PRIVACY POLICYLast updated: July 14, 2023This 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 legal@xrgoods.co.SUMMARY OF KEY POINTSThis 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. Do we process any sensitive personal information? We do not process sensitive personal information.Do we receive any information from third parties? We do not receive 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. In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. How do we keep your information safe? We have organizational 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 unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.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. How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.Want to learn more about what we do with any information we collect? Review the privacy notice in full.TABLE OF CONTENTS1. WHAT INFORMATION DO WE COLLECT?2. HOW DO WE PROCESS YOUR INFORMATION?3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?6. HOW LONG DO WE KEEP YOUR INFORMATION?7. HOW DO WE KEEP YOUR INFORMATION SAFE?8. DO WE COLLECT INFORMATION FROM MINORS?9. WHAT ARE YOUR PRIVACY RIGHTS?10. CONTROLS FOR DO-NOT-TRACK FEATURES11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?13. DO WE MAKE UPDATES TO THIS NOTICE?14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?1. WHAT INFORMATION DO WE COLLECT?Personal information you disclose to usIn 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:phone numbersnamesemail addressesmailing addressespasswordsusernamescontact preferencescontact or authentication databilling addressesSensitive Information. We do not process sensitive information. Such as SSNs or health info. Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, motion data (acceleration sensor), location, microphone, storage, sensors, and other features. If you wish to change our access or permissions, you may do so in your device's settings.Mobile Device Data. We automatically collect device information (such as your model, and manufacturer), operating system, version information and system configuration information, device, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, and information about the features of our application(s) you accessed.This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.Information automatically collectedIn 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.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).Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.Location Data. We may collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.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 fulfill and manage your orders. We may process your information to fulfill 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 fulfill our contractual obligations, to protect your rights, or to fulfill 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. Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill 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 wayFor investigations and fraud detection and preventionFor business transactions provided certain conditions are metIf it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claimFor identifying injured, ill, or deceased persons and communicating with next of kinIf we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuseIf 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 provinceIf disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of recordsIf 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 producedIf the collection is solely for journalistic, artistic, or literary purposesIf the information is publicly available and is specified by the regulations4. 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.Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout5. 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 access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.6. HOW LONG DO WE KEEP YOUR INFORMATION?In Short: We keep your information for as long as necessary to fulfill 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 anonymize 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.7. HOW DO WE KEEP YOUR INFORMATION SAFE?In Short: We aim to protect your personal information through a system of organizational and technical security measures.We have implemented appropriate and reasonable technical and organizational 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 unauthorized 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.8. 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 solicit data from or market to children under 18 years of age. 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 legal@xrgoods.co.9. WHAT ARE YOUR PRIVACY RIGHTS?In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), 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.In some regions (like the EEA, UK, 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; and (iv) if applicable, to data portability. 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. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.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.Account InformationIf you would at any time like to review or change the information in your account or terminate your account, you can:Contact us using the contact information provided.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. If you have questions or comments about your privacy rights, you may email us at legal@xrgoods.co.10. CONTROLS FOR DO-NOT-TRACK FEATURESMost 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 recognizing and implementing DNT signals has been finalized. 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.11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.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 using the contact information provided below.If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).CCPA Privacy NoticeThe California Code of Regulations defines a "resident" as:(1) every individual who is in the State of California for other than a temporary or transitory purpose and(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purposeAll other individuals are defined as "non-residents."If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.What categories of personal information do we collect?We have collected the following categories of personal information in the past twelve (12) months:CategoryExamplesCollectedA. IdentifiersContact 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 categories listed in the California Customer Records statuteName, contact information, education, employment, employment history, and financial information
NO
C. Protected classification characteristics under California or federal lawGender and date of birth
YES
D. Commercial informationTransaction information, purchase history, financial details, and payment information
NO
E. Biometric informationFingerprints and voiceprints
NO
F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
NO
G. Geolocation dataDevice location
YES
H. Audio, electronic, visual, thermal, olfactory, or similar informationImages and audio, video or call recordings created in connection with our business activities
YES
I. Professional or employment-related informationBusiness 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 InformationStudent records and directory information
NO
K. Inferences drawn from other personal informationInferences 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