Your privacy is important to us. This Privacy Policy explains our collection, use and disclosure of personal information that is collected or processed by Xfinion, Inc. (“we,” “us” or “our”) in connection with your access to and use of our website or otherwise interact with us outside of our products and services (individually or collectively, our website and other interactions are referred to herein as the “Website”). Please take a moment to read this document to learn about our personal information collection practices that may affect you (“User,” “you” or “your”) during your use of our Website. This Privacy Policy applies to our Website that displays or references this Privacy Policy, but it does not apply to our products and services governed under any separate agreements or different privacy policy or notice.
This Privacy Policy does not apply to personal information we process as a service provider or data processor on behalf of our business customers.
Your use of the Website and any information you provide through the Website remains subject to the terms of this Privacy Policy as well as in our Terms and Conditions.
Personal Information We Collect
The personal information we collect depends on how you interact with us, and the choices you make.
We collect information about you from different sources and in various ways when you use our Website, including information you provide directly, information collected automatically, third-party data sources, and information we infer or generate from other information.
Information you provide directly. We collect personal data you provide to us. For example:
- Contact information. We collect name, username or alias, email address, job title, company, postal address, and phone number.
- Content and files. If you send us email messages or other communications, we will collect and retain those communications.
Information we collect automatically. When you use our Website, we collect some information automatically. For example:
- Identifiers and device information. When you visit our Website, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the Cookies section below, our Website stores and retrieves cookie identifiers, mobile IDs, and other data.
- Geolocation data. Depending on your device and settings, we collect geolocation data when you use our Website.
- Usage data. We automatically log your activity on our Website, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, mouse clicks, access times, and other details about your use of and actions on our Website.
Information we create or generate. We infer new information from other information we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.
Information we obtain from third-party sources. We also obtain information from third parties. These third-party sources include, for example:
- Third party partners. Third party applications and services, including any you choose to connect with or interact with through our Website.
- Co-Branding/Joint Partners. Partners with which we offer co-branded features or engage in joint marketing activities.
- Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.
- Publicly available sources. Public sources of information such as open government databases.
When you are asked to provide personal information, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain features, those features may not be available or function correctly.
Cookies, Mobile IDs and Similar Technologies
We use cookies, web beacons, mobile analytics and advertising IDs, and similar technologies to operate our Website and to help collect data, including usage data, identifiers, and device information.
What are cookies and similar technologies? Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.
Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our Website (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our promotional email messages or newsletters to tell us if you open and act on them.
How do we and our partners use cookies and similar technologies? We, and our analytics and advertising partners, use these technologies in our Website to collect personal information (such as the pages you visit, the links you click on, and similar usage information, identifiers, and device information) when you use our Website, including personal information about your online activities over time and across different websites or online services. This information is used to store your preferences and settings, enable you to sign-in, analyze how our Website performs, track your interaction with the Website, develop inferences, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the information we collect or infer with third parties for these purposes.
The third-party analytics and advertising providers we use on our Website include, for example: Google Ads and Google Analytics. To learn about their privacy practices and how to opt-out from their use of cookie data for targeted advertising purposes, visit their respective settings pages.
What controls are available?
- Advertising controls. Our advertising partners may participate in associations that provide simple ways to opt out of ad targeting, which you can access at: United States: NAI and DAA; Canada: Digital Advertising Alliance of Canada; Europe: European Digital Advertising Alliance. These choices are specific to the browser you are using.
- Browser cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features of our Website.
- Email web beacons. Most email clients have settings which allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.
- Do Not Track. Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Website does not currently respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.
Our Use of Personal Information
We use the personal information we collect for purposes described in this Privacy Policy or as otherwise disclosed to you. For example, we use personal information for the following purposes:
- Functionality and Maintenance of the Website — To maintain the performance and functioning of our Website, including troubleshooting and improvement.
- Business Operations — To operate our business, such as improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations.
- Research and Development — To develop new features and conduct research.
- Personalization — To understand you and your preferences to enhance your experience and enjoyment using our Website.
- Customer Support — To provide customer support and respond to your questions.
- Communications — To send you information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
- Marketing — To communicate with you about new offers, promotions, rewards, contests, upcoming events, and other information about our products and services and those of our selected partners.
- Advertising — To display advertising to you. See the Cookies section above for information about personalized advertising and your advertising choices.
We combine data we collect from different sources for these purposes and to give you a more seamless, consistent, and personalized experience.
Our Sharing of Personal Data
We share personal information as necessary to complete or fulfill the transactions you have requested or authorized. For example, we share usage data and inferences with our advertising partners for analytics purposes.
In addition, we share each of the categories of personal information described above for the following business purposes:
- We share personal information with vendors or agents working on our behalf for the purposes described in this Privacy Policy. For example, service providers who facilitate user account authentication or assist us in analyzing how our Website is being used.
- We will also access, transfer, disclose, and preserve personal information when we believe that doing so is necessary to: comply with applicable law or respond to valid legal process; protect our customers and others, for example to prevent spam or attempts to commit fraud; operate and maintain the security of our Website; or protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies.
Third party analytics and advertising companies also collect personal information through our Website. These third party vendors may combine this data across multiple sites to improve analytics for their own purpose and others.
Finally, we may share de-identified information in accordance with applicable law.
Please note that some of the features on our Website may include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal information to any of those third parties, or allow us to share personal information with them, that information is governed by their privacy policies.
Choice and Control of Personal Data
Xfinion is a service provider to its business customers that use our products and services. These business customers determine which personal information to collect, process, and store for their own purposes. To exercise your individual rights, please contact the business you deal with directly to make your request.
Access, correction, and deletion. If you wish to access, correct, or delete personal information about you that we hold, please email us at legal@xfinion.com.
Communications preferences. You can choose whether to receive promotional communications from us by email. If you receive promotional email from us and would like to stop, you can do so by following the directions in that message or by contacting us. These choices do not apply to certain informational communications including surveys and mandatory service communications.
Choices for Cookies and Similar Technologies. See the Cookies section above for choices about cookies and other analytics and advertising controls.
European Data Protection Rights
If the processing of personal information about you is subject to European Union data protection law, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, personal information;
- If any automated processing of personal information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal information in a usable and portable format;
- If the processing of personal information is based on your consent, you can withdraw consent at any time for future processing;
- You can object to, or obtain a restriction of, the processing of personal information under certain circumstances; and
- For residents of France, you can send us specific instructions regarding the use of your information after your death.
To make such requests, please email us at legal@xfinion.com. When we are processing data on behalf of our business customer that is the “data controller,” you should direct your request to that business. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing personal information about you, for example, with your consent and/or as necessary for the functionality and maintenance of our Website, operate our business, meet our contractual and legal obligations, protect the security of our systems and our users, or fulfill other legitimate interests.
California “Do Not Sell My Personal Information”
Our Services may contain links to other websites and online services. If you choose to click on an advertisement or another third party link, you may be directed to that third party’s website or service. The fact that we link to a third party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites or services. We encourage you to read the privacy policies or statements of the other websites and services you use.
The CCPA requires us to describe the categories of personal information we sell to third parties and how to opt-out of future sales. We let advertising and analytics providers collect IP addresses and cookie IDs along with associated device and usage data when you access our Website, but we do not “sell” any other personal information.
If you do not wish for us or our partners to “sell” personal information relating to your visits to our Website for advertising purposes, you can make your Do Not Sell Request using the choices in the Cookies section of this Privacy Policy. If you opt-out using these choices, we will not share or make available such personal information in ways that are considered a “sale” under the CCPA.
We do not knowingly sell the personal information of minors under 16 years of age.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Finally, you have a right to receive notice of our practices at or before collection of personal information, and you have a right to not be discriminated against for exercising these rights set out in the CCPA.
Retention of Personal Data
We retain personal information for as long as necessary for operation of our Website and to fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different transactions, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.
Location of Personal Data
The personal information we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use data centers in the United States. The storage location(s) are chosen to operate efficiently and improve performance. We take steps designed to ensure that the information we collect under this Privacy Policy is processed and protected according to the provisions of this Privacy Policy and applicable law wherever the data is located.
Location of Processing European Personal Information. We transfer personal information from the European Economic Area (EEA), UK, and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections.
Our Policy Toward Children
IF YOU ARE UNDER 18 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE WEBSITE AT ANY TIME OR IN ANY MANNER. We do not permit users under the age of 18 to create accounts with us.
How We Protect Your Personal Information
We take reasonable steps to safeguard your information from unauthorized access, use, disclosure, alteration, and destruction. You are responsible for maintaining the secrecy of your unique account information at all times.
Changes to Privacy Policy
We will update this Privacy Policy when necessary to reflect changes in our Website, how we use personal information, or the applicable law. When we post changes to the Privacy Policy, we will revise the “Last Updated” date at the top of the Privacy Policy. If we make material changes to the Privacy Policy, we will provide notice or obtain consent regarding such changes as may be required by law.
Contacting Us
If you have any questions about our Privacy Policy or information practices, please contact us at contact@xfinion.com.