Last Update: 2022/02/22
We reserve the right to make changes to this policy at any given time. If at any point in time we decide to make use of any personally identifiable information on file in a manner vastly different from that which was stated when this information was initially collected, you shall be promptly notified by email. At that time, you shall have the option to permit the use of your information in a different manner.
This policy applies to your use of our platform, and it governs any data collection and usage by us in compliance with applicable regulations. By using the platform, you are hereby consenting to the data collection procedures expressed in this policy.
We gather various types of information from our users, as explained in more detail below. We use this information internally in connection with our platform, including personalizing, providing, and improving our XROBIUM; allowing you to set up a user account and profile; contact you; enable other users to contact you; and analyze how you use the platform. In some instances, we may also share some information with third parties, but only as described below.
3. Information we collect
A. Information you provide:
"Personal Information" means any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your contact information such as your name, email address, telephone number, demographic information, billing address, username and account password; as well as any other non-public information about you that is associated with or linked to any of the foregoing data such as your API key to connect your XROBIUM account with the desired cryptocurrency exchange platform.
"Anonymous Data" means data that is not associated with or linked to your Personal Data. Anonymous Data does not, by itself, permit the identification of individual persons.
We collect Personal Data and Anonymous Data and a few other categories of information, from a few different sources, as described below. We receive the information you provide to us as outlined below:
i) Account information, such as online password and other log-in details used to access the Platform;
ii) We may receive information from your cryptocurrency exchange platform provider when you connect your exchange account to your XROBIUM account;
iii) When you post User Generated content or provide us with feedback on our platform or on our community, the information contained in such user content will be stored on our servers and will be available to be seen by other users who make use of our platform.
iv) We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version and other requested information if you contact us via email regarding support for the platform.
Please note that you can choose not to provide us with certain information, but this may limit the features of the platform you are able to use.
A. Automated information collection
We may collect certain information (which does not identify you as an individual) about your use of the platform through the use of tracking technologies or by other passive means and other relevant statistics, including the following:
ii. Links: The platform or content made available on the platform may include links in a format that enables us to track whether IP addresses have followed these links. We use this information to improve the quality of our products and design.
iii. Beacons: Beacons (also known as "pixel tags" or "clear GIFs") are 1×1 single-pixel graphics that allow us to count the number of users who have visited or accessed the platform and to recognize users by accessing our cookies. We may employ beacons to facilitate platform administration and navigation, track users' actions, compile aggregated statistics about platform usage and response rates, and provide an enhanced online experience for visitors to the Platform.
iv. Geo-location Information: IP address of a user’s device or the mobile device’s GPS (to offer an improved user experience) - some mobile devices allow users to control the use of location platforms for applications installed on the device in the device’s settings menu. You also understand that XROBIUM may collect this geo-location information even when the user is not using the platform where a connection is enabled through the settings or device permissions;
vi. Payment Transaction Information: Through the use of a third-party payment processor, certain financial information used by the User for payment transactions for platforms received through the platform may be collected. Payment amount, date and time of the transaction, payment instrument expiration date and billing post code, the user’s IBAN information, user’s address, and other details related to the transaction may be collected as well.
vii. Commercial information: When you make use of our services, we may collect certain commercial information such as records of transactions carried out via our services, transaction date, amount of transaction, and other related information.
A. Information automatically collected by third parties about you
Please rest assured that the platform will only collect personal information that you knowingly and willingly provide to us by way of surveys, completed user forms, and emails. XROBIUM intends to use personal information only for the purpose for which it was requested and any additional uses specifically provided for in this Policy.
4. What We Use Your Personal Information For
Generally, we use the information gathered to provide, improve, and develop our platform and the platforms we provide to you, communicate with you, offer you a better platform, and protect our users and us. When you interact with or make use of our platform, we use a variety of technologies to process the personal information that we collect about you for various reasons.
i. facilitate the creation of your XROBIUM account, set up the account, secure your XROBIUM account and enable the Software and its functionalities;
ii. identify you as a user of our services and enable the administering, facilitating and to communicate with you on matters relating to your use of the services that we provide to you;
iii. Personalize your experience with our platform. We may use personal information to assist in the operation of our platform and to ensure delivery of the services you need and request in a customized manner. At times, we may find it necessary to use personally identifiable information as a means to keep you informed of other possible products and/or services that may be available to you from us.
iv. Allow you to participate in certain features of the service; send newsletters, surveys, offers, and other promotional materials and for other marketing purposes;
v. Increase and maintain the safety and security of our platform, and community and prevent misuse;
vi. To understand, diagnose, troubleshoot, and fix issues with the platform as well as to monitor and analyze trends, usage and activities in connection with our services;
vii. Communicate with you and provide customer support;
viii. Operate, evaluate, develop, manage and improve our platform (including operating, administering, analyzing, and improving our services; developing new products and platforms; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing reconciliation, and collection activities and other internal functions;
ix. Protect against, identify and prevent fraud and other criminal activity, claims, and other liabilities;
x. To fulfill contractual obligations with third parties, such as licensing agreements and taking appropriate action concerning intellectual property infringement reports and inappropriate content.
5. Personal information that we share
We are committed to maintaining your trust and do not sell, rent, trade, or otherwise share personal information collected through the platform, except as described below:
i. Service providers: We may provide collected data to our service providers such as our payment processor/partners that we may make use of from time to time for payment processing. They may use your data to perform platforms for us and may have access to, store, and process your personal data to provide platforms on our behalf.
ii. Subsidiaries and affiliates: We may share personal information or any information collected through the platform with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes.
iii. Merger and acquisition: We may disclose or transfer personal information or any information collected through your usage of our platform to third parties who acquire all or a portion of XROBIUM’s business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
iv. Compliance with laws: We may disclose personal information or any information collected through the Platform and your usage of our platform if we are required to do so by law or pursuant to legal process, in response to a request from government officials, law enforcement authorities or a valid subpoena, or as necessary or appropriate in connection with an investigation of illegal activity, including without limitation to prevent, investigate, detect or prosecute any criminal offense or attack.
v. Consent: We may share personal information in accordance with any consent you provide.
6. Data retention and deletion
We keep your personal data only as long as necessary to provide you with the service and for legitimate and essential business purposes, such as maintaining performance, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of our platform.
If you request, we will delete or anonymize your personal data so that it no longer identifies you unless we are legally allowed or required to maintain certain personal data, including situations such as the following:
i. If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute, we will retain the necessary personal data until the issue is resolved;
ii. Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
iii. Where necessary for our legitimate business interests, such as fraud prevention or to maintain our users' security.
7. Your Rights
Data Protection laws grants you certain rights ('information rights') which provide you with:
i. Right of rectification or erasure - if you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will/shall take all reasonable steps to inform those with whom we have shared your data about your request for erasure.
ii. Right to restriction of processing - you have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we don't need to hold your data anymore but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data.
iii. Right to object - you have a right to object to our processing of your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling.
iv. Right to withdraw consent - you have the right to withdraw your consent for the processing of your personal data where the processing is based on consent. To withdraw consent, please specify what you wish to withdraw consent for, by emailing us at [email protected].
v. Right of complaint - if you are unhappy with the way we have used or are handling your personal data, you have the right to lodge a complaint with the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the Supervisory Authority. So, please contact us in the first instance by emailing us at [email protected].
8. Keeping your data safe
As a matter of policy, we are committed to protecting your data, and as such, we take precautions to protect your information. When you submit sensitive information through the platform, your information is protected both online and offline. Wherever we collect sensitive information, that information is encrypted and securely transmitted to us.
Your password and other added security features that we make available to you protect your user account, so we encourage you to use a strong password unique to your account, never share your password with anyone, and limit access to your account.
9. California privacy information
Information we collect
The following is a list of personal information that we collect or have collected from California residents within the last twelve months. We will update this disclosure from time to time as appropriate.
● Unique identifiers such as your first name, last name, or similar identifier, address, or IP address;
● Internet or other electronic network activity information, including content interaction information, such as content downloads, search history, transaction and interaction data on your use of our platform and from links in our emails sent to you;
● Geolocation data, such as the location of your device or computer; and
● Inference data, such as information about your purchase preferences, feedback, and survey responses.
● Other information that identifies or can be reasonably associated with you (e.g., the information you voluntarily provide as you use the XROBIUM services, such as additional profile information or user-generated content).
How we collect personal information
We obtain the categories of personal information listed above from the following sources:
● Directly from our website users when they provide the information to us.
● Indirectly from you as you navigate through the website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
● From third-party platform providers.
Categories of personal information disclosed for our business purpose
The personal information that we disclosed about consumers for a business purpose within the past (12) twelve months fall into the following categories established by the California Consumer Privacy Act:
● Identifiers such as your name, email address, billing address, or IP address;
● Personal information, such as a credit card number, for example, if we use a third-party payment processor;
● Your age, gender, or other protected classifications, for example, if you choose to participate in a survey distributed by us or fill the User Content form;
● Geolocation data from your IP address
Access to specific information and data portability:
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and verify your request, we will disclose to you:
● The categories of personal information we collected about you
● The categories of sources for the personal information we collected about you
● Our business or commercial purpose for collecting that personal information
● The specific pieces of personal information we collected about you.
Right to request access to or deletion of personal information
You may have the right under the California Consumer Privacy Act to request information about the collection of your personal information by us, or access to or deletion of your personal information. If you wish to do any of these things, please contact us. Depending on your data choices and subject to applicable regulations, certain platforms may be limited or unavailable.
We may, however, deny your deletion request if retaining the information is necessary for us or our platform providers(s) to:
● Complete the purpose for which we collected the personal information, provide a platform that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
● Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
● Exercise free speech; ensure another consumer's right to exercise their free speech rights or exercise another right provided for by law.
● Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq. or other legal obligation.
● Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
No discrimination rights
You have the right not to receive discriminatory treatment for the exercise of your rights under the CCPA, and we will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.
10. Non-marketing purposes
We at XROBIUM greatly respect your privacy. We maintain and reserve the right to contact you if needed for non-marketing purposes (such as bug alerts, security breaches, account issues, and/or changes in our service). In certain circumstances, we may use our website, newsletters, or other public means to post a notice.
11. Jurisdictional privacy policies
California Privacy Rights
California Consumer Privacy Act of 2018; Effective January 1, 2020:
If you are a California resident, you may have some additional privacy rights regarding the disclosure of your data by XROBIUM, its affiliates, and subsidiaries, or to a third party. We have prepared additional disclosures and notices consistent with the California Consumer Privacy Act (CCPA). Please see our CCPA policy for more about such rights.
California residents may not be discriminated against for exercising any of the rights described above in our CCPA policy.
12. Children under the age of 18
Our Platform is not directed to and does not knowingly collect personally identifiable information from persons under the age of eighteen (18). If we determine that such information has been inadvertently collected on anyone under the age of eighteen (18), we shall immediately take the necessary steps to ensure that such information is deleted from our system's database.
13. Unsubscribe or opt-out
If you have subscribed to our email newsletters, you will always have the opportunity to unsubscribe from future mailings by logging into your account and modifying your preferences. You will also have the opportunity to "opt-out" of commercial email from the applicable service by following the unsubscribe instructions provided in the e-mail you receive or directly contacting us. We will continue to adhere to this Policy with respect to any personal information previously collected.
14. Links to other websites or resources
15. Acceptance of terms
16. How to contact us