Privacy Policy

I. Who we are. How we collect your data.

I. Who we are. How we collect your personal data.

IXXO, with its registered office at 90, Arch. Makariou III, 7060 Livadia, Cyprus (hereafter referred to as “Controller,” “IXXO,” “we,” “us,” or “our”), is the sole controller of your personal data processed in connection with using our services and other functionalities via this website.

IXXO provides a communication platform for businesses to communicate with their customers. Hundreds of merchants worldwide use our service to improve their sales and customer satisfaction rates. Our platform includes features like live chat, bots, Calendar Scheduling and email. Every tool for communicating with your clients is in one place, accessible through our dashboard and mobile apps.

We may collect and process your personal data when we interact with you. We process all personal data that you provide on the Website or that we collect about you when you use our Services as Controller in accordance with the GDPR. Personal data includes any information we can use to identify you as a specific person, such as your name, last name, email address or billing information, and any other information related to you.

We are committed to safeguarding the privacy of your personal data. We will use your personal data in compliance with all applicable laws and regulations relating to data protection and privacy, including:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons about the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”);
California Consumer Privacy Act (together with related amendments and regulations, the “CCPA”), described in the section “Information and Notice for California Residents”;
Nevada applicable law, described in section “Nevada Residents”;

II. Contact us

If you have any questions about this Privacy Policy or wish to exercise any of your rights regarding your personal data, please email us at support@ixxo.com.

III. What are the purposes and grounds for our processing of personal data?

We may process your personal data for the following purposes:

If you have access to and use our Services, according to our Terms & Conditions https://ixxohub.com/terms-conditions/), we will process your personal data to:
1. A. perform an agreement for the provision of Services by electronic means related to the purchase of the Services (GDPR legal basis – Article 6(1) (b) of the GDPR);
2. legal obligations to which the Controller is subject (GDPR legal basis – Article 6(1)(c) of the GDPR read together with the Accounting Act, in case of issuing and storing invoices and accounting documents);
3. pursue our legitimate interest in a proper provision of Services (GDPR legal basis -Article 6(1) of the GDPR), such as:
  - taking steps to set up and properly maintain your account;
  - improving, fixing, customizing, and personalizing the service according to your needs;
  - ensure data safety and security;
  - pursuing claims and defence against claims, including third parties.

If you have entered into a contract with us via either a contact form (chat) or e-mail, we will process your personal data to:
1. Pursue our legitimate interest in response to your enquiry or contact and resolve the issue presented (GDPR legal basis Article 6(1) (f) of the GDPR)
2. Take steps to enter into an agreement with you (purchasing the Services), including preparing and presenting an offer to you (which will vary depending on the scope of the matter) with point (b) of Article 6(1) of the GDPR as the legal basis for processing, also.
We can provide you with information about the latest news, special events, offers, and other benefits, or you can subscribe to our newsletter. We will process your personal data based on our legitimate interest (Article 6 (1) (f) of the GDPR). Remember that you can always revoke your consent (unsubscribe from our newsletter). If you wish to unsubscribe, you can also contact us at the following address: support@ixxo.com.
If required by applicable law, we may also collect consent to send you marketing materials.

If you follow our social media profiles, we will process your personal data to pursue our legitimate interests (Art 6(1) (f) GDPR), such as:
1. responding to private messages you send us;
2. conducting conversations via the comments under individual posts;
3. sharing our posts with you as a follower of our profile;
4. marketing, consisting of informing you about our services and ourselves through our profile posts;
5. via statistics presented to us by social media entities, such as Facebook Ireland Ltd., LinkedIn Ireland Unlimited Company, and Twitter Inc., including data about the display of our posts, their reach, number of interactions, and the demographics of our followers; the data presented to us by Social media entities are statistics created on the basis of observations by that company of your behaviour on our profile.

If you apply for a job, we will process your personal data to:
1. Carrying out the recruitment process in which you are taking part, with point (GDPR legal basis -Article 6(1)(b) and point (c) of Article 6(1) (c) of the GDPR to the extent of legal obligations to which the Controller is subject),
2. Processing of other your data you voluntarily send us or processing for future recruitment if you consented to it (GDPR legal basis- Article 6(1)(a) of the GDPR);

The provision of your personal data is voluntary but may be necessary to pursue the purposes as mentioned earlier. However, due to the rules applied by Social media, we will see your name (or nickname) or photo if you write to us or comment on our post.

IV. What types of data can we process?

We may collect and process different forms of personal data depending on the functionalities you use:

If you have access to and use our Services, we will process your:
1. identification data such as your name, email address,
2. financial data necessary for the processing of invoices and also
3. Other data you may provide while using these Services, particularly data relating to the conclusion and performance of the contract with you.
4. Automatically collected information, i.e.:
  - usage and log information, which includes information about your activity, log files, and diagnostic, crash, website, and performance logs and reports;
  - transaction information;
  - devices and connection information, including information such as hardware model, operating system information, browser information, IP address, mobile network information and device identifiers;
  - status information, i.e. information about your online and status message changes on our Services, such as whether you are online;
  - sales data relating to you, including but not limited to business, financial and product information, and any information relating to your customer, including, but not limited to, order information, payment information, and account information;

If you wish to contact us, we will process your identification data, such as your name, email address and any other data you may provide, using our contact form (chat) or e-mail.
We will also process your email address if you subscribe to our newsletter or otherwise consent to our services’ marketing.
As part of your activity on our social media profiles, we may process your personal data posted on your profile and other data related to our use of social media functionality.
If you apply for a job, we may process your personal data indicated in the Labour Code or other specific laws, processed based on legal provisions.

V. Your right to object.

You are entitled to object to processing your personal data based on legitimate interest at any time. In such case, we will cease to process your data for these purposes unless there are legitimate grounds that prevent the cessation of processing or the processing may be necessary for the potential establishment, exercise or defence of legal claims.
As mentioned in Section III, point (3), you are entitled to object at any time to the processing of your personal data for direct marketing purposes.

VI. How long do we keep your personal data?

Depending on the purposes and grounds described in Section III. above, your data will be processed for the time it takes to :

Service and process your account in our Services, but no longer than until the account is deleted, except in the case of your violation of the Terms resulting in the assertion of claims. In that case, your personal data will be processed for the time necessary to assert claims but, at most, the period of limitations for claims under generally applicable law.
Provide services (duration of the agreement). Still, suppose the processing is necessary to fulfil a legal obligation by IXXO. In that case, your data will be processed for a period resulting from generally applicable laws, in particular tax law and accounting regulations. Suppose the processing is necessary for purposes arising from legitimate interests pursued by the Data Controller or a third party. In that case, your personal data will be processed for no longer than necessary for the purposes for which the data are processed or until you object to processing your personal data.
Resolve your case. Depending on the type of case, your data could also be processed for the time needed to improve performance and the time required to establish that we have resolved the case correctly, i.e. for the period of limitations for claims.
Provide our marketing activities (newsletter) until you object to processing your data for this purpose or revoke your consent to send messages to your email address. Your revocation of consent does not affect the lawfulness of processing before withdrawing that consent. You can unsubscribe/ withdraw consent by clicking the opt-out link in our newsletter and marketing e-mails.
We will interact with you via our social media profiles if you comment on our posts or follow us. Remember that you can permanently delete your comments under our posts, stop following us, or cancel your social media account.
If you consent to the processing of your data for future recruitment purposes until the end of the recruitment process, your data will be processed for 48 months, but no longer than until you withdraw your consent.

VII. Data recipients.

We could provide your data to other companies and service providers who perform certain business operations on our behalf. These companies and service providers may participate in processing Personal Data to the extent necessary to perform services for IXXO. Depending on your activities as described in Section III, recipients of your data may be:

Service hosting providers;
Website hosting providers;
Subjects involved in storing data for us;
Entities providing ICT services;
Social media providers such as Facebook Ireland Ltd., LinkedIn Ireland Unlimited Company, Twitter Inc.,

Personal data may also be disclosed to other entities that support our operations, i.e.

servicers of IT systems,
law firms, auditors;
third-party companies and individuals who facilitate our Services, to provide the Services on our behalf, to perform Service-related services, or to assist us in analyzing how our Services are used, or
entities to which the Data controller is obliged to transfer data under the provisions of law.

VIII. Your rights as a data subject

By law, you have the following rights regarding your data: Further information and advice about your rights can be obtained from your national data protection regulator. If you wish to exercise any of your rights to your personal data, please contact us here.

Right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your data and your rights. This is why we’re providing you with the information in this Privacy Policy.
Right to access
You have the right to obtain access to your personal data (if we’re processing it) and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your personal data by data protection law.
Right to rectification
You are entitled to have your personal data corrected if it’s inaccurate or incomplete.
Right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
Right, to restrict processing
You have the right to ‘block’ or suppress further use of your data. When processing is restricted, we can still store your personal data but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to ensure the restriction is respected in the future.
Right to data portability
You can obtain and reuse your personal data across different services. For example, suppose you decide to switch to a new provider. This enables you to move, copy, or transfer your data safely and securely between our IT systems and theirs without affecting its usability.
Right to object to processing
You have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent).
Right to withdraw consent
If you have given your consent for direct marketing, you can withdraw it at any time. The withdrawal does not affect the lawfulness of previous processing, but from the time you withdraw your consent, we will not process any further personal data. As noted above, if you withdraw consent, we may be unable to provide you with all the benefits of the IXXO platform.
Right to lodge a complaint, Right to explanation & human intervention.
You can complain to your national data protection regulator about how we handle or process your data. You also have the right to explain an automated decision, contest it, express your views, and obtain human intervention to make a new decision.

We are required by law to act on requests and provide information free of charge, except where your requests are manifestly unfounded or excessive (in particular because of their repetitive nature). In that case, we may charge a reasonable fee (considering the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month of receiving your request, but we will let you know if the request takes longer to deal with. Please see the Contact Us section to find out how to submit a request.

IX. Information on data transfers outside of the EEA

We mainly process the data you submit within the EEA and its servers. Note, however, that IXXO LTD, as the entity entering into the Agreement with you, is a U.S.-based entity. Therefore, some of your data may be transferred from the EEA and the United Kingdom and processed in the United States.

Information for individuals in the EEA and UK
Because we operate globally, IXXO may transfer your Personal Information from the EEA or the UK to the United States and other countries. This may include Personal Information that we receive from individuals residing in the EEA or the UK who visit our Websites, use our Services, or otherwise interact with us. When we transfer Personal Information, we rely on the Adequacy Decisions of the European Commission (“EC”), based on Article 45 of Regulation (EU) 2016/679 (GDPR) and the UK Secretary of State,
Based on Article 45 of the UK GDPR and Section 17A of the Data Protection Act 2018 or the EC’s Standard Contractual Clauses (“SCCs”) and the UK Information Commissioner’s Office’s International Data Transfer Addendum (“IDTA”), as applicable, supplemented by additional security measures as recommended by the European Data Protection Board. The EC and the UK’s Information Commissioner’s Office (“ICO”) have determined that the SCCs and IDTA may provide sufficient safeguards to protect personal data transferred outside the EEA and the UK. Where we transfer data, we perform transfer impact assessments (“TIAs”) and continually monitor the circumstances surrounding such transfers to ensure that these maintain, in practice, a level of protection equivalent to the one guaranteed by the EEA and UK data protection laws. 

Additional information for individuals from the EEA and Switzerland: EU-US Data Privacy Framework
In addition to utilizing SCCs, as part of our commitment to maintaining high data protection standards when transferring Personal Information between EEA/Switzerland and the United States, we participate in the EU-US Data Privacy Framework (“EU-US DPF”) and the Swiss-US Data Privacy Framework (“Swiss-US DPF”). IXXO complies with the EU-US DPF and the Swiss-US DPF set forth by the US Department of Commerce. We have certified to the US Department of Commerce that it adheres to the EU-US DPF Principles (“EU-US DPF Principles”) about processing personal data from the European Union in reliance on the EU-US DPF. We have certified to the US Department of Commerce that we adhere to the Swiss-US DPF Principles (“Swiss-US DPF Principles”) about processing personal data from Switzerland in reliance on the Swiss-US DPF.  If there is any conflict between the terms in this Privacy Policy and the EU-US DPF Principles or the Swiss-US DPF Principles, the Principles shall govern.  Use hyperlinks to learn more about the Data Privacy Framework (“DPF”) program.

Concerning personal data received or transferred under the Data Privacy Frameworks, IXXO is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Under the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you access to the personal data we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks should direct their query to privacy@ixxo.net. If you request that data be removed, we will respond within a reasonable timeframe. We will provide an individual opt-out choice or opt-in for sensitive data before we share your data with third parties other than our agents or before we use it for a purpose other than which it was initially collected or subsequently authorized. To request to
Limit the use and disclosure of your personal information; please submit a written
Please send your request to privacy@ixxo.net. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement.
Requirements. IXXO’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, IXXO remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles unless IXXO proves that it is not responsible for the event giving rise to the damage. In compliance with the EU-US DPF Principles, we commit to resolving complaints about your privacy and our collection or use of your Personal Information transferred to the United States under the EU/SWISS DPF Principles.  European Union and Swiss individuals with DPF inquiries or complaints should contact IXXO: Data Protection Officer, privacy@ixxo.com. We will investigate and attempt to resolve any complaints or disputes regarding processing Personal Information within 45 days of receiving your privacy complaint. 

IXXO has further committed to refer unresolved privacy complaints under the EU/SWISS DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you are still waiting to receive timely acknowledgement of your complaint, or if your complaint is satisfactorily addressed, please visit the BBB National Programs website for more information and to file a complaint. This service is provided free of charge to you. Suppose your DPF complaint cannot be resolved through the above channels under certain conditions. In that case, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms; see DPF Arbitration Procedures. IXXO is subject to the jurisdiction of the US Federal Trade Commission for DPF enforcement.

X. Automated decision, including profiling.

Except for the cookie-based advertising profiling described below, automated decision-making, including profiling, may take place during your use of our Service, among other things, to provide you with basic rules (“Service onboarding”) and predict your behaviour (i.e., to enable you to take advantage of our benefits and support your use of our Service). These activities aim to help you use our service in the best version, plan, and price. At the same time, our goal is to support your use of our Service in the most suitable model and form for you.

Your personal data, including data obtained based on your activity and how you use our Service, will be processed by us to evaluate and analyze your activity and information about you. We will explore and forecast aspects of your behaviour and preferences as our client, including in an automated manner, to create your profile and present dedicated offers and functionalities (“profiling”).

Certain decisions taken by IXXO at the stage of performance of a contract may be based solely on the automated processing of personal data, including on a set of rules and algorithms used by IXXO to provide you with our Service with all the benefits and improve the Service. These decisions may produce legal effects concerning you or similarly significant effects.

Remember, if you don’t agree with an automated decision that our technology has made regarding you, you can contact us, and we will look into it for you.

You have the right to explain an automated decision, contest it, express your views, and obtain human intervention to make a new decision.

XI. Security of your personal data

We are committed to protecting your privacy. The security of your privacy, including your personal data, is our priority. We take every precaution to ensure that personal data provided by website users is protected from loss, destruction, disclosure, unauthorised access, or misuse.

The security of your personal information is important to us, but remember that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. As such, we make no warranties as to the level of security afforded to your data, except that we will always act under the relevant EU and United States law.

XII. Cookies

General information about cookies:

Like other companies, we use cookies on our website. Cookies are small text files stored on your computer or other device by websites you visit. For general information on cookies, please visit www.allaboutcookies.org and www.youronlinechoices.eu.

We use cookies and other technologies to understand, secure, operate, and provide our Services.

We use cookies and other technologies to:

Provide IXXO for web and desktop and other web-based Services; Improve your experiences, understand how our Services are being used, and customize our Services;
Understand which of our FAQs are most popular and show you relevant content related to our Services;
Remember your choices, such as your language preferences and otherwise, to customize our Services for you;
Understand mobile versus desktop users of our web-based Services or understand the popularity and effectiveness of certain web pages. Assess and analyze users’ activity and information; and
present advertisements, offers, or promotions (discounts) regarding the products or services of IXXO.

Please note that restricting or blocking cookies on our website may affect its functionality or operation and prevent you from using specific services.

Cookies used by us include:

1. Necessary cookies – Necessary to use our website’s features and Services. Necessary cookies help make a website usable by enabling essential functions like page navigation and access to secure website areas. If you block these cookies, we cannot guarantee access to the associated Services or website performance during your visit.
2. Preferences cookies – Functional cookies allow our website to remember your choices, such as customizations you make to website pages during your visit.
3. Statistics cookies – These help us understand how you use our website. For example, they collect information on which pages on our website you select most frequently, which features you use and which sites you have visited previously. We use this information to improve our website and provide a better user experience.
  
  They also allow us to provide related entities and third parties authorised to post links on our website with feedback about users visiting their websites. Such third parties may use this information to improve their websites or services. Analytical cookies are also used to support website layout and functionality testing.
4. Marketing cookies – Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and, thereby, more valuable for publishers and third-party advertisers:
5. Unclassified cookies—We are in the process of classifying unclassified cookies together with the providers of individual cookies.

How to delete cookies?

You can configure your web browser to prevent cookies from being stored on your computer, phone or tablet.

You can delete cookies after we have stored them. To do this, you can use the relevant functions of your browser, programs for this purpose or the tools available within your operating system.

The following links contain information on how to delete cookies in the most popular web browsers:

Firefox:
https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox,
Opera:
https://help.opera.com/en/latest/web-preferences/,
Internet Explorer:https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc
Chrome: https://support.google.com/chrome/answer/95647?hl=en&co=GENIE.Platform%3DAndroid
Safari:
https://support.apple.com/en-us/HT201265

The effect of changing your browser settings on your use of the Website.

Changing the configuration of your web browser to one that prevents or restricts the storage of cookies may result in restrictions on the website’s functionality. Deleting cookies while providing a service may lead to similar consequences. This means that some of our services will not be available without cookies; for example, you cannot use the contact form.

XIII. Information and Notice for California Residents

Information and Notice for California Residents

This section (the “California Notice”) covers our Collection, use, disclosure, and Sale of California consumers’ “Personal Information” (“PI”) as such are defined by the California Consumer Privacy Act and California Privacy Rights Act (together with related amendments and regulations, collectively, the “CCPA”). This California Notice also explains California Consumers’ rights under the CCPA and other notices to Californians required by different laws. The description of our data practices in this Privacy Policy’s Information Collection and Personal Data Details section covers the prior calendar year and will be updated annually. Our current practices may change and will be updated in this Privacy Policy. If our practices materially change, we will provide appropriate pre-collection notices, which may include reference to this Privacy Policy or other applicable privacy policies and notices. We recommend you regularly review this Notice.

Do Not Track

Please also note that, in addition to the information in the sections above, when you use our Application, we and third parties may use tracking technologies to collect usage information based on your device for a variety of purposes, including serving you advertising, based on your having visited our services or your activities across time and third-party locations. Some browsers may enable you to turn a so-called “Do Not Track” signal on or off. Because there is no industry consensus on what these signals should mean and how they should operate, we do not look for or respond to “Do Not Track” signals.

Sensitive Data

IXXO does not collect or process sensitive personal data (SPI). We ask that users of our services refrain from sharing this data with us.

Use of your Personal Data

Subject to restrictions and obligations of the CCPA, our service providers may also use your PI for some or all of the business purposes identified in this Privacy Policy and those disclosures noted in the Information Collection and Information Use sections of this Privacy Policy. Our service providers may engage providers or subcontractors to enable them to perform our services. That subcontracting is, for clarity, an additional business purpose for which we are providing you notice.

We may also collect and use your PI for commercial purposes, such as interest-based advertising, if you have not opted out.

Please note that we process your data to:

Provide services to you, including user support;
Manage requests and complaints received from users;
Maintain and improve our Application, including debugging;
Promote our Application Services to our users and others;
Ensure the quality of our Application and related products and Application Services, including developing new products and services;
Comply with applicable laws and regulations, including obligations to comply with governmental requests, court orders, regulatory guidelines, and similar compliance obligations; or
make or defend legal claims.

CCPA Do Not Sell or Share

We did not “sell” PI in the previous calendar year, and we will not sell your PI collected by us during a period in which we did not offer you the opportunity to opt out of the sale unless we first obtain your affirmative consent.

We may share your data with our third-party analytics providers. If you wish us not to share your PI, please follow the link on our webpage: “DO NOT SELL OR SHARE MY PERSONAL INFORMATION.”
We may disclose your PI for the following purposes, which are not sales: (i) if you direct us to share the PI; (ii) to comply with your requests under the CCPA; (iii) disclosures among the IXXO companies; (iv) as part of a merger or asset sale; and (v) as otherwise required or permitted by applicable laws.

Consistent with the CCPA and our interest in the security of your PI, in response to a CCPA rights request from you, even if we have the following, we will not deliver to you a Social Security number, driver’s license number or other government-issued ID numbers; financial account number; any health or medical identification number; genetic data; race or ethnic data; sex act or sexual orientation data; an account password; security questions or answers in response to your security questions; your precise geolocation; or unique biometric data generated from measurements or technical analysis of human characteristics. However, you may be able to access some of this information yourself through your account if available and if you have an active account with us.

In addition, we do not share your mail, email, or text message content except as outlined in this privacy policy.

Automated Decision Making

IXXO does not use your data to make automated decisions within the scope of the CCPA. If we do, you may opt out by contacting us through one of the contact channels outlined in this Privacy Policy.

CCPA Right-to-Know and Access Categories Request – You have the right to send us a request, no more than twice in a twelve (12) month period, for any of the following for the period that is twelve (12) months before the request date:

The categories of PI we have collected about you.
The categories of sources from which we collected your PI.
For business or commercial purposes, we are collecting your PI.
The categories of third parties to whom we have disclosed your PI.
A list of the categories of PI disclosed for a business purpose in the prior twelve (12) months and, for each, the categories of recipients or that no disclosure occurred.
A list of the categories of PI sold about you in the prior twelve (12) months and, for each, the categories of recipients or that no sale occurred.

CCPA Specific Pieces of PI Request – You have the right to make or obtain a transportable copy, no more than twice in a twelve (12)-month period, of your PI that we have collected in the period that is twelve (12) months before the request date and are maintaining.

CCPA Correction Request – You may request that we correct the PI we have collected directly from you and are maintaining by sending us a CCPA Request for correction through the channels below.

CCPA Deletion Request – You may request that we delete the PI that we have collected directly from you and are maintaining and directing those with whom we have shared your data to do the same. However, we may have a basis for retaining your PI under the CCPA. Our retention rights include (i) to complete transactions and services you have requested or that are reasonably anticipated, (ii) for security purposes, and (iii) for legitimate internal business purposes, including maintaining business records, complying with the law, exercising or defending legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI, which we did not collect directly from you.

Making CCPA Requests

To make a CCPA request, you or an Authorized Agent (as indicated below) may email us here or write us at IXXO LTD, 90 Arch. Makariou III, 7060 Livadia Cyprus (Attn: CCPA Request).
Authorized Agent Request – As permitted by the CCPA, any request submitted to us is subject to an identification and verification process and confirmation of the agent’s authority, which may include attestation under penalty of perjury. Absent a power of attorney, we will also require the consumer to verify his or her identity. We may verify your identity based on matching information you provided with data we have maintained on you in our systems. This data could include email address, mailing address, or phone number.

Third-Party Marketing and Other California Privacy Rights

We allow California residents to opt into sharing “personal information,” as defined by California’s “Shine the Light” law, with third parties other than our affiliates for such third parties’ direct marketing purposes. California residents may prospectively withdraw that consent or request information about our compliance with the Shine the Light law and obtain disclosure of third parties we have shared information with under the law for those companies’ direct marketing purposes and the categories of information shared. To obtain such information, email us here, or write us at 90, Arch. Makariou III, 7060 Livadia, Cyprus (Attn: California Privacy Rights Request). Requests must include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made other than through the provided email address or postal address. As these rights and your CCPA rights are different and exist under various laws, you must exercise your rights under each law separately.
California Minors—As noted above, IXXO is intended for a general audience and is not directed to children under thirteen (13) years of age.

XIV. Nevada Residents

Nevada law allows customers to “opt out” of selling certain personal information, called “covered information.” We do not sell covered information as defined in the law and have no plans to change that practice. If you want to be notified if we change that practice, you may email us here and provide your name, Nevada resident address, and email address. We will contact you if there are any changes, and you can complete your opt-out at that time. If your contact information changes at any point, contact us in the same manner to update your contact information. We may share your data, as explained in this Privacy Policy, for different purposes, such as to make your experience and our Application Services better, and those activities are separate from your opt-out request.

XV. Links to Other Sites

We strongly advise you to review every site’s privacy policy.

Our Service may contain links to other websites operated by unrelated companies and persons (“Third-Party Website(s)”). These links are provided for your information only. Including any link to a third-party website on the service does not mean that we accept any responsibility for that third-party website, its content or use, or the use of any features, products, or services made available through that third-party website.

We have no control over Third-Party Websites or any information or materials. We have not investigated, monitored, or checked any Third-Party Websites for accuracy, completeness, or conformance with applicable laws and regulations. We are not responsible for any damages caused by your use of, or reliance on, Third-Party Websites or any information or materials contained in them. You access and use Third-Party Websites at your own risk.

XVI. Children’s Privacy

Our Service does not address anyone under 13 (“Children”).

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and know that your Children have provided us with Personal Information, please contact us here. If we become aware that we have collected Personal Information from children under age 13 without verification of parental consent, we take steps to remove that information from our servers.

XVII. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Policy on this page. You can see this from the date of the last update, posted at the beginning of the Policy. Changes to this Policy are effective when they are posted on this page.