Privacy Policy

Last updated on July 5, 2024 / Effective from 2024

Objective: About Your Privacy

We Only Grasp What's Essential

In the course of utilizing our service, we might request that you furnish us with specific pieces of information that enable us to contact or recognize you.

We Aren't Privy to Your Online Activities

Your browsing and chatting habits are your own. XXAI operates without intruding into your personal activities online. We collect no information on the sites you visit or the content you engage with. Our focus is solely on improving your experience without compromising your privacy.

We Don't Capitalize on Your Confidence

We are staunch advocates for gaining and preserving your trust, not commercializing it. Your personal information is not a marketable asset in our view. Consequently, we are not in the business of vending any details to external entities. Our commercial approach is anchored in delivering a premium service rather than exploiting user information for financial gain.

Privacy Policy

At XXAI, we are dedicated to protecting our customers' privacy. This Privacy Policy outlines how we handle your personal and usage data, ensuring it is collected, utilized, shared, stored, safeguarded, or disclosed with care through our service, including our website (https://www.hixx.ai).

This policy governs the computer app and website we've developed relating to the services we provide from time to time. By engaging with our services, you consent to the terms of this Privacy Policy. Should you not agree with these terms, please refrain from using our app or website.

PLEASE NOTE: IF YOU CONTINUE USING OR ACCESSING OUR SERVICES, YOU WILL BE DEEMED TO HAVE FULLY UNDERSTOOD AND ACCEPTED AND ARE WILLING TO COMPLY WITH ALL THE FOLLOWING CLAUSES. THESE TERMS SHALL BECOME EFFECTIVE BETWEEN YOU AND US. IF YOU DISAGREE WITH THESE TERMS IN WHOLE OR PART, YOU SHALL IMMEDIATELY STOP USING OUR SERVICES.

Our services are currently available to users in North America, the EEA, and the United Kingdom. If you are not a user in these regions, you may not receive adequate protection from this Privacy Policy, so please be aware of the privacy laws and regulations in your region. We will not discriminate against any user in regions where we are not yet able to provide services.

We advise you to review this policy thoroughly before conducting any transactions on our platform.

Information We Collect

We gather data about you for several primary objectives:

To handle your registration and account management, ensuring your seamless access and utilization of our services
To engage in general communication with you, including updates about our operations
To showcase your reviews, forum contributions, and other submissions
To address your inquiries and feedback
To preempt any activities that may be illicit or against regulations
To uphold our Terms of Use

We may process your personal data for the purposes specified in this Privacy Policy. The personal data of users collected and used by us, in particular, includes:

Order information if you make a purchase through in-app purchase
Identifier for advertisers designated in your mobile device used in accessing our services (The Identifier for Advertisers-IDFA)
Identifier for vendors/developers designated in your mobile device (The Identifier for Vendors-IDVF)
Internet Protocol Address (IP Address)

Data Categories and Data Types

Process Security

Internet traffic data (network movements, IP address, visit data, time and date information)
Device name
In-app purchase history
Token ID (when you allow notifications through your device)
Identifier for advertisers designated in your mobile device used in accessing our services (if you give permission, the Identifier for Advertisers-IDFA)
Identifier for vendors/developers designated in your mobile device (The Identifier for Vendors-IDVF)

Customer

Order information

Transaction

Marketing Data

IDFA
IDVF

We may collect your data directly from you through electronic or physical mediums, our Official Website, third-party applications, or third-party sources, such as Safari or Google, for the purposes of compliance with legal obligations, enhancing our services, administering your use of our services, and enabling you to enjoy and easily navigate our services.

We may collect your log data generated while you are using our services/applications (through our products or third-party products). This log data may include information such as your device’s Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our service/application, the time/date of your use of the service/application, and other statistics.

Personal Data

In the course of utilizing our Service, we might request that you furnish us with specific pieces of personally identifiable information which are essential for communication purposes or to uniquely identify you. Such information may encompass but is not confined to:

Email address
Given name and surname

General Principles Regarding Personal Data Processing

In accordance with this Privacy Policy, personal data are processed by us as a data controller in line with the basic principles named here:

Being in accordance with law and good faith
Being accurate and where necessary up-to-date
Being processed for specific, explicit, and legitimate purposes
Being limited for the purpose for which they are processed and data minimization
Being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed

Purposes of Processing Personal Data and Legal Reasons

We will use the personal data we collect about you in accordance with the laws. The establishment of a contract or direct relation to the execution or performance of the contract and for the legitimate interests of us provided that your fundamental rights and freedoms are protected.

Since our servers are located in the United States, information collected in other countries/regions is usually transmitted to the United States for processing. We participate in the EU-US Privacy Shield frameworks II and Swiss-US Privacy Shield frameworks ("Frameworks") regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom, and Switzerland.

In the event of any conflict between this Privacy Policy and the Frameworks, the terms of the Frameworks shall govern.

Purposes of Processing Personal Data

In accordance with this text, your personal data is processed for the following purposes in accordance with the above general conditions:

Process Security

Execution of activities in compliance with legislation
Execution of company/product/service commitment operations
Execution of communication activities
Execution/auditing of business activities
Conducting after-sales support services for goods/services
Execution of goods/services sales processes
Conducting storage and archive activities
Execution of agreement processes
Execution of information security processes
Conducting audit/ethical activities
Execution/audit of business activities
Conducting activities to ensure business continuity
Providing information to authorized persons, institutions, and organizations

Customer Transaction

Execution/auditing of business activities
Conducting after-sales support services for goods/services
Execution of goods/services sales processes
Conducting activities for customer satisfaction
Execution of agreement processes

Marketing Data

Conducting marketing analysis studies
Execution of advertising/campaign/promotion processes

Purposes of Personal Data Processing

We may update the purposes of processing personal data in accordance with our company policies and legal obligations including but not limited to:

User Account Creation: Establishing accounts for recipients of our service or application users.
Service Customization: Tailoring our services to understand user preferences, enhancing user experience and enjoyment.
Communication: Informing users about new products, services, applications, and providing information on advertisements and promotions.
Subscription Management: Handling digital subscriptions and in-app purchase processes for our services.
Auto-Renewable Subscriptions: Facilitating access to content services or premium features through auto-renewable subscription models.
Information Security: Executing processes to ensure the security of user information.
Compliance with Legislation: Undertaking activities as required by law.
Regulatory Requirements: Meeting the demands of competent authorities when necessary.
Financial Transactions: Managing financial and accounting processes.
Communication Activities: Engaging in communication efforts with users and stakeholders.
Contract Administration: Overseeing the processes related to contracts.
Strategic Planning: Performing activities that contribute to our strategic planning.
Request and Complaint Handling: Following up on user requests and addressing complaints.

Children's Privacy

The services are restricted to users who are over the age of 18 or the equivalent age as specified by law in your jurisdiction (In certain cases, this age may be higher due to local regulatory requirements. Please see your local privacy policy for more information). We do not knowingly collect any information about or market to children, minors, or anyone under the age of 18 or the equivalent age as specified by law in your jurisdiction. If you are less than 18 years old or the equivalent age as specified by law in your jurisdiction, we request that you do not submit information to us. If we become aware that a child, minor, or anyone under the age of 18 or the equivalent age as specified by law in your jurisdiction has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

Your personal data, which you provided/will provide to our Company and/or obtained by our Company by any external means, may be processed by our Company as “Data Controller”;

In the context of the objective of processing your personal data and in connection with this purpose in a limited and measured manner
By maintaining the accuracy and up-to-date version of the personal data as reported or notified to our Company
May be recorded, stored, preserved, reorganized, and be transferred to the institutions authorized to request such personal data by law and shall be transferred, classified, and shared with third parties within the country or abroad under the conditions stipulated by legislation and upon your explicit consent if necessary, and they may be processed by other means listed under the legislation and be subject to other procedures set forth in the legislation.

This Privacy Policy describes which data we collect, how we intend to use, store, protect, and share the data we collect, how you can withdraw your consent for the processing of these data, and how you can correct and revise the data.

Capitalized terms in this Policy shall have the meanings specified in the Terms and Conditions unless defined separately in this Policy.

GDPR Privacy

Legal Basis for Handling Personal Data under GDPR

We handle Personal Data under several legitimate conditions:

Consent: You've granted permission for specific purposes regarding the processing of Personal Data.
Contract Performance: Sharing Personal Data is essential for fulfilling an agreement with You and/or addressing pre-contractual steps.
Legal Compliance: We process Personal Data to adhere to legal obligations binding on the Company.
Vital Interests: Processing is necessary to safeguard Your or another individual's critical interests.
Public Interest or Official Authority: Processing is related to a task performed for the public good or exercising official authority granted to the Company.
Legitimate Interests: Processing is required for pursuing the Company's legitimate interests.

The Wenpeach LLC (Company) is ready to clarify the particular legal basis for processing and to determine if providing Personal Data is mandatory for legal or contractual reasons or to form an agreement.

Your GDPR Rights

The Company is committed to protecting Your Personal Data privacy and ensuring Your rights are honored:

Access Rights: You have the right to view, update, or delete the information We hold accessible within Your account settings when possible. Contact Us for assistance if needed and to obtain a copy of Your Personal Data.
Rectification Rights: You may correct any incomplete or inaccurate information We have about You.
Objection Rights: You can object to our processing based on legitimate interests, especially relating to Your unique situation or if used for direct marketing.
Erasure Rights: You may request the deletion of Personal Data when continued processing is unjustified.
Data Portability: We will provide Your Personal Data in a structured, common, machine-readable format applicable to automated data based on consent or contract performance.
Consent Withdrawal: You can retract consent which may affect access to specific Service features.

CCPA Privacy

This CCPA privacy notice supplements our main Privacy Policy, applying solely to California residents.

Sources of Personal Information

We gather personal information from various sources:

Directly from you via forms on our Service or your expressed preferences.
Indirectly from your activity observed on our Service.
Automatically through cookies and similar technologies on your device.
From third-party service providers who assist with monitoring, analytics, advertising, payment processing, and other services.

Business and Commercial Use of Personal Information

We may use or disclose personal information for business or commercial purposes including but not limited to:

Operating our Service and fulfilling our service provision to you.
Providing support, responding to inquiries, and improving our Service.
Fulfilling the reason you provided the information, such as processing payments and facilitating deliveries.
Complying with legal obligations, including law enforcement requests.
For internal administrative purposes as described at the time of collection or as required by CCPA.
Detecting and preventing security incidents and illegal activities.

Minors' Personal Information

If you suspect a child under 13 (or 16) has shared personal information with us, contact us to ensure it is removed.

Your CCPA Rights

As a California resident, you have specific rights regarding your personal information:

Right to Notice: You have the right to be informed about the categories of Personal Data collected and their usage purposes.
Right to Request: You can request disclosure of our collection, use, sale, and sharing of personal information. Upon confirmation of your request, we will disclose:
The categories of personal information collected.
The sources of this information.
Our business or commercial purpose for collecting or selling the information.
Third parties with whom we share this information.
Specific pieces of personal information collected.
If we sold or disclosed your information for business purposes, we will reveal the categories of information sold or disclosed.
Right to Opt-Out of Sale: You can direct us not to sell your personal information.
Right to Delete: You can request the deletion of your personal information subject to exceptions. We may deny your deletion request if retaining the information is necessary for:
Completing transactions, providing goods or services, or fulfilling our contract.
Detecting security incidents and preventing illegal activities.
Debugging products to repair errors.
Complying with legal obligations or exercising rights provided by law.
Internal uses aligned with consumer expectations.
Right Against Discrimination: You have the right not to face discrimination for exercising your CCPA rights, including in the provision of goods, services, or pricing.

Exercising Your CCPA Data Protection Rights

To exercise your CCPA rights as a California resident, contact us by email.

We periodically revise Our Privacy Policy to ensure it remains current and comprehensive. You will be informed of any updates by the publication of the revised Privacy Policy on this webpage. We will provide you with advance notice via email and/or a noticeable announcement on Our Service before the changes take effect, and we will update the "Last updated" date at the beginning of this Privacy Policy. We recommend that you periodically review this Privacy Policy to stay informed of any modifications. Once changes are posted on this page, they are considered effective.

Third Party Websites and Applications

XXAI may contain links to other websites that are unknown to us and whose content is not controlled by us. These linked websites may contain terms and conditions different from ours. We cannot be held responsible for the use or disclosure of information that these websites may process. Likewise, we shall not have any responsibility for any links from other sites provided to XXAI owned by us.

We collect information by fair and lawful means with your knowledge and consent. We also let you know why we’re collecting it and how it will be used. You are free to refuse our request for this information with the understanding that we may be unable to provide you with some of your desired services without it.

Cookies

Cookies are small text files that are saved on your computer or mobile device when you visit our web page or application. They help our site run more efficiently and tailor the content to better fit your personal preferences and needs. Cookies only retain information about your visit history and do not collect personal data or files from your device. We utilize cookies to operate our services, enhance performance, and deliver relevant content and advertisements. You can manage or delete cookies through your browser settings.

Accessibility

By accepting our privacy policy, you grant permission to use the Accessibility function for the PC AI Copilot feature. Without this permission, access to the AI Copilot feature will not be possible.

Push Notifications

We may occasionally send you push notifications via its mobile applications regarding application upgrades or notifications about our services. You can always edit such communication and notifications through the settings on your device and stop receiving such communications and notifications.

How and Where We Store Your Personal Information

Your data will be stored for the duration specified in the applicable legislation or for a reasonable time until the purpose of processing ceases to exist or during legal periods of limitation. The personal information we collect from you may be stored on a server located in the USA (“storage area”) outside of the country where you live.

If your location is not within the above range, your data may be transferred to our storage area through cross-border transmission. You need to be aware and agree that this cross-border transmission is allowed in accordance with the corresponding laws or policies of your region, and your consent has been obtained. For example, if you are a user of an EU member state, you understand and are aware that this XXAI will store your data in the United States. We will provide you with services based on the EU-US Privacy Shield 2.0.

In cases that you allow XXAI to store your personal data for additional time by giving your consent, such data shall be immediately deleted, destructed, or anonymized upon the expiry of such additional time or once the purpose of processing no longer exists.

Technical and Administrative Measures

We retain personal data in compliance with relevant legislation and take necessary precautions to ensure its confidentiality, integrity, and security. Measures include:

Installing updated anti-virus software on all IT infrastructure.
Protecting data centers with software-loaded firewalls and SSL-VPN access control.
Limiting employee system access based on job requirements.
Using an "Information Security Threat and Event Management" system for immediate threat response.
Encrypting sensitive data and securely storing cryptographic keys.
Maintaining secure logs of all sensitive data transactions.
Conducting regular penetration tests and addressing security gaps.
Auditing information security measures monthly at ISMS meetings.
Providing regular training to employees to enhance information security awareness.
Ensuring physical data security and entering into non-disclosure agreements with relevant personnel.
Using encrypted email for transferring sensitive data.
Notifying users immediately in case of data breaches and taking necessary action.

We may also share your personal data with our service providers such as Microsoft, Google, and Stripe.

Changes To This Privacy Policy

We reserve the right to update or modify this Policy from time to time to reflect the changes in our business, technology, and applicable law and practice. In case of any modification of this Policy, we will notify you of the latest Policy here or by posting it on our official website or sending you separate notifications. Please pay attention to this website and the notifications we send to you for the latest updates of this Privacy Policy. Although this Privacy Policy may be modified, your rights under this Policy will not be diminished without your explicit consent.

We will ask for your explicit consent again in accordance with applicable laws before we collect additional personal information from you or when we use or disclose your personal information for new purposes. Your continued use of the Service on the website, mobile, and/or any other device constitutes your agreement to the updated Privacy Policy.

Contact Us

For any inquiries or clarifications regarding this Privacy Policy, please reach out to us at our support channel:

By email: Wendy@hixx.ai