XD Innovaion has always recognized data protection as an important topic for its stakeholders in the digital age and understands the responsibility that comes with the handling of personal data. This Privacy Policy describes the privacy practices of XD Innovation related to personal data collected, used, stored and otherwise processed.
Please be aware that some supplemental country terms may be applicable as detailed at the end of this Privacy Policy.
This privacy policy applies to the personal data XD Innovation processes as a data controller, i.e. as the party that determines what personal data to collect online (including in connection with XD Innovation websites, mobile apps) or offline and to what end.
When you use a XD Innovation cloud offering ordered by your employer or school, the processing of your personal data is determined and administered by its own privacy statement and not by this privacy policy. Should you have any concern about how and why your personal data is processed within this framework, please refer to your employer or school as the case may be.
In addition, XD Innovation only collects personal data from children, who are considered minors under the applicable data protection law, with the prior consent of their parents or guardians. Such consent is required before a minor can create a user profile or use any XD Innovation products or services. If the child is a minor they must provide an email address for their parent or guardian to receive a message from XD Innovation instructing them on how to provide their consent. Schools should always ensure that they have received permission from parents or guardians to do so. Parents or guardians can ask XD Innovation to review the personal data collected about their child, to remove it and terminate the child’s account or make any other request regarding their child’s personal data by submitting a request via https://xdinnovation.com/contact-us/ whether or not they gave consent to collect their child’s personal data. If XD Innovation learns that it has collected personal data from a child, it will delete that information as quickly as possible unless his or her authorized representative is willing to ratify the situation.
For your convenience, hyperlinks may be posted on the XD Innovation websites or apps that link to other websites or apps that XD Innovation does not own or control. This privacy policy is not applicable to them and XD Innovation has no liability for the content of third-party websites nor the personal data they collect.
Personal data means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the natural person.
Depending on the purposes detailed below, personal data processed by XD Innovation includes:
- Personal and Business contact information such as first and last name, postal address, email address, telephone number(s) and job title.
- Profile information such as user ID, login and password, profile picture, university, degree, certification and courses taken; type of organization (company, school, etc.), organization name, organization size, department, industry and sub-industry sectors.
- Transaction information details related to purchases you make, including through XD Innovation websites and apps, event registrations and billing data (such as credit card details, bank account information).
- Operation and usage data (IP and Mac Addresses, logs, etc.) on how you use XD Innovation websites, apps and services, including data from cookies as described below and through the XD Innovation marketing preferences Center as applicable.
In any event, the personal data processed by XD Innovation is limited to data necessary for the purposes described in this Privacy Policy. XD Innovation will only process personal data from a parent or guardian of a minor child for purposes of obtaining their consent to collect the child’s personal data. If they do not provide that consent within a reasonable period of time, XD Innovation will delete this personal data.
XD Innovation will process your personal data for one or several of the following purposes.
With your Consent
- To communicate with you, including when you request information related to XD Innovation products and services, and more generally to manage XD Innovation marketing activities.
- To ascertain your requirements and interests and provide you with the most suitable products and/or services.
- To provide you with a personalized, interactive use of XD Innovation websites and apps and allow you to access all their features.
- To enable you to display certain of your personal information related to your profile while exchanging ideas and other information about XD Innovation products and services with other users of XD Innovation websites and apps.
To provide you with XD Innovation products or services
- To enable you to
- Register for an event, seminar, webinar.
- Enter a contest.
- To enable XD Innovation to manage its business relationships with you, (including sales opportunities, commercial offers, purchasing, contracts, orders, invoices, which may include conversational data triggered via chat functionalities on XD Innovation websites and apps, contact forms, emails, and voice messaging data, delivery of XD Innovation products, support or professional services).
- To manage your training and/or certification on XD Innovation products and services, which may include tracking your learning progress in order to make this information available to you.
If you attend an event organized by XD Innovation, you may be asked for health information for the purpose of identifying and being considerate of individuals who have disabilities, special dietary requirements as well as other additional personal data that are necessary to be processed throughout the event.
To comply with the following legitimate interests:
XD Innovation takes into consideration and balances any potential impact on you (both positive and negative) and your rights before processing your personal data for legitimate interest purposes. Unless XD Innovation has your consent or is otherwise required or permitted to do so by law, XD Innovation will not use your personal data in situations where the impact on you outweighs its legitimate interest in processing your personal data:
- To improve your experience.
- To remember your settings.
- To provide you with information related to marketing activities for similar goods and products if you are already using XD Innovation products and services.
- To enable XD Innovation to manage its business relationships when you are acting on behalf of a XD Innovation prospect or customer (including sales opportunities, commercial offers, purchasing, contracts, orders, invoices, which may include conversational data triggered via chat functionalities on XD Innovation websites or apps, contact forms, emails, and voice messaging data, deliver of XD Innovation products, support or professional services).
- To manage the XD Innovation Anti-Privacy and Compliance program. Within this program, XD Innovation may combine your personal data together with additional relevant publicly available information or personal data collected through other processing activities.
- To create anonymous data for analytics and for compliance, fraud prevention and safety.
To comply with law
- To manage XD Innovation legal obligations related to applicable export laws, trade sanctions, and embargoes issued, by the European Union and its member states, and of the United States of America and other countries, if any. This may include (i) conducting automated checks of any user registration data identified in this Privacy Policy and other information you provide about your identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when you update your information; (iii) blocking of access to XD Innovation services and systems in case of a potential match; and (iv) contacting you to confirm your identity in case of a potential match;
- To keep your financial data with a third party payment provider.
XD Innovation does not store your personal data for more time than necessary and only as long as required to fulfill the purposes set out above. Retention periods may vary depending on the data categories and the processing activities. To determine the appropriate retention period for personal data, XD Innovation considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which XD Innovation processes your personal data and whether XD Innovation can achieve those purposes through other means, and the applicable legal requirements:
- Where XD Innovation is required to comply with a legal obligation, the retention period will be determined according to the applicable law.
- Where you gave your consent, until you withdraw it.
- Where XD Innovation has entered into an agreement with you or your employer, as long as the agreement is into force plus the applicable local statutes of limitations.
- Where XD Innovation has a legitimate interest in using your personal data, for a limited period of time appropriate to ensure a fair processing of your personal data or until you object to XD Innovation’s use of your personal data.
Where your personal data is required to assert or defend against legal claims, XD Innovation will retain your personal data until the end of the relevant retention period or until the claims in question have been settled.
XD Innovation does not rent or sell information but may share your necessary personal data for certain business purposes with the following categories of organizations:
- Within XD Innovation group: XD Innovation Group is a worldwide multi-tiered organization, located in the Americas, Asia and Europe to provide you with responsive and proactive services. In that globalized context, XD Innovation may need to share your personal data for example to provide you with support services.
- Event or marketing sponsors: XD Innovation may share your personal data with trusted sponsors. When you register for an event, XD Innovation may share your name, company, and email address with other participants and sponsors of the same event for the purpose of communication about the event and the exchange of ideas.
- Third parties acting on XD Innovation behalf: XD Innovation may share your personal data with third party vendors, consultants and other service providers that XD Innovation employs to perform tasks on its behalf (such as hosting services by a third-party or payment services to enable you to purchase from XD Innovation products or services) or to protect XD Innovation’s legal interests (such as in the event of a sale of assets to a third company, or a change of control or a total or partial liquidation of XD Innovation ).
- Law enforcement: Under certain circumstances, XD Innovation may also disclose your personal data if required by law or if XD Innovation believes in good faith that such disclosure is reasonably necessary to comply with legal process (for example, a warrant, a subpoena, or other court order) or protect the rights, property, or personal safety of XD Innovation , XD Innovation’s customers, or the public.
When accessing a XD Innovation website or app, please note that through your continued use of it, if you are located in a different country than the XD Innovation website or app, you consent to the transfer of your personal data to a country outside of your own.
As part of a worldwide multi-tiered organization, XD Innovation may transfer your personal data from Europe (or a country that is considered as offering an adequate level of protection as adopted by the European Commission on the basis of Article 45 of the General Data Protection Regulation 2016/679 (GDPR)) to another country. This can for example happen when XD Innovation provides you with training, support services or cloud offerings. XD Innovation continually monitors the circumstances surrounding any transfer in order to ensure that these transfers maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR and relies on the Standard Contractual Clauses issued by the European Commission in the absence of an adequacy designation.
Depending on the applicable data protection laws, you may have some or all of the following rights with regard to your personal data:
- Access your personal data;
- Request the rectification, completion, update or erasure of your personal data.
- Restrict processing.
- Obtain a copy of your personal data stored by XD Innovation.
- Object to specific processing of your personal data if that processing is based on legitimate interests; and
- Data portability.
If the processing of your personal data is based on your consent, you have a right to withdraw that consent at any time.
If you have an account, you can exercise your rights by logging on to your account. Otherwise, you may exercise your rights by submitting your request here:https://xdinnovation.com/contact-us/. Parents can exercise these rights if allowed by applicable law on behalf of their minor children by this same method.
Depending on the scope of the request, and if permitted under applicable law, XD Innovation may charge a reasonable fee to cover costs incurred in connection with such request. XD Innovation may deny access to your personal data in limited circumstances in accordance with applicable laws and regulations or if XD Innovation’ legal grounds override your legitimate interest to privacy.
XD Innovation maintains appropriate technical and organizational measures to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction during transmission and once in its possession. However, while XD Innovation strives to protect your personal data, in light of the inevitable risks linked to the Internet, XD Innovation cannot guarantee full protection against any leak.
It is important for you to exercise caution to prevent unauthorized access to your personal data. You are responsible for the confidentiality of your password and information appearing on your account. Consequently, you must ensure that you log out of your session in the event of shared use of a computer.
In order to improve your browsing experience on XD Innovation websites and apps, XD Innovation uses cookies or other similar technologies that may process your personal data.
Depending on the website or app, XD Innovation uses different types of cookies:
- Strictly necessary cookies are always used, are essential for you to properly browse the XD Innovation website or app and cannot be switched off. For example, they allow you to save your personalization settings (choice of language, presentation of a service, saving your shopping cart).
- Functional cookies are used in order to improve the performance of the XD Innovation websites and apps, to provide you with optimized features and a more personal experience by collecting information when you visit a XD Innovation website or app. Some of them, that are solely performance cookies, collect aggregated information that are therefore anonymous.
- Advertising cookies are implemented by XD Innovation or third parties, in order to build a profile of your interests, to provide you with personalized and targeted content. They do not store personal information directly, but are based on uniquely identifying your browser and internet device.
You can remove or reject functional and advertising cookies. However, if you do not accept certain cookies, some functionalities and features of the sites and apps may not function properly and you may experience some inconvenience in their use.
You can set your cookie preferences at any time by clicking “Manage my cookies preferences” link in the footer of the website.
XD Innovation is committed to ensuring the privacy of personal data: You can contact the XD Innovation Data Protection Officer via the following form:https://xdinnovation.com/contact-us/ if:
- You have any questions about this Privacy Policy.
- You encounter any issue when having access to your personal data or related to your rights as described above.
- You believe that XD Innovation is not complying with the GDPR or the applicable local data protection laws.
- You have a reason to believe that the security of your personal data has been compromised or misused.
When you want to report a claim by lodging a complaint to the XD Innovation Global Data Protection Officer, you will need to send a letter to the address mentioned at the end of this Policy or submit your claim using the form referenced above containing (in addition to the information required by the form and depending on the type of rights) the name or reference of the concerned processing and any additional information as reasonably requested by the XD Innovation Global Data Protection Officer.
If your usual place of residence is in European Union, Lichtenstein, Norway or Iceland, you have a right to file a complaint with your local data protection authority.
This Privacy Policy may be updated from time to time in accordance with XD Innovation requirements and circumstances, or where required by applicable laws and regulations so please check back periodically for updates. If major changes occur to this Privacy Policy, XD Innovation may inform you via email or by posting a notice on XD Innovation websites or apps.
Last modification: April 21, 2022.
Depending on where you are living, some additional terms as detailed below may be applicable to you. Where the Privacy Policy refers to “personal data”, it shall be interpreted, as applicable, to mean “personal information” as defined by the applicable data protection law.
All payments made in connection with the XD Innovation website or app are processed through a third party payment service provider to which XD Innovation or you provide necessary personal data to enable you to purchase XD Innovation products or services. These payment service providers may share your personal data with other services providers (such as verification service, web posting, data analytics) to perform the services in connection with completing a transaction including the processing of payments. XD Innovation authorizes such payment service provider and related service providers to use and disclose your personal data as long as necessary to perform the foregoing services provided they comply with legal requirements.
With regard to your rights or any concern you may have related to your personal data, you may either contact XD Innovation by filling in this form https://xdinnovation.com/contact-us/
XD Innovation may collect the following categories of personal information under the circumstances as below:
- Registration: You may register an account through XD Innovation websites and other apps and XD Innovation will collect your personal and business contact information
- Purchase of XD Innovation products and services: Transaction information details related to your purchases may be collected by XD Innovation to perform the deal
- Use of XD Innovation products or services: When you request for or use XD Innovation products or services, XD Innovation will collect your profile information and other specific information depending on the needs of such products or services to be provided by XD Innovation.
- Feedback: You may submit feedback in a survey or interact with XD Innovation through XD Innovation websites and other apps, where XD Innovation may collect such information from you
- Cookies: XD Innovation will collect your operation and usage data through cookies when you visit XD Innovation websites and other apps, in particular in order to review your network environment and constantly improve the XD Innovation service to make it more user-friendly.
Sensitive Personal Information
Sensitive personal information means personal information the divulgence, illegal provision or misuse of which may endanger the bodily or property safety or may result in damage to personal reputation or bodily or mental injury or discrimination, which may be composed of information concerning race, religion, political position, personal property, personal health and physiological information, personal identity and network identifier information. In this Privacy Policy, personal sensitive information collected or processed are summarized as below for your attention.
- Financial personal information (credit card number and expiry date, name and address of the cardholder).
- Conversational information triggered via chat functionalities on XD Innovation sites or apps (contact forms, emails, and voice messaging data).
- Health information (for the sole purpose of identifying and being considerate of individuals who have disabilities or special dietary requirements throughout events to which you attend).
Marketing Communications
If you accept to receive marketing communications and other relevant information from XD Innovation, XD Innovation will send you this commercial information, as well as recommendation of contents that you may be interested in via SMS, email or phone. You can unsubscribe from receiving such marketing materials with the help of customer service, or through the instructions in the SMS and email.
International Data Transfers
Your Personal Information will be stored on servers in China and France. As part of a worldwide multi-tiered organization, XD Innovation may share your personal information outside China, for example, with other XD Innovation affiliates and with XD Innovation suppliers or business partners, to support the products and services provided to you or the organization you are working for. XD Innovation will comply with the Chinese Regulations for such transfer, including taking reasonable steps to safeguard the privacy of your personal information in accordance with the Chinese Regulations.
What Are Your Rights And Choices
- Withdraw your consent: certain basic personal information may be required by XD Innovation to provide you with products or services. For personal information , which is not necessary, you may withdraw your consent at any time.
- Delete your account: You may ask for the deletion of your account at any time, and XD Innovation will process your request as soon as practicable after verifying your identity and related authorization.
- File a complaint: You can address a request to XD Innovation if you have any concern related to the processing of your personal information.
With regard to your rights as mentioned above, you may either contact XD Innovation by filling in this form https://xdinnovation.com/contact-us/
XD Innovation will provide you with a response to your request without undue delay and in any event within a maximum period of fifteen (15) days of receipt of a complete request.
Where the Privacy Policy refers to “Personal Data” it shall be interpreted to mean “Personal Information” as defined in Act on Protection of Personal Information of Japan (“APPI”) but only for personal information subject to APPI.
Additional Information Related To Your Personal Information Processed By XD Innovation
- Items regarding joint use of your Personal Information
Your Personal Information may be shared with XD Innovation affiliates and third parties (including, the organizations involved with the events) that are contributing to the performance of one or several purposes listed in the Privacy Policy. Your Personal Information will be shared according to a secured process. The items regarding joint use are as follows:
– Personal Information jointly used: Personal Information as described in “WHAT PERSONAL DATA IS COLLECTED AND PROCESSED BY XD INNOVATION ” above.
-Entities with whom Personal Information may be jointly used: Entities as described in “WITH WHOM XD INNOVATION SHARES YOUR PERSONAL DATA” above.
-Purposes of joint use of Personal Information: Purposes of use as described in “WHY YOUR PERSONAL DATA IS PROCESSED BY XD INNOVATION?” or for the organizations involved with the events, purposes of use as described in the registration page.
- Your rights
With regard to your rights to request disclosure of purpose of use, correction, addition, deletion, suspension of use/erasure, stop of third party provision regarding Personal Information held, you may either contact XD Innovation Global Data Protection Office by filling in this form https://xdinnovation.com/contact-us/
With regard to your Retained Personal Information (as defined in APPI), for notification of purpose of use or request for disclosure of Retained Personal Information, we may charge JPY 800 per request.
Processing and Sharing of Your Personal Data
XD Innovation is the operator (as defined in Federal Law No. 152-FZ “On Personal Data” of 27 July 2006) of your personal data under this Privacy Policy.
You hereby expressly consent to XD Innovation instructing third parties listed in this privacy policy to process your personal data for the purposes provided for in this privacy policy. XD Innovation will be responsible for the processing of your personal data by such third parties.
Processing of Health Information
If you attend an event organized by XD Innovation, and you are asked for health information for the purpose of identifying and being considerate of individuals who have disabilities, special dietary requirements, XD Innovation will only process such health information upon your separate consent in a written form
International Data Transfers and Localization of Personal Data
If you are a Russian Federation resident, XD Innovation will provide recording, systematization, accumulation, storage, adjustment (update, modification), and extraction of your personal data with the use of databases located in the territory of the Russian Federation. XD Innovation may transfer your personal data to another country and subsequently store your personal data on additional databases. XD Innovation may also transfer your personal data to a country that, under the applicable data protection laws, does not provide for the adequate level of protection of data subject’s rights. You hereby expressly consent to such transfer for the purposes of performing XD Innovation’s obligations under this Privacy Policy.
What Are Your Rights
With regard to your rights or any concern you may have related to your personal data, you may either contact XD Innovation by filling in this form https://xdinnovation.com/contact-us/
Under the California Consumer Privacy Act (“CCPA”) applicable to California residents, you are entitled to benefit from the following additional provisions regarding your personal information.
What are the Categories of Personal Information Collected
The categories of personal information XD Innovation collects about California residents are identifiers (e.g. name, address, email, phone number, job title, and transactional information), and internet or other electronic network activity information (e.g. usage information, IP and MAC address, cookie information, and customer feedback).
What Are Your Rights And Choices
You have the right to request that XD Innovation discloses to you certain information about XD Innovation’ collection and use of your personal information over the past 12 months. That information includes:
- The categories of personal information XD Innovation collected about you;
- The categories of sources from which XD Innovation collected your personal information;
- XD Innovation business or commercial purpose for collecting, or sharing your personal information;
- The categories of third parties with whom XD Innovation shares your personal information, if any;
- A copy of your personal information and a list of recipients, as applicable.
To exercise the rights described in the Privacy Policy you can submit the request using the following form: https://xdinnovation.com/contact-us/
Only you, or a person, or a business entity registered with the California Secretary of State to conduct business in California that you authorize to act on your behalf, may make a request related to your Personal Information. The request must provide enough information to allow XD Innovation to 1) reasonably verify you are the person about whom XD Innovation collected Personal Information or an authorized representative and 2) enable XD Innovation to properly understand, evaluate, and respond to it. Making such a request does not require you to create an account with us. XD Innovation will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.
Non-Discrimination
XD Innovation will not discriminate against you (for example by denying you products or services, charging you a higher price or giving you a different level or quality of service) for exercising any of your CCPA rights.
Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which XD Innovation collects and processes your personal information, your privacy choices and rights under California law or wish to exercise your privacy rights, please do not hesitate to contact XD Innovation at:
Email- contact@xdinnovation.com
Postal Address: XD Innovation SILICON VALLEY
46750 Fremont Blvd. Suite 204
Fremont, CA 94538
Or by contacting the XD Innovation Data Protection Officer via the following form:https://xdinnovation.com/contact-us/