X-CLUSIVE CONTENT PRIVACY POLICY

 

If you have any questions about our privacy practices, please refer to the contact link located on our website for information on how to contact us.

 

We collect, process and retain personal data to the extent necessary to provide users with our service. This privacy policy applies to the information we collect:

 

• On this Web site,
• on emails, text messages and other communications between you and this website.
• Through mobile applications that you download from this website, which provide dedicated non-browser-based interaction between you and this website, or
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this privacy policy.

 

Not applicable to information collected by:

 

• By us offline or by any other means, including on any other website operated by us or by a third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any applications or content (including advertising) that may link to or be accessible from or on the Website. Clicking on such links or enabling such connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements.

 

THE DATA WE COLLECT ABOUT YOU:

Personal Data, or Personal Information, means any information about an individual from which that person can be identified ("Personal Information"). It does not include data that has been anonymized or pseudonymized.

 

We may collect, use, store and transfer different types of Personal Data about you, which we have grouped as follows:

 

• Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

 

• Contact details include billing address, email address and telephone numbers.

 

• Financial data includes bank account and payment card details.

 

• Transaction Data includes details of payments to and from you and other details of products and services you have purchased or received from us.

 

• Technical Data includes Internet Protocol (IP) address, your login details, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

 

• Profile data includes your username and password, purchases or orders placed by you, your interests, preferences, comments and survey responses.

 

• Usage data includes information about how you use our website, products and services.

 

• Marketing and communications data includes your preferences for receiving marketing from us and our third parties and your communication preferences.

 

We may also collect, use and share your data to produce and share aggregated information that does not identify you. Aggregate data may be derived from your personal data, but it is not considered personal data because this data does not directly or indirectly reveal your identity. We may also aggregate your usage data to calculate the percentage of users accessing a specific website feature. For example, we may use your data to generate statistics about our users, to calculate the percentage of users accessing a specific website feature, to calculate ad impressions served or clicked on, or to publish visitor demographics.

 

We do not collect special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership or health information). However, depending on how you use our website and services, your personal information may include biometric information or information that allows conclusions to be drawn about your sex life or sexual orientation ("Sensitive Personal Information"). The collection, use and disclosure of such Sensitive Personal Information is necessary to provide you with some of our services.

 

BIOMETRIC DATA

 

We cooperate with third-party service providers such as Ondato who provide identity verification, customer onboarding, data validation, authentication tools to help verify your identity and age and to verify the authenticity of any identification documents you provide using facial recognition technology. Facial recognition technology creates a mathematical representation of your face and detects facial features from the live scan of your face, your selfie and the government-issued identification you submit or have previously submitted to us. This mathematical representation, which is considered biometric information/identifier/data under the laws of certain states and countries, is not shared by our service providers with us and is deleted by our service providers after its creation. Information derived from this mathematical representation, which may be considered biometric information/identifier/data under the laws of certain states and countries, is shared by our service providers with us and subsequently deleted by us, as described below.

YOUR BIOMETRIC INFORMATION WILL BE USED FOR:

 

• verify that you are a real and live person and avoid using methods that would allow a user to identify themselves as someone else.
• match your selfie with your government-issued identification that you will send or have previously sent to us to ensure that no one is impersonating you.
• help confirm your age.

 

We may disclose your biometric, facial scan, selfie and government-issued identification information (including any government-issued identification or selfie you have previously submitted to us) within our corporate group members and with third party service providers. These entities may be located in jurisdictions that do not offer the same level of data protection as your jurisdiction. We, and any of these entities, may perform facial recognition and collect your biometric information from your facial scan, selfie and any government-issued identification, and use your biometric information for the above purposes.

 

Biometric information shared by our service providers with us will be stored for as long as you maintain an account on the website. We will delete your biometric information within two (2) years of deleting your account from the website or withdrawing your consent, subject to any legal obligations we may have.

 

You will be asked to provide your consent for biometric processing, from which you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any collection, use, processing or disclosure that occurred prior to the withdrawal.

 

How is your personal information collected?

 

We use a variety of methods to collect data from and about you, including through:

 

• DIRECT INTERACTIONS. Information you provide when you perform search queries on our Website or complete forms on our Website, in particular when registering to use our Website, subscribing to our service, posting material, participating in surveys, entering a contest or promotion sponsored by us, reporting a problem with our Website or requesting additional services.

 

• AUTOMATED TECHNOLOGIES OR INTERACTIONS. Please see "Cookie Usage Policies" in a section of our website" for details on how we may automatically collect your personal data.

 

• THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES. We may receive personal data about you from various third parties, for example, other websites controlled by us or members of our corporate group, our business partners or other third parties and publicly available sources.

 

USER CONTRIBUTIONS

 

We may provide areas on our website where you can post information about yourself and others and communicate with others, upload content (e.g., images, videos, audio files, etc.) and post comments or reviews of content found on the website. Such postings are governed by our terms of use found on our website http://xclusive-content.com/. If you use a forum, blog, user comment, community or other social or interactive sharing features that may be offered through our website, you should be aware that any personal information you submit, display or post there is considered publicly available and may be read, collected, used and disclosed by other users of those features, by us and other third parties without restriction, except to the extent limited access features are available, if any. In addition, such postings may appear on other websites or when you search on the subject of your posting. If you post your e-mail address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. Once you have posted information, you may not be able to edit or remove such information. To request removal of your personal information from our blog, sharing service or community forum, for example, please email us at info@xclusive-content.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

 

As you browse and interact with our website, we use automatic data collection technologies to collect certain information about your computer, browsing actions and patterns, including information such as your IP address, browser type, operating system, referring website, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms and cookie information.

 

We also use these technologies to collect information about your online activities over time and across third-party websites or other online services ("interest-based advertising"). See "Choices about how we collect, use and disclose your personal information" below for information about how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that allow consumers to exercise choice about behavioral tracking.

 

LEGAL BASIS: we rely on the following three legal bases to process your personal data for the specific purpose of providing, improving and developing the website as described above.

 

1. we process this information in order to properly perform our contract with you;
2. our legitimate business interests in processing your personal data, specifically for the purpose of improving the website and our users' experience with it, which we have determined can only be achieved by processing your personal data. We consider the processing of your personal data to be proportionate to your interests, rights and freedoms;

 

3. to the extent necessary to perform our contract with you and to personalize your experience, provide your consent to process special categories of data.

 

WE PROTECT OUR USERS AND OUR WEBSITE FROM:

 

• Detect and prevent fraud, spam, abuse, security incidents and other harmful activities.
• Conduct security investigations and risk assessments, including reports that third parties may file about you or the content you have uploaded in accordance with the Terms of Service.
• Comply with our legal obligations, including assisting in the prevention of crime, including child sexual abuse material or non-consensual sexual acts.
• Resolve any disputes with any of our users and enforce our agreements with third parties.
• Contact you about any reports of abuse (if you do not submit them anonymously), or any requests for removal for copyright infringement or counter-notices (which cannot be submitted anonymously) that you may submit pursuant to the Terms of Service.
• Enforce our Terms of Service and other policies.

 

GLOBAL OPERATION

 

When we transfer, store and process your personal data outside the United States, we ensure that appropriate security measures are in place to ensure an adequate level of data protection.

 

CHANGES TO THIS PRIVACY POLICY

 

We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Website and update the "Last Updated" date at the top of this Privacy Policy. For individuals who have created an account on or through this website we will also send you an email to inform you of any changes. If you do not agree with the revised Privacy Policy, you may cancel your account. If you do not cancel your account prior to the date the revised privacy policy becomes effective, your continued access to or use of the website will be subject to the revised privacy policy.