EFFECTIVE DATE: July 16, 2020
Xigo, LLC, an NTT Ltd company, (“us” or “we”), has created this Privacy Policy to explain what information we collect from individuals (“you”) who access the CLM platform (“Website”) and use the services provided through this Website for personal or business uses. It also explains how we may use and share information you provide through this Website. If you have any questions about our Privacy Policy, please contact us using the information provided at the bottom of this Privacy Policy.
Please read this Privacy Policy carefully. By accessing, using, registering for an account, or otherwise interacting with this Website, you acknowledge that you have read, understand, and agree to be bound by all the terms of this Privacy Policy. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE EXIT THIS WEBSITE AND DO NOT ACCESS OR USE THE WEBSITE OR PROVIDE PERSONAL INFORMATION TO US THROUGH THIS WEBSITE.
1. GENERAL INFORMATION COLLECTION PRACTICES
We may collect two types of information from End Users of this Website: Personal Information and Non-Personal Information.
Personal Information. Personal Information is information that identifies a particular individual. We collect Personal Information in several ways at different points on the Website. For example, some information is gathered when you register to open an account. Additionally, we may ask you to provide Personal Information when you engage in certain activities on the Website. These activities include, but are not limited to, creating an account, requesting service through the Website, uploading content to us through the Website, completing surveys, sending feedback to us, requesting information about us or our services, applying for a job, or signing up for special offers from third parties through the Website. The types of Personal Information we may collect through any of these activities may include, without limitation, your first and last name, mailing address including postal code, email address, and telephone number. Additionally, we may ask for your credit card number, expiration date, and authentication or other billing information when you order services through the Website. If you provide us access to download and/or review your telecommunications invoices, pursuant to the Xigo Terms of Use or Terms of Service Agreement, we may obtain personal information from your phone bill, including but not limited to the numbers that you dial or receive calls from in any month. Depending on the activity that you are engaging in, some of the information that we ask you to provide is mandatory and some is voluntary. Where practical, we will identify which information is mandatory and which is voluntary. If you contact us to report a problem with the Website or our services, we may keep a record of that correspondence. Wherever we collect Personal Information, we make an effort to include a link to this Privacy Policy on that page.
We use Personal Information to
provide services to you, improve our service offerings, enhance our Website
operation, improve our marketing and promotional efforts, analyze Website use,
tailor your experience with the Website or our services, and for any other
purpose specified at the time of collection. You can always decline to provide
information, although this may limit your ability to use certain services or engage
in certain activities on the Website. We may also use Personal Information
to troubleshoot, resolve disputes, accomplish administrative tasks, contact
you, enforce our agreements with you, comply with applicable laws, and
cooperate with law enforcement activities.
We may also use Personal Information as
a data processor providing services on behalf of a data controller. The data controller
may be a company that has engaged Xigo to provide services on their behalf, including the
processing of Personal Information for their employees. Non-Personal
Information. Non-Personal Information is anonymous information that
cannot be associated with a particular individual. For example, we, and/or our
authorized third party service providers and advertisers, may automatically
collect non-personal information about your computer and navigation patterns
when you visit the Website. This information may include, but is not limited
to, your browser type, operating system, IP address, and the website you
visited immediately before and after coming to our website. We collect this
information through the use of electronic tools like cookies, web beacons, and
pixel tags, which are described in Section 7 of this Privacy Policy. We use Non-Personal Information to troubleshoot problems,
administer the Website, analyze trends and demographic data, to comply with the
law, and cooperate with law enforcement. We may also share Non-Personal
Information with authorized third party service providers and advertisers to
analyze the quality and effectiveness of our Service offerings, advertising,
and Website content. 2. HOW WE
SHARE PERSONAL INFORMATION In addition to any other information sharing or disclosure
practices described in this Privacy Policy, we may share your Personal
Information with companies that assist us in providing the services to you
and/or perform some of our business functions on our behalf. These
functions may include, without limitation, sending administrative and
promotional emails and service processing and fulfillment. For example,
we may disclose your billing information to payment processors to process fee
payments or other financial transactions, or we may disclose your email address
to email fulfillment contractors to send you emails from us. Those
companies are authorized to use your Personal Information only as necessary to
provide these services to us. We may share some or all of your Personal Information with our
subsidiaries and affiliates, joint venturers, or other companies under a common
control (collectively, “affiliates”), in which case we will require these
affiliates to honor this Privacy Policy. If we or our assets are acquired
by another company, that company will possess the Personal Information
collected by us and it will assume the rights and obligations regarding your
Personal Information as described in this Privacy Policy. We may disclose Personal Information if required to do so by law
or to comply with a valid legal process (such as a search warrant, subpoena, or
court order), to protect the company’s rights or property (including, without
limitation, in the event of a transfer of control of company or substantially
all of its assets), or during emergencies when safety is at risk. 3. HOW WE
SHARE NON-PERSONAL INFORMATION We may disclose or share Non-Personal Information with certain
business partners including, but not limited to, individuals and companies with
whom we have business relationships. We may share aggregated demographic
information (which does not include any Personal Information) with third
parties. Additionally, we may use third party service providers to track and
analyze Non-Personal Information usage and volume statistics in order to
administer and improve our Website. These statistics may also be used for
promotional purposes, or to provide a representative audience for advertisers.
This information provides only general summaries of Website visitor activities,
and it does not include Personal Information. 4. HOW YOU
CORRECT, UPDATE, OR MAKE CHANGES TO YOUR INFORMATION If your Personal Information changes, please log in to your
Account and make the appropriate correction, change, or update. You may
have your Account information deleted or removed; however, you cannot delete
information associated with any past transactions conducted through the
Website. Because we periodically backup our information, we may not be able to
completely delete all of your information. In cases where your Personal Information
may have been provided to us by your employer, your request will be referred to that corporate entity,
which acts as data controller, and provides direction to us as a data processor. 5.
INFORMATION SECURITY We take information security seriously and take reasonable
precautions to protect your Personal Information from unauthorized access
and/or use, loss, disclosure, or alteration. Your password and email address
are required for you to access your Personal Information on our Website.
In addition, we store your Personal Information on a secure server using
industry recognized measures, and access to this server is limited to select
personnel and contractors. We facilitate transmission of certain sensitive
information from you to our Website using Secure Socket Layer (SSL) technology
to protect your Personal Information as it is transmitted to us. Nonetheless, no data transmission over the Internet or any
wireless network can be guaranteed to be 100% secure. As a result, while we
employ commercially reasonable security measures to protect data and seek to
partner with companies which do the same, there are security and privacy limitations
of the Internet which are beyond our control. Accordingly, we cannot absolutely
guarantee the security, integrity, and privacy of any and all information
exchanged between you and us through the Website. We make no warranty, express,
implied, or otherwise, that we will prevent unauthorized access to your private
information. 6. DATA
TRACKING Cookies.
This Website stores cookies on your computer in order to improve your
experience in using the Website. Cookies are small text files stored by your
browser on your computer’s hard drive used to record a User's preferences and
session information. We use cookies to remind us who you are and track your
interests so that we can provide you with a more customized experience. We may
also use cookies to collect Non-Personal Information (such as the links you
clicked on and other pages you visited) in order to improve our service. Advertisers may display advertisements on the Website, and these
companies may place separate cookies on your computer. We have no control over
these cookies, and such cookies are not covered by this Privacy Policy. Most
browsers automatically accept cookies, but you may change your browser settings
to limit which cookies you accept or to disable cookies altogether. If you
decline or delete our cookies, some parts of the Website may not work properly. Pixel Tags
and Web Beacons. We, along with third party service providers working on
our behalf, may use technologies such as pixel tags and web beacons to track
your use of our Website. Pixel tags and web beacons are tiny graphic images
that we place on certain portions of our Websites or in our emails that
generate a non-personally identifiable notice when a user performs a specific
action. We also use pixel tags to measure visitor traffic, visitor behavior on
the Website, our promotions, and our performance. Pixel tags and web beacons may
also be provided by our affiliates and/or marketing partners, and we use them
for the same purposes. 7. OTHER PRIVACY ISSUES Third
Party Websites. This
Privacy Policy only applies to our Website. Our Website may include links to
third party websites. These other sites are outside of our control. Please be
aware that these websites may collect information about you, and they may
operate according to their own privacy practices which may differ from those
contained in our Privacy Policy. Please read carefully that website's own
privacy policy, as once you leave our Website, any information you submit
is no longer in our control. Children.
Individuals under the age of legal capacity in their local jurisdiction (18
throughout most of the United States) may not use the Website. We do not sell
products or services for purchase by children or minors. If we become
aware that a minor child has provided us with Personal Information without
parental consent, we take steps to remove such information and terminate the
minor's account. We do not collect or maintain information from anyone known to
be under the age of legal capacity. Public
Areas. The Website may have public areas where you can
communicate with other customers, write reviews, or submit content. Please
note that this information may be accessible to others, and it may appear on
other websites or in web searches where it can be seen and used by others.
We cannot control who accesses and uses information (including Personal
Information) you post in a public forum, so please use discretion when
disclosing any personal information in these areas. Your use of such
public areas may be subject to additional terms and conditions, including any
applicable terms and conditions included in the Website Terms of Use. Notice of
Privacy Rights to California Residents. Companies that collect
Personal Information from California residents and disclose such information to
third parties (including affiliated entities) for marketing purposes must, in
response to a request by a consumer, either (1) provide a list detailing the
categories of information shared and the entities to which such information was
provided, or (2) provide a mechanism by which a consumer may opt-out of having
his or her information shared with third parties. We have elected the
second option, and you may request that your Personal Information not be shared
with third parties by sending your request, including your full name, email
address, and postal address, to: Xigo, LLC, 5870 Trinity Parkway, Suite
250, Centreville, VA 20120. California residents are also entitled to
know that they may file grievances and complaints with the California
Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814;
or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov. 8. PRIVACY
SHIELD
This Privacy Policy replaces the old policy in relation to Safe Harbor and EU-US
Privacy Shield and is effective from 16th July 2020. It sets forth the privacy
principles that Xigo follows with respect to transfers of personal information between
the European Economic Area or EEA, Australia and the United States. In accordance
with our commitment to protect personal privacy, Xigo adheres to the principles of
the GDPR and Standard Contractual Clauses.
9. CHANGES TO THE PRIVACY POLICY
We reserve the right, in our sole discretion, to modify this Privacy Policy at any time to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the “Effective Date” at the top of this Privacy Policy. If we make any material changes in the way we collect, use and/or share personal information that may impact you, we will notify you by sending an e-mail to the e-mail address you most recently provided to us, and/or by prominently posting notice of the changes to this Website. If we post those changes on this page of the Website and update the “Effective Date” at the top of this page.
10. ADDITIONAL QUESTIONS REGARDING THE PRIVACY POLICY?
If you have additional questions or comments regarding this policy, please send them via email to US.CLM.Security@global.ntt with the words "Privacy Policy Issue" in the subject line, or via regular post to our Corporate Address listed below:
Corporate Address
Xigo, LLC
5870 Trinity Parkway Suite 250
Centreville, VA 20120
Email: US.CLM.Security@global.ntt
For Customers
Customer Service Inquiries | US.CLM.Security@global.ntt