Effective as of Apr 10th, 2018
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.
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.
We also use the following third party cookies on the Website: Google Analytics.
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.
Onward Transfer to Third Parties
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 email@example.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 firstname.lastname@example.org.
In each instance, please allow us a reasonable time to process your response.
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
Retention of Personal Information
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.
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.
How to Contact Us