Updated July 16, 2018
Information You Provide to Us – Personal Data
We are required by law and regulatory bodies to ask for certain information in order to provide our Services to you. When you use our Site’s “Contact” link, register for an account for Services or download certain content, we collect and store certain personal information from you that may include, without limitation your name, password, age, email address, postal mailing address, telephone number(s), bank information, Social Security number and/or taxpayer identification number, investment objectives and experience, assets and income, and other similar information, or other personally identifying information related to our providing Services to you (“Personal Information”).
Use of Personal Information
We use the Personal Information we receive about you to provide you with the Site and Services, such as:
- authenticating your identity to help protect you and Xebec from fraud,
- responding to your requests for certain information,
- customizing the features that we make available to you,
- improving the Site, Services and internal operations (including troubleshooting, testing, and analyzing usage and trends and preference of our Users), and
- complying with certain legal and regulatory requirements.
In addition, we may use such information to periodically provide you with information, press releases, monthly newsletters, or investment opportunities available through our Services that may be of interest to you. However, you will have the option to opt out of receiving such information per the “Opting-Out of Xebec Promotional Communications” section below.
What Device and Usage Data We Process
In connection with our Site, we, and our third-party service providers, use common information-gathering tools, such as log files, cookies, web beacons and similar technologies to automatically collect information, which may contain Personal Information, from your computer as you navigate our Site or interact with emails we send you.
- Log Files- As is true of many websites, we automatically gather certain types of information whenever you visit the Site via log files. This collected information may include, among other things, Internet Protocol (IP) addresses, device and application identification numbers, your location, your browser, your Internet service providers, your searches on the Site, pages viewed and Services used, clickstream data and date/time stamps associated with your usage. This information is used to help us provide and improve our Site, improve its security and continued proper functioning and analyze overall trends. We also collect IP addresses from users when they log into the Services as part of Xebec’s security features. None of this information personally identifies you and it does not constitute personal information.
- De-identification- Xebec, or its service providers, may aggregate and de-identify databases containing Personal Information to derive non-personally identifiable data sets, and Xebec or its systems may automatically collect technical, non-personal information from you or your devices used to access the Sites or Services (including without limitation information about the user’s device, operative system, browser, page views, or clicks). Any non-personal data derived or collected by Xebec may be used by Xebec or disclosed to non-agent third parties by Xebec for any purpose whatsoever.
Opting-Out from the Collection of Device and Usage Data
Sharing of Personal Information with Third Parties
Xebec tries our best to protect that information and make sure we are responsible in handlings, disclosing and retaining your data. We do not sell, rent, license, or lease your Personal Information to anyone. Xebec shares your Personal Information as described below.
- Agents and third-party service providers- To help us improve our Services, we may engage third parties to help us to carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to our business and the Site. Examples of the types of outside companies with which we may share information include non-financial companies that perform services for us, such as data processing, website development, and companies that perform or assist in reporting or tax documentation on our behalf. Use of any Personal Information we share with these third parties is limited to the performance of the task we request. The third parties with which we share Personal Information are required to protect it in a manner similar to the way we protect your Personal Information.Additional Information for EU Individuals Regarding Transfers to Third Parties Governed by GDPR– If you are from the EU and one of our agents or third-party service providers fails to uphold these standards with respect to your Personal Information that we transferred to that agent or provider on your behalf, that agent or third-party service provider may be liable for any injury as required by GDPR.
- Business transfers- If Xebec is acquired or merged with another company, user information, including your Personal Information may be one of the assets transferred to or acquired by that company. You acknowledge that such a transfer may occur, and that any acquirer of Xebec may continue to use your Personal Information as set forth in this Policy. You will be notified via email or some other means of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information (including the right to delete your information). If Xebec goes out of business without a successor Xebec will delete your information.
- Protection of Xebec and others- We may release Personal Information when we believe in good faith that release is necessary or advisable to:
- comply with the law or national security request (for example, responding to subpoenas, court orders or other legal process),
- cooperate with government agencies, other regulatory bodies and law enforcement officials,
- enforce or apply our Terms of Service and other agreements, or
- protect the rights, property, or safety of Xebec, our employees, our users, or others. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to government requests.
Xebec takes precautions including organizational, technical, and physical measures, to help safeguard against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the Personal Information we process or use. While we follow generally accepted standards to protect Personal Information, no method of storage or transmission is 100% secure. Therefore, you should not expect, and Xebec does not warrant or guarantee, that your Personal Information will remain protected and private. You are solely responsible for protecting your password, limiting access to your devices, and signing out of the Site after your sessions. If Xebec knows or becomes aware of a security breach of your Personal Information, Xebec will notify you as required by applicable laws and may post a notice on the Site as required by applicable law(s). Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Opting-Out of Xebec Promotional Communications
We may at times send you e-mail communications with marketing, newsletters or investment opportunities. To stop receiving these materials, follow the unsubscribe or opt-out instructions in the email and we will take reasonable measures to promptly process your request. Please note that if you are a Xebec investor at times we may need to send you communications that are transactional in nature which are communications you will not be able to opt-out of.
Reviewing, Changing or Correcting Account Information
You are solely responsible for helping us to maintain the accuracy and completeness of your Personal Information and other information. We urge you to review your account information regularly to ensure that it is correct and complete. You will be able to change your e-mail address, password, contact information, or other login information by visiting your account’s settings page subject to this Policy. When you update information, however, we often maintain a copy of the unrevised information in our records. In addition, some content of your account will not be able to be edited or removed, such as information relating to your Xebec investment(s). If you need help modifying your account information, please contact us at firstname.lastname@example.org.
Deleting Your Account
For citizens of the European Union, please contact email@example.com for requests and inquiries regarding the data retained and managed by this portal and your rights to be forgotten related to the General Data Protection Regulation (GDPR).
Our Site is not intended for use by anyone under eighteen (18) years of age. No one under eighteen (18) years of age is allowed to use the Site, provide any Personal Information or receive our email distributions. If you believe that a minor has disclosed Personally Identifiable Information to Xebec, please report this to us immediately by emailing us at firstname.lastname@example.org.
Applicable Law and Jurisdiction