Privacy Policy

This Privacy Policy describes the privacy practices of IPXO LLC, (“IPXO,” “we,” “us,” or “our”) and describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

This Privacy Policy describes how specific categories of customer personal data are collected, used and protected by IPXO in connection with our Platform. Individuals located in the European Union or in the State of California, USA should be sure to read the important information addressed to their regions. Please be additionally informed that, IPXO shall not further collect, sell (as defined in the CCPA), or use personal data except as necessary to perform the business purpose in the main agreement.

Please note that this Policy does not govern the collection and use of information by companies that IPXO does not control, nor by individuals not employed or managed by us. If you visit a website that we mention or link to, be sure to review its privacy policy before providing the site with information. It is highly recommended and suggested that you review the privacy policies and statements of any website you choose to use or frequent to better understand the way in which websites garner, make use of and share the information collected.

This policy addresses the rights of individuals in the EU, US or elsewhere with regards to their personal information and the means and contacts needed to assure those rights.

Through the use of our Platform you are herein consenting to the following data procedures expressed within this agreement.

What personal data do we collect?

Processing of your data

You provide us with your personal data creating your account at Platform. The personal data you provide to us includes your first and last name, your email address, phone number, address, financial information for payments processing, your IP address, a unique identifier for your computer or other access devices, company information and alike. We maintain personal data as a result of your website usage, for example when you visit our website, login to your account or use our services. We also record and monitor communications with you for our internal compliance requirements.

Information for creating your account at Platform

Email address. As part of your registration we ask to provide an email address, which is necessary for establishing a Platform account, retrieving a lost password, and using our services.

Payment data. In order to use our Platform, you must submit valid credit card or other payment method information. Our payment processing partners process basic billing information for payment processing and refund requests. We also process some of the same payment information ourselves (e.g., card owner’s full name, last few digits of your credit card) in cases of recurring payments.
Country details. For VAT calculation purposes we may ask our users to provide the country where they are registered or have a permanent address.

Communication data

Email address. We will only send you emails if you have agreed to receive emails from IPXO, either by entering into a contract with us (using our Platform) or by actively giving consent. We may use your email address to: a) send emails to you related to payment transactions b) send updates and announcements; c) communicate with you about subscribed Services or respond to your communications to us; d) send to you marketing information (you have the right to “opt out” at any time).
Chat-bot. We collect only personally identifiable information that is specifically and voluntarily provided by users to the Chat-bot. We receive limited identifiable information, such as name, title, address, email address, and phone numbers from Chat-bot users, we will also be able to see your IP address.

Information collected on our website

Access logs. In the process of administering our Platform, we maintain and track usage through Web server logs. This information is also essential for fighting against DDoS attacks, scanning and similar hacking attempts.
Cookies. We use “cookies” to help you personalise the use of our Platform. Cookies used by us do not contain personal information or other sensitive information. Some cookies are essential for our Platform to operate smoothly while others are used to improve Platform’s functionality or analyze aggregated usage statistics to improve website performance (as in the case of Google Analytics, a web analytics service provided by Google, Inc.). We also use affiliate cookies to identify the customers referred to the website by our partners so that we can grant the referrers their commission. Users may choose to reject all or some cookies at any time by changing the setting of your web browser on your device. However, please be aware that you will not be able to use some of the functions of our Platform if you choose to delete or restrict cookies.

How We Use Your Personal Information

Account Management

We use your personal information:

to provide the Services to you, to verify your identity, to operate, maintain and administer the Platform;
to provide you with information regarding the Services;
to monitor, detect and deter unauthorized or fraudulent use of, or abuse of, the Services;
to manage and communicate with you regarding your account on Platform, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages;
to improve and/or optimize the Services;
provide support and maintenance for Platform and our services;
to notify you of any other important information regarding the Services, if necessary;
to enable us to provide customer support, and to respond effectively to your inquiries and claims, questions and feedback;
to comply with applicable laws or legal obligations.

To send marketing communications

We may send you IPXO related marketing communications as permitted by law (you have the right to “opt out” at any time).

We may use or share your personal information in other ways described in this Policy or to which you have otherwise consented.

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern Platform; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations. We disclose personal information to third parties under the following circumstances:

Service Providers. We may employ third parties in conducting and managing our business to enable us to give you the best Services and the most secure experience. These third parties may only use your information as directed by IPXO and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Compliance with Laws and Law Enforcement; Protection and Safety. IPXO may disclose information about you to government or law enforcement officials or private parties as required by law in order to comply with a legal or regulatory obligation. We may disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Business Transfers. We may also disclose your information to affiliates or other third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings), in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your Choices

Access, update, correct or delete your information

You have the right to request that we delete personal information about you that we have collected from you. If your personal information changes, or if you no longer desire our services, you may correct, update, or delete it by emailing [email protected]. We will respond to your request within a reasonable timeframe.

Marketing communications

You may opt-out of marketing-related emails by clicking on a link at the bottom of each such email, or by contacting us at [email protected]. You may continue to receive service-related and other non-marketing emails.

How long we retain your Personal Information

We keep your personal information for as long as is necessary to provide Services to you, and for as long as your account and/or registration with Platform is active. We will retain and use your information as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements.

Where we are required by law to collect your personal information, or where we need your personal information in order to provide a requested service to you or operate Platform, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the requested service(s) or operate Platform. We will tell you what information you must provide to receive a requested service or interact with Platform by designating it as required on Platform or through other appropriate means.

Security

We take the security of all the data we hold seriously. Our employees are trained on data protection, confidentiality and security. We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure. All information you provide to us is stored on our secure servers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

If you have questions about our security measures in place, please contact us at [email protected]

Children

Our Platform is not directed to children under 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information from our files as soon as reasonably practicable.

International Transfer

IPXO is headquartered in US and United Kingdom and has service providers in other countries, and your personal information may be transferred to other locations outside of your country, where privacy laws may not be as protective as those in your jurisdiction.

Other Sites and Services

Platform may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

Changes to this Privacy Policy

We are required to review and update, and will review and update, this policy at least annually or if there are any substantive change to our data collection and processing practices. We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices.

If we make material changes to this Privacy Policy, we will notify you in a manner that we believe will be reasonably likely to reach you (which may include posting a new privacy policy on Platform – or a specific announcement on this page or on our blog). Any modifications to this Privacy Policy will be effective upon our posting of the new terms (or as otherwise indicated at the time of posting).

Contact Us

If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at [email protected], or write to us at:

IPXO LLC,
3132 State Street,
Dallas, TX 75204, USA

Information for UK and European Union Users

Personal information

References to “personal information” in this Privacy Policy are equivalent to “personal data” as defined by the European Union General Data Protection Regulation 2016/79 (“GDPR”), and any laws or regulations that amend, supplement, supersede, repeal or replace the GDPR or that are intended to ensure the continued application of the GDPR in the United Kingdom once it ceases to be a member state of the European Union (including the Data Protection Act 2018 (collectively, “UK Privacy Law”). We are the processor of your personal information for GDPR and UK Privacy Law purposes.

Legal bases for processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information which are based on one or more of the following:

Consent: The consent you provide to us when you share or submit your personal information with or to us.
Legitimate interest: Our “legitimate interest,” as defined by GDPR and UK Privacy Law, or the legitimate interest of a third party, including you. For example, we may use your data for fraud and security monitoring to ensure our networks and websites are secure, to administer and conduct our business with you, and to respond to your requests, inquiries and complaints.
Contract: Our performance of a contract, directly or indirectly, between us and you or your employer.
Legal Obligation: Our compliance with a legal obligation that we are or may be subject to.

Grounds for data processing

Your personal data is mainly processed for the purpose of providing you the best services under the legal basis of performance of the contract between You and IPXO, as provided in our Terms of Service. We also process Your personal data under the legal basis of our legitimate interest:

to properly administer business communication with users;
to operate Platform and ensure its secure, reliable, and robust performance;
to receive knowledge of how Platform and applications are being used.

IPXO may process your personal data for marketing purposes in the following cases: when we obtain your consent for such processing (the legal basis for processing, in this case, is your consent) or when applicable law permits us to contact you without separate consent (under the legal basis of a legitimate interest).

Term for storing personal data

We keep your personal data for as long as reasonably necessary for the purposes set out in this Privacy Policy. The data might be kept longer if required for tax, accounting, payment processing purposes, to ensure we would be able to defend or raise a claim, or where we have a specific need – though we will generally not keep personal data for longer than two years following the last date of communication with you, unless the data is necessary in order to provide the service.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We keep basic information about our customers for the duration of the agreement.

If you have questions about the legal bases of how we process your personal information, contact us at [email protected].

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Your rights

GDPR and UK Privacy Law gives you certain rights regarding your personal information. In relation to your personal information that we hold you may request:

Access to your personal data held by us as a data controller.
To rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
That we erase your personal data.
Where we process personal data based on consent, you may withdraw your consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
You may have other rights to restrict or object to our processing of personal data and the right to data portability.
You may request information about, or human intervention into, any automated data processing that we may undertake.

You can submit these requests by email to [email protected] or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you explain, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns.

Cross-Border Data Transfer

Whenever we transfer your personal information out of the European Economic Area (EEA) to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:

The consent you provide to us when you share or submit your personal information with or to us, and when you visit Platform;
Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see the European Commission Model contracts for the transfer of personal information to third countries;
or
Other valid and applicable safeguards under GDPR and UK Privacy Law.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

Additional Information for Californian Consumers

The California Consumer Privacy Act (Assembly Bill 375), as amended (“CCPA”), affords Californian consumers specific rights regarding their personal information.

We are also required under Californian and similar laws to specifically disclose the categories of information that we have collected and sold or disclosed for any commercial purpose for the prior twelve-month period. We do not sell or disclose ‘personal identifiers’ or any other category of collected personal information for any commercial purpose or for the commercial benefit of any party. We have not done so in the past 12-months or at any time prior to that.

If you are a California resident, you can implement your rights as provided in the CCPA by contacting us at [email protected]. As per definitions in the CCPA, please note that IPXO does not sell your personal information.

For more information on the CCPA please visit https://www.oag.ca.gov/privacy/ccpa.

Changes to our privacy statement

Updates to this privacy statement will appear on this website. This privacy statement was last updated on 27 May 2021.