Effective Date: October 2020
OUR PRIVACY COMMITMENT TO YOU IS SIMPLE:
- We are not in business to sell your personal information.
- We built our company and technology to make your life easier, not more complicated. So, we only use your personal information for the defined, appropriate purpose, of delivering our Services in a manner that meets—and hopefully exceeds—your expectations.
- We adhere to the highest legal standards where we operate and have committed to continuously improve what we do as privacy laws and regulations change.
- We work with ISO (International Organization for Standardization), American, Canadian, European, and other borderless best practices guidance to make sure that your privacy rights aren’t lost in the shuffle of competing interests.
- We care about your privacy and want to hear from you if you have questions, comments, or concerns. Contact us at email@example.com.
- X2X, Inc. supports the principles and values of Privacy by Design. Privacy by Design provides guidance regarding the protection of consumer privacy. For more information about Privacy by Design, please visit https://iapp.org/media/pdf/resource_center/pbd_implement_7found_principles.pdf
By using the Services, you hereby consent to allow us to process information in accordance with this Policy.
In particular, we recognize the sensitive and confidential nature of the information which may be shared between users of our Service. We are making every reasonable effort to secure your data and have engaged an Advisory Committee so that we follow and maintain the best practices in the industry.
Our Services include tools designed to help you and your co-parent, guardian, and/or other legally-recognized co-care-taker(s)(also a “Partner”) manage communication, parenting plans, and scheduling, shared expenses, contacts, and other critical information, and send and receive payments to one another. In order for you to use the Services effectively, you will need to provide us with information about your family, your schedules, and your parenting responsibilities, as well as any shared expenses, contacts, or other information that you would like to manage via the Services. You will also have the option to upload, store and search your relevant documents (such as documents related to scheduling, court orders, and agreements), as well as related information, that is legally required or practically-needed to be shared between Partners with shared custody and/or supervision responsibilities, which we will store on our server.
Your account and that of your Partner will be connected so that you both will have access to the Services in order to manage and facilitate your interactions. You will control what information is shared with your Partner. To this end, you are encouraged to post and share responsibly. Also, you will be provided with the means to edit your sharing preferences for certain documents, uploads, or lists. Similarly, you will have the ability to share certain information with others, such as other family members, caretakers, Family, marriage therapists, other medical personnel, attorneys, and financial professionals such as accountants.
If you sign up for our Services in the USA or are given access to our services through an American affiliate, then regardless of where you or our servers are located, your personal data may be processed by us in the United States. BY VISITING THE WEBSITE AND USING THE SERVICES, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.
If you sign up for our Services in Europe or are given access to our services through an EU affiliate, then your data will be stored and processed on servers located within the EU that may only transfer data to jurisdictions outside the EU that abide by similar protections to those that exist in the EU. Data transfers that do take place must be subject to contracts and protections that are reflective of best practices in data transfers and data privacy, and ensure that protections available to EU citizens are available as required.
If you sign up for or use our Services elsewhere in the world, you are consenting to our US-based data collection, storage, and transfer practices.
We collect two types of information about and from persons who use the Services: Personal Information and Anonymous Information.
“Personal Information” is information that is personally identifiable to you, such as your name, address, email address, or phone number, as well as other non-public information that is associated with the foregoing. Anything you publicly post or that is available publicly will not be considered Personal Information, and will be outside the restrictions of this policy.
“Anonymous Information” means information that is not associated with or linked to your Personal Information. We may create Anonymous Information from (i) automatically gathered information or (ii) Personal Information by excluding information (such as name) that reasonably makes the original information personally identifiable to you.
Personal Information Collected
We collect certain Personal Information about you or about those you identify, which may be supplied when you interact with the Services, enter documents or information into the Service, complete a survey or respond to requests for information, make a Transaction, make a payment for Service, schedule an event, share information, when you request services or initiate a transaction with us, or otherwise when you submit such information. The information collected may include one or more of the following:
- Phone Number(s);
- E-mail address;
- Credit card and/or related billing information;
- Social security number;
- Bank account information;
- Date of birth;
- Your schedule and the schedule(s) of your children or dependent adults;
- Employment information;
- Other family information;
- Physical Address;
- IP Address;
- Information from your activities on the Services;
- Other financial information (e.g. child care expenses and other expense items entered in the Services); and
- information you enter into the Services including messages, attachments, and documents.
We may receive information from you, your partner, or trusted sources such as your ISP’s provision of your device’s IP address regarding your location. Your location, to the extent available to us, is primarily used to validate your identity. We do not use or sell your location for advertising purposes. Location features may not be available at all times, or on all types of devices or platforms, or in certain locations. If location features are available, your device settings will provide you with the option to enable or disable location features.
Anonymous Information is collected about you when you use the Services, including but not limited to enrollment history, the type of device you used and its operating system, the pages accessed most frequently, how pages are used, search terms entered, and similar data. Anonymous Information may also be created from any of the Content we receive. This Anonymous Information is used to help us improve our Services, improve the delivery of these Services to you, and improve our understanding of how aggregated groups of consumers interact with our Services. Anonymous Information, including securely anonymized formerly Personal Information, will not identify you or your specific usage of our Services. Such Anonymous Information can be used by us to maintain and improve our Services available to all Users and Partners. We do not sell our Anonymous Information to third parties for advertising purposes.
“Sensitive Information” is information that you upload, share with your Partner through our Service, or share with us, that pertains to practically sensitive matters, such as a person’s health or finances. Sensitive Information may be eligible for heightened security and/or privacy safeguards. Sensitive Information is sometimes also (or includes) Personal Information. Sensitive Information that is also Personal Information must be de-identified to become Anonymous Information.
The Service charges a fee, facilitates payments between you and other users and collects payment information which may include credit card, ACH, debit card, or bank account information. All payments between you and us, and between and among you and other users (a “Transaction”) will be accomplished through a third-party payment processor and is subject to the policies of that processor.
Additional financial services are provided by our third-party partners. When completing your requested transaction, your information will be subject to the terms and policies of those third parties, and we encourage you to review their policies accordingly. Banking services are provided in part by MainStreet Bank, member FDIC, Equal Housing Lender, NMLS# 416495.
The Service does not permit you to log in through, or directly share any information with, any third party social media platform (such as Facebook, Twitter, Instagram, etc.). We are not a social media platform. We encourage you to post responsibly.
If you choose to follow us or otherwise interact with us on any social media platform, the nature of our relationship and communication will be governed by that platform’s terms of service and use.
Do Not Track
At present, the Services do not specifically respond to browser do-not-track signals.
Our Services may utilize other common forms of website and/or app usage analytics, such as those associated with Amazon, Google, or other commercially-available cloud hosting or browser analytics systems.
We may offer automatic, also known as push notifications. We will provide push notifications only if you opt-in to receive them. You may use your device or browser settings to turn on or disable these push notifications.
USE OF INFORMATION
Internal Use of Information by Us
We accept and gather Personal Information and Anonymous Information in an effort to provide the Services to you. We may also use this information to help us develop and improve our Services, fulfill your requests, execute Transactions, send materials to you, inform you about our offers and those of others, tailor our Services to meet your interests and needs, and for other purposes permitted or required by law, such as internal compliance and training.
We may use Personal Information or Anonymous Information for any business purpose including, but not limited to, analyzing traffic and usage patterns, diagnosing problems, administering the Service, improving the Service, executing requests you make through the Service, tracking how users are using the Service, and improving reporting, marketing, or communication systems.
Sharing Collected Information
We may share Personal Information and Anonymous Information with our business associates, consultants, service providers, advisors, and affiliates in order for them to provide services to us, to you, and to enable us to provide the Services. For example, our payment processor requires us to pass Personal Information and Transaction information to it in order to verify your credentials or identity and allow you to make or receive payments.
We may ask you to share email addresses or other information in your address book in order to invite other users (i.e. your Partner or other authorized third parties) to our Services. In some cases, this will be required for use of the Service. If you wish to invite your Partner or someone else to use the Services, or you wish to recommend the Services to other friends, we will automatically send an email, text message, or another form of a message (as selected by you) to each person that you select to receive your recommendation. We store the contact information you provide so that we can (a) send an initial message to your contact, and (b) monitor the effectiveness of our invitation services. For contacts that do not respond, or that do respond but do not elect to give us their contact information for subsequent information and updates, we will delete that information when we periodically purge our files.
We may share Personal Information and Anonymous Information with other users of the Service that you interact with or that you select or indicate for information sharing, or if required by an applicable legal obligation such as a court order.
We may share Personal Information and Anonymous Information with third parties that are necessary for the completion of our Services, or legal compliance of our Services. For example, when you initiate a payment transaction, our Services must be able to have a connection to your bank account to complete a payment transfer, and our Services must be able to verify standard anti-fraud information about you and your account such as confirming that your name within our Services matches the name on your linked bank account.
We do not and will not share Personal Information with any third parties for their marketing purposes.
We may share Anonymous Information with service providers for the purposes of analytics and for our own marketing of Services, and for other purposes permitted by law. The use of such Anonymous Information by third-parties will be governed by their own policies and may be broader than the uses outlined in this Policy.
Further, we may disclose collected information, including Personal Information and Anonymous Information, to the extent we believe it necessary to comply with the law, such as in response to a subpoena or court order, to defend a legal claim, to fulfill a legal compliance requirement, or establish or protect our legal rights or otherwise as permitted by applicable law (a “Compelled Disclosure”). You agree to such Compelled Disclosures, whether or not you are ever made aware of such disclosures, and will indemnify, defend, and hold X2X harmless for any information related to your account that X2X shares pursuant to a Compelled Disclosure. Please be aware that some government agencies may require that we not inform you that such Compelled Disclosure has been required or made.
We may also disclose any information in our possession in the event that we believe it necessary or appropriate to prevent criminal activity, personal injury, property damage, or bodily harm.
Additionally, we may transfer your information to a successor in interest, which may include but may not be limited to a third-party in the event of an acquisition, sale, asset sale, merger, or bankruptcy. The policies applicable to your information thereafter may be determined by the transferee, except that we will require the transferee to prohibit the use of Personal Information for marketing purposes.
Retention of Information
All information you generate or submit through the use of the Service will be retained while you have an active account, regardless of whether you deleted it locally from your computer or mobile device. That information includes, but is not limited to, Personal Information such as posted messages, photos, requests, calendar entries, financial entries, all whether received or sent within each six month period ("Account Activity") and for a period of time after termination of your account, as determined by X2X (“Retention Term”). If there is no Account Activity for six months or longer, you agree that X2X has no obligation to contact you or advise you that your account (along with its associated data) has terminated or is scheduled to be terminated due to inactivity and that in such event we have the right to terminate your account without liability to you, and may permanently delete and/or de-identify all Personal Information associated with your account. We do not have the ability to delete Anonymous Information. For the Retention Term, you unconditionally and irrevocably grant to X2X the authority to retain any data or records created by you, including but not limited to, text messages, financial transactions, photos, calendar events, and all Personal Information created or shared by you.
During the Retention Term, your Personal Information may be retrieved by you, other persons you have previously authorized us to provide that Personal Information, or your child’s (or children’s or ward’s) other parent or legal guardian (or in some cases by another court-appointed professional, such as a guardian ad litem). A person requesting such information must have an active account at the time of the request.
We employ procedural and technical safeguards to secure your personal information against loss, theft, alteration, and unauthorized access, use, and disclosure. We also employ security procedures to protect your information from unauthorized access by users inside and outside the company.
Regardless of the precautions we take, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect personal information, we cannot ensure or warrant the security of any information you transmit to us or enter into the Service.
EMAIL AND ELECTRONIC NEWSLETTERS
We may offer electronic newsletters and emails concerning existing and new products and services or may provide other marketing or informational materials as a service to our users. Users may receive newsletters and emails concerning promotions and marketing of ours or of our business partners, after registering with the Services or after engaging with us in person or through our agents.
If you have received a message from us, and you no longer wish to receive such materials, you may opt-out by following the unsubscribe instructions included in each electronic newsletter and e-mail.
Please note that you may be required to separately opt-out of any e-mails sent by our business associates. You may not be able to opt-out of messages related to your account, the availability of Services, or other technical, security, or privacy-related messages.
Children and Privacy
We do not knowingly permit users to use our Services if they are under 13 years old, and therefore do not request personally identifiable information from anyone under the age of 13.
If we become aware that a user or customer is under the age of 13 and has registered without verifiable parental consent, we will remove his or her personally identifiable registration information from our files and will disable the account. If you are the parent or guardian of a person under the age of 13 who has provided personally identifiable information to us without your approval, please inform us by contacting us at the e-mail address below and we will remove such information from our database.
California Privacy Rights
California law allows California residents to request information regarding our disclosures in the prior calendar year, if any, of their personally identifiable information to third parties. To make such a request, please contact us at firstname.lastname@example.org with "Request for Privacy Information" in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and address. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted in a form other than as prescribed in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.
General Data Protection Regulation and Other Extra-Jurisdictional Requirements
X2X is based in the United States and operates based upon United States law. However, we aspire to the best borderless practices in data privacy, data security, quality control, product management, and product safety. As a result, we may voluntarily seek to comply with laws or requirements that do not actually apply to X2X. We are not responsible for any failure to meet compliance with any laws or requirements that we voluntarily commit to following.
Sensitive Records Laws