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Privacy Policy

Effective: April 12, 2025
This Privacy Notice explains how XIO Genesis LTD, XIO mobile application and xio.ai (collectively referred to as “we,” “us,” “our” or “XIO”) collects, uses, discloses, and otherwise processes personal data in connection with our website and mobile application.

This Privacy Notice does not address our privacy practices relating to XIO job applicants, employees and other employment-related individuals, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Privacy Notice is also not a contract and does not create any legal rights or obligations not otherwise provided by law.

1. Our Collection and Use of Personal Data

The categories of personal data we collect depend on how you interact with us and our services. For example, you may provide us your personal data directly when you access our website, make an account, download our mobile application, or otherwise contact us or interact with us.We also collect personal data automatically when you interact with our websites and other services and may also collect personal data from other sources and third parties.

2. Personal Data Provided by Individuals

We collect the following categories of personal data individuals provide us:
  • Contact Information, including first and last name, email address, phone number, and communication preferences. We use this information primarily to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences. We may use a third party service provider to process your sensitive Personal Data or criminal records to perform Know Your Customer (KYC) checks to comply with applicable Anti-Money Laundering (AML) laws.
  • Account Information, including first and last name, email address, account credentials or one-time passcodes, and the products or services you are interested in, purchased, or have otherwise used. We use this information primarily to administer your account, provide you with our products and services, communicate with you regarding your account and your use of our products and services, and for customer support purposes.
  • Payment Information. Please note that we use third-party payment providers to process payments made to us. We do not retain any personally identifiable financial information, such as payment card number, you provide these third-party payment providers in connection with payments. Rather, all such information is provided directly by you to our third-party payment providers. The payment provider’s use of your personal data is governed by their privacy notice.
  • Feedback and Support Information, including email addresses, or other contact information we make available to customers, where permitted by law (including through the use of automated tools provided by us or our third-party provider). We use this information primarily to investigate and respond to your inquiries, to communicate with you via email, and to improve our products and services.
  • If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

3. Personal Data Automatically Collected

We, through our third-party partner (who supports beta testing, debugging and errors submission), automatically collect information you provide to us and information about how you access and use our products and services when you engage with us. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.
We, and our third-party partner, may use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us:
  • Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.
  • Information About the Way Individuals Use Our Services and Interact With Us, including the site from which you came, the site to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, videos you watch, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on our services, which may record your mouse movements, scrolling, clicks, and keystroke activity on our services and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with our products or services, or engage in chat features or other communication platforms we provide.

All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our products and services, and to improve the effectiveness of our products, services, offers, advertising, communications and customer service. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) identify you across multiple devices; (c) provide and monitor the effectiveness of our services; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our products and services.For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below.

4. Personal Data from Other Sources and Third Parties

We may receive the same categories of personal data as described above from the following sources and other parties:
  • Mobile Sign-On: We may provide you, including through Passkeys, the ability to log in to our mobile applications or authenticate yourself using facial, fingerprint, or other biometric recognition technology available through your mobile device. If you choose to utilize these login features, information about your facial geometry, your fingerprint, or other biometric information will be collected by your mobile device for authentication purposes. We do not store or have access to this biometric information. Instead, your mobile device will perform the biometric authentication process and only let us know whether the authentication was successful. If the authentication was successful, you will be able to access the applicable mobile application or feature without separately providing your credentials. For more details, please refer to the biometric authentication guides offered by your device provider.
  • Service Providers: Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share some or all of this information with us. For example, we receive personal data you may submit in response to requests for feedback to our survey providers.
  • Other Sources: We may also collect personal data about you from other sources, including publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.
  • Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.

5. Additional Uses of Personal Data

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:
  • Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations or to deliver the services requested or provided by our third-party service providers;
  • Manage our organization and its day-to-day operations;
  • Communicate with you, including via email;
  • Facilitate the relationship we have with you and, where applicable, the company you represent;
  • Request you provide us feedback about our product and service offerings;
  • Address inquiries or complaints made by or about an individual in connection with our products or services;
  • Create and maintain accounts for our users;
  • Market our products and services to you, including through email and social media;
  • Administer, improve, and personalize our products and services, including by recognizing you and remembering your information when you return to our products and services;
  • Develop, operate, improve, maintain, protect, and provide the features and functionality of our products and services;
  • Identify and analyze how you use our products and services;
  • Infer additional information about you from your use of our products and services, such as your interests.
  • Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Notice;
  • Conduct research and analytics on our user base and our products and services, including to better understand the demographics of our users;
  • Improve and customize our products and services to address the needs and interests of our user base and other individuals we interact with;
  • Test, enhance, update, and monitor the products and services, or diagnose or fix technology problems;
  • Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
  • Defend, protect, or enforce our rights or applicable contracts and agreements, as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
  • Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Legend and others;
  • Facilitate business transactions and reorganizations impacting the structure of our business;
  • Comply with contractual and legal obligations and requirements;
  • Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

6. Our Disclosure of Personal Data

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:
  • Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations or to deliver the services requested or provided by our third-party service providers;
  • Manage our organization and its day-to-day operations;
  • Communicate with you, including via email;
  • Facilitate the relationship we have with you and, where applicable, the company you represent;
  • Request you provide us feedback about our product and service offerings;
  • Address inquiries or complaints made by or about an individual in connection with our products or services;
  • Create and maintain accounts for our users;
  • Market our products and services to you, including through email and social media;
  • Administer, improve, and personalize our products and services, including by recognizing you and remembering your information when you return to our products and services;
  • Develop, operate, improve, maintain, protect, and provide the features and functionality of our products and services;
  • Identify and analyze how you use our products and services;
  • Infer additional information about you from your use of our products and services, such as your interests.
  • Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Notice;
  • Conduct research and analytics on our user base and our products and services, including to better understand the demographics of our users;
  • Improve and customize our products and services to address the needs and interests of our user base and other individuals we interact with;
  • Test, enhance, update, and monitor the products and services, or diagnose or fix technology problems;
  • Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
  • Defend, protect, or enforce our rights or applicable contracts and agreements, as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
  • Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Legend and others;
  • Facilitate business transactions and reorganizations impacting the structure of our business;
  • Comply with contractual and legal obligations and requirements;
  • Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

7. Our Disclosure of Personal Data

We disclose or otherwise make available personal data in the following ways:
Communication Preferences
  • Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our email communications. Please note you cannot opt-out of service-related email communications (such as, account verification, transaction confirmation, or service update emails).
  • Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device’s notification settings menu or in the applicable service-specific application. Please note we do not have any control over your device’s notifications settings and are not responsible if they do not function as intended.
  • Direct Mailing Preferences: You can stop receiving promotional direct mail communications from us by contacting us at support@xio.ai. Please note this opt-out does not affect any mailings that are controlled by third parties that may feature or mention our services.
Withdrawing Your Consent
Where we have your consent for the processing of your personal data (e.g., when you opt in to receive certain types of marketing communications from us), you may withdraw your consent by following the instructions provided when your consent was requested or by contacting us as set forth in the Contact Us section below.
Automatic Data Collection Preferences
Where a XIO-specific preference manager or privacy setting is not available, you may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.
Modifying or Deleting Your Personal Data
If you have any questions about reviewing, modifying, or deleting your personal data, you can contact us directly at support@xio.ai. We may not be able to modify or delete your personal data in all circumstances.
Partner-Specific Preferences
Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide:
  • Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us (such as you mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

8. Children's Personal Data

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.

8. Children's Personal Data

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.