Last modified: 31 October 2022
Who we are
We are XetData, Inc. (“XetData,” “we,” “us,” and “our”), a company based in the United States that offers its XetHub™ asset management platform, which enables collaboration on large files while automatically tracking asset provenance and file access to ensure compliance and reproducibility (the “Platform”). The Platform comprises our main websites and associated webpages at xetdata.com and xethub.com (collectively, the “Site”), among other things.
Our intended users
The Platform is for use by persons at least 18 years of age. It is not directed to anyone under the age of 18. We do not knowingly collect Data from users who are under the age of 18. If we become aware that we have gathered Data from a person under the age of 18, we will attempt to delete such Data as soon as practical, subject to our obligations under any applicable laws.
Data we collect and how we use it
Described below are the types and categories of Data we collect when you access and use the Platform (collectively, “Data”). We never sell your Data, and we always have a lawful basis for collecting the Data, but that lawful basis might be different for different types and categories, and we describe those uses below. Regardless, we never use your Data for any purpose other than the purpose for which we collected the Data in the first place, unless we get your express prior consent. In all cases, we will comply with applicable privacy laws and cease processing your Data after the legal right, obligation, or other lawful basis expires.
When you enter into an agreement with us – for example, by registering for, subscribing to, enrolling with, or otherwise accessing or using the Platform – we will process your Data for the purposes of fulfilling the terms of our agreement with you. In that case, our processing of your Data is based on our agreement, so your withdrawal of consent will only be effective after the purposes for processing that Data have been fulfilled and after we no longer have a legal obligation to keep that Data.
Lawful Basis for Processing: Our lawful basis for processing Registration Data is our agreement with you and your consent. We can only provide certain of the features and functions of the Platform to you if we have the Registration Data, so we need to collect, use, store, and process that Registration Data during the term of our agreement. Even when the Registration Data is not critically necessary to the provision of the Platform, we may still process that Registration Data to facilitate the interactions with you contemplated by our agreement with you.
How We Use It and Who We Share It With: Registration Data is accessible generally only to us and to you. We use it to provide the Platform to you. In limited circumstances, we may share your Registration Data with our third-party service providers that help us provide the Platform to you and are under obligations to us to protect the confidentiality of your Registration Data. At times, we will share the Registration Data with other third parties at your request or to fulfill requests that you make of us. We may also use your Registration Data to offer our own products and services to you, either directly through emails or through third-party platforms, but you may opt out of those communications at any time. We will never share your authentication credentials with any third party.
Lawful Basis for Processing: Our lawful basis for processing Engagement Data is (1) our agreement with you, (2) our obligation to provide you with the features and functions of the Platform in which you have registered, subscribed, or enrolled; and (3) our legitimate interest in improving the Platform based on the Engagement Data we receive from you.
How We Use It and Who We Share It With: Your Engagement Data is accessible to us, to you, and to limited third parties that we use to provide and improve the Platform. If we share your Engagement Data with a third party, that third party will be obligated to us to protect the confidentiality of your Engagement Data. We may also share Engagement Data with other third parties at your specific request. We may also use Engagement Data to make improvements to the Platform. We do not de-identify or aggregate your Engagement Data for use for any purpose other than to provide the Platform to you and to improve the Platform, which may include understanding how the Platform is used by Users.
- Description of Usage Data: “Usage Data” consists of the following and similar information:
- Information about your interactions with the Platform, most commonly our Site, which includes the date and time of any requests you make. This also may include details of your use of third-party products and services made accessible to you via the Platform, if any.
- Adjustments you make to the default state of your User Account, such as custom settings.
- The timing of the information you post to the Platform, including messages you send or receive via the Platform and your interactions with our support personnel, but not including the content of those messages and interactions, which are Engagement Data (as defined above).
- Technical data, which may include URL information; cookie data; your IP address; the types of devices you are using to access the Platform or navigate to the Site; unique device IDs; device attributes; network-connection type (i.e., Wi-Fi, 4G, LTE, Bluetooth); provider, network, and device performance; browser type; language; information enabling digital, mouse movements (including scrolling data); and GPS data (only upon your express prior consent).
- Information concerning rights management, operating system, and application version.
- Application features, pages viewed, and application crash information.
Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our agreement with you and (2) our legitimate interest in improving the Platform based on the Usage Data we receive from you.
- Description of Payment Data: “Payment Data” is only collected when you choose to access or use those elements of the Platform that we provide to Users in consideration for your payment of a fee, or fees. Payment Data is the information necessary for us to process your payment. Payment Data will vary depending on the payment method you use – for example, bank transfer or credit card – but will include information such as:
- First and last name.
- Date of birth.
- The information related to your applicable account, or accounts, required by our applicable authorized payment processor.
- Address and postal code.
- Mobile phone number.
- Email address.
Lawful Basis for Processing: Our lawful basis for processing Payment Data is (1) our agreement with you and (2) our legitimate interest in improving the Platform based on the Payment Data we receive from you.
How We Use It and Who We Share It With: We only use your Payment Data to facilitate payments authorized by you, and we only communicate Payment Data to those parties who are strictly necessary for that purpose.
Who we share your information with
Except where a specific limitation is noted above, we may share your Data as follows:
- At Your Instruction. If you request us to make your Data available to a third party, and such request furthers the purposes of the Platform, we will do so.
- Sharing with Third-Party Vendors. In certain cases, we use the services of third-party vendors to assist us in providing certain features and functions of the Platform. We may share your Data with such third-party vendors solely for that purpose, and we will require those third parties to abide by our privacy policies and data security practices or privacy policies and data security practices that conform in all material respects with ours.
- Public Access. We may share information between Users and with the public that you have designated as public information on the Platform in order to facilitate the provision of the features and functions of the Platform to Users.
- Third-Party Offers. We may allow third parties to offer you their products and services, including offers through our Platform, co-branded web pages hosted by the third parties, or via email. Whether or not you decide to participate in any such offers is up to you. If you purchase a product or service on a co-branded web page or via a third-party offer on the Platform that requires you to submit financial and personally identifiable information, you are also consenting to our delivery of that information to the applicable third party. The offer will notify you if any financial or personally identifiable information will be shared. Such third party will be authorized to use the information in keeping with our contractual relationship with them and in accordance with their own privacy policies and data security practices. We do not control these third parties, and you acknowledge and agree that we are not liable for their acts or any failure to act on their part.
- Third-Party Service Providers. We may sometimes use a third party to provide certain elements of the Platform on our behalf, including sending emails to you, conducting surveys, or performing statistical analyses. In these cases, we may provide certain personal information, such as your first and last name and email address and other financial information necessary for the third-party service to be provided. However, these third parties are required to maintain the confidentiality of this information and are prohibited from retaining, sharing, storing, or using this information for any other purposes.
- Business Transitions. In the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets, the information we have about you will, in most instances, be part of the assets transferred. We reserve the right to transfer that information in connection with such transactions without notice to you, provided that the acquiror has expressed to us its intent to continue to operate the Platform for the benefit of you and other Users. We will not be required to obtain your consent for such a transfer.
- Legally Required Disclosure. We may disclose your Information if required to do so by law or in the good faith belief that such action is necessary to conform to one or more applicable laws; comply with a judicial proceeding, court order, or legal process served on us; protect and defend our rights or property; or investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of the Terms of Services.
Technologies we use
The technologies we use for Data collection may include the following:
- Web Beacons. Webpages included as an element of the Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count Users who have visited those webpages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Other Technologies. We may also use device identifiers, local storage, html modifiers, and different types of caching to help us understand the devices and Users who access and use the Platform. Those methods include device identifiers that are either hardware-based or software-based, persistent or non-persistent, and which may identify either a device or a software module within a device (such as a web browser).
Do Not Track options
Your web browser(s) may offer a "Do Not Track" option, which allows the individual to signal to operators of websites and online applications and services (including behavioral advertising services) that the individual does not wish such operators to track certain of their online activities over time and across different websites. The Platform does not support “Do Not Track” requests at this time, which means that we may collect information about your online activity both while you are using the Platform and after your use of the Platform.
Your rights regarding your data
Under applicable data security, privacy, and other laws, you may have certain rights related to your access and control of your Data. Such rights may include the following:
- The right to access, correct, update, or request deletion of your Data.
- The right to object to processing or restrict the processing of your Data. Please note that if you exercise this right, it may limit or eliminate our ability to provide you all or some of the elements of the Platform.
- The right to request portability of your Data.
- The right to opt-out of marketing communications we send you. You can exercise this right by clicking the "Unsubscribe" or "Opt-Out" link found in these communications.
- The right to not be subject to a decision based solely on automated processing, including profiling, known as Automatic Decision Making.
- The right to submit a complaint to any applicable regulatory authority about our processing activities.
- The right to opt-out of us sharing (as defined in the California Privacy Rights Act) your Data, including for direct marketing purposes, subject to certain legal exceptions.
We may use additional processes to verify your identity before we reveal or delete any of your Data, including two-factor or two-step authentication measures to ensure we can identify you.
Further, although we currently do not process Data without consent, if we at any time in the future process Data without your express consent, you may opt-out or withdraw consent at any time.
If our processing of your Data is based on your consent, you may withdraw your consent at any time, and we will cease collecting and processing your Data. However, in some cases, this may result in your inability to access and use all or some of the elements of the Platform, and your withdrawal of consent does not limit our ability to use the De-Identified Usage Data (as defined above) for use by us in connection with our legitimate business efforts in the future. In addition, your withdrawal of consent may not prevent us from retaining and processing Data if we have gathered such Data pursuant to a different lawful basis or to preserve legal claims. For example, if you give your consent for us to process your Data, but we are also required by law to keep your Data, that separate “lawful basis” will still apply, even if you withdraw your consent.
Please note that in cases where, by exercising any of the above rights, you end up limiting or eliminating our ability to provide you with all or some of the elements of the Platform, we shall have the right, but not the obligation, to cancel or suspend your User Account and/or terminate your access to or use of the Platform.
We will try to comply with your request(s) as soon as reasonably practicable. Upon receipt of your written request, we will provide you with a copy of your information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another User. In such circumstances, we will provide reasons for the denial to you upon request.
Please also note that, if you do opt-out of receiving marketing-related emails from us, we may still send you messages for administrative or other purposes directly relating to your use of the Platform, and you cannot opt-out from receiving those messages while continuing to use the Platform.
To exercise any of these rights, or if you have any questions about our processing of your Data, please contact us at email@example.com.
Privacy for California residents
California adopted the California Consumer Privacy Act (“CCPA”), which took effect at the beginning of 2020 and has now adopted the California Privacy Rights Act ("CPRA"), portions of which took effect on January 1, 2022. We comply with the requirements of the CCPA and CPRA to the extent they apply to us.
If you are a California resident, you may request to exercise your rights for any Data we have processed in the 12 months prior to your request. Such request covers any categories, sources, purposes, and, if applicable, third parties to whom we share the Data. Further, you can exercise any of your rights free of discrimination – for example, we cannot increase the fees charged to you or decrease the quality of the products or services provided to you because you exercise your rights.
For more information, please direct your questions to us at firstname.lastname@example.org.
Our security notices
The security of your Data is important to us. We use commercially reasonable efforts to store and maintain your Data in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Data that you provide to us. We have implemented procedures designed to limit the dissemination of your Data to only such designated personnel as are reasonably necessary to carry out the stated purposes we have communicated to you.
Third-party policies and data security practices
You may be able to access third-party websites and other tools and services or products via a link on the Site or made available as part of the Platform or via our other tools. The privacy policies and data security practices of these third parties are not under our control and may differ from ours. The use of any Data that you may provide to any third parties will be governed by the privacy policies and data security practices of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy or security of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policies and data security practices.
Our retention of data
You can help by informing us of any changes in your information or circumstances, such as a change of your personal contact information. If you would like to access your information; if you have any questions, comments, or suggestions; or if you find any errors in our information about you, please contact us at:
999 3rd Ave, 34th Floor
Seattle, Washington 98104