Privacy PolicyLast Updated: 30 Oct 2023Tokuten Pte Ltd (Tokuten Pte Ltd, together with all its affiliates including global subsidiaries, collectively "xalts," "we," " us," or "our") respects, and works hard to protect, your privacy.
Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy. Remember that your use of xalts's Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. You may print a copy of this Privacy Policy.What this Privacy Policy coversThis Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage. Additionally, this Privacy Policy does not cover information that we collect when we act as a service provider for our customers.Personal DataThis chart details the categories of Personal Data that we collect and have collected over the past 12 months:
Category of Personal Data
Examples of Personal Data We Collect
Categories of Third Parties With Whom We Share this Personal Data
Profile or Contact data
First and last name, Email
Service Providers
Device/IP data
IP address, Device ID, Domain server, Type of device/operating, system/browser used to access the Services
Service Providers
Web analytics
Web page interactions, Referring webpage/source through which you accessed the Services, Non-identifiable request IDs, Statistics associated with the interaction between device or browser and the Services
Service Providers
Geolocation data
IP-address-based location information
Service Providers
Other Identifying Information that You Voluntarily Choose to Provide
Identifying information in emails or letters you send us
Service Providers
Categories of Sources of Personal DataWe collect Personal Data about you from the following categories of sources:You
  • When you provide such information directly to us
  • When you use our interactive tools and Services
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.
  • When you provide such information directly to us.
  • Through Cookies (defined in the "Tracking Tools and Opt-Out" section below).
  • If you use a location-enabled browser, we may receive information about your location.
  • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.
Third Parties VendorsThis chart details the categories of Personal Data that we collect and have collected over the past 12 months:Our Commercial or Business Purposes for Collecting Personal DataProviding, Customizing and Improving the Services
  • When you provide such information directly to us
  • When you use our interactive tools and Services
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.
  • When you provide such information directly to us.
  • Through Cookies (defined in the "Tracking Tools and Opt-Out" section below).
  • If you use a location-enabled browser, we may receive information about your location.
  • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.
Marketing the Services
  • Marketing and selling the Services.
Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about xalts or the Services.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
  • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, xalts or another party.
  • Enforcing any agreements with you. Responding to claims that any posting or other content violates third-party rights. Resolving disputes.
How We Share Your Personal DataaWe disclose your Personal Data to the categories of service providers and other parties listed in this section.Service Providers
    These parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology and communication providers.
  • Support and customer service vendors.
Advertising Partners
  • These parties help us market our services and provide you with other offers that may be of interest to you. They include ad networks.
Legal Obligations
  • We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.
Business Transfers
  • All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Data that is Not Personal DataWe may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.Tracking Tools and Opt-OutThe Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data, usually text files, placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support "Do Not Track" requests sent from a browser at this time.We use the following types of Cookies:
  • Essential Cookies: Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
  • Functional Cookies: Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Retargeting/Advertising Cookies: Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled "Information about Interest-Based Advertisements."
You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.Information about Interest-Base Advertisements:We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads"). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users' activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.Data Security and RetentionWe seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personallyAccessYou have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
  • The categories of Personal Data that we have collected about you.
  • The categories of sources from which that Personal Data was collected.
  • The business or commercial purpose for collecting or selling your Personal Data.
  • The categories of third parties with whom we have shared your Personal Data.
  • The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.DeletionYou have the right to request that we delete the Personal Data that we have collected about you. To exercise the right, you or your Authorized Agent (defined below) must send us a request that:
  • It provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data.
  • It describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.You may submit a Valid Request by sending us an email us at: compliance@xalts.ioYou may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.Changes to this Privacy PolicyWe're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by updating the effective date and/or placing a notice on the website. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.Contact InformationIf you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at compliance@xalts.io
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