PRIVACY POLICY
Last updated
September 18, 2024
This privacy notice for Xentrix Limited ('we', 'us', or
'our'), describes how and why we might collect, store, use, and/or share
('process') your information when you use our services ('Services'), such as
when you:
- Visit our website at
https://xentrix.org, or
any website of ours that links to this privacy notice
- Engage with us in other related ways,
including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help
you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not
use our Services. If you still have any questions or concerns, please contact us at
Julian.Phillips@xentrix.org.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any
of these topics by clicking the link following each key point or by using our table of contents below to find
the section you are looking for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact
with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal
information.
Do we collect any information from third parties?
We do not collect any information from third parties.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for security
and fraud prevention, and to comply with law. We may also process your information for other purposes with your
consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
How do we keep your information safe?
We have organisational and technical processes and procedures in place to protect your personal information.
However, 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 unauthorised third parties
will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn
more about how we keep your information safe.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights
regarding your personal information. Learn more about your
privacy rights.
How do you exercise your rights?
The easiest way to exercise your rights is by visiting https://app.xentrix.org, or by contacting us. We will consider and act upon any
request in accordance with applicable data protection laws.
TABLE OF CONTENTS
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
register on the Services, express an interest in obtaining information about us or our products and Services, when
you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information
that we collect depends on the context of your interactions with us and the Services, the choices you make, and
the products and features you use. The personal information we collect may include the following:
-
names
-
email addresses
-
passwords
-
billing addresses
Sensitive Information. We do not process sensitive information.
Microsoft Login Data.
We may provide you with the option to register with us using your existing Microsoft account. If you choose
to register in this way, we will collect certain profile information about you from Microsoft, as described in
the section called
'HOW DO WE HANDLE YOUR MICROSOFT LOGIN?' below.
All personal information that you provide to us must be true, complete, and
accurate, and you must notify us of any changes to such personal 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 Services.
We automatically collect certain information when you visit, use, or navigate the Services. 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 Services, and other
technical information. This information is primarily needed to maintain the security and operation of our
Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
You can find out more about this in our Cookie Notice:
https://app.xentrix.org/cookiepolicy.
The information we collect includes:
-
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information
our servers automatically collect when you access or use our Services and which we record in log files. Depending
on how you interact with us, this log data may include your IP address, device information, browser type, and
settings and information about your activity in the Services (such as the date/time stamps associated with your
usage, pages and files viewed, searches, and other actions you take such as which features you use), device event
information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
Google API
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short:
We process your information to provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process your information for other purposes
with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our
Services, including:
-
To facilitate account creation and authentication and otherwise manage user accounts. We may
process your information so you can create and log in to your account, as well as keep your account in working
order.
-
To deliver and facilitate delivery of services to the user. We may process your information to
provide you with the requested service.
-
To respond to user inquiries/offer support to users. We may process your information to respond
to your inquiries and solve any potential issues you might have with the requested service.
-
To send administrative information to you. We may process your information to send you details
about our products and services, changes to our terms and policies, and other similar information.
-
To fulfil and manage your orders. We may process your information to fulfil and manage your
orders, payments, returns, and exchanges made through the Services.
-
To save or protect an individual's vital interest. We may process your information when necessary
to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only process your personal information when we
believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like
with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual
obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to
you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on
in order to process your personal information. As such, we may rely on the following legal bases to process your
personal information:
-
Consent. We may process your information if you have given us permission (i.e. consent) to use
your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your
consent.
-
Performance of a Contract. We may process your personal information when we believe it is
necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior
to entering into a contract with you.
-
Legal Obligations. We may process your information where we believe it is necessary for
compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency,
exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are
involved.
-
Vital Interests. We may process your information where we believe it is necessary to protect your
vital interests or the vital interests of a third party, such as situations involving potential threats to the
safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e. express consent) to use your
personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied
consent). You can
withdraw your
consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without
your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be
obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to
assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of
kin
- If we have reasonable grounds to believe an individual has been, is, or may be
victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the
availability or the accuracy of the information and the collection is reasonable for purposes related to
investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or
rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business,
or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information in specific situations described in this section
and/or with the following third parties.
We may need to share your personal information in the following
situations:
-
Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business
to another company.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short:
We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and
pixels) to gather information when you interact with our Services. Some online tracking technologies help us
maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and
assist with basic site functions.
We also permit third parties and service providers to use online tracking
technologies on our Services for analytics and advertising, including to help manage and display advertisements,
to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your
communication preferences). The third parties and service providers use their technology to provide advertising
about products and services tailored to your interests which may appear either on our Services or on other
websites.
To the extent these online tracking technologies are deemed to be a
'sale'/'sharing' (which includes targeted advertising, as defined under the applicable laws) under applicable US
state laws, you can opt out of these online tracking technologies by submitting a request as described below under
section '
DO UNITED STATES RESIDENTS
HAVE SPECIFIC PRIVACY RIGHTS?
'
Google Analytics
6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED
PRODUCTS?
In Short: We offer products, features, or tools powered by artificial intelligence,
machine learning, or similar technologies.
As part of our Services, we offer products, features, or tools powered by
artificial intelligence, machine learning, or similar technologies
(collectively, 'AI Products'). These tools are designed to enhance your experience and provide you with innovative
solutions. The terms in this privacy notice govern your use of the AI Products within our Services.
Use of AI Technologies
We provide the AI Products through third-party service providers ('AI Service Providers'), including OpenAI
. As outlined in this privacy notice, your input, output, and personal information will be shared with and
processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?
You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.
Our AI Products
Our AI Products are designed for the following functions:
How We Process Your Data Using AI
All personal information processed using our AI Products is handled in line
with our privacy notice and our agreement with third parties. This ensures high security and safeguards your
personal information throughout the process, giving you peace of mind about your data's safety.
7. HOW DO WE HANDLE YOUR MICROSOFT LOGIN?
In Short:
If you choose to register or log in to our Services using your Microsoft account, we may have access to
certain information about you.
Our Services offer you the ability to register and log in using your Microsoft account login.
Where you choose to do this, we will receive certain profile information about you from Microsoft. The profile
information we receive may include your name, email address, and profile picture, as well as other information you
choose to make public on that platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are
otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible
for, other uses of your personal information by Microsoft. We recommend that you review their privacy notice to
understand how they collect, use, and share your personal information, and how you can set your privacy
preferences on their sites and apps.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short:
We keep your information for as long as necessary to fulfil 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). No purpose in this notice will require us keeping your
personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymise 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.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short:
We aim to protect your personal information through a system of organisational and technical security
measures.
We have implemented appropriate and reasonable technical and organisational
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 unauthorised 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
Services is at your own risk. You should only access the Services within a secure environment.
10. 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 collect, solicit data from, or market to children under 18 years of age, nor do we knowingly
sell such personal information. By using the Services, 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 Services. 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 at Julian.Phillips@xentrix.org
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:
Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA),
United Kingdom (UK), Switzerland, and Canada, 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, depending on your
country, province, or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), 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; (iv) if
applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances,
you may also have the right to object to the processing of your personal information. You can make such a request
by contacting us by using the contact details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below.
We will consider and act upon any request in accordance with applicable data
protection laws.
Withdrawing your consent:
If we are relying on your consent to process your personal information, which may be express and/or implied
consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw
your consent at any time by contacting us by using the contact details provided in the section
HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below or updating your
preferences.
However, please note that this will not affect the lawfulness of the
processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications:
You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe
link in the emails that we send, or by contacting us using the details provided in the section
HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below. You will then be
removed from the marketing lists. However, we may still communicate with you — for example, to send you
service-related messages that are necessary for the administration and use of your account, to respond to service
requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your
account or terminate your account, you can:
-
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with
applicable legal requirements.
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser
to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect
certain features or services of our Services. For further information, please see our Cookie Notice:
https://app.xentrix.org/cookiepolicy.
If you have questions or comments about your privacy rights, you may email us at Julian.Phillips@xentrix.org
.
12. 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 recognising and implementing
DNT signals has been finalised. 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.
California law requires us to let you know how we respond to web browser DNT
signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not
respond to them at this time.
Some browsers and browser extensions support the Global Privacy Control ('GPC') that can send a signal to the websites
you visit indicating your choice to opt-out from certain types of data processing, including data "sales" as defined
under certain laws. In certain territories, when we detect such a signal, we will make reasonable efforts to respect
your choices indicated by a GPC setting as required by applicable law.
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In Short:
If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky,
Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to
request access to and receive details about the personal information we maintain about you and how we have
processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the
right to withdraw your consent to our processing of your personal information. These rights may be limited in
some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:
Category
|
Examples
|
Collected
|
A.
Identifiers
|
Contact details, such as real name, alias, postal address, telephone
or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email
address, and account name
|
YES
|
B. Personal information as defined in the California Customer Records
statute
|
Name, contact information, education, employment, employment history,
and financial information
|
NO
|
C. Protected classification characteristics under state or federal
law
|
Gender, age, date of birth, race and ethnicity, national origin,
marital status, and other demographic data
|
NO
|
D. Commercial information
|
Transaction information, purchase history, financial details, and
payment information
|
NO
|
E. Biometric information
|
Fingerprints and voiceprints
|
NO
|
F. Internet or other similar network activity
|
Browsing history, search history, online behaviour, interest data,
and interactions with our and other websites, applications, systems, and advertisements
|
YES
|
G. Geolocation data
|
Device location
|
NO
|
H. Audio, electronic, sensory, or similar information
|
Images and audio, video or call recordings created in connection with
our business activities
|
NO
|
I. Professional or employment-related information
|
Business contact details in order to provide you our Services at a
business level or job title, work history, and professional qualifications if you apply for a job with
us
|
NO
|
J. Education Information
|
Student records and directory information
|
NO
|
K. Inferences drawn from collected personal information
|
Inferences drawn from any of the collected personal information
listed above to create a profile or summary about, for example, an individual’s preferences and
characteristics
|
NO
|
L. Sensitive personal Information
|
|
NO
|
We may also collect other personal information outside of these categories
through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide
the Services or for:
- Category A - As long as the user has an
account with us
- Category F - As long as the user has an
account with us
Sources of Personal Information
How We Use and Share Personal Information
Will your information be shared with anyone else?
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 information.
We have not disclosed, sold, or shared any personal information to third
parties for a business or commercial purpose in the preceding twelve (12) months.
We will not sell or share personal information in the future belonging to website visitors, users, and other
consumers.
Your Rights
You have rights under certain US state data protection laws. However, these
rights are not absolute, and in certain cases, we may decline your request as permitted by law.
These rights include:
- Right to know whether or not we are processing your
personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously
shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if
it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal
data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')
Depending upon the state where you live, you may also have the following
rights:
- Right to obtain a list of the categories of third parties to which we have
disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
- Right to obtain a list of specific third parties to which we have disclosed
personal data (as permitted by applicable law, including Oregon’s privacy law)
- Right to limit use and disclosure of sensitive personal data
(as permitted by applicable law, including California’s privacy law)
- Right to opt out of the collection of sensitive data and personal data collected
through the operation of a voice or facial recognition feature (as permitted by applicable law, including
Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by visiting https://app.xentrix.org, or by referring to the contact details at the bottom of
this document.
We will honour your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.
Under certain US state data protection laws, you can designate an authorised agent to make a request on your
behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly
authorised to act on your behalf in accordance with applicable laws.
Request Verification
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. We will only use personal
information provided in your request to verify your identity or authority to make the request. However, if 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.
If you submit the request through an authorised agent, we may need to collect
additional information to verify your identity before processing your request and the agent will need to provide a
written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal
our decision by emailing us at Julian.Phillips@xentrix.org. We will inform you in writing of any
action taken or not taken in response to the appeal, including a written explanation of the reasons for the
decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California
'Shine The Light'
Law
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 by using the contact details provided in the section
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You
may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and
conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This privacy notice satisfies the notice requirements defined in both Privacy
Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and
other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfil
their applicable purpose, it may affect our ability to provide our services, in particular:
- offer you the products or services that you
want
- respond to or help with your requests
- manage your account with us
- confirm your identity and protect your
account
Republic of South Africa
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal
information, you can contact the office of the regulator, the details of which are:
15. 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 at the top of this privacy notice. 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.
16. HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
If you have questions or comments about this notice, you may contact our Data
Protection Officer (DPO) by email at Julian.Phillips@xentrix.org.
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request
access to the personal information we collect from you, details about how we have processed it, correct
inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our
processing of your personal information. These rights may be limited in some circumstances by applicable law. To
request to review, update, or delete your personal information, please visit:
https://app.xentrix.org.