COLLECTING OF PERSONAL INFORMATION
When you access or use the xChange site or Services, we may collect some information, including:
Information you may provide to us: Your email address, virtual currency addresses, mobile phone number, alias, password, mobile PIN code, and any other information you choose to provide.
Log Information: We may log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our websites.
Device Information: We may collect information about the mobile device you use to access our mobile application, including the hardware model, operating system and version, unique device identifiers and mobile network information.
Wallet Address Information: When you create a wallet through our Services, an encrypted wallet public key and private key pair is automatically generated and stored via our Services. When you enable notifications through your Account Settings, we will collect the unencrypted wallet public key in order to provision such notifications. Under no circumstances do we ever collect an unencrypted private key from you.
Information We Collect From Other Sources: We may also obtain information from other sources and combine that with information we collect through our Services. For instance, when you log in to our support desk center via a third-party social media service, we may collect information about your social media account in accordance with the authorization procedures determined by such social media service, including your public profile, friend list and email address. We may use third-party services. Any third-party services may collect information as determined by their own privacy policies.
USE AND DISCLOSURE OF PERSONAL DATA
Except as part of the sale of all or substantially all of the assets of xChange (in which case you will be given prior notice), xChange will not use your Personal Data unless we have your consent. We will only use and/or disclose Personal Data internally in order to:
- Understand and meet your needs and preferences;
- Develop new and enhance existing service and product offerings;
- Manage and develop our business and operations;
- Carry out any purposes for which we have received your consent; and
Meet legal and regulatory requirements.
We also reserve the right to use aggregated Personal Data provided that those data do not relate to any individual.
Personal Data may be collected, stored and/or processed by third party service providers or by companies in the xChange corporate family (XGroup Companies) to perform functions on our behalf. All such third parties will be contractually bound to protect data in compliance with our policy.
We shall require any third party, including without limitation any government or enforcement entity, seeking access to data we hold to have obtained a Court Order, or proof they are statutorily empowered to access your data and that their request is valid and within their power.
We will process your Personal Data legally and fairly and not use it outside the purposes of which we have informed you. So far as we are able we shall ensure that all of your Personal Data is accurate and up to date.
SECURITY OF YOUR PERSONAL DATA
We protect Personal Data with appropriate physical, technological and organisational safeguards and security measures. Your Personal Data comes to us via the internet which chooses its own routes and means whereby information is conveyed from location to location. As such we cannot give any warranty or assurance that the means where information is conveyed to us are safe, reliable or have integrity. We audit our procedures and security measures regularly to ensure they are being properly administered and remain effective and appropriate. Every member of xChange is committed to our privacy policies and procedures to safeguard Personal Data. Our site has security measures in place to protect against the loss, misuse and unauthorised alteration of the information under our control. More specifically, our server uses SSL (Secure Sockets Layer) security protection by encrypting your Personal Data to prevent individuals from reading Data as it travels over the Internet. The length of time we retain Personal Data outside our back up system varies depending on the purpose for which it was collected and used. This period may extend beyond the end of the particular relationship with us but only for so long as we are contractually bound to do so, or so far as is necessary for audit or other accounting purposes. When Personal Data are no longer needed we have procedures either to destroy, delete, erase or convert it to an anonymous form. We reserve the right to maintain your Personal Data as part of our standard back up procedures.
STORAGE OF PERSONAL DATA
Data provided to xChange is stored in accordance with applicable laws of the jurisdiction of the data subject. xChange has ensured that appropriate security standards are in place regarding the safeguarding, confidentiality and security of Data.
WITHDRAWAL OF CONSENT
Except as required or enabled by law, we will not use or disclose your Personal Data for any purpose for which you refuse consent or later withdraw your consent. If you withdraw consent, you agree that in spite of this withdrawal, we may continue to use those Personal Data previously provided to us to the extent that we are contractually or otherwise legally obliged to do so and to the extent necessary to enforce any contractual obligation you may have towards xChange or in any other way permitted by law. You also understand that although you can use our site for some purposes without providing Personal Data, we need certain Personal Data, including data linked to payment or involving an ongoing relationship with xChange or our partners. If you refuse to provide us with Personal Data we require or later withdraw your consent, we may no longer be able to provide you with certain services.
By using this site, you signify your agreement to this Policy. xChange reserves the right to change this Policy at any time. Any changes will be posted so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it.
Any questions about this policy, the collection, use and disclosure of Personal Data by xChange or access to your Personal Data should be directed to privacy@xChange.lu