Effective as of Feb 2, 2024.
This Privacy Policy describes how XPNetwork, LLP handles personal
information that we collect through our online SaaS platform, website and mobile app that link to this
Privacy Policy (collectively, the “Service”), as well as through our marketing and other activities
described below. References to app throughout this Policy is interchangeable with our platform and
website as appropriate.
Personal Information We Collect
Information you provide to us. You may provide us with the following categories of personal
information:
● Account data. Information you provide to create a Service account, including your name, email,
and the password you set.
● Transaction data. Information about your purchases in the Service, including what you
purchased, the price, and the date. Your in-app purchase transactions are processed by third
party payment processors, such as Apple (for purchases on iOS devices) and Stripe, which collect
your personal information as described below under How we share your personal information.
● Communication data. The contents of your communications with us or other users, whether
through the Service, email, or otherwise, including your support requests, and any feedback
you provide about the Service and your responses to any future surveys.
● Location data. When you opt-in to the collection and sharing of geolocation data from your mobile
device, we use that data to help you identify event and to find local points of interest including
premises/stores around you which relate to games and other publisher related products that
you may be interested in. We do not share inferred home and work locations.
If we ask you to provide other categories of personal information not listed above from you, we will use
it consistent with this Privacy Policy or as otherwise explained at the time of collection.
Automatic data collection. We and our service providers may automatically log information about you,
your computer or mobile device, and your interaction over time with the Service, and our
communications, such as:
● Device data. Your computer or mobile device’s operating system type and version,
manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device
type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising
purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE,
3G), and general location information (e.g., city/town).
● Usage data. The events you attended or participated in, the pages or screens you viewed, your
search terms, any embedded content that you viewed, how long you spent on a page or screen,
the website you visited before browsing to the Service, navigation paths between pages,
information about your activity on a page, access times and duration of access, and whether you
have opened our emails or clicked links within them.
Cookies and similar technologies. Some of the automatic collection described above is facilitated by the
following technologies:
● Cookies. These are small data files that are placed on your computer or mobile device when you
visit a website to help website operators understand site traffic and use, help you navigate
between pages efficiently, remember your preferences, and enable functionality. Cookies used
on our site include cookies that we serve as well as cookies served by third party vendors that
we work with to enable the services they provide, such as website analytics services that track
traffic and usage. You can learn more about cookies and how to control them at
www.allaboutcookies.org and you can set preferences for which cookies you wish to remove or
reject in your browser.
● Pixels. We may use pixels (also known as web beacons and clear GIFs) on our site and in our
HTML formatted emails to track the actions of users on our sites and interactions with our
emails, such as when an email was opened. Pixels are embedded invisibly in image files within
webpages or HTML formatted emails. Most browsers and devices allow you to configure your
browser or device to prevent images and any pixels embedded in them from loading.
● SDKs. Software development kit (SDK) refers to third-party computer code, which may from
time to time, be incorporated into our mobile application to enable functions and tracking
similar to those enabled by the other technologies described above, including to enable
authentication services, analytics services and functionality provided by third parties.
● Browser web storage. Browser web storage (including via HTML5), also known as locally stored
objects, functions like cookies but enables the storage of a larger amount of data. Your web
browser may provide functionality to clear your browser web storage.
If you block or reject these technologies, certain areas or features of the Service may not work or be
accessible.
Third party sources. We may combine personal information we receive from you or collect
automatically when you use the Service with personal information we obtain from other sources, such
as:
Third party authentication services. If the Service provides you an ability to log into the Service
by using your credentials on a third party service, such as Apple, Google, and Microsoft, the
service may share information about you to facilitate the authentication as described in the
service’s settings or privacy policy.
How We Use Your Personal Information
We may use your personal information for the following purposes or as otherwise described at the time
of collection:
Service delivery. To provide, operate, support and improve the Service and our business. This includes
communicating with you via text message or email, including to provide support, respond to questions
and send you reminders, updates, and other administrative messages.
Marketing. To send you marketing emails. You may opt-out of our marketing emails as described in
the Opt-out of marketing communications section below.
Research and development. For research and development purposes, including to analyze and improve
the Service and our business. As part of these activities, we may create aggregated, de-identified and/or
anonymized data from personal information we collect. We make personal information into de-
identified or anonymized data by removing information that makes the data personally identifiable to
you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third
parties for our lawful business purposes, including to analyze, improve and promote the Service and our
business.
Compliance and protection. To comply with applicable laws, lawful requests, and legal process (such as
to respond to subpoenas or requests from government authorities), and to protect our, your or others’
rights, privacy, safety, or property (including by making and defending legal claims), including by
enforcing the terms and conditions that govern the Service, and taking steps to prevent, investigate and
deter fraud, cyberattacks or other unauthorized, unethical, or illegal activity.
How We Share Your Personal Information
We may share your personal information with the following categories of recipients and as otherwise
described in this Privacy Policy or at the time of collection:
Service providers. Third parties that provide services on our behalf or help us operate the Service or our
business (such as hosting, information technology and security, support, email delivery, payments,
safety monitoring, performance monitoring, marketing, customer research, and analytics).
Payment processors. When you make purchases through the Service, your transactions are processed
by third party payment processors, such as Apple (for purchases on iOS devices) or Stripe. These
payment processors may collect your name, phone number, e-mail address, mailing address, billing
address, payment card information, and other information needed to process your payment. They may
also retain this information to enable you to purchase additional items through our Service without
having to re-enter your payment information each time. They do not share your payment card
information with us. Their collection and use of your personal information is governed by their own
privacy policies, terms and rules – we encourage you to read them. Stripe’s Privacy Policy is available at
https://stripe.com/privacy and Apple’s privacy policy is available at
https://www.apple.com/legal/privacy/.
Third party authentication services. When you log into the Service by using your credentials on a third
party service, such as Apple, Google and Microsoft, the service will collect personal information from
you to facilitate the authentication as described in the service’s relevant settings or privacy policy.
Your social media platforms. When you click on a social widget in the Service to share the content we
generate or other content on your social media services, your social media service will collect and use
the content and your other personal information as described in their privacy policy.
CAPTCHA services. To enhance the security of our Service, we use captcha features that require users to
complete a task to authenticate to the Service. Third party providers of these CAPTCHA services collect
Device Data and Usage Data, as described above to enable the CAPTHCA features and as described in
their privacy policies.
Professional advisors. Professional advisors, such as lawyers, accountants, auditors, bankers, and
insurers, where necessary in the course of the professional services that they render to us.
Affiliates. Corporate affiliates that we control, are controlled by, or with which we are under common
control, for purposes consistent with this Privacy Policy.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in
good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Parties (and their advisors) to business transactions (or negotiations of or due
diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition,
reorganization, sale or other disposition of all or any portion of the business or assets of, or equity
interests in, XPN or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Your Choices
Access or update your information. You may review and update certain XPN account information within
your account.
Set notification preferences. You can set preferences regarding push notifications sent by our mobile
app in your mobile device’s operating system settings.
Opt-out of marketing communications. You may opt-out of marketing emails by following the opt-out
or unsubscribe instructions at the bottom of the email, or by contacting us with your opt-out request.
Please note that if you opt-out of promotional emails, you may continue to receive service-related and
other non-marketing emails.
Cookies. The settings of most browsers let you remove or reject cookies. See the “Cookies and similar
technologies” section above for more information about your choices.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online
services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about
“Do Not Track,” please visit http://www.allaboutdnt.com.
Delete your account. You can request that we delete your account by contacting us with your account
deletion request or deleting your account through the Services. Please note that if we delete your
account, we will be unable to provide any online or digital services to you or support for past services
you have requested.
Exercise California removal rights. Registered users of the Service who are California residents and
under 18 years of age may request and obtain removal of content or information that they posted on
the Service where it can be accessed by others. Please contact us with these requests. Upon receipt of
the request, we will comply with applicable legal requirements to remove it or ensure that it is
anonymized. Such removal does not ensure complete or comprehensive removal of the content, as, for
example, some of the content or data may have been reposted by another user.
Other Sites And Services
The Service may link to or integrate with websites and other online services operated by third parties. In
addition, our content may be integrated into web pages or other online services that are not associated
with us. These links and integrations are not an endorsement of, or representation that we are affiliated
with, any third party. We do not control websites or other online services operated by third parties, and
we are not responsible for their actions. We encourage you to read the privacy policies of the other
websites, mobile applications, and online services you use.
Security And Retention
We employ technical, organizational, and physical safeguards designed to protect the personal
information we collect. However, security risk is inherent in all internet and information technologies,
and we cannot guarantee the security of your personal information.
The length of time we retain a category of personal information is determined based on whether it is
sufficient to fulfill the purposes for which we collected it, including to satisfy legal, regulatory,
accounting, or reporting requirements, establish or defend legal claims, enforce our agreements, resolve
disputes or fraud prevention. We may either delete or anonymize personal information we no longer
require.
International Data Transfers
We are headquartered in the United States and may use service providers that operate in the United
States and other countries. Your personal information may be transferred to the United States or other
locations where privacy laws may not be as protective as those in your state, province, or country.
Children
The Service is not intended for use by anyone under 16 years of age. If you are a parent or guardian of a
child under 16 from whom you believe we have collected personal information in a manner prohibited
by law, please contact us. If we learn that we have collected personal information through the Service
from a child under 16 years of age without the consent of the child’s parent or guardian as required by
law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this
Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service
or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting
the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the
Service after the effective date of any modified Privacy Policy indicates your acknowledgment that the
modified Privacy Policy applies to your interactions with the Service and our business.
How to contact us
If you have questions or concerns about this Privacy Policy or our practices, please contact us
support@xpnetwork.com
or write to us at
XP Network
500 Seawall Blvd, STE 611
Galveston, TX 77550.