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X-trodes website privacy policy

This Privacy Policy (“Privacy Policy”) governs the processing and transfer of personal data collected or processed by X-trodes Ltd. (Collectively with its affiliates and subsidiaries shall be referred to as “Company”, “we”, “us” or “our”) when you access or use any of our websites (“website” and “you” or “your”).

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below), as required under applicable privacy regulation, including (where applicable) the EU General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”) and other US states as further detailed below.

If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us at: contact@xtrodes.com

You are not required by law to provide us with any Personal Data. However, please note, that some of our services and website features require the processing of certain Personal Data and without such data we may not be able to provide you with all or part of such services and features.

1. PRIVACY NOTICE

We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Services. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information.

A. POLICY AMENDMENTS: 

We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. Any amendments to the Policy will become effective immediately, unless we notify otherwise. If we materially change the way in which we process your previously collected personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to review this Policy periodically to ensure that you understand our most updated privacy practices.

B. CONTACT INFORMATION AND DATA CONTROLLER INFORMATION:

X-trodes Ltd. is the Data Controller (as such term is defined under the GDPR or equivalent privacy legislation) of your Personal Data of the Personal Data collected from you as a visitor or user of our website. 

You may contact us as follows: 

X-trodes Ltd. 

4 Maskit st, HERZLIYA 4673304

Israel

Representative for data subjects in the EU and UK Contact Information:

C. DATA SETS WE COLLECT AND FOR WHAT PURPOSE:  

You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.  

Non-Personal Data

During your interaction with the Website, we may collect aggregated, non-personal non-identifiable information (“Non-Personal Data “). We are not aware of the identity of the user from which the Non-Personal Data is collected. We collect Non-Personal Data regarding your use of the website, such as the scope, frequency, latency, pages accessed and viewed, time and date stamp, interactions with content and materials displayed through our website, language preference, and other technical information regarding the device used to access the website, for example type of device, type of browser, operating system, etc. Non-Personal Data may be used by us without limitation and for any purpose.

We may sometimes process and anonymize or aggregate Personal Data and identifiable information in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified natural person. 

If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.  

Personal Data

We may also collect from you, directly or indirectly, during your access or interaction with the website, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data”). The types of Personal Data that we collect as well as the purpose for processing and the lawfulness are specified in the table below. 

On our website, we do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”). 

The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations: 

Contact Information:

DATA SET
If you voluntarily contact us, e.g., through a “contact us” or “order now” form in our website, you may be required to provide us with certain information such as your name, job title, company name, email address (“Contact Information”) and any additional information you decide to share with us.

PURPOSE AND OPERATIONS

We will use this data to respond to your inquiry.

The correspondence with you may be processed and stored by us in order to improve our internal operations, as well as in the event we reasonably determine it is needed for future assistance or to handle any dispute you might have with us.

LAWFUL BASIS

We process such Contact Information subject to our legitimate interest.

Newsletter & Updates Registration:

DATA SET
In the event you sign up to receive our newsletter or other promotional materials, you will be requested to provide your contact details, such as email address. 

PURPOSE AND OPERATIONS

We will use the information you provide in order to include you in our mailing list and send you the materials you have signed up to receive. 

LAWFUL BASIS

Our lawful basis for the processing of this data is your consent. 

You may withdraw your consent at any time by clicking the “unsubscribe” link which will be included in the email we will send you. You may also contact us through the above means of contact and request to unsubscribe. 

Online Identifiers and Advertising and Targeting data:

DATA SET
When you interact with the website, we may collect online identifiers such as your Internet Protocol address (IP), Cookie-ID, etc., and other information that relates to your activity through the website, such as pages viewed, click stream data, login time and date stamp, etc. This data might be collected directly by us or by through our use of third parties’ cookies and advertisement platforms.

Similarly, we may collect Ad calls, which is a code shared with advertisers, include zip code, advertiser ID, the webpage the end user came from, the IP address, approximate location which assists the advertiser to determine which ads to place. The ad call will also include the end user’s preference regarding interest-based advertisement as further explained herein. 

PURPOSE AND OPERATIONS

Collection of device identifiers is needed for the following purposes: 

(i) Internal statistics and analysis, for which device identifiers might be combined with usage data, for example, to analyze how many visitors have accessed certain content and from which country (where the country is extracted from the IP address) in order to enhance and improve our website and its content; 

(iii) Marketing and advertising purposes. Our partners will process this data to manage and deliver advertisements and content more effectively and personally, including contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners and advertisers, including for re-targeting purposes.

LAWFUL BASIS

Our lawful basis for the processing this data for technical and security purposes is based on our legitimate interests. 

Where required under applicable laws, we will obtain your consent for the purpose of data collection through our use of third-party cookies for analytics and advertising purposes.  In any such case, you may withdraw consent or change your preferences at any time by using the cookie settings tool available on our website.

For more information about Interest Based Advertisement practices please read below.

Customer Portal access:

DATA SET
as part of the website, we have a dedicated area for our customers to allow them to read and access certain technical and engagement-related materials (“Customer Portal”). For accessing the Customer area, you will be required to use your credentials, i.e., username and password. As part of such Customer Portal data, we will keep your name, email and contact information. 

PURPOSE AND OPERATIONS

We use such data to provide you, as representative our customer, with access to information regarding our services and your company engagement with us. 

LAWFUL BASIS

We process such access and account data to execute the contract between us. 

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of personal data to third-party countries, as further detailed in the Data Transfer Section, is based on the same lawful basis as stipulated in the table above. 

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the website and to enforce the Terms, as well as to protect the security or integrity of our databases and the website, and to take precautions against legal liability. Such processing is based on our legitimate interests. 

D. HOW WE COLLECT YOUR INFORMATION: 

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows: 

  • Automatically – we may use cookies (as elaborated in the section below) or similar tracking technologies (such as pixels, tags, agent, etc.) to gather some information automatically.
  • Provided by you or about you voluntarily – we will collect information if and when you choose to provide us with the information, such as through online registration, contact us form, etc. all as detailed in this Privacy Policy.
  • Provided from third-parties – where permitted under applicable law and provided with your consent for cookie usage, we may enrich the Personal Data collected about you with data provided by third parties. 

E. COOKIES

When you access or use the website, we use “cookies” or similar tracking technologies, which store certain information on your device (i.e., locally stored). The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies are used by us for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and advertising. You can find more information about our use of cookies here: www.allaboutcookies.org. 

There are several types of cookies, including:

  • Essential, Functionality, Operation & Security Cookies. These cookies are essential for enabling Visitor movement around the website, for the website to function properly, and for security purposes (i.e., used to authenticate Visitors, prevent fraudulent use, and protect Visitor data from unauthorized parties). This category of cookies either cannot be disabled, or if disabled, certain features of the website may not work.
  • Analytic, Measurement & Performance Cookies. These cookies are used to collect information about how Visitors use our website, in order to improve our website, content, and the way we offer them, as well as assess performance of the content and marketing campaigns. These cookies enable us, for example, to assess the number of Visitors who have viewed a certain page as well as their country of origin. It enables our website to remember information that changes the way it behaves or looks, such as your preferred language.
  • Preference, Targeting & Advertising Cookies. These cookies are used to advertise across the internet and to display relevant ads tailored to Visitors based on the parts of the website they have visited (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage).

You may find more information about the cookies we use as well as opt-out of cookies or change your preferences ant any time by using the cookies setting tool available on our website.  

Where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies and we are not responsible for their privacy practices.

F. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:

We share your data with third parties, including our partners or service providers that help us operate and make the most of the website. You can find here information about the categories of such third-party recipients. 

Categories of Recipients

Our Affiliated Companies 

Additional Information

We may share Personal Data with our affiliated companies and subsidiaries in order to provide joint services, for example, marketing, improving our services, etc.  

Categories of Recipients

Our Service Providers

Additional Information

We share your Personal Data with our trusted service providers and business partners that perform business operations for us on our behalf (as data processors) and pursuant to our instructions.

This includes the following categories of service providers:

  • Advertising and marketing service providers, who help us with advertising measurements, email marketing, etc.; 
  • Data storage providers, with whom we entrust the hosting and storage of our data;
  • Consent Manager (CMP), an external service that provides us with the ability to allow website visitors to control and manage their cookies preferences and consent;
  • General IT and SaaS providers – providing us with IT systems for the management of our daily conduct;
  • Data analytics and data management providers, who help us improve, personalize and enhance our operation.
  • Data security partners, who help us detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches and ensure compliance with legal obligations.

Categories of Recipients

Media Buyers

Additional Information

In some cases when we buy media online, we may submit unique identifier. This unique identifier provided to the media owner, may become personally identifiable when and if such media owner combines our parameters with its own existed information about you, to which you gave your consent when first interacting with such media owner’s services (for example social media Services).

Categories of Recipients

Legal and Law Enforcement 

Additional Information

We may disclose certain Personal Data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other Visitor to legal liability, and solely to the extent necessary to comply with such purpose.

Categories of Recipients

Corporate Transactions 

Additional Information

In the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation, or asset sale) we will share the Personal Data we store with our acquiring company. 

We will obligate the acquiring company to assume the rights and obligations as described in our Privacy Policy. 

When we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary for us to operate the website. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

G. DATA RETENTION: 

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable. 

Other circumstances in which we will retain your Personal Information for longer periods of time include: (i) where we are required to do so in accordance with legal requirements, or (ii) for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any

particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.

H. SECURITY MEASURES: 

We take great care in implementing physical, technical, and administrative security measures for the website that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost. 

If you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data, please contact us at our email. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) if we discover a security incident related to your Personal Data.

I. INTERNATIONAL DATA TRANSFER: 

Due to our global business operation, we may store or process your Personal Data in several territories, including, for example in Israel, the UK, EU, US or in other countries (whether directly or through the use of our vendors). Thus, your Personal Data may be transferred to and processed in countries other than the country from which you accessed our websites or otherwise the country of your jurisdiction. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer in accordance with applicable law. 

Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred under the provisions of the standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact us at our email.

In addition, some of the third parties used for cookies management in our website, may store and process data globally, including in the US (e.g., Google Analytics servers). When granting consent for such cookies through the cookies tool on the website, you hereby acknowledge and approve such cross-border transfer, in accordance with such third party’s privacy practices.  

J. YOUR RIGHTS

According to data protection and privacy laws may grant you with certain rights with regards to your Personal Data, all according to your jurisdiction. The rights may include one or all of the following: (i) request to amend your Personal Data we store accessing; (ii) review and access your Personal Data that we hold; (iii) request to delete your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) restrict or object to the process your Personal Data; (v) exercise your right of data portability (vi) contact to a supervisory authority in your jurisdiction and file a complaint; and (vii) withdraw consent (to the extent applicable). 

If you wish to submit a request to exercise your rights, please fill out the Data Subject Request Form (“DSR”) available here and send it to our email at: contact@xtrodes.com

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply. 

You have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with the way in which we handled the complaint. 

For additional rights under various jurisdictions, including US state laws, please refer to Section ‎II “JURISDICTION-SPECIFIC NOTICES” herein below. 

K. OPT OUT OPTIONS 

Interest-Based Advertising (“IBA“): We do not sell your Personal Data. Our websites may include providing you with advertisements therefor we may “share” your Personal Data with third parties for personalized advertising purposes. If you wish to opt-out from the sharing of your personal data with third parties for the purpose of cross-contextual interest-based advertising there are many ways to do so, as further detailed below. Please note that even if you opt-out you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them.

For IBA opt out options on desktop and mobile websites, please visit: 

Additional information on opt-out rights and means are available through the designated cookie bar in our website.  

L‍. THIRD PARTY WEBSITES:

Our Privacy Policy only addresses the use and disclosure of Personal Data we collect from you. To the extent that you disclose your Personal Data to other parties via the website (e.g., by clicking on a link to any other website or location), different rules may apply to their use or disclosure of the Personal Data you disclose to them, and this Privacy Policy does not apply to any such third-party products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

M. ELIGIBILITY AND CHILDREN PRIVACY:

The website is not intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly process children’s information. We will discard any information we receive from a user that is considered a “child” immediately upon discovering that such a user shared information with us. Please contact us at: contact@xtrodes.com if you have reason to believe that a child has shared any information with us. 

2. JURISDICTION-SPECIFIC NOTICES

 A. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the CPRA, effective January 1, 2023. 

Please see the CCPA Privacy Notice which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sole or shared, the retention period, and how to exercise your rights as a California resident.

B. ADDITIONAL NOTICE TO SPECIFIC US STATES RESIDENTS

This section applies to residents of specific US States under applicable specific state laws, including residents of Virginia, Connecticut, Colorado, Utah, Texas, Oregon, Montana (effective of October 1, 2024), and effective of January 1, 2025 – Nebraska, New Hampshire, New Jersey, Delaware, and Iowa, as amended or superseded from time to time and including any implementing regulations and amendments thereto (collectively, “US Privacy Laws”). Any term not defined herein under this section shall have the meaning ascribed to such term in the Privacy Policy above or applicable US Privacy Laws.

The specific disclosures hereunder supplement our general Privacy Policy as detailed above and provides additional details to the extent we are deemed as a “Business” or “Controller” under applicable US Privacy Laws – for example where we process your Personal Information regarding your use of the website.

The Personal Information We Process

Section ‎‎ C of the Privacy Policy “DATA SETS WE COLLECT AND FOR WHAT PURPOSE”, describes the categories of Personal Data that are collected and processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for a materially different, unrelated, or incompatible purpose without obtaining your consent. As further set forth there, collected Personal Data may include, depending on your interaction with us:

  • Contact Communications Information – including your identifiers and contact information (name, email, phone, etc.), the content of your inquiry, and additional information as provided voluntarily by you, such as your workplace and position, country of residence, etc. – collected and processed to respond to your inquiry and to keep a record of our interaction with you.
  • Customer Portal Access – to grant our customers access to a dedicated area containing certain technical and engagement-related materials (“Customer Portal”). For accessing the Customer Portal, you will be required to use your credentials, i.e., username and password. As part of such Customer Portal data, we will keep your name, email and contact information and your interaction and use of the Customer Portal.
  • Newsletter Registration and Promotional Communications – such as your email, phone number, and your interaction with the messages and content we will send you – collected and processed for sending you news, promotional material and updates regarding our services per your consent and subject to applicable law, and to offer you to participate in certain events. Further, we will use such information, subject to applicable law, for our marketing and promotional communications, including by email or SMS.
  • Recruitment Data – CV, resume, name, email, phone number, professional experience and other related information as further detailed above – to process your job application and candidacy.
  • Online Identifiers and Advertising and Targeting data – your IP address, location and time zone setting, operating system and platform, browser plug-in types, domain name and your choice of browser, approximate location (derives from IP address), etc. – processed as part of our technical website management and operation, analytics and online marketing activity.

 

“Sensitive Data” under US Privacy Laws is generally defined as data revealing racial or ethnic origin, religious beliefs, mental or physical health history, condition or diagnosis, sex life or sexual orientation, citizenship or immigration status, genetic or biometric data that can be processed/is processed to uniquely identify an individual, precise geolocation or personal data from a known child. As a “Business” or “Controller” (i.e. the legal owner of personal data), we do not collect or process or use any of your Sensitive Data. However, note that our customers may use our products and services for such processing under their capacity as the Controllers or legal owners of such data, under and per there separate and independent privacy policies and practices.

Further, under US Privacy Laws, Personal Data does not include publicly available information and information that cannot be reasonably linked to you, directly or indirectly, such as de-identified or aggregated data, and information governed by other state or federal laws, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA), Personal Data covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), etc.

Disclosures of your Personal Data to Third Parties, and Sale or Share of Personal Data

Under Section ‎F “DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH” of the Privacy Policy, you will find details regarding the categories of third parties we share Personal Data with for business purposes.

We do not sell your personal information for profit. However, we do engage in targeted advertising on the website. Some of those marketing activities, when conducted through the use of third parties, may be considered a “Sale” or “Share” under certain US Privacy Laws. In this context, as is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third-party businesses to collect information directly from your browser or device through cookies or similar tracking technology when you visit or interact with the website, for example, for collection of Online Identifiers and Advertising and Targeting data as detailed above. These third parties use this personal information to deliver targeted advertising (also known as “cross-context behavioral advertising”) and personalized content to you on our website, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. To learn more about this please read section E of the Privacy Policy regarding Cookies. Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal information or the processing of personal information for purposes of targeted advertising through the use of the Cookie Toolbar on the Website’s footer or as described above in Section K of the Privacy Policy.

We do not knowingly sell or share personal information of individuals younger than 16 years of age. Similarly, as a “Business” or “Controller”, we do not collect or process, therefore not Sell or Share, any Sensitive Data.

Exercising Your Privacy Rights

Subject to certain legal limitations and exceptions, you may be able to exercise some or all of the rights detailed in Section J of the Privacy Policy, “Your Rights”, by filing the Data Subject Request Form (“DSR”) available HERE or send it to: contact@xtrodes.com. Under US Privacy Laws, the following rights may apply to you:

Right to Access/ Right to Know

You have the right to confirm whether and know the Personal Data we collected on you 

You can exercise your right by reviewing this Privacy Policy. If you want to get access to your Personal Data, please fill in this form

Right to Correction

You have the right to correct inaccuracies in your Personal Data, taking into account the nature and purposes of processing of such Personal Data.

You can exercise this right directly through your account or by filling in this form

Right to Deletion

You have the right to delete the Personal Data, this right is not absolute and in certain circumstances we may deny such request. We may deny your deletion request, in full or in part, if retaining the information is necessary for us or our service provider(s) for any of the following reasons: (1) Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you; (2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3)  Debug products to identify and repair errors that impair existing intended functionality; (4) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (5)  Comply with the law or legal obligation; (6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our processors to take similar action.

If you would like to delete your Personal Data please fill in this form

You do not need to create an account with us to submit a request to know or delete.

Right to Portability 

You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

If you would like to exercise your portability right please fill in this form, and we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

Right to opt out from selling Personal Data 

You have the right to opt out of the sale of your Personal Data for the purposes of targeted advertising, sale to a third party for monetary gain, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or any other consumer. 

You may authorize another person acting on your behalf to opt out, including by broad technical tools, such as DAA, NAI, etc. 

We do not sell your personal information, so we do not offer an opt out. 

We may “share” personal information with third parties for personalized advertising purposes. You may opt-out of the sharing of your Personal Data with third parties for personalized advertising on third party sites as detailed in Section ‎I.K OPT OUT OPTIONS.  

To opt out from the use of cookies on our website, please click the “do not sell or share my personal information” or otherwise use the settings of our cookies bar in the footer of the website which will enable you to customize the use of cookies on our website.  

Right to opt out from Profiling 

You have the right to opt out of the sale of your Personal Data for the purposes of targeted advertising, sale to a third party for monetary gain, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or any other consumer. 

You may authorize another person acting on your behalf to opt out, including by broad technical tools, such as DAA, NAI, etc. 

We do not profile you, thus we do not need to provide an opt-out. 

Right to Appeal 

If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal.

If we deny the appeal, you may contact the Colorado Attorney General using this link: https://coag.gov/office-sections/consumer-protection/  or (720) 508-6000.

Not more than 60 days after receipt of an appeal we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decisions. 

Duty not to violet the existing laws against discrimination or non-discrimination 

Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices.

We do not discriminate our users.

We reserve the right to ask for reasonable evidence to verify your identity before providing you with any such information per applicable law, including requesting a photo ID or other similar documentation and records. We will always maintain the privacy and security of such evidence.

Further, and as explained in Section J of the Privacy Policy, certain rights can be easily executed independently by you without the need to contact us, for example: (i) You can opt-out from receiving our marketing emails by clicking the “unsubscribe” link; and (ii) You can use the cookie settings tool on our Website to change your preferences.

Authorized Agents

In certain circumstances, and subject to applicable US Privacy Laws, you may permit an authorized agent to submit requests on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf or provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney. For security purposes, we may need to verify your identity and confirm directly with you that you have provided the authorized agent with permission to submit the request, and it may take additional time to fulfill agent-submitted requests. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf. Please note that for privacy and security reasons, we will direct future communications to the individual on whose behalf the request was made.

Appeal Rights

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request, by contacting us as instructed in our response. Please send your appeal request with a summary of the request and decision you want to appeal to contact@xtrodes.com.

Not more than 60 days after receipt of an appeal, and always in accordance with the timelines set by the applicable US Privacy Laws, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decision.

If you are not happy with our response, depending on your jurisdiction, you may have the right to lodge a complaint against us with the relevant State’s Attorney General:

Last updated: June 25, 2024