Privacy Policy

Last updated October 05, 2022 This privacy notice for Xily Ltd. ('Company', 'we', 'us', or 'our',), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you: 

Download and use our mobile application (Rejoy), or any other application of ours that links to this privacy notice 

Engage with us in other related ways, including any sales, marketing, or events 

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@xily.app. 

SUMMARY OF KEY POINTS 

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents. 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Xily Ltd. and the Services, the choices you make, and the products and features you use. Click here to learn more. 

Do we process any sensitive personal information? We do not process sensitive personal information. 

Do we receive any information from third parties? We do not receive any information from third parties. 

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more. 

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Click here to learn more. 

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Click here to learn more. 

What are your rights? Depending on where you are located geographically, theapplicable privacy law may mean you have certain rights regarding your personalinformation. Click here to learn more.

How do you exercise your rights? The easiest way to exercise your rights is byfilling out our data subject request form available here, or by contacting us. We willconsider and act upon any request in accordance with applicable data protectionlaws.

Want to learn more about what Xily Ltd. does with any information we collect?Click here to review the notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONALINFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECTFROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you registeron the Services, express an interest in obtaining information about us or our productsand Services, when you participate in activities on the Services, or otherwise whenyou contact us.

Personal Information Provided by You. The personal information that we collectdepends on the context of your interactions with us and the Services, the choices youmake, and the products and features you use. The personal information we collectmay include the following:

email addresses

usernames

passwords

contact preferences

contact or authentication data

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with ususing your existing social media account details, like your Facebook, Twitter, or othersocial media account. If you choose to register in this way, we will collect theinformation described in the section called 'HOW DO WE HANDLE YOUR SOCIALLOGINS?' below.

Application Data. If you use our application(s), we also may collect the followinginformation if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to tracklocation-based information from your mobile device, either continuously orwhile you are using our mobile application(s), to provide certain location-based  services. If you wish to change our access or permissions, you may do so inyour device's settings.

Mobile Device Access. We may request access or permission to certainfeatures from your mobile device, including your mobile device's calendar,contacts, microphone, reminders, storage, camera, and other features. If youwish to change our access or permissions, you may do so in your device'ssettings.

Mobile Device Data. We automatically collect device information (such as yourmobile device ID, model, and manufacturer), operating system, versioninformation and system configuration information, device and applicationidentification numbers, browser type and version, hardware model Internetservice provider and/or mobile carrier, and Internet Protocol (IP) address (orproxy server). If you are using our application(s), we may also collectinformation about the phone network associated with your mobile device, yourmobile device’s operating system or platform, the type of mobile device youuse, your mobile device’s unique device ID, and information about the featuresof our application(s) you accessed.

Push Notifications. We may request to send you push notifications regardingyour account or certain features of the application(s). If you wish to opt outfrom receiving these types of communications, you may turn them off in yourdevice's settings.

This information is primarily needed to maintain the security and operation of ourapplication(s), for troubleshooting, and for our internal analytics and reportingpurposes.

All personal information that you provide to us must be true, complete, and accurate,and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/orbrowser and device characteristics — is collected automatically when you visit ourServices.

We automatically collect certain information when you visit, use, or navigate theServices. This information does not reveal your specific identity (like your name orcontact information) but may include device and usage information, such as your IPaddress, browser and device characteristics, operating system, languagepreferences, referring URLs, device name, country, location, information about howand when you use our Services, and other technical information. This information isprimarily needed to maintain the security and operation of our Services, and for ourinternal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similartechnologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic,usage, and performance information our servers automatically collect whenyou access or use our Services and which we record in log files. Depending onhow you interact with us, this log data may include your IP address, deviceinformation, browser type, and settings and information about your activity inthe Services (such as the date/time stamps associated with your usage, pagesand files viewed, searches, and other actions you take such as which featuresyou use), device event information (such as system activity, error reports(sometimes called 'crash dumps'), and hardware settings).

Device Data. We collect device data such as information about your computer,phone, tablet, or other device you use to access the Services. Depending onthe device used, this device data may include information such as your IPaddress (or proxy server), device and application identification numbers,location, browser type, hardware model, Internet service provider and/ormobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about yourdevice's location, which can be either precise or imprecise. How muchinformation we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologiesto collect geolocation data that tells us your current location (based on your IPaddress). You can opt out of allowing us to collect this information either byrefusing access to the information or by disabling your Location setting on yourdevice. However, if you choose to opt out, you may not be able to use certainaspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer ourServices, communicate with you, for security and fraud prevention, and to complywith law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending onhow you interact with our Services, including:

To facilitate account creation and authentication and otherwise manageuser accounts. We may process your information so you can create and login to your account, as well as keep your account in working order.

To request feedback. We may process your information when necessary torequest feedback and to contact you about your use of our Services.

To send you marketing and promotional communications. We mayprocess the personal information you send to us for our marketing purposes, ifthis is in accordance with your marketing preferences. You can opt out of ourmarketing emails at any time. For more information, see 'WHAT ARE YOURPRIVACY RIGHTS?' below).

To protect our Services. We may process your information as part of ourefforts to keep our Services safe and secure, including fraud monitoring andprevention.

To identify usage trends. We may process information about how you useour Services to better understand how they are being used so we can improvethem.

To determine the effectiveness of our marketing and promotionalcampaigns. We may process your information to better understand how toprovide marketing and promotional campaigns that are most relevant to you.

To save or protect an individual's vital interest. We may process yourinformation when necessary to save or protect an individual’s vital interest,such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESSYOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessaryand we have a valid legal reason (i.e. legal basis) to do so under applicable law, likewith your consent, to comply with laws, to provide you with services to enter into orfulfil our contractual obligations, to protect your rights, or to fulfil our legitimatebusiness interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explainthe valid legal bases we rely on in order to process your personal information. Assuch, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission(i.e. consent) to use your personal information for a specific purpose. You canwithdraw your consent at any time. Click here to learn more.

Legitimate Interests. We may process your information when we believe it isreasonably necessary to achieve our legitimate business interests and thoseinterests do not outweigh your interests and fundamental rights and freedoms.For example, we may process your personal information for some of thepurposes described in order to:

Send users information about special offers and discounts on ourproducts and services 

Analyse how our services are used so we can improve them to engageand retain users

Support our marketing activities

Diagnose problems and/or prevent fraudulent activities

Understand how our users use our products and services so we canimprove user experience

Legal Obligations. We may process your information where we believe it isnecessary for compliance with our legal obligations, such as to cooperate witha law enforcement body or regulatory agency, exercise or defend our legalrights, or disclose your information as evidence in litigation in which we areinvolved.

Vital Interests. We may process your information where we believe it isnecessary to protect your vital interests or the vital interests of a third party,such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the 'data controller' under European data protectionlaws of the personal information described in this privacy notice, since we determinethe means and/or purposes of the data processing we perform. This privacy noticedoes not apply to the personal information we process as a 'data processor' onbehalf of our customers. In those situations, the customer that we provide services toand with whom we have entered into a data processing agreement is the 'datacontroller' responsible for your personal information, and we merely process yourinformation on their behalf in accordance with your instructions. If you want to knowmore about our customers' privacy practices, you should read their privacy policiesand direct any questions you have to them.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e.express consent) to use your personal information for a specific purpose, or insituations where your permission can be inferred (i.e. implied consent). You canwithdraw your consent at any time. Click here to learn more.

In some exceptional cases, we may be legally permitted under applicable law toprocess your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot beobtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary toassess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with nextof kin

If we have reasonable grounds to believe an individual has been, is, or may bevictim of financial abuse

If it is reasonable to expect collection and use with consent would compromisethe availability or the accuracy of the information and the collection isreasonable for purposes related to investigating a breach of an agreement or acontravention of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, orrules of the court relating to the production of records

If it was produced by an individual in the course of their employment, business,or profession and the collection is consistent with the purposes for which theinformation was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOURPERSONAL INFORMATION?

In Short: We may share information in specific situations described in this sectionand/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connectionwith, or during negotiations of, any merger, sale of company assets, financing,or acquisition of all or a portion of our business to another company.

When we use Google Maps Platform APIs. We may share your informationwith certain Google Maps Platform APIs (e.g. Google Maps API, Places API).To find out more about Google’s Privacy Policy, please refer to this link. Weobtain and store on your device ('cache') your location. You may revoke yourconsent anytime by contacting us at the contact details provided at the end ofthis document.

Offer Wall. Our application(s) may display a third-party hosted 'offer wall'.Such an offer wall allows third-party advertisers to offer virtual currency, gifts,or other items to users in return for the acceptance and completion of anadvertisement offer. Such an offer wall may appear in our application(s) and bedisplayed to you based on certain data, such as your geographic area ordemographic information. When you click on an offer wall, you will be broughtto an external website belonging to other persons and will leave ourapplication(s). A unique identifier, such as your user ID, will be shared with theoffer wall provider in order to prevent fraud and properly credit your accountwith the relevant reward.

5. DO WE USE COOKIES AND OTHER TRACKINGTECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and storeyour information.

We may use cookies and similar tracking technologies (like web beacons and pixels)to access or store information. Specific information about how we use suchtechnologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social mediaaccount, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party socialmedia account details (like your Facebook or Twitter logins). Where you choose to dothis, we will receive certain profile information about you from your social mediaprovider. The profile information we receive may vary depending on the social mediaprovider concerned, but will often include your name, email address, friends list, andprofile picture, as well as other information you choose to make public on such asocial media platform.

We will use the information we receive only for the purposes that are described in thisprivacy notice or that are otherwise made clear to you on the relevant Services.Please note that we do not control, and are not responsible for, other uses of yourpersonal information by your third-party social media provider. We recommend thatyou review their privacy notice to understand how they collect, use, and share yourpersonal information, and how you can set your privacy preferences on their sitesand apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposesoutlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for thepurposes set out in this privacy notice, unless a longer retention period is required orpermitted by law (such as tax, accounting, or other legal requirements). No purposein this notice will require us keeping your personal information for longer than twentyfour (24) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personalinformation, we will either delete or anonymise such information, or, if this is notpossible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it fromany further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system oforganisational and technical security measures.

We have implemented appropriate and reasonable technical and organisationalsecurity measures designed to protect the security of any personal information weprocess. However, despite our safeguards and efforts to secure your information, noelectronic transmission over the Internet or information storage technology can beguaranteed to be 100% secure, so we cannot promise or guarantee that hackers,cybercriminals, or other unauthorised third parties will not be able to defeat oursecurity and improperly collect, access, steal, or modify your information. Althoughwe will do our best to protect your personal information, transmission of personalinformation to and from our Services is at your own risk. You should only access theServices within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), UnitedKingdom (UK), and Canada, you have rights that allow you greater access to andcontrol over your personal information. You may review, change, or terminate youraccount at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights underapplicable data protection laws. These may include the right (i) to request access andobtain a copy of your personal information, (ii) to request rectification or erasure; (iii)to restrict the processing of your personal information; and (iv) if applicable, to dataportability. In certain circumstances, you may also have the right to object to theprocessing of your personal information. You can make such a request by contactingus by using the contact details provided in the section 'HOW CAN YOU CONTACTUS ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable dataprotection laws. 

If you are located in the EEA or UK and you believe we are unlawfully processingyour personal information, you also have the right to complain to your local dataprotection supervisory authority. You can find their contact details here:https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authoritiesare available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process yourpersonal information, which may be express and/or implied consent depending onthe applicable law, you have the right to withdraw your consent at any time. You canwithdraw your consent at any time by contacting us by using the contact detailsprovided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'below.

However, please note that this will not affect the lawfulness of the processing beforeits withdrawal nor, when applicable law allows, will it affect the processing of yourpersonal information conducted in reliance on lawful processing grounds other thanconsent.

Opting out of marketing and promotional communications: You can unsubscribefrom our marketing and promotional communications at any time by clicking on theunsubscribe link in the emails that we send, or by contacting us using the detailsprovided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'below. You will then be removed from the marketing lists. However, we may stillcommunicate with you — for example, to send you service-related messages that arenecessary for the administration and use of your account, to respond to servicerequests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account orterminate your account, you can:

Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete youraccount and information from our active databases. However, we may retain someinformation in our files to prevent fraud, troubleshoot problems, assist with anyinvestigations, enforce our legal terms and/or comply with applicable legalrequirements.

Cookies and similar technologies: Most Web browsers are set to accept cookiesby default. If you prefer, you can usually choose to set your browser to removecookies and to reject cookies. If you choose to remove cookies or reject cookies, thiscould affect certain features or services of our Services. To opt out of interest-basedadvertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you may email us atinfo@xily.app.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applicationsinclude a Do-Not-Track ('DNT') feature or setting you can activate to signal yourprivacy preference not to have data about your online browsing activities monitoredand collected. At this stage no uniform technology standard for recognising andimplementing DNT signals has been finalised. As such, we do not currently respondto DNT browser signals or any other mechanism that automatically communicatesyour choice not to be tracked online. If a standard for online tracking is adopted thatwe must follow in the future, we will inform you about that practice in a revisedversion of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFICPRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rightsregarding access to your personal information.

California Civil Code Section 1798.83, also known as the 'Shine The Light' law,permits our users who are California residents to request and obtain from us, once ayear and free of charge, information about categories of personal information (if any)we disclosed to third parties for direct marketing purposes and the names andaddresses of all third parties with which we shared personal information in theimmediately preceding calendar year. If you are a California resident and would liketo make such a request, please submit your request in writing to us using the contactinformation provided below.

If you are under 18 years of age, reside in California, and have a registered accountwith Services, you have the right to request removal of unwanted data that youpublicly post on the Services. To request removal of such data, please contact ususing the contact information provided below and include the email addressassociated with your account and a statement that you reside in California. We willmake sure the data is not publicly displayed on the Services, but please be awarethat the data may not be completely or comprehensively removed from all oursystems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a 'resident' as:

(1) every individual who is in the State of California for other than a temporary ortransitory purpose and

(2) every individual who is domiciled in the State of California who is outside theState of California for a temporary or transitory purpose

All other individuals are defined as 'non-residents'.

If this definition of 'resident' applies to you, we must adhere to certain rights andobligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve(12) months:Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias,postal address, telephone or mobilecontact number, unique personal identifier,online identifier, Internet Protocol address,email address, and account name

NO

B. Personal informationcategories listed in theCalifornia CustomerRecords statute

Name, contact information, education,employment, employment history, andfinancial information

NO

C. Protected classificationcharacteristics underCalifornia or federal law

Gender and date of birth

NO

D. Commercial information

Transaction information, purchase history,financial details, and payment information

NO

E. Biometric information

Fingerprints and voiceprints

NO

F. Internet or other similarnetwork activity

Browsing history, search history, onlinebehaviour, interest data, and interactionswith our and other websites, applications,systems, and advertisements

NO

G. Geolocation data

Device location

NO

H. Audio, electronic, visual,thermal, olfactory, or similarinformation

Images and audio, video or call recordingscreated in connection with our businessactivities

NO

I. Professional oremployment-relatedinformation

Business contact details in order toprovide you our Services at a businesslevel or job title, work history, andprofessional qualifications if you apply fora job with us

NO

J. Education Information

Student records and directory information

NO

K. Inferences drawn fromother personal information

Inferences drawn from any of the collectedpersonal information listed above to createa profile or summary about, for example,an individual’s preferences andcharacteristics

NO

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to awritten contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as forundertaking internal research for technological development and demonstration. Thisis not considered to be 'selling' of your personal information.

Xily Ltd. has not disclosed or sold any personal information to third parties for abusiness or commercial purpose in the preceding twelve (12) months. Xily Ltd. willnot sell personal information in the future belonging to website visitors, users, andother consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete yourpersonal information, we will respect your request and delete your personalinformation, subject to certain exceptions provided by law, such as (but not limited to)the exercise by another consumer of his or her right to free speech, our compliancerequirements resulting from a legal obligation, or any processing that may berequired to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell your personal information to third parties;

the categories of personal information that we sold or disclosed for a businesspurpose;

the categories of third parties to whom the personal information was sold ordisclosed for a business purpose; and

the business or commercial purpose for collecting or selling personalinformation.

In accordance with applicable law, we are not obligated to provide or deleteconsumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you arethe same person about whom we have the information in our system. Theseverification efforts require us to ask you to provide information so that we can match itwith information you have previously provided us. For instance, depending on thetype of request you submit, we may ask you to provide certain information so that wecan match the information you provide with the information we already have on file,or we may contact you through a communication method (e.g. phone or email) thatyou have previously provided to us. We may also use other verification methods asthe circumstances dictate.

We will only use personal information provided in your request to verify your identityor authority to make the request. To the extent possible, we will avoid requestingadditional information from you for the purposes of verification. However, if we cannotverify your identity from the information already maintained by us, we may requestthat you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally providedinformation as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longerrelevant, or ask to restrict the processing of the information.

You can designate an authorised agent to make a request under the CCPA onyour behalf. We may deny a request from an authorised agent that does notsubmit proof that they have been validly authorised to act on your behalf inaccordance with the CCPA.

You may request to opt out from future selling of your personal information tothird parties. Upon receiving an opt-out request, we will act upon the requestas soon as feasibly possible, but no later than fifteen (15) days from the dateof the request submission.

To exercise these rights, you can contact us by email at info@xily.app, or by referringto the contact details at the bottom of this document. If you have a complaint abouthow we handle your data, we would like to hear from you.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevantlaws.

We may update this privacy notice from time to time. The updated version will beindicated by an updated 'Revised' date and the updated version will be effective assoon as it is accessible. If we make material changes to this privacy notice, we maynotify you either by prominently posting a notice of such changes or by directlysending you a notification. We encourage you to review this privacy notice frequentlyto be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us atinfo@xily.app or by post to:

Xily Ltd.

89-90 Paul Street 3rd floor

London, Greater London Area EC2A 4NE

United Kingdom

If you are a resident in the European Economic Area, the 'data controller' of yourpersonal information is Xily Ltd.. Xily Ltd. has appointed Xily Ltd. to be itsrepresentative in the EEA. You can contact them directly regarding the processing ofyour information by Xily Ltd., by email at info@xily.app, by visiting http://www.xily.app,or by post to:

89-90 Paul Street 3rd floor

London, Greater London Area EC2A 4NE

United Kingdom

If you are a resident in the United Kingdom, the 'data controller' of your personalinformation is Xily Ltd.. Xily Ltd. has appointed Oliver Petrus to be its representativein the UK. You can contact them directly regarding the processing of your informationby Xily Ltd., by email at info@xily.app, by visiting http://www.xily.app, or by post to:

89-90 Paul Street 3rd floor

London, Greater London Area EC2A 4NE

United Kingdom

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THEDATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to requestaccess to the personal information we collect from you, change that information, ordelete it. To request to review, update, or delete your personal information, pleasesubmit a request form by clicking here.

Last updated October 05, 2022 This privacy notice for Xily Ltd. ('Company', 'we', 'us', or 'our',), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you: 

Download and use our mobile application (Rejoy), or any other application of ours that links to this privacy notice 

Engage with us in other related ways, including any sales, marketing, or events 

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@xily.app. 

SUMMARY OF KEY POINTS 

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents. 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Xily Ltd. and the Services, the choices you make, and the products and features you use. Click here to learn more. 

Do we process any sensitive personal information? We do not process sensitive personal information. 

Do we receive any information from third parties? We do not receive any information from third parties. 

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more. 

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Click here to learn more. 

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Click here to learn more. 

What are your rights? Depending on where you are located geographically, theapplicable privacy law may mean you have certain rights regarding your personalinformation. Click here to learn more.

How do you exercise your rights? The easiest way to exercise your rights is byfilling out our data subject request form available here, or by contacting us. We willconsider and act upon any request in accordance with applicable data protectionlaws.

Want to learn more about what Xily Ltd. does with any information we collect?Click here to review the notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONALINFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECTFROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you registeron the Services, express an interest in obtaining information about us or our productsand Services, when you participate in activities on the Services, or otherwise whenyou contact us.

Personal Information Provided by You. The personal information that we collectdepends on the context of your interactions with us and the Services, the choices youmake, and the products and features you use. The personal information we collectmay include the following:

email addresses

usernames

passwords

contact preferences

contact or authentication data

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with ususing your existing social media account details, like your Facebook, Twitter, or othersocial media account. If you choose to register in this way, we will collect theinformation described in the section called 'HOW DO WE HANDLE YOUR SOCIALLOGINS?' below.

Application Data. If you use our application(s), we also may collect the followinginformation if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to tracklocation-based information from your mobile device, either continuously orwhile you are using our mobile application(s), to provide certain location-based  services. If you wish to change our access or permissions, you may do so inyour device's settings.

Mobile Device Access. We may request access or permission to certainfeatures from your mobile device, including your mobile device's calendar,contacts, microphone, reminders, storage, camera, and other features. If youwish to change our access or permissions, you may do so in your device'ssettings.

Mobile Device Data. We automatically collect device information (such as yourmobile device ID, model, and manufacturer), operating system, versioninformation and system configuration information, device and applicationidentification numbers, browser type and version, hardware model Internetservice provider and/or mobile carrier, and Internet Protocol (IP) address (orproxy server). If you are using our application(s), we may also collectinformation about the phone network associated with your mobile device, yourmobile device’s operating system or platform, the type of mobile device youuse, your mobile device’s unique device ID, and information about the featuresof our application(s) you accessed.

Push Notifications. We may request to send you push notifications regardingyour account or certain features of the application(s). If you wish to opt outfrom receiving these types of communications, you may turn them off in yourdevice's settings.

This information is primarily needed to maintain the security and operation of ourapplication(s), for troubleshooting, and for our internal analytics and reportingpurposes.

All personal information that you provide to us must be true, complete, and accurate,and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/orbrowser and device characteristics — is collected automatically when you visit ourServices.

We automatically collect certain information when you visit, use, or navigate theServices. This information does not reveal your specific identity (like your name orcontact information) but may include device and usage information, such as your IPaddress, browser and device characteristics, operating system, languagepreferences, referring URLs, device name, country, location, information about howand when you use our Services, and other technical information. This information isprimarily needed to maintain the security and operation of our Services, and for ourinternal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similartechnologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic,usage, and performance information our servers automatically collect whenyou access or use our Services and which we record in log files. Depending onhow you interact with us, this log data may include your IP address, deviceinformation, browser type, and settings and information about your activity inthe Services (such as the date/time stamps associated with your usage, pagesand files viewed, searches, and other actions you take such as which featuresyou use), device event information (such as system activity, error reports(sometimes called 'crash dumps'), and hardware settings).

Device Data. We collect device data such as information about your computer,phone, tablet, or other device you use to access the Services. Depending onthe device used, this device data may include information such as your IPaddress (or proxy server), device and application identification numbers,location, browser type, hardware model, Internet service provider and/ormobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about yourdevice's location, which can be either precise or imprecise. How muchinformation we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologiesto collect geolocation data that tells us your current location (based on your IPaddress). You can opt out of allowing us to collect this information either byrefusing access to the information or by disabling your Location setting on yourdevice. However, if you choose to opt out, you may not be able to use certainaspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer ourServices, communicate with you, for security and fraud prevention, and to complywith law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending onhow you interact with our Services, including:

To facilitate account creation and authentication and otherwise manageuser accounts. We may process your information so you can create and login to your account, as well as keep your account in working order.

To request feedback. We may process your information when necessary torequest feedback and to contact you about your use of our Services.

To send you marketing and promotional communications. We mayprocess the personal information you send to us for our marketing purposes, ifthis is in accordance with your marketing preferences. You can opt out of ourmarketing emails at any time. For more information, see 'WHAT ARE YOURPRIVACY RIGHTS?' below).

To protect our Services. We may process your information as part of ourefforts to keep our Services safe and secure, including fraud monitoring andprevention.

To identify usage trends. We may process information about how you useour Services to better understand how they are being used so we can improvethem.

To determine the effectiveness of our marketing and promotionalcampaigns. We may process your information to better understand how toprovide marketing and promotional campaigns that are most relevant to you.

To save or protect an individual's vital interest. We may process yourinformation when necessary to save or protect an individual’s vital interest,such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESSYOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessaryand we have a valid legal reason (i.e. legal basis) to do so under applicable law, likewith your consent, to comply with laws, to provide you with services to enter into orfulfil our contractual obligations, to protect your rights, or to fulfil our legitimatebusiness interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explainthe valid legal bases we rely on in order to process your personal information. Assuch, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission(i.e. consent) to use your personal information for a specific purpose. You canwithdraw your consent at any time. Click here to learn more.

Legitimate Interests. We may process your information when we believe it isreasonably necessary to achieve our legitimate business interests and thoseinterests do not outweigh your interests and fundamental rights and freedoms.For example, we may process your personal information for some of thepurposes described in order to:

Send users information about special offers and discounts on ourproducts and services 

Analyse how our services are used so we can improve them to engageand retain users

Support our marketing activities

Diagnose problems and/or prevent fraudulent activities

Understand how our users use our products and services so we canimprove user experience

Legal Obligations. We may process your information where we believe it isnecessary for compliance with our legal obligations, such as to cooperate witha law enforcement body or regulatory agency, exercise or defend our legalrights, or disclose your information as evidence in litigation in which we areinvolved.

Vital Interests. We may process your information where we believe it isnecessary to protect your vital interests or the vital interests of a third party,such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the 'data controller' under European data protectionlaws of the personal information described in this privacy notice, since we determinethe means and/or purposes of the data processing we perform. This privacy noticedoes not apply to the personal information we process as a 'data processor' onbehalf of our customers. In those situations, the customer that we provide services toand with whom we have entered into a data processing agreement is the 'datacontroller' responsible for your personal information, and we merely process yourinformation on their behalf in accordance with your instructions. If you want to knowmore about our customers' privacy practices, you should read their privacy policiesand direct any questions you have to them.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e.express consent) to use your personal information for a specific purpose, or insituations where your permission can be inferred (i.e. implied consent). You canwithdraw your consent at any time. Click here to learn more.

In some exceptional cases, we may be legally permitted under applicable law toprocess your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot beobtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary toassess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with nextof kin

If we have reasonable grounds to believe an individual has been, is, or may bevictim of financial abuse

If it is reasonable to expect collection and use with consent would compromisethe availability or the accuracy of the information and the collection isreasonable for purposes related to investigating a breach of an agreement or acontravention of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, orrules of the court relating to the production of records

If it was produced by an individual in the course of their employment, business,or profession and the collection is consistent with the purposes for which theinformation was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOURPERSONAL INFORMATION?

In Short: We may share information in specific situations described in this sectionand/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connectionwith, or during negotiations of, any merger, sale of company assets, financing,or acquisition of all or a portion of our business to another company.

When we use Google Maps Platform APIs. We may share your informationwith certain Google Maps Platform APIs (e.g. Google Maps API, Places API).To find out more about Google’s Privacy Policy, please refer to this link. Weobtain and store on your device ('cache') your location. You may revoke yourconsent anytime by contacting us at the contact details provided at the end ofthis document.

Offer Wall. Our application(s) may display a third-party hosted 'offer wall'.Such an offer wall allows third-party advertisers to offer virtual currency, gifts,or other items to users in return for the acceptance and completion of anadvertisement offer. Such an offer wall may appear in our application(s) and bedisplayed to you based on certain data, such as your geographic area ordemographic information. When you click on an offer wall, you will be broughtto an external website belonging to other persons and will leave ourapplication(s). A unique identifier, such as your user ID, will be shared with theoffer wall provider in order to prevent fraud and properly credit your accountwith the relevant reward.

5. DO WE USE COOKIES AND OTHER TRACKINGTECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and storeyour information.

We may use cookies and similar tracking technologies (like web beacons and pixels)to access or store information. Specific information about how we use suchtechnologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social mediaaccount, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party socialmedia account details (like your Facebook or Twitter logins). Where you choose to dothis, we will receive certain profile information about you from your social mediaprovider. The profile information we receive may vary depending on the social mediaprovider concerned, but will often include your name, email address, friends list, andprofile picture, as well as other information you choose to make public on such asocial media platform.

We will use the information we receive only for the purposes that are described in thisprivacy notice or that are otherwise made clear to you on the relevant Services.Please note that we do not control, and are not responsible for, other uses of yourpersonal information by your third-party social media provider. We recommend thatyou review their privacy notice to understand how they collect, use, and share yourpersonal information, and how you can set your privacy preferences on their sitesand apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposesoutlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for thepurposes set out in this privacy notice, unless a longer retention period is required orpermitted by law (such as tax, accounting, or other legal requirements). No purposein this notice will require us keeping your personal information for longer than twentyfour (24) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personalinformation, we will either delete or anonymise such information, or, if this is notpossible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it fromany further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system oforganisational and technical security measures.

We have implemented appropriate and reasonable technical and organisationalsecurity measures designed to protect the security of any personal information weprocess. However, despite our safeguards and efforts to secure your information, noelectronic transmission over the Internet or information storage technology can beguaranteed to be 100% secure, so we cannot promise or guarantee that hackers,cybercriminals, or other unauthorised third parties will not be able to defeat oursecurity and improperly collect, access, steal, or modify your information. Althoughwe will do our best to protect your personal information, transmission of personalinformation to and from our Services is at your own risk. You should only access theServices within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), UnitedKingdom (UK), and Canada, you have rights that allow you greater access to andcontrol over your personal information. You may review, change, or terminate youraccount at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights underapplicable data protection laws. These may include the right (i) to request access andobtain a copy of your personal information, (ii) to request rectification or erasure; (iii)to restrict the processing of your personal information; and (iv) if applicable, to dataportability. In certain circumstances, you may also have the right to object to theprocessing of your personal information. You can make such a request by contactingus by using the contact details provided in the section 'HOW CAN YOU CONTACTUS ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable dataprotection laws. 

If you are located in the EEA or UK and you believe we are unlawfully processingyour personal information, you also have the right to complain to your local dataprotection supervisory authority. You can find their contact details here:https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authoritiesare available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process yourpersonal information, which may be express and/or implied consent depending onthe applicable law, you have the right to withdraw your consent at any time. You canwithdraw your consent at any time by contacting us by using the contact detailsprovided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'below.

However, please note that this will not affect the lawfulness of the processing beforeits withdrawal nor, when applicable law allows, will it affect the processing of yourpersonal information conducted in reliance on lawful processing grounds other thanconsent.

Opting out of marketing and promotional communications: You can unsubscribefrom our marketing and promotional communications at any time by clicking on theunsubscribe link in the emails that we send, or by contacting us using the detailsprovided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'below. You will then be removed from the marketing lists. However, we may stillcommunicate with you — for example, to send you service-related messages that arenecessary for the administration and use of your account, to respond to servicerequests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account orterminate your account, you can:

Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete youraccount and information from our active databases. However, we may retain someinformation in our files to prevent fraud, troubleshoot problems, assist with anyinvestigations, enforce our legal terms and/or comply with applicable legalrequirements.

Cookies and similar technologies: Most Web browsers are set to accept cookiesby default. If you prefer, you can usually choose to set your browser to removecookies and to reject cookies. If you choose to remove cookies or reject cookies, thiscould affect certain features or services of our Services. To opt out of interest-basedadvertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you may email us atinfo@xily.app.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applicationsinclude a Do-Not-Track ('DNT') feature or setting you can activate to signal yourprivacy preference not to have data about your online browsing activities monitoredand collected. At this stage no uniform technology standard for recognising andimplementing DNT signals has been finalised. As such, we do not currently respondto DNT browser signals or any other mechanism that automatically communicatesyour choice not to be tracked online. If a standard for online tracking is adopted thatwe must follow in the future, we will inform you about that practice in a revisedversion of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFICPRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rightsregarding access to your personal information.

California Civil Code Section 1798.83, also known as the 'Shine The Light' law,permits our users who are California residents to request and obtain from us, once ayear and free of charge, information about categories of personal information (if any)we disclosed to third parties for direct marketing purposes and the names andaddresses of all third parties with which we shared personal information in theimmediately preceding calendar year. If you are a California resident and would liketo make such a request, please submit your request in writing to us using the contactinformation provided below.

If you are under 18 years of age, reside in California, and have a registered accountwith Services, you have the right to request removal of unwanted data that youpublicly post on the Services. To request removal of such data, please contact ususing the contact information provided below and include the email addressassociated with your account and a statement that you reside in California. We willmake sure the data is not publicly displayed on the Services, but please be awarethat the data may not be completely or comprehensively removed from all oursystems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a 'resident' as:

(1) every individual who is in the State of California for other than a temporary ortransitory purpose and

(2) every individual who is domiciled in the State of California who is outside theState of California for a temporary or transitory purpose

All other individuals are defined as 'non-residents'.

If this definition of 'resident' applies to you, we must adhere to certain rights andobligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve(12) months:Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias,postal address, telephone or mobilecontact number, unique personal identifier,online identifier, Internet Protocol address,email address, and account name

NO

B. Personal informationcategories listed in theCalifornia CustomerRecords statute

Name, contact information, education,employment, employment history, andfinancial information

NO

C. Protected classificationcharacteristics underCalifornia or federal law

Gender and date of birth

NO

D. Commercial information

Transaction information, purchase history,financial details, and payment information

NO

E. Biometric information

Fingerprints and voiceprints

NO

F. Internet or other similarnetwork activity

Browsing history, search history, onlinebehaviour, interest data, and interactionswith our and other websites, applications,systems, and advertisements

NO

G. Geolocation data

Device location

NO

H. Audio, electronic, visual,thermal, olfactory, or similarinformation

Images and audio, video or call recordingscreated in connection with our businessactivities

NO

I. Professional oremployment-relatedinformation

Business contact details in order toprovide you our Services at a businesslevel or job title, work history, andprofessional qualifications if you apply fora job with us

NO

J. Education Information

Student records and directory information

NO

K. Inferences drawn fromother personal information

Inferences drawn from any of the collectedpersonal information listed above to createa profile or summary about, for example,an individual’s preferences andcharacteristics

NO

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to awritten contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as forundertaking internal research for technological development and demonstration. Thisis not considered to be 'selling' of your personal information.

Xily Ltd. has not disclosed or sold any personal information to third parties for abusiness or commercial purpose in the preceding twelve (12) months. Xily Ltd. willnot sell personal information in the future belonging to website visitors, users, andother consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete yourpersonal information, we will respect your request and delete your personalinformation, subject to certain exceptions provided by law, such as (but not limited to)the exercise by another consumer of his or her right to free speech, our compliancerequirements resulting from a legal obligation, or any processing that may berequired to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell your personal information to third parties;

the categories of personal information that we sold or disclosed for a businesspurpose;

the categories of third parties to whom the personal information was sold ordisclosed for a business purpose; and

the business or commercial purpose for collecting or selling personalinformation.

In accordance with applicable law, we are not obligated to provide or deleteconsumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you arethe same person about whom we have the information in our system. Theseverification efforts require us to ask you to provide information so that we can match itwith information you have previously provided us. For instance, depending on thetype of request you submit, we may ask you to provide certain information so that wecan match the information you provide with the information we already have on file,or we may contact you through a communication method (e.g. phone or email) thatyou have previously provided to us. We may also use other verification methods asthe circumstances dictate.

We will only use personal information provided in your request to verify your identityor authority to make the request. To the extent possible, we will avoid requestingadditional information from you for the purposes of verification. However, if we cannotverify your identity from the information already maintained by us, we may requestthat you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally providedinformation as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longerrelevant, or ask to restrict the processing of the information.

You can designate an authorised agent to make a request under the CCPA onyour behalf. We may deny a request from an authorised agent that does notsubmit proof that they have been validly authorised to act on your behalf inaccordance with the CCPA.

You may request to opt out from future selling of your personal information tothird parties. Upon receiving an opt-out request, we will act upon the requestas soon as feasibly possible, but no later than fifteen (15) days from the dateof the request submission.

To exercise these rights, you can contact us by email at info@xily.app, or by referringto the contact details at the bottom of this document. If you have a complaint abouthow we handle your data, we would like to hear from you.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevantlaws.

We may update this privacy notice from time to time. The updated version will beindicated by an updated 'Revised' date and the updated version will be effective assoon as it is accessible. If we make material changes to this privacy notice, we maynotify you either by prominently posting a notice of such changes or by directlysending you a notification. We encourage you to review this privacy notice frequentlyto be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us atinfo@xily.app or by post to:

Xily Ltd.

89-90 Paul Street 3rd floor

London, Greater London Area EC2A 4NE

United Kingdom

If you are a resident in the European Economic Area, the 'data controller' of yourpersonal information is Xily Ltd.. Xily Ltd. has appointed Xily Ltd. to be itsrepresentative in the EEA. You can contact them directly regarding the processing ofyour information by Xily Ltd., by email at info@xily.app, by visiting http://www.xily.app,or by post to:

89-90 Paul Street 3rd floor

London, Greater London Area EC2A 4NE

United Kingdom

If you are a resident in the United Kingdom, the 'data controller' of your personalinformation is Xily Ltd.. Xily Ltd. has appointed Oliver Petrus to be its representativein the UK. You can contact them directly regarding the processing of your informationby Xily Ltd., by email at info@xily.app, by visiting http://www.xily.app, or by post to:

89-90 Paul Street 3rd floor

London, Greater London Area EC2A 4NE

United Kingdom

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THEDATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to requestaccess to the personal information we collect from you, change that information, ordelete it. To request to review, update, or delete your personal information, pleasesubmit a request form by clicking here.