PRIVACY POLICY

Privacy Policy

1.Introduction

1.1Xaloon provides its App users with access to information, updates and certain products and services (the “Services”) through this App (the “Xaloon App”).

1.2This Privacy Policy details the Xaloon practices in connection with the collection and use of information and the circumstances when Xaloon may disclose such collected information.

1.3By using the Xaloon App, you acknowledge that you accept the practices and policies as detailed in this Privacy Policy and you consent to the collection, use and sharing of your information by Xaloon as detailed in this Privacy Policy.

1.4This Privacy Policy deals with the treatment of the personal information of App usersto the Xaloon App. This Privacy Policy does not extend to the practices of companies or people that are not controlled or managed by Xaloon.

2.Commitment

2.1Xaloon is committed to creating a safe and secure online environment and safeguarding the privacy of its App visitors.

3.Collecting Information

3.1App usersmay access the Xaloon App while remaining anonymous and without disclosing any personal information.

3.2During a visit to the Xaloon App, Xaloon may collect, store and use the following kinds of personal information from App visitors, including but not limited to:

(a)information about your computer and about your visits to and use of the Xaloon App (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and App navigation paths);

(b)information that you provide to Xaloon for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);

(c)information that you provide to Xaloon when using the Services on the Xaloon App, or information that is generated in the course of the use of those Services;

(d)information contained in or relating to any communication that you send to Xaloon or send through the Xaloon App;

(e)any other personal information that you choose to send to Xaloon.

5.Disclosing Personal Information

5.1Xaloon may disclose your personal information to any of its employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy.

5.2Xaloon may disclose your personal information to any Xaloon Affiliate (which shall mean for the purposes of this Privacy Policy any individual or corporation, partnership, trust, incorporated or unincorporated association, joint venture, limited liability company, or joint stock company that, directly or indirectly through one or more intermediaries, controls or is controlled by or is under common control with such individual or corporation, partnership, trust, incorporated or unincorporated association, joint venture, limited liability company, or joint stock company) insofar as reasonably necessary for the purposes set out in this Privacy Policy.

5.3Xaloon may disclose your personal information:

(a)to the extent that Xaloon is required to do so by law;

(b)in connection with any ongoing or prospective legal proceedings;

(c)in order to establish, exercise, protect or defend the legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk) of Xaloon;

(d)to the purchaser (or prospective purchaser) of any business or asset that Xaloon are (or are contemplating) selling.

5.4Except as provided in this Privacy Policy, Xaloon will not provide your personal information to third parties.

6.International Data Transfers

6.1Information that Xaloon collects may be stored and processed in and transferred between any of the countries in which Xaloon operates in order to enable Xaloon to use the information in accordance with this Privacy Policy.

6.2You expressly agree to the transfers of personal information described in this Section 6 and as may be provided elsewhere in this Privacy Policy.

7.Retaining Personal Information

7.1This Section 7 sets out the Xaloon data retention policies and procedure, which are designed to help ensure that Xaloon is compliant with its legal obligations in relation to the retention and deletion of personal information.

7.2Personal information that Xaloon processes for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3Notwithstanding the other provisions of this Section 7, Xaloon will retain documents (including electronic documents) containing personal data:

(a)to the extent that Xaloon is required to do so by law;

(b)if Xaloon believes that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c)in order to establish, exercise or defend the legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk) of Xaloon.

8.Security of Personal Information

8.1Xaloon will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.

8.2Xaloon will store all the personal information you provide on its secure servers.

8.3You are advised that Xaloon uses third party vendors to provide the necessary hardware, software, networking, storage and related technology required to run the Xaloon App. By using the Xaloon App you acknowledge that your data may be stored on a third party storage server and transmitted through third party networks.

8.4You acknowledge that the transmission of information over the internet is inherently insecure, and Xaloon cannot guarantee the security of data sent over the internet.

9.Amendments

9.1Xaloon may at its sole discretion and without notice update this Privacy Policy from time to time by publishing a new version on the Xaloon App.

9.2You should check this page occasionally to ensure you are happy with any changes to this Privacy Policy.

9.3Xaloon may notify you of changes to this Privacy Policy by email.

10.Your Rights

10.1You may instruct Xaloon to provide you with any personal information Xaloon may hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, Xaloon may accept a photocopy of your passport certified by an attorney or bank plus an original copy of a utility bill showing your current address).

10.2Xaloon may withhold personal information that you request to the extent permitted by law.

10.3You may instruct Xaloon at any time not to process your personal information for marketing purposes.

10.4In practice, you will usually expressly agree in advance to the use by Xaloon of your personal information for marketing purposes.

10.5App userswho do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Xaloon App. If you refuse cookies, you do so with the knowledge that such refusal will result in a drawback to the extent that certain features of the Xaloon App may not function properly without the aid of cookies.

11.Updating Information

11.1 Please let Xaloon know if the personal information that Xaloon holds about you needs to be corrected or updated.

12.Cookies

12.1The Xaloon App uses cookies.

12.2A cookie is a file containing an identifier that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

12.3Cookies do not typically contain any personal information that may personally identify a user, but personal information that Xaloon stores about you may be linked to the information stored in and obtained from cookies.

12.4Most browsers allow you to refuse to accept cookies.

13.Child Users

13.1 Protecting the privacy of young children is especially important to Xaloon. Xaloon does not knowingly collect or maintain personal information from persons under 13 years for age (“Child Users”). The Xaloon App is not directed to Child Users. If Xaloon becomes aware of personal information that has been collected from a Child User without verified parental consent, Xaloon will delete such information.

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