Collection And Use Of Personal Information
Personal information is data that can be used to identify or contact a single person.
I. Introduction
The General Data Protection Regulation (GDPR) is a European Union (EU) law that sets rules and requirements for the protection of personal data. The law applies to any organization that collects, processes, or stores personal data of EU citizens, regardless of where the organization is located.
II. Key Provisions of the GDPR
Personal data must be processed lawfully, fairly, and transparently, and only for specified, explicit, and legitimate purposes. Organizations must obtain explicit and informed consent from individuals before collecting and processing their personal data. Individuals have the right to access their personal data, as well as the right to request rectification, erasure, or restriction of their data. Organizations must implement appropriate technical and organizational measures to ensure the security of personal data. Organizations must report data breaches to the supervisory authority within 72 hours of becoming aware of them, and must notify affected individuals if the breach is likely to result in a high risk to their rights and freedoms. Organizations that process personal data on behalf of other organizations (processors) must comply with specific GDPR requirements, such as implementing appropriate security measures and signing data processing agreements with their clients (controllers).
III. Our GDPR Compliance Measures
At [Your Organization Name], we are committed to complying with the GDPR and protecting the personal data of our customers and users. We have implemented appropriate technical and organizational measures to ensure the security of personal data, including encryption, access controls, and regular backups. We obtain explicit consent from individuals before collecting and processing their personal data, and provide them with the right to access, rectify, erase, and restrict their data. We have designated a Data Protection Officer (DPO) to oversee our GDPR compliance efforts and ensure that we meet our obligations under the law. We have signed data processing agreements with our processors and vendors to ensure that they comply with the GDPR and protect the personal data they process on our behalf. In the event of a data breach, we will promptly notify the supervisory authority and affected individuals, as required by the GDPR.
IV. Conclusion
By following the GDPR's provisions and requirements, we aim to protect the personal data of our customers and users and maintain their trust and confidence in our organization.
If you have any questions or concerns about our GDPR compliance measures, please contact our Data Protection Officer at [1-855-934-3466].
You may be asked to provide your personal information anytime you are in contact with XP Life Inc. or an XP Life Inc. affiliated company. XP Life Inc. and its affiliates may share this personal information 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, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have. Our Privacy Policy is effective as of January 19, 2020
Here are some examples of the types of personal information XP Life Inc. may collect and how we may use it.
When you create an XP Life Inc. Account, register your products, apply for commercial credit, purchase a product, download a software update, register for a class at an XP Life Inc. Digital Store, contact us or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, and credit card information.
When you share your content with family and friends using XP Life Inc. products, send gift certificates and products, or invite others to join you on XP Life Inc. forums, XP Life Inc. may collect the information you provide about those people such as name, mailing address, email address, and phone number.
In the U.S., we may ask for your Social Security number (SSN) but only in limited circumstances such as when setting up a merchant account and determining whether to extend commercial credit.
How We Use Your Personal Information The personal information we collect allows us to keep you posted on XP Life Inc.’s latest product announcements, software updates, and upcoming events.
We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes.
From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with XP Life Inc., you may not opt out of receiving these communications.
We may also use personal information for internal purposes such as auditing, data analysis, and research to improve XP Life Inc.’s products, services, and customer communications.
If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs.
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it
We may collect information such as occupation, language, zip code, area code, unique device identifier, location, and the time zone where an XP Life Inc. product is used so that we can better understand customer behavior and improve our products, services, and advertising.
We may collect information regarding customer activities on our website, XP Life services, MYXP, XP Eats and digitaladportal and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non-personal information for the purposes of this Privacy Policy.
If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.
XP Life Inc.’s website, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies . These technologies help us better understand user behavior, tell us which parts of our website people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.
XP Life Inc. and its partners use cookies and other technologies in mobile advertising services to control the number of times you see a given ad, deliver ads that relate to your interests, and measure the effectiveness of ad campaigns. If you do not want to receive ads with this level of relevance on your mobile device, you can opt out by accessing the following link on your device: http://.XP Life Inc.media.com/opt_out. Opting out through XP Life Inc.media.com/opt_out applies only to XP Life Inc. advertising services and does not affect interest-based advertising from other advertising networks.
XP Life Inc. and our partners also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with XP Life Inc. more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit the XP Life Inc. digitaladportal. Knowing your country and language − and if you are an educator, your school − helps us provide a customized and more useful shopping experience. Knowing someone using your computer or device has shopped for a certain product or used a particular service helps us make our advertising and email communications more relevant to your interests. And knowing your contact information, product serial numbers, and information about your computer or device helps us register your products, personalize your operating system, set up your digitaladportal service, and provide you with better customer service.
As is true of most websites, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit pages, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, and to gather demographic information about our user base as a whole. XP Life Inc. may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on the XP Life Inc. website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
At times XP Life Inc. may make certain personal information available to strategic partners that work with XP Life Inc. to provide products and services, or that help XP Life Inc. market to customers. For example, when you purchase and activate your iPhone, you authorize XP Life Inc. and your carrier to exchange the information you provide during the activation process to carry out service. If you are approved for service, your account will be governed by XP Life Inc. and your carrier’s respective privacy policies. Personal information will only be shared by XP Life Inc. to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.
XP Life Inc. shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever XP Life Inc. operates.
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for XP Life Inc. to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
XP Life Inc. takes the security of your personal information very seriously. XP Life Inc., online services such as the XP Life Inc. MYXP, XP Eats and Digitaladportal protect your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by XP Life Inc., we use computer systems with limited access housed in facilities using physical security measures. XP Life, MYXP, XP Eats, Digitaladportal data is stored in encrypted form including when we utilize third party storage.
When you use some XP Life Inc. products, services, or applications or post on an XP Life Inc. forum, chat room, or social networking service, the personal information you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.
XP Life Inc. makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account at www.digitaladportal.com For other personal information we hold, we will provide you with access for any purpose including to request that we correct the data if it is inaccurate or delete the data if XP Life Inc. is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.
The information we collect from you falls into two categories: (i) personally identifiable information (i.e., data that could potentially identify you as an individual) (“Personally Identifiable Information” or “PII”), and (ii) non-personally identifiable information (i.e., information that cannot be used to identify you ) (“Non-Personally Identifiable Information” or “Non-PII”). This Privacy Policy covers both categories and will tell you how we might collect and use each type.
We may collect a variety of PII, including:
* Information from Third Party Services (defined below) that you explicitly give us access to; and
* Your contact information, such as your email address (depending on how you contact us).
We may also collect a variety of Non-PII, including various analytics data, such as:
* the IP address of the computer you use to access XP Life, MYXP, XP Eats, Digitaladportal;
* the type of browser software you are using;
* the operating system you are using;
* the date and time you access or use XP Life, MYXP, XP Eats, Digitaladportal;
* the website address, if any, that linked you to XP Life, MYXP, XP Eats, Digitaladportal;
* the website address, if any, you leave our website and travel to;
* other non-personally identifiable traffic data;
* versions of the XP Life, MYXP, XP Eats, Digitaladportal operating system and browser; and
* any username, including your first and last name, you submit to associate with your account on XP Life, MYXP, XP Eats, Digitaladportal.
We do not knowingly collect personal information from children under 13 except where a parent has set up an XP Life Inc. account for their child through the XP Life, MYXP, XP Eats, Digitaladportal for Students program and provided XP Life Inc. with verified parental consent.
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
To provide location-based services on XP Life Inc. products, XP Life Inc. and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your XP Life Inc. computer or device. This location data is collected anonymously in a form that does not personally identify you and is used by XP Life Inc. and our partners and licensees to provide and improve location-based products and services. For example, we may share geographic location with application providers when you opt in to their location services.
XP Life Inc. websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties − for example, a third-party iPhone app. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. XP Life Inc. abides by the “safe harbor” frameworks set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information collected by organizations in the European Economic Area and Switzerland. Learn more about the U.S. Department of Commerce Safe Harbor Program.
To make sure your personal information is secure, we communicate our privacy and security guidelines to XP Life Inc. employees and strictly enforce privacy safeguards within the company.
If you have any questions or concerns about XP Life Inc.’s Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us. You can always contact us by phone at the XP Life Inc. Support number.
All such communications are examined and replies issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
XP Life Inc. may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.
XP Life Inc. Inc. 7250 Keele Street, Suite 270 Vaughan, ON L4K 1Z8