This Privacy Policy (this “Policy”) describes how xx Foundation and its related companies and affiliates (collectively, the “Company”, “xx Foundation”, “us”, “our” and “we”)  collect, use, and share your personal information when you visit or interact with https://sale.xx-coin.io, https://xx-coin.io/ and the xx collective app or any other websites, content, APIs, or mobile applications we own or operate (collectively, the “Site”).  This Policy also applies to any of our other websites that post this Policy. This Policy does not apply to other websites or applications that post other statements. By signing up to create an account or submitting personal information to us through our Site, you agree that you have read, understood, and accept all of the terms of this Policy.

Unless otherwise noted, all terms not specifically defined in this Privacy Policy have the meaning assigned to them in our Terms of Use. This Privacy Policy forms part of the Terms of Use.

Personal Information We Collect

We get information about you in a range of ways and this includes personal information:

• Information You Give Us.  We collect your‎ name, postal address, email address, date of birth, username and password, virtual currency address as well as other information you directly give us on our Site. We may also collect certain personal information (e.g., social security number or other proof of identity such as driver’s license, passport or government-issued ID) in order to verify and authenticate your identity as required by applicable law. In addition, to participate in certain transactions or interactions on the Site, you may be required to submit additional financial information.
• Information We Get From Others. We may get information about you from other sources, including from publicly available data on a blockchain network, such as information collected from using blockchain explorers. We may add this to information we get from this Site. We also receive information about you from third party services we partner with to verify and authenticate your identity as required by applicable law.
• Information Automatically Collected. We automatically collect certain information about your device when you use the Site, including information about your web browser, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.
• We may log information using “cookies” or similar technologies such as pixel tags. For purposes of this Policy, all such technologies shall be referred to as cookies. Cookies are data files that are placed on your device or computer and often include an anonymous unique identifier. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. For more information about cookies, and how to disable cookies, see below under the section entitled “Cookies” and visit http://www.allaboutcookies.org/.

How We Use Your Personal Information

We use the personal information that we collect generally to fulfill the purpose for which it was provided. We have set out below a description of the ways we plan to use your personal information. We note that unless otherwise stated, we rely on the legal basis of legitimate interest to process your personal information:

• We use your personal information to operate, maintain, and improve the Site, products, and our services.
• We use your personal information to create and manage your account, including communicating with you regarding your account.
• We use your personal information to link or combine user information with other personal information as part of our process to verify and authenticate your identity as required by applicable law, including anti-money laundering laws and sanctions laws applicable in various jurisdictions.
• On the basis of it being necessary for the performance of a contract, we use your personal information to process and deliver xx Foundation digital assets legitimately purchased by you through the Site.
• On the basis of it being necessary for the performance of a contract, we use your personal information to enable you to access and use certain of our services in connection with your purchase, sale, or use of xx Foundation digital assets.
• We use your personal information to respond to and provide customer service.
• We use your personal information to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
• With your consent, we use your personal information to communicate about promotions, upcoming events, and other news, including news about products and services offered by us and our selected partners.
• We use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity or money laundering.
• We use your personal information to conduct security investigations and risk assessments.
• We use your personal information as described in the “Sharing Your Personal Information” section below.

Sharing Your Personal Information

We may share personal information as follows:

• We may share personal information with your express consent.
• We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
• We may share personal information for legal, protection, compliance and safety purposes.
• • We may share information to comply with applicable laws.
  • We may share information to respond to law enforcement, officials, regulatory agencies and other lawful requests, subpoenas and legal processes.
  • We may share information to protect the rights and property of the Company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
  • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
• We may share your information with financial institutions and service providers with which we partner to provide you certain of our services. For instance, we may share financial information with payment processors, or we may share identification information with third-party identity verification partners.
• We may share your information with our corporate affiliates.

Cookies

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on or to our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies We Use

Our Site uses the following types of cookies for the purposes set out below:

• Essential Cookies. These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
• Functionality Cookies. These cookies allow our Site to remember choices you make when you use our  Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
• Analytics and Performance Cookies. These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered does not identify any individual visitor. We use this information to help operate our Site more efficiently and to monitor the level of activity on our Site. We use the following analytics or third-party services:
• • Google Analytics. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here, and you can read more about how Google uses your personal information by reading Google’s Privacy Policy. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link.
  • Hubspot. We use Hubspot to provide certain support services and to improve how our Site works. You can find out more information about Hubspot and how it uses your personal information by reading Hubspot’s Privacy Policy, and you can manage your personal information use by Hubspot by emailing [email protected].
  • Facebook Event Tracking. We use Facebook Pixel Events for purposes of event tracking in order to better understand your use of the Site and improve how we deliver content or other aspects of the Site. You can find out more information about Facebook Pixel Events here, and you can read more about how Facebook uses your personal information by reading Facebook’s Privacy Policy.
• Third Party Cookies. As mentioned above, these are cookies placed by a third party on your device and may provide information to those third parties about browsing habits (including your visits to our Site, the pages you have visited and the links and advertisements you have clicked) that may help identify if certain services that such third parties provide are being used, identify your interests, retarget you and serve advertisements that are relevant to you. We do not have control or access to such cookies. If you look at one page on our Site, an advertisement may be delivered to you on our Site or on other sites, for products referenced on that page or for similar products and services. We do not engage in retargeted advertising for children users of our Site.

Disabling cookies

You can typically remove and reject cookies from our Site with your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

Your Rights

You have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. In accordance with applicable laws, you may send requests about personal information to our Contact Information below regarding the following:

• Opt-out.  You may contact us anytime to opt-out of: (i) direct marketing communications; and (ii) any new processing of your personal information that we may carry out beyond the original purpose. Please note that your use of some of the Site and our services may be ineffective upon opt-out.
• Access. You may access the information we hold about you at any time by contacting us directly.
• Amend. You can also contact us to update or correct any inaccuracies in your personal information.
• Move. Your personal information is portable – i.e. you have the flexibility to move your data to other service providers as you wish.
• Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, you may contact Rick Carback, who we have designated as the Company’s Data Protection Officer under the GDPR (as defined below),  at [email protected]. In your request, please make clear: (i) what personal information is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note, certain applicable laws may require that we maintain a record of certain personal information notwithstanding your wish to exercise these rights, such as financial information for purposes of complying with anti-money laundering laws or sanctions laws. Whenever possible, we will disclose any conflicts between such laws and your request to exercise your rights under this section and work with you to reach a resolution in compliance with applicable laws.

Information Security

We take your privacy very seriously and work hard to protect the Company and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of information we collect and store. Your personal information will be stored on a series of servers which have implemented industry standard security measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure and/or access. We encrypt the Site using SSL encryption technology and all traffic on the Site is forced to use SSL. We review all information practices on a regular basis, and we restrict access to information on a need-to-know basis for all employees and other Company service providers who are subject to confidentiality obligations and are subject to termination or disciplinary action, including legal action, should such employees or service providers breach these obligations. While two factor authentication is not presently required to access the Site and use our services, we reserve the right to require use of two factor authentication in the future. By submitting to us personal information, you give your express consent to the transfer and storage of your personal information as described in this Policy.

GDPR and International Transfers

All collection, processing and storing of personal data is performed in accordance with the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”), and the Company’s processing will take place in accordance with the GDPR. You can exercise your right to complain to a data protection authority by using the contact info found here.

Your information, including personal information that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy.  One such step we will take to ensure the security of your personal information is to enter into specific contract clauses approved by the European Commission which ensure your personal information is given the same protection it has in Europe.

Data Retention

We will only retain your personal information for as long as is reasonably required for you to use the Site and our services (and in the event you have created an account with us, until you close such account), unless a longer retention period is required or permitted by law. For instance, certain anti-money laundering requirements may require that we retain certain financial information for five or more years.

Do Not Track

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

Minors

The Site and our services are not intended for individuals under the age of 18. By using or interacting with our Site, you are affirming that you are at least 18 years old.  We do not knowingly collect personal information from children under 13. If you believe that a child under the age of 13 has provided information to us, please notify us at [email protected]. If we inadvertently collect information of children under 13, we will delete that information immediately upon notice. We are not liable for any damages that may result from the user’s misrepresentation of age.

Changes

We may update this Policy from time to time in our sole discretion. We may update the Policy for a variety of reasons. For instance, we may update the Policy in order to reflect changes to our practices or for other operational, legal or regulatory reasons. If we make any substantial changes, we may notify you by sending you an e-mail to the last e-mail address you provided to us (if any), and/or by prominently posting notice of the changes on our Site. You are responsible for providing us with your most current e-mail address or other contact information.  In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. Continued use of our Site and any related services following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Acceptance of the Privacy Policy

We assume that all visitors of the Site have carefully read this document and, by using the Site, you agree to its contents. If someone does not agree with this Privacy Policy, they should refrain from using the Site. The Company reserves the right to change its Privacy Policy as necessity dictates. Continued use of the Site after having been informed of any such changes to these conditions implies acceptance of the revised Privacy Policy.

This Privacy Policy is an integral part of the Site’s Terms of Use.

Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at: [email protected]. You may direct privacy inquiries to the attention of Rick Carback, our designated Data Protection Officer.

xx Foundation Privacy Policy