All information about our policy
Last Updated: November 24, 2022
1.0 Policy overview
This Policy applies worldwide to all clients, employees, contractors and any other users of XTROPS. This policy also applies to all XTROPS users, including Consumers, Service Providers and Businesses, and to all XTROPS platforms and services, including our website, app, features, and other services (collectively, the “XTROPS Platform”). Please remember that your use of the XTROPS Platform is also subject to our Terms and Conditions.
1.3 Application of local laws
Each user and member of XTROPS is responsible for compliance with this Policy. If there is reason to believe that local law requirements or other legal obligations contradict the duties under this Policy, you must inform us. In the event of conflicts between applicable local laws, rules or regulations and the Policy, XTROPS will work to find a practical solution that reconciles these requirements.
Any information that can directly or indirectly be used to identify a natural person, whether that individual is an employee, a customer or employee of a customer, a vendor or employee of a vendor, a job applicant or any other third party.
- Phone numbers
- Email addresses
Any operation performed on Personal Data, with or without the use of automated systems, such as to collect, store, organize, retain, archive, record, view, modify, adapt, alter, query, use, retrieve, forward, transmit or combine data. This also includes disposing of, deleting, erasing, destroying or blocking data.
- Storing information in databases
- Viewing information stored on another computer
- Transferring information from one database to another
2. Data protection principles
Personal Data will be collected, recorded and used in a proper and professional manner, whether the Personal Data is on paper, in computer records or recorded by any other means. XTROPS is accountable for and must be able to demonstrate compliance with the following principles of data protection ONLY when data is held by us but after we hand over the data, we are not responsible for third parties’ action. Nonetheless we believe in these data principles:
2.2 Fair and lawful
When Processing Personal Data, the rights of the individual related to their Personal Data must be protected. Personal Data must be collected and processed fairly and lawfully.
2.3 Purpose specification
Personal Data can be used or processed only for the purpose defined at the time of collection and shall not be further used or Processed in any manner incompatible with that purpose. Personal Data may not be collected and stored for potential future use unless allowed by local law.
2.4 Collection limitation
XTROPS only collects Personal Data necessary to meet the specified purpose at the time of collection and only to the extent allowed by local law.
Personal Data no longer needed for the purpose specified at the time of collection shall be deleted according to applicable retention schedules unless it is subject to an exception from us.
2.6 Data quality
Personal Data should be accurate, and if necessary, kept up to date.
2.7 Security safeguards
Personal Data must be protected using technical, managerial and physical security measures against risk of loss or unauthorized access, destruction, use, modification or disclosure.
Individuals must be notified at the time of collection how their Personal Data is being used or processed. They must be aware of who is collecting the Personal Data, the purpose for the Processing of the Personal Data and if third parties will Process the Personal Data, that adequate safeguards are in place. All such notices must be approved by us.
2.9 Individual participation
To the extent required by local law, individuals have a right to access their Personal Data and, where appropriate, to correct or delete it and exercise any other right provided by local law.
3. Does this Privacy Notice apply to you?
This Privacy Notice applies to you if you are a user of XTROPS,
4. What Personal Data does XTROPS collect?
In the course of its business activities and providing the services, XTROPS will need to process Personal Data. Without your Personal Data, we will not be able to provide you with the requested services. As a rule, the Personal Data that you provide directly or indirectly to XTROPS when using our services and visiting our Website and Application are:
Contact information. Such as your name, address, e-mail address and phone number;
Financial information. This will include your payment method, payment status, and invoices;
Account information. This will include log-in details, including your email address, and other information provided through your account;
Automatically generated information. This will include IP address, unique device or user ID, system and browser type, date and time stamps, referring website address, content and pages you accessed on our Websites or mobile apps, dates, times and locations actions take place, websites you visit (if you connect to our in-store wireless services), click-stream information and device location (if you turn on the feature in the mobile app).
5.1 What is a cookie?
A cookie is a series of data characters that, when programmed into a web site, is placed by the web server into the browser's application folder on your computer. Once placed onto your machine, the cookie will allow the web site to "recognize" you as a unique individual.
5.2 Can cookies be removed from my hard drive?
Yes, cookies can be removed from your hard drive. Also, depending on what type of web browser and what browser version you are using, you may be able to change the properties on your cookie file so that cookies are not used or saved. Please check with your browser provider for more information on removing cookies.
6. Why does XTROPS process Personal Data?
Personal Data shall be collected, used, stored or otherwise processed when necessary within the framework of responsible, efficient and effective business management of XTROPS. XTROPS processes Personal Data based on applicable legal ground(s). The legal ground is often intrinsically linked to the business purpose. This means, for example, that the performance of an agreement can be both a legal ground and a business purpose for XTROPS. Therefore, we will first clarify the legal ground(s) on which XTROPS processes your Personal Data and, subsequently, the business purpose(s) that we use your Personal Data for:
6.1 Legal Grounds.
In general, XTROPS processes your Personal Data based on one of the following legal grounds:
- The processing is necessary to perform an agreement between you and XTROPS,
- The processing is necessary for us to comply with our legal obligations,
- The processing is necessary to protect your vital interests or of other individuals,
- The processing is necessary for the legitimate interests of XTROPS, except where such interests are overridden by your interests or fundamental rights and freedoms, or
Where appropriate and required, we will ask for your consent.
6.2 Business Purposes.
XTROPS shall only collect, use or otherwise process Personal Data if the processing falls within the scope of one (or more) of the legitimate business purposes listed below:
6.3 Product development, research and improvement of XTROPS services.
XTROPS processes Personal Data as necessary for the development and improvement of XTROPS services, research and development.
6.4 Performing agreements.
This includes business services, implementing XTROPS services, communication with individuals and other parties regarding services, responding to requests for (further) information, dispute resolution and preparing agreements.
6.5 Relationship management and marketing for commercial activities.
In general, XTROPS processes Personal Data as necessary for the development and improvement of XTROPS products and/or services, account management, client services and the performance of (targeted) marketing activities in order to establish a relationship with a client and/or maintaining as well as extending a relationship with a client, business partner or supplier and for performing analyses with respect to Personal Data for statistical and scientific purposes (e.g. deliver advertising, sponsorships, loyalty programs or other campaigns, communications and content from us on our sites and those of third parties more specific to your interests).
6.7 Business process execution, internal management and management reporting.
This includes addressing activities such as managing company assets, conducting internal audits and investigations, finance and accounting, implementing business controls, provision of central processing facilities for efficiency purposes, managing mergers, acquisitions and divestitures and Processing Personal Data for management reporting and analysis.
6.8 Safety and security.
Personal Data shall be included in the processing for activities such as those involving health and safety, the protection of XTROPS and customer, service providers or business partner assets and the authentication of customer, service provider or business partner status and access rights (e.g. provide a safe and secure services for online and offline transactions).
Protecting the vital interests of individuals. This includes processing data when necessary to protect your vital interests or of other individuals (e.g. for urgent medical reasons).
6.9 Compliance with legal obligations.
This addresses the processing of Personal Data as necessary for compliance with laws, regulations and sector specific guidelines to which XTROPS is subject (e.g. matching names of clients, service providers and business partners against denied parties’ lists for the purposes of avoiding conflict of interests, ensuring trade compliance, anti-money laundering, anti-bribery or other compliance policies and procedures).
7. Who has access to your Personal Data?
As a rule, XTROPS shares your Personal Data with third parties in the following circumstances:
With data processors, i.e. parties processing Personal Data on our behalf. In such cases, these third parties only use your Personal Data for the purposes described above and only in accordance with our instructions. XTROPS will only use processors which provide sufficient guarantees to implement appropriate technical and organizational measures and ensure the protection of the rights of data subjects.
With its employees if and to the extent necessary for the performance of their tasks. In such a case, access will be granted only if and to the extent necessary for the purposes described above and only if the employee is bound by confidentiality.
If and when required to do so by law, court order, or other legal process, for example, with law enforcement agencies or other governmental agencies, to establish or exercise our legal rights or in connection with a corporate transaction, such as a divesture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
8. How long will XTROPS process your Personal Data?
We will retain your Personal Data no longer than necessary for the purpose(s) for which we process your Personal Data. After the retention period we will delete or anonymize your Personal Data, unless we need to retain certain of your Personal Data for another purpose. We will only do so if we have a legal ground to retain your Personal Data. We will also ensure that Personal Data are only accessible for that other purpose.
9. What measures does XTROPS take to protect your Personal Data?
XTROPS has taken appropriate technical and organizational measures to protect your Personal Data against accidental or unlawful processing, including by ensuring that:
Your Personal Data is protected against unauthorized access;
The integrity and availability of your Personal Data will be maintained;
Personnel is trained in information security requirements; and
Actual or suspected data breaches are reported in accordance with applicable law.
10. Where does XTROPS store or transfer your Personal Data?
Personal Data is stored in Germany. We shall update this Policy in the event such data is transferred elsewhere as required by data protection legislation in Germany and the European Union such as the EU GDPR.
11. What rights can you exercise in relation to your Personal Data?
Based on the law applicable to the use of your Personal Data, you have rights in relation to your Personal Data. Note that we will have to balance your rights and your request to exercise them against our rights and obligations to process your Personal Data and to protect the rights and freedoms of others. A number of the rights you have in relation to your Personal Data, as applicable in the Germany, the EU and other regions, are explained below:
Right of access
You are entitled to a copy of the Personal Data we hold about you and to learn details about how we use it. Your Personal Data will usually be provided to you digitally. We may require you to prove your identity before providing the requested information.
Right to rectification
We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you believe this is not the case, you have the right to request that any incomplete or inaccurate Personal Data that we process about you is amended.
Right to erasure
You have the right to ask us to erase your Personal Data, for example where the Personal Data is no longer necessary for the original purpose for which they were collected, where Personal Data has become obsolete or where you withdraw your consent to the grounds on which data is processed. However, this will need to be balanced against other factors. For example, we may not be able comply with your request due to certain legal or regulatory obligations.
Right to restriction of processing
You are entitled to ask us to (temporarily) stop using your Personal Data, for example where you think that the Personal Data we hold about you may be inaccurate or where you think that we no longer need to use your Personal Data.
Right to data portability
You may have the right to ask that we transfer Personal Data that you have provided to us to a third party of your choice. This right can only be exercised when you have provided the Personal Data to us, and when we are processing that data by automated means on the basis of your consent or in order to perform our obligations under a contract with you.
Right to object
You have the right to object to processing which is based on our legitimate interests. You may also ask us to stop using your Personal Data for marketing purposes at any time, and if you do so, XTROPS will immediately cease to use your Personal Data. For other purposes based on our legitimate interests, we will no longer process the Personal Data on that basis when you file an objection, unless we have a compelling legitimate ground for the processing. Note, however, that we may not be able to provide certain services or benefits if we are unable to process the necessary Personal Data for that purpose.
Rights relating to automated decision-making
You have the right not to be subjected to a decision based solely on automated decision-making, including profiling, which produces legal effects concerning you or similarly significantly affects you. If you have been subject to an automated decision and do not agree with the outcome, you can contact us using the details below and ask us to review the decision.
Right to withdraw consent
We may ask for your consent to process your Personal Data in specific cases. When we do this, you have the right to withdraw your consent at any time. XTROPS will stop the further processing as soon as possible after the withdrawal of your consent. However, this does not affect the lawfulness of the processing before consent was withdrawn.
Emails: For your email preferences, visit the Email Preference Center.
Cookies and other technologies: To opt out of advertising, visit NAI Consumer Opt Out.
12. What if I have other questions or complaints?
Questions or complaints regarding the processing of your Personal Data can be directed to XTROPS by using the contact information as provided at the top of this Privacy Notice.
You also have the right to lodge a complaint with the competent (local) data protection authority in the jurisdiction where you work, where you live or where an alleged infringement takes place.
13. Will there be updates to this Privacy Notice?
XTROPS may update this Privacy Notice from time to time. If an amendment will have a serious impact, XTROPS will endeavor to actively inform you about such amendments.
14. Security and access on personal data
Personal Data is classified as confidential. Any unauthorized Processing of such data by employees is prohibited. Any Processing undertaken by an employee that is not part of his or her legitimate duties is prohibited. Employees may have access to Personal Data only as is appropriate for the type and scope of the task in question. This requires the definition and separation, as well as implementation, of roles and responsibilities.
Employees are prohibited from using Personal Data outside of the scope of their employment at XTROPS, to disclose it to unauthorized persons or to make it available in any other way outside the permitted business use. Supervisors must inform their employees at the start of the employment relationship about the obligation to protect Personal Data. This obligation shall remain in force even after employment has ended.
Personal Data must be safeguarded from unauthorized access and unlawful Processing or disclosure. This applies regardless of whether data is processed electronically or in paper form. Before the introduction of new methods of data Processing, a privacy impact assessment should be performed for new IT systems, which may lead to implementing technical and organizational measures to protect Personal Data.
Employees are expected to follow XTROPS Information Security Standards, which can be found by searching keyword “standards.” Note that Information Security classifies all data as Sensitive, Internal or Public. Depending on its classification, Personal Data must be protected in accordance with the applicable Information Security Standards. In the event of suspicious activity, suspected cyberattack, suspected security incident or possible breach of Personal Data, all XTROPS employees must notify Information Security immediately via the Incident Notification Website, keyword “incident,” or call us to report the incident.
15.0 Special circumstances
Data transferring or processing by third parties
Personal Data may not be transferred to a country outside the country of origin unless the transfer has been approved by us, who will ensure an adequate level of data protection or suitable safeguards are in place. If a vendor or third party is engaged to Process Personal Data, a data transfer agreement must be in place with that external provider. An external provider can Process Personal Data only in accordance with instructions from XTROPS.
Processing of special categories of Personal Data
Special categories of Personal Data that are highly sensitive can be processed only under certain conditions. These categories include an individual’s racial and ethnic origin, political beliefs, religious or philosophical beliefs, union membership or the health and sexual life of the data subject. Under local law(s), further data categories may necessitate special treatment. Personal Data that relates to a crime can often be processed under special requirements of local law.
If there are plans to implement a new system, procedure or Process that includes Personal Data in a special category, we must be informed in advance.
Telecommunications and internet
Telephone equipment, email addresses, intranet and Internet, along with internal social networks, are provided primarily for work-related assignments. They can be used within the applicable legal regulations and internal policies. In the event of limited acceptable usage for private purposes, the local laws on secrecy of telecommunications and any local telecommunication laws must be observed.
16. Details On The Information We Collect
When you use the XTROPS Platform, we collect the information you provide, usage information, and information about your device. We also collect information about you from other sources like third-party services, and optional programs in which you participate, which we may combine with other information we have about you. Here are the types of information we collect about you:
A. Information You Provide to Us
Account Registration. When you create an account with XTROPS, we collect the information you provide us, such as your name, email address, phone number, birth date, and payment information. You may choose to share additional info with us for your profile, like your photo or saved addresses (e.g., home or work), and set up other preferences (such as your preferred pronouns).
Communications. When you contact us or we contact you, we collect any information that you provide, including the contents of the messages or attachments you send us.
B. Information We Collect When You Use the XTROPS Platform
Device Information. We collect information about the devices you use to access the XTROPS Platform, including device model, IP address, type of browser, version of operating system, identity of carrier and manufacturer, radio type (such as 4G), preferences and settings (such as preferred language), application installations, device identifiers, advertising identifiers, and push notification tokens.
Cookies, Analytics, and Third-Party Technologies. We collect information through the use of “cookies”, tracking pixels, data analytics tools like Google Analytics, SDKs, and other third-party technologies to understand how you navigate through the XTROPS Platform and interact with XTROPS advertisements, to make your XTROPS experience safer, to learn what content is popular, to improve your site experience, to serve you better ads on other sites, and to save your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the XTROPS Platform. You should consult your web browser(s) to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may miss out on certain features of the XTROPS Platform.
C. Information We Collect from Third Parties
Third-Party Services. Third-party services provide us with information needed for core aspects of the XTROPS Platform, as well as for additional services, programs, loyalty benefits, and promotions that can enhance your XTROPS experience. These third-party services include background check providers, insurance partners, financial service providers, marketing providers, and other businesses. We obtain the following information about you from these third-party services:
Information about your participation in third-party programs that provide things like insurance coverage and financial instruments, such as insurance, payment, transaction, and fraud detection information;
Information to operationalize loyalty and promotional programs or applications, services, or features you choose to connect or link to your XTROPS account, such as information about your use of such programs, applications, services, or features; and
Information about you provided by specific services, such as demographic and market segment information.
Referral Programs. Friends help friends use the XTROPS Platform. If someone refers you to XTROPS, we will collect information about you from that referral including your name and contact information.
Other Users and Sources. Other users or public or third-party sources such as law enforcement, insurers, media, or pedestrians may provide us information about you, for example as part of an investigation into an incident or to provide you support.
Providing the XTROPS Platform. We use your personal information to provide an intuitive, useful, efficient, and worthwhile experience on our platform. To do this, we use your personal information to:
- Verify your identity and maintain your account, settings, and preferences;
- Collect feedback regarding your experience; and
- Facilitate additional services and programs with third parties.
- Providing Customer Support. We work hard to provide the best experience possible, including supporting you when you need it. To do this, we use your personal information to:
- Investigate and assist you in resolving questions or issues you have regarding the XTROPS Platform; and
- Provide you support or respond to you.
Improving the XTROPS Platform. We are always working to improve your experience and provide you with new and helpful features. To do this, we use your personal information to:
- Perform research, testing, and analysis;
- Develop new products, features, partnerships, and services;
- Prevent, find, and resolve software or hardware bugs and issues; and
- Monitor and improve our operations and processes, including security practices, algorithms, and other modeling.
Responding to Legal Proceedings and Requirements. Sometimes the law, government entities, or other regulatory bodies impose demands and obligations on us with respect to the services we seek to provide. In such a circumstance, we may use your personal information to respond to those demands or obligations.
17. How We Share Your Information
We do not sell your personal information. To make the XTROPS Platform work, we may need to share your personal information with other users, third parties, and service providers.
A. Sharing With Third-Party Service Providers for Business Purposes
XTROPS may share the following categories of your personal information for a business purpose:
- Personal identifiers, such as your name, address, email address, phone number, date of birth, government identification number (such as social security number);
- Financial information, such as payment information you provide us;
- Internet or other electronic network activity information, such as your IP address, type of browser, version of operating system, carrier and/or manufacturer, device identifiers, and mobile advertising identifiers; and
- Location data.
B. We disclose those categories of personal information to service providers to fulfill the following business purposes:
- Maintaining and servicing your XTROPS account;
- Processing or fulfilling orders and deliveries;
- Providing you customer service;
- Providing marketing and advertising services to XTROPS;
- Providing analytics services to XTROPS; and
- Undertaking internal research to develop the XTROPS Platform.
C. For Legal Reasons and to Protect the XTROPS Platform
We may share your personal information in response to a legal obligation, or if we have determined that sharing your personal information is reasonably necessary or appropriate to:
- Maintaining and servicing your XTROPS account;
- Processing or fulfilling orders and deliveries;
- Providing you customer service;
- Providing marketing and advertising services to XTROPS;
- Providing analytics services to XTROPS; and
- Undertaking internal research to develop the XTROPS Platform.
D. In Connection with Sale or Merger
We may share your personal information while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.
E. Upon Your Further Direction
With your permission or upon your direction, we may disclose your personal information to interact with a third party or for other purposes.
18. How To Delete Your Information
We retain your information for as long as necessary to provide you and our other users the XTROPS Platform. This means we keep your profile information for as long as you maintain an account. If you request account deletion, we will delete your information as set forth in the “Deleting Your Account” section below.
We take reasonable and appropriate measures designed to protect your personal information. But no security measures can be 100% effective, and we cannot guarantee the security of your information, including against unauthorized intrusions or acts by third parties.
19. Your Rights And Choices Regarding Your Data
As explained more below and on our privacy homepage, XTROPS provides ways for you to access and delete your personal information as well as exercise other data rights that give you certain control over your personal information.
A. All Users
Email Subscriptions. You can always unsubscribe from our commercial or promotional emails by clicking unsubscribe in those messages. We will still send you transactional and relational emails about your use of the XTROPS Platform.
Push Notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the XTROPS Platform.
Profile Information. You can review and edit certain account information you have chosen to add to your profile by logging in to your account settings and profile.
Location Information. You can prevent your device from sharing location information through your device’s system settings. But if you do, this may impact XTROPS’s ability to provide you our full range of features and services.
Cookie Tracking. You can modify your cookie settings on your browser, but if you delete or choose not to accept our cookies, you may be missing out on certain features of the XTROPS Platform.
Do Not Track. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. The XTROPS Platform does not currently support Do Not Track requests at this time.
Deleting Your Account. If you would like to delete your XTROPS account, please visit our privacy homepage. In some cases, we will be unable to delete your account, such as if there is an issue with your account related to trust, safety, or fraud. When we delete your account, we may retain certain information for legitimate business purposes or to comply with legal or regulatory obligations. For example, we may retain your information to resolve open insurance claims, or we may be obligated to retain your information as part of an open legal claim. When we retain such data, we do so in ways designed to prevent its use for other purposes.
20. Children’s Data
XTROPS is not directed to children, and we don’t knowingly collect personal information from children under the age of 18. If we find out that a child under 18 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 18 has given us personal information, please contact us.
21. Disclaimer On Links to Third-Party Websites
The XTROPS Platform may contain links to third-party websites. Those websites may have privacy policies that differ from ours. We are not responsible for those websites, and we recommend that you review their policies. Please contact those websites directly if you have any questions about their privacy policies.
We may update this policy from time to time as the XTROPS Platform changes and privacy law evolves. If we update it, we will do so online, and if we make material changes, we will let you know through the XTROPS Platform or by some other method of communication like email. When you use XTROPS, you are agreeing to the most recent terms of this policy.
24. Communication and responsibilities
All users are responsible for:
- Reading and complying with this Policy and related policies, along with related documents/guidelines that may be developed and maintained to implement the requirements of this Policy.
- Reporting violations of this Policy.
Management is additionally responsible for:
- Ensuring all reporting personnel understand the requirements of this Policy.
- Ensuring appropriate safeguards are in place to protect Personal Data.
XTROPS prohibits any form of retaliation for reporting in good faith a suspected violation of this Policy.
25. Contact Us
If you have any questions or concerns about your privacy or anything in this policy, including if you need to access this policy in an alternative format, we encourage you to contact us on:
our team will help you