TRIO PRIVACY POLICY

Effective as of Apr 10th, 2018

We have created this privacy policy (this “Privacy Policy”), because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of I.X (“I.X” , “we”, “us” or “our”) when you access and/or use the Website and when you access and/or use our Service through the Application and I.X Trio Device.

By visiting our Website, downloading our Application and/or accessing the Service, you are agreeing to the terms of this Privacy Policy and the accompanying Terms and Conditions, which are incorporated herein by reference.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms and Conditions.

What Information We Collect; the Purpose of Collection and Use

We collect the following categories of information:

    • Contact Information

When you create an Account to become a user of the Service, you will be required to provide us with personal information about yourself, which may include your name and e-mail address (collectively, “Contact Information”). We do not collect any Contact Information from you when you use the Service or the Website unless you provide us with the Contact Information voluntarily. The Contact Information is used to provide the requested Service, and occasionally to contact users of our Service to notify them of our current and future products and features.

    • Message Information

When you use the Service to send and/or receive encrypted messages, including VOIP calls, text messages, voice messages and document files (“Messages”), we may temporarily process and store your Message (in encrypted form), log and contact data, and other related information (collectively, the “Message Information”) in order to provide the Service to you. We do not read your encrypted Messages.

    • Billing Information

If users wish to purchase a Subscription for accessing the Service, they will be required to provide certain information in addition to the information noted above. Such information may include a debit card number, credit card number, expiration date, bank account information, billing address, activation codes, and similar information. Such information is collectively called the “Billing Information.” Billing Information will be collected and processed by a third-party payment vendor acting as our agent (See, Onward Transfers to Third Parties). Although we do not directly process any Billing Information, we may retain and use your Billing Information to facilitate or effectuate the process of your purchase of the Subscription. Please note that we will not retain your Billing Information beyond the period necessary to facilitate the relevant payment.

Use of Your Information

We may use your information, including personal information, to:

  • operate and improve our Website, Application, Account, I.X Trio Device, Service and marketing;
  • provide you with a personalized and customized experience, content, marketing and recommendations across all our Services;
  • respond to your comments and questions and provide customer service;
  • provide and deliver Application, I.X Trio Devices, and Service that you request;
  • send you information related to your requests and purchases, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
  • communicate with you about contests, promotions, rewards, upcoming events and news about products and services offered by us and/or our selected partners (we do this as per your choices, as outlined by our policies) and to process and deliver contest entries and rewards;
  • link or combine your personal information with other information we get about your use of other I.X services and from third parties for the purposes that we disclose in this policy, including to help understand you and your needs, and provide you with recommendations, better service and customized marketing;
  • protect, investigate and deter against fraudulent, unauthorized or illegal activity;
  • filter the content to be displayed as part of the Service;
  • compile usage and other statistics and insights relating to the Service; and
  • facilitate sharing of information and content that you upload via social media.

Automatic Data Collection Technologies

Like most organizations, we rely on automatic data collection technology (such as Google Analytics and Facebook Analytics) when you visit our Website or use our Service. These technologies may collect information on our behalf such as your IP address, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, number of links you click while on the Website, search terms, and other data. They may also collect information about your Device, including universally unique ID (“UUID”), MAC address, operating system and version (e.g., iOS, Android or Windows), carrier and country location, hardware and processor information (storage, chip speed, camera resolution, NFC enabled, and network type (WiFi, 2G, 3G, 4G). This information is collected automatically and anonymized. The third parties we currently work with are those listed below.

Fabric (Google Inc.)Firebase (Google Inc.)

These third parties may change from time to time, but in each case we will provide you with the links to view these organizations’ privacy policies and find out more about what data they hold about you, what they do with it, and how to opt-out from certain data collection. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website, the Application, Account, I.X Trio Device and/or Service.

Cookies

A cookie is a small text file that is stored on your computer when visiting a website. This text file stores information that can be read by the website when visiting it again at a later date. Some of these cookies are necessary because otherwise the site is unable to function properly. Other cookies are convenient for the visitor: they remember your username in a secure way as well as your language preferences, for example. Cookies mean that you do not need to fill out the same information each time you visit a website. We use cookies and similar local storage technologies: (i) to help us maintain your session when you use Website, Application, Account, I.X Trio Device, and /or Service; (ii) to enhance security of our systems; (iii) to store your preferences and provide customized Service to you; (iv) to help us understand how people use Service and to improve them; and (v) to remember your language preference on the Website or Service.

We also use the following third party cookies on the Website: Google Analytics.

You may be able to turn cookies off on your device. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Website or the Service may not function properly. By continuing to use Website, Application, Account, I.X Trio Device or Service, you consent to our use of cookies and similar technologies in accordance with this Privacy Policy.

Aggregate Data

In an ongoing effort to better understand our users and the Website, Application, Account, I.X Trio Device, and Service, we might analyze your information in aggregate form to operate, maintain, manage, and improve the Website, Application, Account, I.X Trio Device and Service. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and the Website to current and prospective business partners and to other third parties for other lawful purposes.

Additional Uses

We also use Contact Information, and other information collected pursuant to this Privacy Policy to respond to general inquiries, solicit feedback and inform about our products/services and those of any third parties, provide customer support, and to communicate with you regarding our current and future products.

Onward Transfer to Third Parties

Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: marketing assistance, data storage, hosting services, customer support, and payment processors. All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by I.X. You may opt out of having your personal information transferred to any or all of our categories of agents by contacting us at support@ix-security.com. Please allow us a reasonable time to process your request. If you opt out of having your personal information transferred to certain categories of agents, you may not be able to use certain functionality of our Website, Application, Account, I.X Trio Device and Service.

Opt-In to Certain Onward Transfers

We do not currently transfer your personal information to a third party controller. In the future, we will not transfer your personal information to a third party controller without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent. If/when applicable, you will be able to grant such consent by contacting us at support@ix-security.com.

We do not currently collect sensitive personal information from you. If we start collecting your sensitive personal information in the future, we will not disclose your sensitive personal information to any third party without first obtaining your opt-in consent. If/when applicable, you will be able to grant such consent by contacting us at support@ix-security.com.

In each instance, please allow us a reasonable time to process your response.

Business Transfers

In the event of a merger, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.

Disclosure to Public Authorities

We may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Access to Personal Information

I.X acknowledges that individuals located in certain jurisdictions (e.g. EU) have the right to access the personal information that we maintain about them pursuant to their local laws. Upon request to support@ix-security.com, we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time. You have the right to correct, amend or delete your personal information where it is inaccurate or has been processed in violation of this privacy policy. Please allow us a reasonable time to respond to your inquiries and requests.

Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this privacy policy, or subsequently authorized or for complying with applicable laws and regulations. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of statistical analysis, and subject to the protection of this privacy policy. We may retain your personal information following the closure or termination of your Account if retention is reasonably necessary: (i) to comply with applicable laws, regulations or legal obligations; (ii) to provide and complete customer support service; (iii) to resolve disputes between or with I.X users, for the duration of the applicable limitation period; or (iv) to detect and deter unauthorized or fraudulent use of, or abuse of, Services and Website. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.

How We Protect Your Information

We take commercially reasonable steps to protect the personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, Website, Application or Service, nor can we guarantee that the information or Messages you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Website, and/or the Application may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Children

We do not knowingly collect personal information from children under the age of 13 through the Website, Application. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information through the Website, Application without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Where We Store Your Information; Transfer of Your Information

Information that we collect may be stored on your devices or stored on our servers and transferred to, stored and processed in the United States, Taiwan, EU member state countries and any other country where I.X or its service providers maintain facilities, including jurisdictions that may not have data privacy laws that provide protections equivalent to those provided in your home country. However, we will protect all personal information that we obtain in accordance with this Policy. By using the Services, you consent to our transfer of your personal information in accordance with this Policy.

External Websites

The Website, the Application and the Service may contain links to third-party websites. I.X has no control over the privacy practices or the content of any of these websites. As such, we are not responsible for their content or privacy policies. You should check the applicable third-party privacy policy and terms of use when visiting any other websites, and before providing any personal information to such external sites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Website as soon as they go into effect. By accessing the Website or the Application and/or using the Service after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at support@ix-security.com.