Privacy Privacy
Last updated: 12 May 2022
Privacy Policy
The privacy policy for Xctuality Pte Ltd (‘Company’, ‘we’, ‘us’, or ‘our’), describes how and why we might collect, store, use, and/or share (‘process’) your information when you use our services (‘Services’), such as when you: Visit our website at https://xctualyfe.com/, or any website or app of ours that links to this privacy policy Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns?
Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Service. If you still have any questions or concerns, please contact us at [email protected] .
Summary of Key Points
This summary provides key points from our privacy policy.
- We do not process sensitive personal information
- We do not receive any personal information from third parties
- We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so
- We may share information in specific situations and with specific third parties such as Google Analytics
- Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information
- The easiest way to exercise your rights is by filling out our data subject request form by contacting us at [email protected] . We will consider and act upon any request in accordance with applicable data protection laws
What information do we collect?
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
The personal information that we collect depends on the context of your interaction with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- Name
- Email Address
- Username
- Password
- Billing Address
We do not process sensitive information.
All personal information that you provide us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data
Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, the log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date / time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
- Device Data
We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data
We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
How we process your information
- We process your personal information so you can create and log in to your account, as well as keep your account in working order.
- We may process our information to respond to your inquiries and solve any potential issues you might have with the requested service.
- We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
Legal bases we rely on to process your information
If you are located in EU or UK, this section applies to you:
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information.
- Consent
We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
- Performance of a Contract
We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legal Obligations
We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests
We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you:
We may process your information if you have given us specific permission to use your personal information for a specific purpose, or in situations where your permission can be inferred. You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
When and with whom we share your personal information
We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties’) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The third parties we may share personal information with are as follows:
- Web and Mobile Analytics
- Google Analytics
We also may need to share your personal information in the following situations:
- Business Transfers
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Cookies and other tracking technologies
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our cookie policy.
- Duration of information storage
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
- Keeping your information safe
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
- Your privacy rights
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right;
- to request access and obtain a copy of your personal information;
- to request rectification of erasure;
- to restrict the processing of your personal information; and
- if applicable, to data portability.
In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us at [email protected] . We will consider and act upon your request in accordance with applicable data protection laws.
- Withdrawing your consent
If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at [email protected] .
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing ground other than consent.
- Opting out of marketing and promotional communications
You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us at [email protected] . You will then be removed from the mailing list. However, we may still communicate with you - for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
- Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account
- Contact us using the contact information provided
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
- Cookies and similar technologies
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. We do not have third-party ads on our website.
- Controls for Do-Not-Track features
Most Web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates with your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in future, we will inform you about that practice in a revised version of this privacy notice.
- Policy Updates
We may update the privacy policy from time to time. The updated version will be indicated by an updated “Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
- Contact Us
If you have questions or comments about this notice, you may email us at [email protected] .
Review, update, or delete the data we collect from you Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request review, update, or delete your personal information, please log in to your user portal to make the necessary amendments.