Privacy Policy

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application means the software program provided by the Organization downloaded by You on any electronic device, named X-Analytics.
• Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Organization as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
• Organization (referred to as either “the Organization”, “We”, “Us” or “Our” in this Agreement) refers to Secure Systems Innovation Corporation, 1655 N. Fort Myer Drive.
• For the purpose of the GDPR, the Organization is the Data Controller.
• Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident.
• Country refers to: Virginia, United States.
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Organization as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• Personal Data is any information that relates to an identified or identifiable individual.
• Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Organization.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
• You means the individual accessing or using the Service, or the organization, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name

Use of Your Personal Data

The Organization may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services.
• To provide You with news, special offers and general information about other goods, services and events which we offer.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, and determining the effectiveness of our promotional campaigns.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Organization assets, financing, or acquisition.
• With Affiliates: We may share Your information with Our affiliates.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

The Organization will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

The Organization will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Your information, including Personal Data, is processed at the Organization’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Organization will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Business Transactions

If the Organization is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred.

Law Enforcement

Under certain circumstances, the Organization may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.

Other Legal Requirements

The Organization may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Organization
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Organization is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Organization.

Your Rights under the GDPR

The Organization undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data.

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. Categories collected may include:

• Category A: Identifiers — such as real name, alias, email address, online identifier, IP address. Collected: Yes.
• Category B: California Customer Records statute — such as name, address, telephone number. Collected: Yes.
• Category C: Protected classification characteristics — such as age, race, religion, sex. Collected: No.
• Category D: Commercial information — records of products or services. Collected: No.
• Category E: Biometric information. Collected: No.
• Category F: Internet or network activity — interaction with our Service. Collected: Yes.
• Category G: Geolocation data. Collected: No.
• Categories H–K: Sensory, employment, education, inference data. Collected: No.

Your Rights under the CCPA

The CCPA provides California residents with the following rights regarding their personal information:

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which they are used.
• The right to request. You have the right to request disclosure of information about Our collection, use, sale, and sharing of your personal information.
• The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information.
• The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights.

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

If you have any questions about this Privacy Policy, You can contact us by email at privacy@x-analytics.com.