of our phone calls with users
Handling contact and user support requests	We process your Personal data if you fill out a “Contact Me” web form or request user support, or if you contact us by other means including but not limited to via phone	Necessary for the performance of a contract or our legitimate interest in fulfilling your requests and communicating with you
Legal Notifications	We process your Personal data if the law requires us to advise you of certain changes to products or services or laws. We may need to inform you of changes to the terms or the features of our products or services. We need to process your personal information to send you these legal notifications. You will continue to receive this information from us even if you choose not to receive direct marketing information from us	Our legitimate interest in responding to lawful requests
Our products and services
Provision of services	We process your Personal data to perform our contract with you for the provision of our services and to satisfy our obligations under the applicable terms of use	Necessary for the performance of a contract or our legitimate interest to provide and administer our services
Recording of public blockchain	our funding of bitcoin, XRP, ether, and other Digital Assets, may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks which are not controlled or operated by the Operator or its affiliates, we are not able to erase, modify, or alter the Personal data from such networks.	Necessary for the performance of a contract or our legitimate interest in managing the provision of our services to customers
Optimizing the performance of the services	We process your Personal data to optimize or improve the performance of the services	Legitimate interest to ensure that the service is performing in line with customer expectations; if special categories of the Personal data are processed, where the Personal data is manifestly made public by the data subject
Usage and licensing compliance	We process your Personal data (including Usage Data) to assess and manage usage and licensing compliance with the applicable terms of use of our services	Necessary for the performance of a contract or our legitimate interest in managing the provision of our services to customers
Internal reporting and business modeling	We process your Personal data (including Usage Data) for internal reporting and business modeling purposes (e.g., forecasting, revenue, capacity planning, product strategy)	Our legitimate interest in the management of our business operations
Improving core functionality	We process your Personal data (including your Usage Data) for the purposes of improving the core functionality of accessibility, privacy or energy-efficiency	Our legitimate interest to offer innovative services to our users and customers, or where we seek your consent
Security	We process your Personal data (including your Usage Data) for the purposes of maintaining the Operator’s own security, including investigating, detecting and preventing suspicious activity, fraud and cybercrime that may affect the Operator or its services	Our legitimate interest in promoting the safety and security of the Operator generally and to protect our rights and the rights of others

Financial reporting	We process your Personal data (including your Usage Data) for the purposes of financial reporting	Our legitimate interest in meeting our obligations associated with the reporting of our finances
Aggregating data	We process your Personal data (including your Usage Data) for the purposes of aggregating this information to ensure that it is no longer identifying	Our legitimate interest in minimizing the amount of Personal data processed as part of the noted processing activity
Compliance with Local Laws and Sanctions	We process your Personal data (including A copy of your passport or the other documents) for the purpose to deem necessary to comply with our legal obligations under various anti-money laundering (AML) obligations, such as under the European Union’s 4th AML Directive and the U.S. Bank Secrecy Act (BSA) or in order to comply with sanctions laws.	Our legitimate interest in compliance and sanctions obligations.
Webinars, programs, trainings, certifications and contests
Managing, and participating in, webinars, contests, programs, training, certifications or promotions	We process your Personal data if you register for a webinar, contest, promotion, training, certification or a program. Some webinars, contests, programs, trainings, certifications and promotions have additional rules containing information about how we will process your Personal data	Necessary for the performance of a contract or where we seek your consent
Other data collection
Managing payments	If you have provided financial information to us, we process your Personal data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you	Necessary for the performance of a contract
Administering surveys and conducting research	We process your Personal data (including, where legally permitted, special categories of Personal data) in order to meet the goals set out in surveys or research as well as to analyze our compliance with internal policies	Consent or explicit consent (if required under applicable law) or our legitimate interest in conducting the survey or research based on its stated goals (where no special categories of Personal data are in scope)
Compliance with legal obligations	We process your Personal data (including Usage Data) when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal data to protect our rights	Legal obligation or our legitimate interest in protecting against misuse or abuse of our websites or services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, responding to lawful requests, or for auditing purposes

7. Who do we share Personal data with?

7.1 We may share your Personal data as follows:

7.1.1 Service providers: with our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment for the purposes and pursuant to the legal bases described above;

7.1.2 Other users of the Platform and third parties: If the transfer of your Private data is necessary for transactions with your digital Assets on your behalf.

7.1.3 Affiliates: With affiliates within the Operator corporate group and companies that we acquire in the future after they are made part of the Operator corporate group, to the extent such sharing of data is necessary to fulfil a request you have submitted via our websites or for customer support, marketing, technical operations, event registration and account management purposes.

7.1.4 Event sponsors: If you attend an event or webinar organized by us, or download or access an asset on our website, we may share your Personal data with sponsors of the event. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not wish for your information to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out it;

7.1.5 Partners: With specific partners that offer supplementary services to those provided by the Operator, to the extent you consent to such sharing (where required by applicable law);

7.1.6 Customers with whom you are affiliated: If you use our services as an authorized user, we may share your Personal data with your affiliated customer responsible for your access to the services to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies;

7.1.7 Contest and promotion sponsors: With sponsors of contests or promotions for which you register in order to fulfil the contest or promotion;

7.1.8 Third party networks and websites: With third-party social media networks, advertising networks and websites, so that the Operator can market and advertise on third party platforms and websites;

7.1.9 Professional advisers: In individual instances, we may share your Personal data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal data;

7.1.10 Third parties involved in a corporate transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal data to an unaffiliated third party.

7.2 We may also share anonymous or de-identified Usage Data with Operator’s service providers for the purpose of helping the Operator in such analysis and improvements. Additionally, the Operator may share such anonymous or de-identified Usage Data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our services.

7.3 Anyone using our services, communities, forums, blogs, or chat rooms on our websites may read any Personal data or other information you choose to submit and post.

7.4 If the Operator discloses your personal information to service providers and business partners, in order to perform the services requested by clients, such providers and partners may store your personal information within their own systems in order to comply with their legal and other obligations.

7.5 We require that service providers and business partners who process personal information to acknowledge the confidentiality of this information, undertake to respect any client’s right to privacy and comply with all relevant privacy and data protection laws and this Privacy Statement.

7.6 For more information on the recipients of your Personal data, please contact us by using the information in the Section 17 below.

8. Storing and International transfer of Personal data

8.1 Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers and business partners store and process your personal data in the European Union.

8.2 Your Personal data may be collected, transferred to and stored by us in Europe and by our affiliates and third-parties disclosed in this Statement, above, that are based in other countries.

8.3 Therefore, your Personal data may be processed outside your country or jurisdiction, including in places that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection. We ensure that the recipient of your Personal data offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators or legislators. Where required by applicable law, we will only share, transfer or store your Personal data outside of your jurisdiction with your prior consent.

9. Children

9.1 Our websites and services are not directed at children. We do not knowingly collect Personal data from children under the age of 18, or such other applicable age of consent

9.2 If we learn that we have inadvertently gathered personal information from a сhild, we will take legally permissible measures to remove that information from our records. The Operator will require the user to close his or her account and will not allow the use of our products and services. If you are a parent or guardian of a сhild, and you become aware that a сhild has provided personal information to us, please contact us at support@xgo.com and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights.

10 How long do we keep your Personal data?

10.1 We may retain your Personal data for a period of time consistent with the original purpose of collection (see above) or as long as required to fulfil our legal obligations (For example, we are subject to certain anti-money laundering laws which require us to retain the following, for a period of 5 years after our business relationship with you has ended). We determine the appropriate retention period for Personal data on the basis of the amount, nature, and sensitivity of the Personal data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

10.2 After expiry of the applicable retention periods, your Personal data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

10.3 Also, the Personal data we hold in the form of recorded information, by telephone, electronically or otherwise, will be held in line with local regulatory requirements. If you have opted out of receiving marketing communications, we will hold your details on our suppression list so that we know you do not want to receive these communications.

10.4 We may keep your data for longer than 5 years if we cannot delete it for legal, regulatory, or technical reasons.

10.5 For more information on data retention periods, please contact us by using the information in the Section 17 below.

11. Your rights relating to your Personal data

11.1 Your rights. You may have certain rights relating to your Personal data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

access your Personal data held by us;
know more about how we process your Personal data;
rectify inaccurate Personal data and, taking into account the purpose of processing the Personal data, ensure it is complete;
erase or delete your Personal data;
restrict our processing of your Personal data;
transfer your Personal data to another controller, to the extent possible;
object to any processing of your Personal data;
opt out of certain disclosures of your Personal data to third parties;
not be discriminated against for exercising your rights described above;
not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"); and
withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawn.

11.2 Where we process your Personal data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection.

Please note that the Automated Decision-Making currently does not take place on our websites or in our services.

12. How to exercise your rights

12.1 To exercise your rights, please contact us by using the information in the Section 17 below. Your Personal data may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information.

12.2 Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.

12.3 To update your billing information, discontinue your account or request return or deletion of your Personal data and other information associated with your account, please contact us by using the information in the Section 17 below.

13. Your preferences for email and SMS marketing communications

13.1 If we process your Personal data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from the Operator by clicking on the “unsubscribe” link located on the bottom of the Operator marketing emails

13.2 You may also turn off push notifications on the Operator apps on your device, or unsubscribe by contacting us using the information in the Section 17 below.

13.3 Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.

14. Your preferences for telemarketing communications

14.1 f you want your phone number to be added to our internal Do-Not-Call telemarketing register, please contact us by using the information in the Section 17 below. Please include your first name, last name, company and the phone number you wish to add to our Do-Not-Call register.

14.2 Alternatively, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.

15. How we protect your Personal data

15.1 The Operator respects the privacy of any users who access its website, and it is therefore committed to taking all reasonable steps to safeguard any existing or prospective clients, applicants and website visitors. We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal data we process or use.

15.2 The Operator keeps any Personal data of its clients and its potential clients in accordance with the applicable privacy and data protection laws and regulations. While we follow generally accepted standards to protect the Personal data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. Remember that you are dealing with the Digital Assets and the Fiat currency, so much of the security lies on your side. If you have any questions about the security of our websites, please contact us by using the information in the Section 17 below.

15.3 We have the necessary and appropriate technical and organizational measures and procedures in place to ensure that your information remains secure at all times. We regularly train and raise awareness for all our employees to the importance of maintaining, safeguarding and respecting your personal information and privacy. We regard breaches of individuals’ privacy very seriously and will impose appropriate disciplinary measures, including dismissal from employment. We have also appointed a Data Protection Officer, to ensure that our company manages and processes your personal information in compliance with the applicable privacy and data protection laws and regulations, and in accordance with this Privacy Statement.

15.4 The personal information that you provide us with when applying to open an account, applying for a role within the Operator, or when using our website, is classified as registered information, which is protected in several ways. You can access your registered information after logging in to your account by entering your username and the password that you have selected. It is your responsibility to make sure that your password is only known to you and not disclosed to anyone else. Registered information is securely stored in a safe location, and only authorized personnel have access to it via a username and password. All personal information is transferred to the Operator over a secure connection, and thus all reasonable measures are taken to prevent unauthorized parties from viewing any such information. Personal information provided to the Operator that does not classify as registered information is also kept in a safe environment and accessible by authorized personnel only through username and password.

16. Changes to this Privacy Statement

16.1 We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes.

16.2 We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal data.

17. Contacting us

17.1 Please contact gdpr@xgo.com

17.2 When you contact us, please indicate in which country and/or state you reside.

17.3 We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website https://edpb.europa.eu/about-edpb/about-edpb/members_en

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