Privacy Policy

HXRO GAMES, LTD. AND AFFILIATES

PRIVACY POLICY

This Privacy Policy provides you with information about how Hxro Games, Ltd. and its affiliates (collectively, “Hxro,” “we,” “us” or “our”) collect, use and share your Personal Data (defined below).  This Privacy Policy applies to Personal Data provided by you, or collected by us, through your use of our website (www.hxro.io) and other sites operated by Hxro, our social media, mobile applications and emails (collectively “the Sites”), in addition to Personal Data provided to Hxro by third parties.

“Personal Data” includes information or a combination of information that could, directly or indirectly, be used to identify you.  Examples of Personal Data include your name, address, phone number, email address, government issued ID number, username, credit card information, location information and IP address.

Your privacy is important to us and we value and respect your Personal Data.  We are committed to handling your Personal Data responsibly, and we will collect, process and use your Personal Data only in accordance with this Privacy Policy and applicable privacy laws. 

By using the Sites, you represent that you are of legal age and you signify your acceptance of our Privacy Policy, and you agree to adhere to the terms and conditions posted on the Sites.  By submitting your information, you agree that it will be governed by our Privacy Policy.  In your registration as a User, we will ask that you agree to the use and transmission of your personal data as described herein.

If you have any questions about this Privacy Policy, or if you wish to exercise any of your rights set out below, contact Hxro via the contact details below.

PERSONAL DATA WE COLLECT

Personal Data You Provide

• Account Creation:  When you create a user account, or after you start using the Sites, we may collect your name, email address, date of birth, tax number, username, password and other Personal Data that may be used to identify you.

• Purchase of Products or Services. When you purchase our products or services on our Sites, we collect your name, email address, mailing address and commercial information, such as billing and shipping information, and other Personal Data that may be used to identify you.

• Your Communications with Us. We collect personal information you such as name, email address, phone number and mailing address when you request information about our products and services, request customer or technical support, apply for a job or otherwise communicate with us.

• Surveys, Sweepstakes, Contests or Games.  We may contact you to participate in surveys, or run sweepstakes, contests, games or other activities on our Sites.  If you decide to participate, you may be asked to provide certain information which may include Personal Data.

• Online Content. Anything you post online (e.g. in a chat room, bulletin or message board, forum or social media) is public information.  We are not responsible for anything you voluntarily post online.  You should use caution when disclosing Personal Data online.

• Third Party Websites. Our Sites may include links or refer to third party websites whose privacy practices may differ from ours.  If you submit Personal Data to any of those websites, your information is governed by their privacy policies.  We encourage you to review the privacy policy of any website you visit.

Personal Data Collected Automatically or From Third Parties

• Automatic Data Collection.  We may collect certain Personal Data automatically when you use the Sites.  This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, Internet service provider, pages that you visit before, during and after using the Sites, information about the links you click and other information about how you use the Sites. In addition, we may automatically collect Personal Data regarding your use of the Sites, such as the types of content you interact with and the frequency and duration of your activities.  We may combine your information with information that other people provide when they use the Sites, including information about you when they tag you.

When you access the Sites by or through a mobile device or a browser, we may also access, collect, process, monitor and/or store your location data, which may include GPS coordinates or similar location data about your device.  We may use the location data to verify your physical location when accessing the Sites, using geo-location technology and/or geo-verification services, such as GeoComply.  By access our Sites, you consent to our transmitting your location data to such services for the purpose of verifying your location.  If you are located in a territory or jurisdiction that does not permit use of Hxro’s services, then you will be unable to use such services.  You may turn off the location services within your device’s settings at any time.  However, turning off location services may prohibit you from using Hxro’s services or our Sites, or it may impact the functionality of our Sites and the services we are able to offer you.

• Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies.  We, as well as third parties that provide content, advertising or other functionality on the Sites, may use cookies, pixel tags, local storage and other technologies (“Technologies”) to automatically collect information through the Sites. These Technologies may be small data files placed on your computer, tablet, mobile phone or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Sites.  See our Cookie Policy for more information on our practices around the use of cookies and other such technologies.

• Information from Other Sources.We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you.  For example, if you access our Sites through a third-party application, such as an app store, a third-party login service or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings.  Information we collect through these services may include your name, user identification number, username, location, gender, date of birth, email, profile picture and your contacts stored in that service.  This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products and services.

HOW WE USE YOUR PERSONAL DATA

We use your information for a variety of business purposes, including to manage your accounts, provide access to our Sites, and our products and services; for account creation, registration, contests, sweepstakes, games, promotions, events and other activities on our Sites; to communicate with you and to provide information to you; to provide personalized and customized content, information, customer and technical support; to provide you with brochures, coupons, samples, offers and other information on our Sites, and products and services; to fulfil our contract with you and provide you with our services; to process your Personal Data needed for the assessment and acceptance of users and for processing financial information and other payment methods for products and services; to provide relevant advertising and analytics; to analyze, improve and enhance our Sites, products and services, such as detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity and prosecuting those responsible for that activity; to measure interest and engagement in our Sites; to research and develop products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency; to ensure quality control; to enforce our terms and policies and comply with applicable laws and our legal obligations; and for all other legitimate business purposes.

SHARING AND DISLCOSING YOUR PERSONAL DATA

We may share or disclose your Personal Data in the instances below.

• With our affiliated companies;

• With third party vendors, agents and service provides that we have engaged to provide services for us or to you. When we share Personal Data with such third party companies, they are not allowed to use it for any other purpose, and they must keep your Personal Data confidential unless you otherwise consent.  Examples of these third party companies include IT and related services, banks and trust companies, payment processors, customer service providers and vendors to support our products and services;

• Where we have received your direction or consent to the disclosure of your Personal Data;

• To comply with the law or respond to legal process or lawful requests, including from law enforcement and government agencies;

• To investigate consumer complaints or possible illegal activity, to protect the integrity of the Sites, to fulfill requests, or to cooperate in any legal investigation;

• To act on a good faith belief that access or disclosure is necessary to protect your, our or others’ rights, property or safety;

• To enforce our policies or contracts;

• Collect amounts owed to us;

• To business partners with whom we jointly offer products or services;

• We may allow third party advertising partners to set Technologies and other tracking tools to collect Personal Data regarding your activities and your device (e.g. your IP address, mobile identifiers, pages visited, location, time of day).  We may also combine and share such Personal Data and other information, such as demographic information and past purchase history, with third party advertising partners.  These advertising partners may use this information and similar information collected from other websites for purposes of delivering targeted advertisements to you when you visit third party websites within their networks.  This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”  We may allow access to other data collected by the Sites to share information that may be useful, relevant, valuable or otherwise of interest to you;

• We may sell anonymized data, and we may share anonymized or non-personally identifying information to third parties. We may combine anonymized or de-identified information with other anonymized or de-identified information from other sources.  We also may share aggregated and anonymized information with third parties, including for example advisors, advertisers and investors, for general business analysis.  For example, we may tell our advertisers the number of visitors to our website and the most popular features or services;

• If all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the Personal Data we have collected from you;

• You acknowledge and agree that all Personal Data processed by us may be transferred, processed and stored anywhere in the world. The servers and databases storing Personal Data may be located outside the country from you accessed the Site and in a country that does not have the same privacy laws as your country of residence.  We have taken appropriate safeguards to require that your Personal Data will remain protected, in accordance with this Privacy Policy and applicable privacy laws; and

• To support other legitimate business purposes.

LAWS AND RIGHTS THAT MAY APPLY TO YOU

Your rights available to you may differ depending on your residence.  Hxro will respond to any rights request in accordance with local legal regulations.  There may be restrictions on the number of times you can exercise some of these rights.  If you would like to make a request related to any of these rights, please contact us via the contact details below.  To protect your privacy, we will take steps to verify your identity.

• Right of Access. You may have the right to access your Personal Data, or have it transferred to another party.  Where feasible and permitted by law, we will provide a copy of your Personal Data in electronic format.  For any further copies or in a different format, we may charge a reasonable fee.

• Right to Rectification. You may have the right to rectify or complete your Personal Data if inaccurate or incomplete.

• Right to Erasure. You may have the right to the erasure of your Personal Data in certain circumstances (e.g. your Personal Data is no longer necessary for the purposes in which it was being processed).  This right shall not apply in certain exceptions prescribed by law.

• Right to Restriction of Processing. You may have the right to restrict the processing of your Personal Data (e.g. you contest the accuracy of your Personal Data, for a period enabling us to verify the accuracy of the Personal Data).

• Right to Object. You may have the right to object to processing of your Personal Data.  We will stop processing the Personal Data unless we have compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

• Automated Individual Decision-Making, Including Profiling. You may have the right not to be subject to a decision based solely on automated processing, including profiling, except under certain exceptions under local law.

• Right to Withdraw Consent. Where the processing of Personal Data is based on your consent, you may have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.

• Right to Anonymity. You may have a right to request anonymity, which means your Personal Data would not be collected or processed.  If you choose to exercise this right, we may not be able to provide you with account access or your requested products or services.

• Right to Lodge a Complaint with a Supervisory Authority. You may have the right to lodge a complaint with a supervisory authority.  If you wish to make a request regarding any of the above rights, please contact us via the contract details below.

HOW WE COMMUNICATE WITH YOU

If you no longer want us to use your contact information to promote our Sites, products and services, contact us via the contact details below. 

If we send you a promotional email, you may unsubscribe at the bottom of the email to opt out of future promotional emails.  In some instances, we may request your consent before sending you promotional emails.  By declining to provide consent, you will not receive certain emails from us.

Even if you choose not to receive promotional emails, you may still receive emails that facilitate, complete or confirm a commercial transaction that you have agreed to enter with us.  These include communications about your completion of registration, correction of user data, password reset requests, transaction confirmations and other communications essential to your transactions with us.

We may also offer text/SMS messaging to you.  In some circumstances, we might require you to opt-in to receive text messages from us.  At any time, you may opt-out of receiving text messages from us by texting STOP in response to any text message from us.  Unless expressly noted, all text messaging services are offered without charge to you.  However, message, data rates and other charges may apply from your carrier.  You are liable for any mobile phone charges incurred (usage, subscription, etc.) as a result of using any of our products or services.  Please consult your mobile service carrier’s pricing plan to determine the charges for sending and receiving text messages.

We may send you push notifications through our mobile application.  You may at any time opt out from receiving these types of communications by changing the settings on your mobile device.  We may also collect location-based information if you use our mobile applications.  You may opt-out of this collection by changing the settings on your mobile device.

“Do Not Track” is a privacy preference that users can set in certain web browsers.  We do not support “Do Not Track” browser settings and do not currently participate in frameworks that would allow us to respond to signals or other mechanisms from you.

DATA RETENTION

We retain and store your Personal Data only for as long as we have a legitimate business purpose and in accordance with our data retention policies.

CHILDREN

The Sites are designed and intended for adults.  If you learn that a child, in violation of this policy, registered for an account or otherwise provided their Personal Data to our Sites, without your consent, you may contact us via the contact details below.  If we learn that we have collected any child’s Personal Data in violation of applicable law, we will take steps to delete such information and terminate the child’s account.

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may change from time to time.  We will tell you about material changes by posting a notice to our website (www.hxro.io) for a reasonable period of time and changing the “Updated” date.  Please check back for updates.  You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Sites after the new Privacy Policy takes effect.   

CONTACT DETAILS

If you have any questions about how your Personal Data is being used, please contact us through our website (www.hxro.io) at [e-mail], or by mail to:

Hxro Games, Ltd.
Clarendon House
2 Church Street
Hamilton, HM 11
Bermuda