Xnova International Privacy Policy

Effective Date:  October 24 2020

A.  Privacy Statement

This document (hereinafter referred to as "Privacy Policy") has the purpose to regulate the use of the different websites owned by Xnova International. Any person accessing this website and using their services (“​Service​”), or providing their data, assumes the role of user commitment to the observance and enforcement of the provisions contained herein, and any other applicable legal provision.

Acceptance of this document means that the user:

a) Read and understood this Privacy Policy.

b) Assumes and accepts all obligations defined.

This Privacy Policy will be valid for an indefinite period or, in any case, shall be valid until changed.

As used in this Privacy Policy, the term “Data” (“​Data​”) means information that identifies you and your company directly or indirectly, by reference to identifier(s) such as your name, your company name, identification number, location data, online identifier or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

The provider reserves the right to modify any information that could appear on the website, without there being any forewarning or report, users of such modifications, will be considered on notice by, but not only, modifying it on the website of the lender.

In this regard, the periodic review of this Privacy Policy is recommended.

By accessing our Service, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you cannot use our Service. Each time you use our Service, the current version of the Privacy Policy will apply. Accordingly, whenever you use our Service, you should check the date of this Privacy Policy and review any changes since the last version. This Privacy Policy is applicable to all Service visitors, registered users, and all other users of our Service.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

B.  Data Collected by Xnova International

When you use our Service, Xnova International collects information (i) that you knowingly and voluntarily Service ​(such as through forms or profile screens) including registration/account setup information, and (ii) that we are able to collect from your web browser, cookies and other similar technologies.

1.  Data that you Knowingly and Willingly Provide

Xnova International collects the information that you knowingly and voluntarily provide when you use our ​Service ​(such as through web forms or profile screens), including registration/account setup information, profile details, and payment information. We primarily use this information to provide you the Service. You can choose not to provide us with certain Data, but then you may not be able to take advantage of our Service ​or other available features we offer. The information that we collect and use may include the following kinds of Data:

  • First and Last Name

  • Email Address

  • Company Name

  • Credit and/or Debit Card Information

  • Purchase Information, including content and the time of the purchase

  • Postal Address

  • Telephone Number

 

We may also receive your Data from trusted third parties (including, for example, business partners, sub-contractors in technical, payment and delivery of membership services, advertising networks, analytics providers, search information providers, credit reference agencies).

2. Data that we collect from you

Xnova International collects information that is sent to us automatically by your web browser. Xnova International may use this information to generate aggregate and/or anonymous statistics about visitors to our Service. This information typically includes details about your:

  • IP Address

  • Browser Type

  • Browser Plug-In Details

  • Operating System

  • Local Time Zone

  • Date and Time of Each Visitor Request (e.g. web pages selected and time spent on each page)

  • Referring Site and/or Search Engine

  • Device Type (e.g. desktop, laptop, tablet, phone, etc.)

  • Screen Size, Color, Depth, and System Fonts 

  • Language Preference

 

Xnova International may use Data for various business purposes such as providing customer service, fraud prevention, market research, and improving our Service.  The information we receive depends on the settings on your browser.  Please check your browser if you want to learn what information your browser sends or how to change your settings.

3. Aggregate Information

We may aggregate and/or anonymize and/or pseudonymize all information that we collect from you. This may be done for the purpose of market research on brands and products, marketing campaigns, and advertising. Data Collected by Cookies, Web Beacons and Other Technologies.

4. Cookies

Xnova International may obtain information about you by installing “cookies” on your computer’s hard drive. We use cookies to collect statistical information about the ways visitors use our ​Service including which pages they visit, which links they use, and how long they stay on each page. Xnova International also may use cookies to create a database of your previous choices and preferences, saving you time and effort.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. If you limit or disable the use of cookies when you visit Xnova International, you may be unable to use the full of the functionality of our ​Service. For more information about cookies, visit: ​http://www.allaboutcookies.org​.

C. Third Parties

Advertisers and third parties also may collect information about your activity on our​ ​Service​ ​and on third-party​ ​sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties can be used to decide which advertisements you see on our Service, and on third-party​ ​sites and applications, but does not identify you personally and is not associated with your registration account.

D. How Is Your Data Used?

We will only process your Data, including sharing it with third parties, where (1) you have provided your consent which can be withdrawn at any time, by contacting info@xnovainternational.com (2) the processing is necessary for the performance of a contract to which you are a party, (3) we are required by law, (4) processing is required to protect your vital interests or those of another person, or (5) processing is necessary for the purposes of our legitimate commercial interests, except where such interests are overridden by your rights and interests.

 

We may use Data we collect about you on its own or combine it with other information we have about you to:

  • To create user accounts and/or profiles through registration;

  • Perform internal operations, such as tracking and improving the effectiveness of our website, mobile experience, and marketing efforts;

  • Provide product and/or Service fulfillment, such as creating accounts, managing purchases, payments, and more; 

  • Personalize user experiences, such as remembering your settings and preferences for things like language, font size, etc.;

  • Provide support; 

  • Resolve disputes between users and/or a user and the company as set forth in our Terms of Service;

  • Use the location of your device to prevent fraud or deliver other location-based services that you may request;

  • Administer a sweepstakes, contest, or similar promotion; 

  • Advertise and market our products and Service – and those of our Business Partners –including to:

    • Present targeted advertising, send or provide you with advertisements, promotions and offers;

    • Analyze whether our advertisements, promotions, and offers are effective;

    • Help us determine whether you may be interested in new products or services

    • Customer Testimonials

  • Conduct surveys;

  • Conduct research;

  • Receive feedback;

  • Conduct audits;

  • Provide information to our business partners;

  • Provide information to the media;

  • Provide information to our suppliers;

  • Provide information to our representatives and/or advisors, such as our attorneys, accountants, and others to help us comply with legal, accounting, or security requirements;

  • Transfer your information, such as to servers outside of the United States, or as part of a merger or sale of the business;

  • Protect the rights, safety, and information of our members, third parties, as well as our own.  This includes fraud prevention, business or product recalls, prosecuting and defending a court arbitration or similar proceeding, and more;

  • Comply with legal 

  • We may also disclose your Data as otherwise set forth in this Privacy Policy, as permitted by law, or with your consent.

 

E. Who Can Access the Information We Collect?

We will only transfer your Data to trusted third-parties who provide sufficient guarantees in respect of the technical and organizational security measures governing the processing to be carried out and who can demonstrate a commitment to compliance with those measures.

Where third parties are processing Data on our behalf, they will be required to agree, by contractual means or otherwise, to process the Data in accordance with the applicable law.

Xnova International may disclose your Data in the following instances:

Agents​. We may employ other companies and individuals to perform functions on our behalf. We may share our users’ Data with these agents as we deem necessary for such third parties to perform their functions.

 

Employees​. Xnova International employees have access to your Data.

 

Affiliates​. When you are asked for information while on our ​Service, you are sharing that information with Xnova International, and our various affiliates, unless specifically stated otherwise. As a result of this sharing, you may receive communications from any of our affiliates.

Affiliates and Subsidiaries​. Xnova International may share Data with our corporate subsidiaries and affiliates for uses consistent with this Privacy Policy.

Affiliated Businesses We Control​. We may share your Data with the affiliated businesses we control to make sure that your experience with us is as seamless as possible and that you have the full benefit of our offerings. The use of your Data by such controlled affiliates remains subject to this Privacy Policy.

Authorized Business Partners​. These include agents, contractors, vendors, licensors, resellers, system integrators, etc. Xnova International, our affiliates, and our business partners may share this Data with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, Service, content, and advertising.

Authorized Service Providers​. An authorized service provider (“​ASP​”) is an individual or entity that is permitted to service products that are still covered by warranties held by another entity. Service provided by anyone other than an authorized service provider will generally render a warranty void. We may share information with such ASPs to perform services on our behalf.

Advertisers​. Third-party advertisers and advertising platforms also may serve targeted advertisements as part of our Service.

Authorized Business Partners, Advertisers, Agents, and Promotional Offers​. We may enter into alliances, partnerships or other business arrangements with third parties to share Data for the purpose of providing you with information regarding products and services that we think may be of interest to you. We may also share your information with third party partners in order for them to better target products and services to their customers. If you do not want to receive such offers, please contact us.

Other Users​. Please remember that any information you share in public areas of our Service, such as on message boards or feedback sections, becomes public and anyone may take and use that information. Please be careful about what you disclose in these portions of our Service and do not post any Data that you expect to keep private. We strongly encourage you not to use any private data in your username or password.

Other Entities. ​If you provide any Data to us for posting in areas of our ​Service ​that may be publicly viewed (e.g., blogs or messaging features), your Data will be available to third parties who use our Service. Please be cautious when using the public features of our Service.

To Comply with Legal Process, Protect xNova International, or Enforce our Rights​. We may release your Data when it is necessary to (i) conform to legal requirements or comply with legal process; (ii) enforce or apply our conditions of use and other agreements (iii) protect the rights, safety or property of Xnova International, our affiliates, service providers, our users or the public, or (iv) prevent a crime or protect national security (including exchanging information with other companies and organizations for fraud protection and credit risk reduction).

As Part of a Merger or Sale of Business​. We may disclose your Data in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the event of bankruptcy.

F. Minors and Children Privacy

1. Children Online Protection

Our Service ​is not directed to children under the age of 16, if you are not 16 years or older, do not use our Service. If you are a parent or guardian and discover that your child or a minor under the age of 13 has posted, submitted or otherwise communicated Data to our Service ​without your consent, then you may alert us at ​info@xnovainternational.com so that we may take appropriate action to remove the minor’s Data from our systems.

2. Erasure Law

In accordance with California law, minors under the age of 18 residing in California may remove or request and obtain removal of content and information that they post on the website or app. In order to remove or to request and obtain removal of such content and information, the user must alert us at ​info@xnovainternational.com . Users should be aware that removal of the content and information posted by a minor does not ensure complete or comprehensive removal of the content or information posted on our Service.

Under certain circumstances, Xnova International may not have to comply with the above removal requirements. Xnova International also reserves the right, to the extent permitted by law, to anonymize the posted content or information or to make such content or information invisible to other users and the public instead of removing or deleting the content or information.

G. Links to Third Party Services

Our Service ​may contain links to third party websites, applications and services not operated by us. These links are provided as a service and do not imply any endorsement by Xnova International of the activities or content of these ​sites, applications or services nor any association with their operators.

Xnova International is not responsible for the privacy policies or practices of any third party including websites or services directly linked to our Service. We encourage you to review the privacy policies of any third party​ ​site that you link from our Service.

H. Social Media Features & Widgets

Our ​Service ​includes social media features, such as the Facebook “Like” button and widgets, such as the “Share This” button or authenticating your identity by logging into our Service ​via a social media account. These features may collect your IP address, which page you are visiting on our ​Service, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our ​Service. Your interactions with these features are governed by the privacy policy of the company providing it.

I. Security & Retention

1. Security

We take reasonable technical and organizational precautions to protect the confidentiality, security and integrity of your Data. Although we use security measures to help protect your Data against loss, misuse or unauthorized disclosure, we cannot guarantee the security of information transmitted to us over the Internet.

 

2. Retention

We will retain your information for as long as is needed. If you wish to cancel your account or request that we no longer use your information to provide you service, contact us at ​info@xnovainternational.com ​. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

J. Xnova International ​International Users

Consent to Transfer

We are headquartered in the United States. Your Data may be accessed by us or transferred to us in the United States or to our affiliates, partners, merchants, or service providers who are located worldwide. If you are visiting our Service from outside the United States, be aware that your information may be transferred to, stored, and processed in the United States. By using our Service, you consent to any transfer of this information.

We will protect the privacy and security of Data according to this privacy statement, regardless of where it is processed or stored, however you explicitly acknowledge and consent to the fact that Data stored or processed in the United States will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your Data.

K. Your Rights

1. Correction & Removal

If any of the information that we have about you is incorrect, or you wish to have information (including Data) removed from our records, please contact us at info@xnovainternational.com. We will respond to such inquiries within forty-five (45) business days.

2. Marketing

By consenting to this Privacy Policy, you agree to receive marketing materials from us. If you prefer not to receive marketing messages from us, please let us know by sending a message to us at ​info@xnovainternational.com

3. Your California Rights

FOR RESIDENTS OF CALIFORNIA ONLY. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your Data with third parties. If you reside in California and have provided your Data to Xnova International, you may request information about our disclosures of certain categories of Data to third parties for direct marketing purposes. Such requests must be submitted to us at one of the following addresses: ​info@xnovainternational.com or

 

Xnova International

Attn: California Privacy Rights

86 SW 8th St, Suite 2602,

Miami, FL 33130

Within thirty (30) days of receiving such a request, we will provide a list of the categories of Data disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this Section.

3. Your European Union Rights

FOR INDIVIDUALS IN THE EUROPEAN UNION​. ​Under the General Data Protection Regulation 2016/679, you have the right to ask us not to process your Data for marketing purposes. You can exercise your right to prevent such processing by contacting us using the Contact section on our Site.

In certain circumstances, you have the right to:

  • request access to any Data we hold about you (“Subject Access Request”) as well as related information, including the recipients or categories of recipients to whom the Data has been shared;

  • obtain without undue delay the completion of any incomplete Data or the rectification of any inaccurate Data we hold about you;

  • prevent or restrict processing of your Data, except to the extent processing is required for the establishment, exercise or defense of legal claims; and

  • request transfer of Data directly to a third party where this is technically feasible.

 

In addition, where you believe that the xNova International has not complied with its obligations under this Privacy Notice or European law, you have the right to make a complaint to an EU Data Protection Authority.  

You can exercise any of these rights by contacting us using the Contact section on our Site.

L. Privacy Inquiries

If you have any questions or concerns about this Privacy Policy or our privacy practices please contact us as follows:

 

Privacy Department

Xnova International

86 SW 8th St, Suite 2602,

Miami, FL 33130,

United States