HXRO GAMES, LTD. AND AFFILIATES
[Effective Date: May 25th, 2021] (This will change each time the policy is materially updated)
PERSONAL INFORMATION THAT WE COLLECT
We collect and receive Personal Information from and about you by different means as described below.
Personal Information You Provide to Us.
- Creating an Account. We may collect your contact information, such as your name, address, email address and phone number; online identifiers, such as your username, password and security questions; payment information, such as your credit card information and billing address; date of birth; and other profile information, such a profile photograph.
- Trades, Sells or Other Transactions. We may ask you to provide additional payment information to process transactions you make on our Sites.
- Customer Support. We may collect your contact information, such as your name, phone number and address; online identifiers, such as your username; date of birth; and information about the issue you are contacting us about.
- Other Business Processes. We may ask you to provide contact information, such as your name, address, email address and phone number; online identifiers, such as your username if you participate in market research surveys, beta and other user testing research, contests, promotions, events or other activities, or if you agree to receive marketing information from us, or apply for a job with us.
Personal Information We Collect Automatically. We collect Personal Information about you and your use of the Sites; your interactions with us, the Sites and our advertising; and your network and electronic device used to access the Sites. If you also sign into an account that you have with us, we may combine this information with other information we have for that account. The information we collect may include:
- Your Activities and Interactions. Your activity on the Sites, such as your trades, sells, transactions, inquiries and other interactions. Your interactions with our emails, text messages and advertising. And, your interactions with our customer support, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings.
- Your Network. Your network IDs, such as your internet protocol (IP) address or MAC address (which may provide general location information), and your connection type (wifi or cellular).
- Your Device Details. Your device IDs and browser details, including statistics on page views, referral source (such as referral URLs), and standard web server log information.
Information from Other Sources. We obtain information about you from other sources, including through third party services and organizations to supplement or combine with information provided by you. These sources vary over time, but include:
- Location Providers. We may use service providers to determine your physical location when accessing certain Sites, such as GeoComply. If you are located in a territory or jurisdiction that does not permit use of our services, then you will be unable to use certain features of the Sites. You may turn off the location services within your network device’s settings at any time. However, turning off location services will prohibit you from using certain features of our Sites, and it may impact the overall functionality of our Sites and the services we are able to offer you.
- Advertising Providers. We may use online and offline data providers, from which we obtain aggregated demographic, interest based and online advertising related data, such as the SignalFox marketing and analytics platform.
- Payment Service Providers. We may use payment service providers who provide us with payment services, including, for example, PaySafe’s Income Access to manage and make payments for our Affiliate Program.
- Security Service Providers. We may use security service providers who provide us with information to secure our systems, prevent fraud and help us protect the security of Hxro’s accounts.
- Publicly-Available Sources. We may use publicly-available sources such as publicly available posts on social media platforms and information available through public databases associating IP addresses with internet service providers (ISPs).
HOW WE USE YOUR PERSONAL INFORMATION
We use your Personal Information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to manage client referrals, to process your registration, trades, sells and other transactions, and to communicate with you on these and other topics. For example, we use your information to:
- Provide access to our Sites, and processing payments and other transactions;
- Determine your geographic location;
- Create and manage your account;
- Verify your identify;
- Communicate with you about your account, your activities on our Sites, about security, privacy and administrative issues, and policy changes;
- Communicate with you about new features, offers and promotions;
- Process applications for and administering our Affiliate Program;
- Provide you with advertising, analytics and marketing;
- Provide you with customer support and assisting with operational requests, such as password reset requests;
- Operate, evaluate, enhance and improve our business, the Sites, services, security, communications, content, advertisements and other activities;
- Measure interest and engagement in our Sites and advertisements;
- Research and develop new products and services, marketing and security procedures, and researching new technologies;
- Audit of interactions, transactions and other compliance activities;
- Secure our systems, prevent fraud and helps us protect the security of Hxro’s accounts;
- Detect, investigate and protect against malicious, deceptive, fraudulent and illegal activity, and prosecute (and assist in the prosecution of) those responsible for such activity;
- Comply with applicable laws and legal requirements, industry standards, and our terms and policies, and enforce compliance with these laws, requirements, standards, terms and policies;
- Evaluate job candidates and making hiring and other personnel decisions; and
- Other purposes you consent to, are notified of, or are disclosed when you provide Personal Information.
DISCLOSING YOUR PERSONAL INFORMATION
We may disclose your Personal Information for certain purposes and to third parties, as described below.
- Affiliates. We may share Personal Information with our affiliated companies.
- Service Providers. We may share Personal Information with third party vendors, agents and service provides that we have engaged to provide services on our behalf or to assist us with the provision of services to you. Examples include service providers for marketing, advertising, communications, security, infrastructure and IT services, payment processors (including for our Affiliate Program), data analytics services and customer service providers.
- Partners. We may disclose Personal Information to our partners with whom we jointly offer products or services or engage in joint marketing efforts.
- Legal Enforcement / Legal Disclosures. We may share your Personal Information with law enforcement or government authorities if we believe that it is reasonably necessary to comply with the law, regulation or legal process; to detect, protect and enforce the safety of our or any person, property or rights (including to enforce any of our terms or other agreements that we may have with you); and to address fraud, security issues and criminal activity.
- Advertising Vendors. We may disclose Personal Information to advertising vendors and other service providers for analytics and advertising related purposes. We may allow advertising vendors to set cookies and other tracking tools to collect Personal Information regarding your activities and your device, such as your IP address, mobile IDs, pages visited, and location and time of day. These advertising vendors 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.
You have certain choices about how your Personal Information is collected, used, stored and shared. These options can be accessed through your account or device settings.
- Email and Text Messages. If you no longer wish to receive certain communications from us through email or text message, you can (a) update your choices regarding the types of communications you receive from us through your Hxro account, or (b) follow the opt-out instructions provided in the email or text message. Please note that you cannot opt-out from certain communications relating to your account or use of our services, such as messages related to your trade transactions.
- Push Notifications. You can choose to receive mobile push notifications from us. On some device operating systems, you will be automatically enrolled in the notifications. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device's settings functionality to turn them off. We also offer push notifications on certain web browsers. If you agree to receive those notifications and subsequently decide you no longer wish to receive these notifications, you can use your browser’s settings to turn them off.
- Interest-Based Ads. Interest-based ads are online ads that are tailored to your likely interests based on your use of various apps and websites across the internet. If you are using a browser, then cookies and web beacons can be used to collect information to help determine your likely interests. If you are using a mobile device, tablet or other network device that includes a resettable device ID, then that identifier can be used to help determine your likely interests. For your choices about interest-based ads from us, see “Cookies and Internet Advertising” below.
Your Personal Information and Rights
In accordance with applicable law, you may have the right to:
- Access Personal Information about you, including (a) confirming whether we are processing your Personal Information, and (b) obtaining access to or a copy of your Personal Information.
- Request Correction of your Personal Information if inaccurate, incomplete or outdated. You may be able to update your Personal Information within your Hxro account settings.
- Request Deletion of your Personal Information we have collected about you in certain circumstances (e.g. your Personal Information is no longer necessary for the purposes in which it was being processed). To request deletion, please contact us with the “Contact Details” below.
- Restriction of our processing of your Personal Information, where such requests are permitted by law.
- Request data portability and receive an electronic copy of Personal Information that you have provided us.
- Object to our processing of your Personal Information. We will stop processing the Personal Information 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.
- Request the Review of Automated Individual Decision-Making that are based solely on automated processing, including profiling, except under certain exceptions under local law.
We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort or could expose us to operational risks.
Your California Privacy Rights
For California residents, you have additional rights under the California Consumer Privacy Act, and the right to be free from unlawful discrimination for exercising your rights under the Act:
- You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
- You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.
California’s “Shine the Light” law requires certain businesses to respond to requests from California residents asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California law, you can contact us at the “Contact Details” below.
Do Not Track Signals
“Do Not Track” is a privacy preference that users can set in certain web browsers. We do not respond to or support “Do Not Track” signals or similar mechanisms transmitted by web browsers.
COOKIES AND INTERNET ADVERTISING
- Web Beacons / Pixel Tags. Some of our Sites and email updates may contain electronic images called “Web Beacons,” also referred to as as one pixel GIFs, clear GIFs or “Pixel Tags.” These allow us to count visitors who have viewed our Sites. In promotional email messages and newsletters, they allow us to count how many subscribers have read them. Web Beacons allow us to develop statistical information about the activities and features that most interest our clients (e.g. who clicked on a particular advertisement) for the purpose of providing more personalized content.
You may stop or restrict the placement cookies, web beacons, pixel tags and other technologies on your device or remove them by adjusting your preferences as your device or browser permits. However, if you disable restrict or remove these technologies, you may be restricted from using features on our Sites.
The Sites are not designed or directed to persons under the age of eighteen (18) years of age or the age of legal majority. We do not knowingly collect Personal Information from minors. If you learn that a minor, in violation of this policy, registered for an account or otherwise provided their Personal Information to our Sites, without proper consent, you may contact us via the “Contact Details” below. If we learn that we have collected any minor’s Personal Information in violation of applicable law, we will take steps to delete such information and terminate the minor’s account.
Security of Your Personal Information
We use commercially reasonable security measures to help protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Despite our efforts, no website, mobile application, database or system is completely secure. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure. We recommend that you also take measures to protect your Personal Information by taking reasonable steps to protect against unauthorized disclosure or misuse.
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 Information to any of those websites, your information is governed by their privacy policies.
If you are located in the European Union or the UK, you have the right to file a complaint concerning our processing of your Personal Information with your national (or in some countries, regional) data protection authority. The EU Commission has a list here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Hxro Games, Ltd.
2 Church Street
Hamilton, HM 11