1. Corporate Commitment to Privacy
This Privacy Policy describes how Xtra Point Group®, LLC (Xtra Point”) collects, uses discloses, stores, and otherwise processes information through www.PodiumX.com and www.xtrapointgroup.com through the products and/or services provided by or through Xtra Point (collectively “Services”). In addition, this policy states how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy.
We urge you to read this Privacy Policy so that you understand our commitment to you and your privacy, and how you can participate in that commitment.
2. Scope
This Privacy Policy applies to personal information and other information collected by Xtra Point or its service providers from or about:
a. visitors to, or users of, its websites;
b. current customers using the Services pursuant to a written agreement with Xtra Point;
c. prospective and current customers using the Services pursuant to a clickwrap, browserwrap, or other online agreement;
d. service providers and business partners;
e. other third-parties that use the Services, including without limitation, the end users of prospective and current customers.
As used in this Privacy Policy, “you” or “your” means, collectively, the entities or individuals set forth in (a) – (e) of this Section 2.
3. Personal Information
a. Definition of Personal Information
Personal information refers to any information relating to an identified or identifiable natural person, such as an identification number, physical, physiological, mental, economic, cultural, or social identifiers.
b. Definition of Personal Information (Special Categories of Information)
Special categories of personal data refers to genetic and biometric data which can identify a unique individual. Under GDPR, these categories require additional privacy protections.
4. Definition of Non-Personal Information
We may also collect information that is related to you but that does not personally identify you (“Non-personal Information”). Non-personal Information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) in order to remove or hide any Personal Information.
5. Consent
Xtra Point collects personal information about you in connection with many of our services. When working or using our company, you may be prompted to make an account which may hold personal information such as your name, mailing address, email address, or credit card information. Prior to collecting this information, Xtra Point will obtain your consent. At any point in time, you can revoke consent and we will cease using and processing your data immediately.
6. Information Collected Automatically
Xtra Point may also collect Technical Information about you when you visit our websites, which your web browser automatically sends whenever you visit a website on the Internet. “Technical Information” is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. Our servers automatically record this information, which may include your Internet Protocol (“IP”) address, browser type, browser language, and the date and time of your request. Gathering your information helps us ensure our websites and other services work correctly and support out customer analytic efforts.
7. Information Collected Automatically (Examples)
a. Email communication
We may use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that is embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on a company website. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.
b. Mobile communication
When you download or use our mobile-device applications, or access one of our mobile-optimized websites, we may receive information about your mobile device, including a unique identifier for your device.
c. Cookies and Similar Technologies
We may collect information about your use of the websites through cookies and similar technology. A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the websites. For example, we may use these technologies to collect information about the ways visitors use our websites, to support the features and functionality of our websites, and to personalize your experience when you use our websites.
8. Information Collected from Other Sources
Xtra Point may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud. We work closely with third parties (for example, business partners, service providers, sub-contractors, advertising networks, analytics providers, search information providers, fraud protection services) and may receive information about you from them. The following are some examples:
a. Third-Party Vendors
In order to provide the services and improve Xtra Point’s websites, we may engage the services of third-party vendors. In the process of supplying services to Xtra Point, these third-party vendors may need to collect Personal Information about you.
b. Log Files
Log files record website activity on our services and enable us to gather statistics about our users’ browsing habits. These entries help Xtra Point determine (among other things) how many and how often users have accessed or used our services, which pages they have visited, and other similar data.
c. Clear GIFs
Clear GIFs, sometimes called “web bugs” or “web beacons,” are small electronic images that are placed on a web page or in an email message. We use clear GIFs to monitor user behavior, deliver cookies, collect information, count visits, understand usage and campaign effectiveness, and to tell if a recipient has opened and acted upon an email.
9. Permitted Use of Personal Information
Xtra Point uses your personal information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your personal information to support our business functions, such as fraud prevention, marketing, and legal functions. To do this, we combine personal and non-personal information, collected online and offline, including information from third party sources. The following are some examples:
a. Fulfill Requests
To fulfill your requests for products and services and communicate with you about those requests;
b. Understand Customer Behavior
To better understand customer behavior so that we may improve our marketing and advertising efforts and to improve the distribution of our products and services;
c. Personalize Offerings
To help us personalize our service offerings, websites, mobile services, and advertising;
d. Legal
To comply with legal and/or regulatory requirements;
e. Responding to Customer
To respond to reviews, comments, or other feedback you provide us;
f. Industry Benchmarking
For industry benchmarking and analysis consistent with our legitimate business purpose.
10. Promotional Messaging or Advertising
Xtra Point uses your contact information to recommend products and services that might be of interest to you, to send you marketing and advertising messages such as newsletters, announcements, or special offers, or to notify you about our upcoming events.
11. Ability to Opt-In to Promotional Messaging or Advertising
Xtra Point allows you to opt-in to receive advertisements based on your interests. If you do not opt-in, you will still receive advertisements but they will not be tailored to your interests.
12. Disclosure of Categories of Personal Information
The California Consumer Privacy Act (CCPA) requires us to disclose categories of personal information we collect and how we use it, the categories of sources from whom we collect personal information, and the third parties with whom we share it, which we have explained above.
We collect the following categories of personal information and have disclosed these categories of personal information for a business purpose to affiliates, service providers and third parties:
- Identifiers such as your name, username, email address, phone number, unique device identifiers, your IP address
- Personal information categories described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as signature, insurance policy number and health insurance information
- Personal characteristics protected by law, such as your gender and age
- Commercial information, such as purchases made and payment information
- Internet or electronic network activity information, such as information about your device and your use of our Services
- Geo-location data, when shared through your device settings or photos
- Electronic, visual, or similar information, such as photos
- Professional or employment information when you link your account to other accounts
- Education information
- Inferences we draw or derive about users, such as your interests or preferences
- Other information you provide, such as your profile picture, bio, pins, and comments
We use and disclose this information for the business purposes described in this Privacy Policy, including to provide Services, detect security incidents and prevent fraud, debug and repair errors, maintain your account, provide customer service, process or fulfill orders, conduct research and development and other activities to improve our Services, show advertising, market our services, and understand how users interact with our Services.
13. Disclosure of Personal Information for Business Purposes
If Xtra Point sells any part of its operations, Xtra Point may transfer personal information in connection with the sale. Prior to a sale occurring, Xtra Point will contact you to gain your consent for the disclosure of your personal information.
14. Disclosure of Personal Information for Legal and Safety Reasons
Xtra Point may be required to disclose personal information to the authorities, law enforcement agencies, government agencies, or legal entities. We may disclose information by law, litigation, or as a matter of national security to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law. We may also need to disclose personal information in the event of an emergency that threatens an individual’s life, health, or security.
15. Disclosure of Personal Information Via Links to Third-Party Websites, Services, and Applications
Using our website or services may link to third party web websites, services, and applications. Xtra Point is not responsible for any personal information collected through these means. Information collected is governed through the third party’s website’s Privacy Policy. Any interactions you have with these web websites, services, or applications are beyond the control of Xtra Point. When you post information to or through such services, those websites’ privacy policies and cookie usage policies apply directly. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.
16. Use of Cookies and Other Technologies (e.g., Web Beacons)
Xtra Point uses cookies to operate and improve our website as well as to simplify the interaction with you. When you visit our websites, our servers send a cookie to your computer or mobile device to help personalize your experience and advertisements. Cookies help us better understand user behavior and facilitate effectiveness of advertisements. Cookies only stand to recognize your web browser but information collected from cookies is not personally identifiable. Xtra Point may also use web beacons or other technologies in conjunction with cookies to gather information about your visit to our websites. Web beacons may be embedded through our website or electronic communications and can allow servers to collect information related to your visit. Web beacons are primarily used to provide content and advertisements that are more relevant to you.
17. Ability to Disable Technologies
Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all features available through our services. For more information, visit the help page for your web browser or see http://www.allaboutcookies.org
18. Consequences of Disabling Technologies
Please note that if you disable your web browser’s cookies and other technologies, certain features of our website and services will be disabled and you will limit the functionality we can provide when you visit our site.
19. Security Measures Taken to Protect Personal Information by Xtra Point
Security of all information is of the utmost importance for Xtra Point. Xtra Point uses technical and physical safeguards to protect the security of your personal information from unauthorized disclosure. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. In the case of a data breach, we will notify you without delay of any loss, misuse or alteration of personal information that may affect you.
20. Security Measures to Protect Personal Information by Third Parties
We require that our third-party service providers and business partners agree to keep all confidential information we share with them and to use the information only to perform their obligations in the agreements we have in place with them. These third-party service providers and business partners are expected to maintain privacy and security protections that are consistent with Xtra Point’ privacy and information security policies.
21. Data Retention and Storage
Some data you can delete whenever you like. The Services offered by Xtra Point Group allow you to correct or delete data stored in your account or podium.
Some data is deleted automatically. In some cases, rather than provide a way to delete data, we store it for a predetermined period of time. For each type of data, we set retention timeframes based on the reason for its collection.
Some data is retained for longer periods of time when necessary. Xtra Point retains your information for business purposes as long as is reasonably necessary to provide you with our products and services. Xtra Point will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time. At any point in time, you can withdraw consent and we will immediately stop processing your data.
22. Choice: Your Privacy Rights
Xtra Point gives you choices about the ways we collect, use, and share your personal information. You can choose what contact information will be stored in your account and preferences. However, if you choose not to provide certain details, some of your experiences with us may be affected. If at any point in time you wish to know what data we process about you, you can request to access the information by contacting us at help@xtrapointgroup.com.
23. Collection of Information from Children
We recognize the importance of protecting the privacy and safety of children. Our website and services are primarily directed towards the general audience and are not directed towards children. We do not knowingly collect information about children under the age of 13 without the consent of a parent or guardian.
24. Contact Point to Update/Delete Personal Information
You have the right to access and limit the use and disclosure of your personal data. If you would like to express your point of view, challenge an explanation of data use, or otherwise obtain further information, contact us help@xtrapointgroup.com. If at any time after registering for information, your personal information changes, notify us and we will update your contact information. Please note, at any time, if you desire to obtain or transfer your information, we will provide you with your personal data in a structured and commonly used electronic format.
25. Location of Data Processing/Storage
Personal information collected about EU data subjects via our website or our Services is processed in the United States by Xtra Point or by a third party acting on our behalf. When you provide personal information to Xtra Point, you consent to the processing of your information in the United States. Our websites are hosted in the United States.
26. California Privacy Rights
If you are a California resident, then under this Privacy Policy and pursuant to the California Consumer Privacy Act (CCPA), you have the following rights:
a. Right to Know and Access
You may submit a verifiable request for information regarding the: (1) categories of personal information we collect, use or share; (2) purposes for which categories of personal information are collected or used by us; (3) categories of sources from which we collect personal information; and (4) specific pieces of personal information we have collected about you. To make such a request, please contact us at help@xtrapointgroup.com. In order to verify any request, you may need to log in to your account or respond to an email verification request.
b. Right to Delete
You also have the right to request the deletion of your personal data that have been collected in the past 12 months. To make such a request, please contact us at help@xtrapointgroup.com. In order to verify any request, you may need to log in to your account or respond to an email verification request.
c. Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with may use technology on the Service that “sells” personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by contacting us at help@xtrapointgroup.com. In order to verify any request, you may need to log in to your account or respond to an email verification request.
d. Right to Equal Service
We will not discriminate against you if you exercise your privacy rights, including by: (1) denying goods or services to you; (2) charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; (3) providing a different level or quality of goods or services to you; or (4) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
e. Exercising Your CCPA Data Protection Rights
To exercise any of your California Privacy Rights, you can contact us at help@xtrapointgroup.com. In order to verify any request, you may need to log in to your account or respond to an email verification request. We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
A list of the categories of personal information we collect and how we use that information is set forth in Section 8 of this Privacy Policy.
27. Europe Privacy Rights
If you are a resident of the European Union, then under this Privacy Policy and pursuant to the General Data Protection Regulation (GDPR), you have the following rights:
a. Right of Access
At any point in time, you can confirm your data is being processed and request to access your data. If you wish to access/confirm your data is being processed, please contact us at . In order to verify any request, you may need to log in to your account or respond to an email verification request.
b. Right to Consent
Before collecting and using your personal data, Xtra Point will obtain consent. At any point in time, you can revoke consent and Xtra Point will stop using and processing your personal data.
c. Right to Erasure
You have the right to request Xtra Point erases all of your personal data on a number of grounds, including if the data is no longer necessary for its original purpose or if you withdraw consent. If Xtra Point receives a request, we will inform all third parties who have the data of this request. For additional information on when you can request data erasure, please contact us at help@xtrapointgroup.com In order to verify any request, you may need to log in to your account or respond to an email verification request.
d. Right to Rectification
If any personal data is inaccurate or incomplete, you can request that Xtra Point correct the data. When this occurs, Xtra Point will notify third parties who have access to the data of the change. If you wish to alter your data, please contact us at help@xtrapointgroup.com. In order to verify any request, you may need to log in to your account or respond to an email verification request.
e. Right to Restrict Processing
Even if personal data is still stored by a company, now or in the future, you can request Xtra Point stops using or processing your data. If you wish to restrict data processing, please contact us at help@xtrapointgroup.com. In order to verify any request, you may need to log in to your account or respond to an email verification request.
f. Right to Object
You have the right to object to your personal data being processed for profiling, direct marketing, scientific research, and statistics. If you wish to object, please contact us at help@xtrapointgroup.com. In order to verify any request, you may need to log in to your account or respond to an email verification request.
g. Rights Related to Automatic Decision Making and Profiling
At any point in time, you can contact a Xtra Point representative to express your point of view, challenge an explanation of data use, or otherwise obtain further information on automatic data processing.
h. Right to Data Portability
You have the right to transfer your personal data from one electronic processing system to another without being prevented from doing so by Xtra Point’ data processor. Unless extended by Xtra Point request, within ninety (90) days, Xtra Point will respond to the request and provide you with the desired information for free in a structured and commonly used electronic format.