Effective date: May 25, 2018
Last updated: November 9, 2020
This Privacy Policy sets out how X2X Ltd., its affiliates and divisions (collectively “X2X”, "we", "us", “our”, or "ours") collect and process information, including what types of information we collect and track, how we use it, and with whom we share it, that identifies you and may be used to contact you (such information, collectively “Personal Information”) when you visit our websites (including codex.online), access and/or use our services, and/or request assistance with the products purchased from us (collectively, the “Services”).
Your privacy is important to us. By using our Services you acknowledge that you have read and understood this Privacy Policy and agree to the processing of your Personal Information by X2X as set out in this Privacy Policy. We will only process your Personal Information as set out in this Privacy Policy which is intended to provide you with notice of this following:
1. What Personal Information We Collect and How We Use It
2. Legal Basis for the Processing of Personal Information
3. How We Share and Disclose Your Personal Information
4. How to Opt-in or Opt-out from Direct Marketing
5. Transfer of Personal Information, Including Internationally
6. Do Not Track
7. Cookies, Web Beacons and Other Technologies
8. I nformation Security and Quality
9. Notification of Changes
10. Access, Correction and Deletion
11. For How Long We Keep Your Personal Information
12. California Residents and California Privacy Rights
13. Service Quality Monitoring
14. Links to Non-X2X Websites
15. Contact Us
1. What Personal Information We Collect and How We Use It
In general, you can visit our websites without telling us who you are and without giving us any Personal Information. There are times, however, when we or our partners may need information from you, for instance in order to perform a transaction (including provision of services and assistance with a purchased product). In particular, we may collect and process the following information (including Personal Information) about you:
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Information you give us. You may give us information about you by filling in forms on X2X websites or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our websites, subscribe to our services, download white papers and case studies, sign up to webinars, contribute to our chat rooms or forums, apply for jobs, purchase or use our products and/or services, sign up for programs, and when you report a problem with our Services. The information you give us may include your name, address, e-mail address, phone number, financial and credit card information, resume, and other information that you choose to give us. If you give us personal data and/or information about somebody else, such as a spouse or work colleague, we will assume that you have their permission to do so. You are responsible for obtaining this permission from other people whose personal information you provide to us.
We use the information you give to us:
- to provide you with the products and services you requested, including support services;
- to provide you with information about product and services that we feel may interest you;
- to contact you as part of our customer satisfaction surveys or for market research purposes;
- to notify you about changes to our Services; and
- for recruitment purposes, if you have applied for a job with us.
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Information we collect automatically. When you visit our websites, we may automatically collect the following information: technical information, including your IP address, log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your visit including the URL clickstream to, through and from our websites (such as scrolling, clicks and mouse overs), products you viewed or searched for, download errors, length of visits to certain pages and page interaction. We collect information automatically through the use of various technologies, including through "cookies", and this is explained further below.
We use the information we collect automatically:
- to administer our websites for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to ensure that content from our websites is presented in the most effective manner for you and your devices;
- to allow you to participate in interactive features of our services; as part of our effort to keep our websites safe and secure
- to make suggestions and recommendations to you and other users of our websites about goods and services that may interest you or them; and
- to measure the effectiveness of advertising we and others serve to you and to deliver relevant advertising to you.
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Information we receive from other sources. We may receive information about you from third parties we work with such as business partners, sub-contractors in technical payment and delivery services, advertising networks, analytics providers and search information providers.
We use the information that we receive about you from other sources for the same purposes as the information you provide to us and the information that we collect automatically, and in addition in order to help us maintain the accuracy of the information we collect.
2. Legal Basis for the Processing of Personal Information
a) Performance of a contract;
b) Legitimate interest taking into account the following criteria:
- X2X’s interest in developing its Services and providing up-to-date and competitive Services;
- X2X’s interest in investigating suspicion of and taking measures against misuse of or damage to our Services, network or the content;
- X2X’s and/or third party's interest in investigating and producing evidence regarding criminal activity, fraud and other threats against its interest;
- X2X’s interest in establishing and exercising its legal rights;
- X2X’s and/or third party’s right to protect its safety or property; and Competent authority’s interest in conducting law enforcement activities and collecting evidence for such purposes.
c) Compliance with legal obligations and exercising its rights under applicable laws;
d) Where required by law, on the basis of the consent of users which may subsequently be withdrawn at any time by contacting us, without affecting the lawfulness of processing based on consent before its withdrawal. We rely on consent for certain marketing purposes. For more information on how you can provide or withdraw your consent, see your choices from Section 10, below; and
e) Compliance with a legal obligation to which X2X is subject
3. How We Share and Disclose Your Personal Information
Personal Information is never sold or leased to any third parties. We limit the disclosure of your Personal Information to the following instances:
- We may share your Personal Information with others, to fulfill your requests and orders, for instance with other parts of X2X, our order fulfillment resellers, business partners, financial institutions, shipping companies, and postal or government authorities (for example, Customs authorities) involved in fulfillment;
- We may also share your Personal Information with advertising networks that require this information to select and serve relevant adverts to you, as well as with analytics and search engine providers who assist us in the improvement of our websites. In addition, we may share your Personal Information with selected business partners for marketing purposes, but at all times in accordance with your marketing preferences as indicated from time to time;
- In some cases, we use suppliers to collect, use, analyze and otherwise process information (including Personal Information) on our behalf. We require suppliers with whom we share Personal Information to handle it in a manner consistent with our policies, and we take steps to ensure that our suppliers preserve the security and confidentiality of Personal Information that they collect and process on our behalf;
- We may use the information that you provide us in connection with a job application or enquiry throughout X2X and its related entities for the purpose of considering your enquiry and application for employment related purposes. Except where you tell us not to, we will keep your Personal Information contained in any job application for possible future consideration;
- We may generally share your Personal Information with our affiliates, subsidiaries, and parent company globally;
- In addition, we may process your Personal Information for the purpose of producing and providing to our partners statistical information (meaning aggregate information that does not identify you personally) about how our customers, collectively, use our Services. We share this type of statistical data so that our partners can understand how often people use their areas, services and our websites, so that they, too, may provide you with an optimal web experience or services experience;
- In certain circumstances, we may disclose your Personal Information to third parties such as law enforcement authorities and agencies, regulatory organizations, courts and governmental or other public authorities if we have to or are authorized to do so by law, for example pursuant to judicial or other government requests, subpoenas, warrants, or orders; and
- Finally, circumstances may arise where, whether for strategic or other business reasons, X2X decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of Personal Information to prospective or actual purchasers, or receiving it from sellers. We will seek appropriate protection for Personal Information disclosed in these types of transactions.
4. How to Opt-In or Opt-Out from Direct Marketing
We may use the information you give us for direct marketing purposes to provide product and service requests, offers, updates, newsletters, events, or promotional communications. However, such marketing will be sent in accordance with applicable law, and any marketing preferences you have expressed. We will offer you an opportunity to either opt-in to or opt-out of such use. There are a few ways to opt-in to or opt-out of the use of your Personal Information for direct marketing purposes. For example, at the point of collection of your Personal Information you may be informed of an opportunity to receive certain communications and be given a choice to opt-in or opt-out, for instance by providing your Personal Information and checking or unchecking an opt-in or opt-out box and any case pursuant to your consent as required by law.
5. Transfer of Personal Information, Including Internationally
X2X’s principal office is located in United Kingdom while its affiliates and parent company have offices in the United States of America, Hungary, New Zealand, and/or Germany. Also, some of our service providers may be located in other countries. Some of these countries may provide less legal protection than others for your Personal Information. To the extent the processing is subject to the General Data Protection Regulation (2016/679) (“GDPR”), cross-border transfers of Personal Information outside the EU/EES may be necessary for the performance of the contract between you and X2X (article 49.1 (b) of the GDPR). The processing of your Personal Information may be conducted outside the EU/EEA, in which case we will take necessary steps required under the GDPR (if applicable) in order for such transfer of data across borders to be compliant with the GDPR. In cases where there is no adequacy decision by the Commission, this may, for example, include the use of EU model clauses (under Article 46.2 of the GDPR). When we transfer your Personal Information internationally, even if such transfer is not governed by GDPR, we will take reasonable steps to ensure that your Personal Information is treated securely, lawfully and in the manner described in this Privacy Policy.
6. Do Not Track
Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not been adopted, X2X websites do not process or respond to “Do Not Track” signals. To learn more about “Do Not Track”, please visit “All About Do Not Track”.
7. Cookies, Web Beacons and Other Technologies
Our websites use cookies and similar technologies, like web beacons, for analytics, account login sessions, remembering choices, functionality and targeted advertising purposes. Cookies are small files that are downloaded to your device through your web browser that enables the website to recognize your browser and capture and remember certain data. Cookies enable us to enhance the user experience with our Services. A cookie usually contains the name of the domain from which the cookie came, the retention period of the cookie, and a value (usually a randomly generated unique number). We use the following types of cookies in our websites:
- Session cookies: temporary cookies that remain in the cookie file of your browser until you leave the website. Session cookies are used to validate your session and carry information across pages of the website, so you don’t have to re-enter information in order to access different files your account has permission to view;
- Persistent cookies: cookies that remain in the cookie file of your browser for a longer period of time (how long will depend on the lifetime of the specific cookie). Persistent cookies are used to help us recognize you as a unique user when you return to our websites. We may also use persistent cookies to compile anonymous, aggregated statistics that allow us to understand how our Services are used and to help us improve the Services; and
- Third Party Cookies: we may allow third party data analytics providers to use cookies on our websites, but we do not control the use or contents of such third-party cookies.
You can change the cookie settings of your web browser, for example erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you choose to block cookies, please note that some functions of our websites may not work properly.
8. Information Security and Quality
We apply appropriate security measures and processes to protect your Personal Information, and maintain its security and quality. All information you provide to us is stored on our secure servers. We use encryption when transmitting certain sensitive information and any payment transactions will be encrypted [using SSL technology]. Where you have a password which enables you to access certain parts of our websites, you are responsible for keeping this password secure and confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our websites at all times. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorized access, disclosure, alteration or loss.
9. Notification of Changes
A notice will be posted on our websites' home pages for 30 days whenever this Privacy Policy is changed in a material way. By continuing to use our websites, you confirm your continuing acceptance of this Privacy Policy.
10. Access, Correction and Deletion
You can access the Personal Information in your online account and correct, amend, or delete information that is inaccurate. You may delete your online account altogether, if you wish. Please note that we may retain some Personal Information in our records even after you delete your online account for legal compliance purposes and/or exercise of legal rights.
More specifically, you have the following rights pertaining to our processing of your Personal Information:
- You are at any time and free of charge entitled to receive a copy of the Personal Information that we hold about you and information about the processing. Please note that X2X needs to, in order to be able to answer your request, be able to determine your identity;
- You have the right to, without undue delay, have inaccurate or incomplete Personal Information about you corrected. Furthermore, you have the right to request that X2X restricts the processing of your Personal Information under certain conditions; for example, if you contest the accuracy of the Personal Data, the processing may be restricted for a period enabling X2X to verify the accuracy of the Personal Information or if X2X no longer needs the Personal Information for the purposes of the processing but you require the Personal Information for the establishment, exercise or defense of legal claims;
- You have the right to have your Personal Information deleted without undue delay if, for example, the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed. Please note that X2X is not obligated to delete the Personal Information if X2X can show that the processing is necessary, for example, for the establishment, exercise or defense of a legal claim or if X2X has other legitimate interests for retaining some personal data in our records;
- You have the right to object, on grounds relating to your particular situation, at any time to X2X’s processing of your Personal Information if the processing is based on, for example, legitimate interests. If you object to such processing, X2X will no longer be entitled to process your Personal Information based on such legal basis, unless X2X can demonstrate compelling legitimate grounds for the processing which overrides your interests, rights and freedom or if it is conducted for the establishment, exercise or defense of a legal claim; and
- You have, under certain conditions, the right to receive the Personal Information concerning you and which you have provided to X2X, in a structured, commonly used and machine-readable format and have the right to transmit such Personal Information to another data controller without X2X trying to prevent this, where X2X’s processing of your Personal Information is based a contract and the processing is carried out by automated means. In such case you have the right to request that the Personal Information shall be transmitted from X2X directly to another data controller, where technically feasible.
11. For How Long We Keep Your Personal Information
The periods for which we retain your information depend on the purpose for which we collected it and we use it. We will not retain your Personal Information for longer than is necessary for our business purposes or for legal requirements. We may retain some information for a few years after you have closed your account with us, for instance if this is necessary to meet our legal obligations.
12. California Residents and California Privacy Rights
If you are a user of our Services and a California resident, you have special rights under California Privacy Act of 2018 (“CCPA”) as described in X2X Privacy Notice for California Residents. We treat the privacy of our users very seriously and for this reason Do Not Sell (as defined by CCPA) your Personal Information. X2X has not and will not knowingly share your Personal Information with third parties for their own direct marketing purposes without your consent.
13. Service Quality Monitoring
Certain transactions may also involve you calling us or us calling you. X2X does not generally audio record such telephone conversations, and instead, collects from you in internal written records any pertinent information necessary to monitor and fulfil your request. Please be aware that X2X may in some cases record such calls for staff training or quality assurance purposes in which case you will be informed at the beginning of such calls of the subsequent planned audio recording along with an option to decline such audio recording.
14. Links to Non-X2X Websites
X2X Services may contain links to other websites. X2X is not responsible for the privacy practices or the content of those other websites, and we encourage you to carefully read the privacy policies of these websites to find out how they use your Personal Information.
15. Questions about this Privacy Policy? Contact Us
X2X’s websites are maintained by X2X internally. If you have a question about this Privacy Policy or our handling of your information, you can contact X2X in the following manner: e-mail us at info@codex.online with an e-mail copy (cc) to privacy@x2x.media.
