Effective Date: Aug 31, 218
XCome Technology Ltd. ("XCome", "we", "us" and "our") headquartered in Taiwan which provides cloud computing services to enable the enterprise customers to secure the connection, manage and automate their mobility devices/equipment behavior. We are committed to protecting the privacy of individuals who interact with us, such as our website visitors, customers, business partners, and end users, event attendees and job applicants ("you" and "your"). The following privacy notices explain the different ways in which XCome collects, uses and shares personal information when:
You visit, interact with or use any of XCome mobile apps and cloud-based service, our websites, social media pages, online advertisements, marketing communications and other our online properties (our "online Properties"); and
You visit, interact with or use any of our events, sales, marketing, and other offline activities or offline Properties (our "offline Properties"); and
You use XCome products and services (including cloud-based and mobile apps) that have been deployed by one of our business customers, such as your employer (our "Services").
We use the term "Properties" when we mean to refer to all three above.
"Personal information" identifies an individual or relates to an identifiable individual. XCome and third-party service providers collect personal information and other information from various sources which generally fall into the following categories:
The information you provide to us through your interactions with us and your use of the Properties
Information we automatically collect from you in connection with your use of online Properties and Services
Information from third-party sources and affiliated companies
We may combine information from these different sources for the purposes set forth in this Privacy Notice.
In relation to the clause of specific Properties, XCome may provide additional "just-in-time" disclosures or additional information about our data collection, use and sharing practices. These notices may complement this Privacy Notice or clarify XCome's privacy practices in the circumstances described or may provide you with additional choices about how XCome processes your data.
Please take the time to read the notices carefully. If you have any questions about this Privacy Notice, please contact us at email@example.com.
INFORMATION XCOME COLLECTS AND CONTROLS
We will collect personal information when you voluntarily actively give it to us (including to our service providers or other parties who collect it on our behalf). For example, we collect personal information when you order, register for (or to use) or request information about XCome services, products, or apps, subscribe to marketing communications, request support, complete surveys, provide in product feedback, or sign up for an XCome event, webinar or other online campaigns. We may also collect personal information from you offline, such as when you attend one of our events, during phone calls with sales representatives, when you contact customer support or other offline activities.
The personal information we collect may include contact information (such as your name, address, telephone number or email address), professional information (such as your job title, department or job role), user IDs and passwords, and contact preferences. We also collect information you choose to provide to us when requesting information or completing any 'free text' boxes in our forms (for example, for event sign-up, product feedback, survey requests or inquiry for marketing cooperation), or the nature of your request or communication. In addition, we may collect personal information disclosed by you on message boards, chat features, blogs, and other services or platforms to which you are able to post information and materials (including third party services and platforms).
When making a purchase from XCome, we may also collect billing and transactional information.
Information we automatically collect
We automatically collect certain information when you use, access or interact with our online Properties, including our online advertisements or marketing communications. This information does not necessarily reveal your identity directly but may include unique identification numbers and other information about the specific device you are using, such as the hardware model, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer), your Internet Protocol (IP) address/MAC address/device identifier, device event information (such as crashes, system activity and hardware settings, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data that uniquely identifies your browser. We may also collect information about how your device has interacted with our online Properties, such as the pages accessed and other statistical information.
In connection with your organization's deployment of certain XCome Services, XCome may automatically collect certain data relating to the performance and configuration of the Services, and our customer's and their end user's consumption of and interaction and use of such Services. This data is generally technical information obtained from software or systems hosting the Services, devices accessing the software or systems and/or log files generated during the use of the Services, along with the types of data identified under 'Online Properties' above. This data is used for the purposes set forth in this Privacy Notice in Part III below and any other relevant program documents.
In some cases, the information collected may directly or indirectly identify an end-user and link an individual to certain online behavior to the extent required for the purposes provided in this Privacy Notice. The information collected does not include any customer content uploaded to the Services by the customer for hosting.
Where data is used for XCome's own purposes, such as for product improvement, customer agreements (including service descriptions), just-in-time notices, or other disclosures contained within or in connection with the provision of the XCome Services may describe more details about our collection and use of this type of usage data, including the types of personal information, if any. Further, XCome provides details regarding our various customer experience improvement programs and, depending on the program, our customers may limit or control the extent of information collected subject to applicable laws and regulations such as General Data Protection Regulations of EU (“GDPR”).
If you are an individual user of XCome Services and you require more information regarding our data collection practices for Services deployed by your organization, please contact your IT administrator.
WHAT WE DO WITH YOUR INFORMATION
XCome uses personal information it collects for the following purposes (unless otherwise restricted by applicable law). For information on how XCome shares personal information, see Part IV.
Respond to Requests and Engage in/Process Transactions:
XCome may use personal information to respond to your requests or provide information requested by you. XCome may also use personal information, including financial, credit card and payment information, to process your transactions.
Provide and Facilitate Delivery of Services:
XCome may use personal information to provide you with XCome Services and to manage your account. This may include managing product downloads, updates and fixes, providing support and recommendations, and sending other administrative or account-related communications, including release notes. XCome will also use personal information to procure the delivery of the Services and this may include tracking entitlements, verifying compliance, monitoring services, and infrastructure performance, ensuring integrity and stability of the Services or simply monitoring or addressing technical issues so we can deliver the Service to the standards XCome has committed to.
Facilitate and Evaluate Use of the Online Properties:
XCome may use personal information to provide you with the online Properties, to facilitate your use of the online Properties (such as make easier to navigation and the login process, preserving information between sessions and enhancing security), to improve quality, to evaluate page response rates and determine content.
Improve our Properties:
XCome uses personal information and other data XCome collects from you to understand our customers, users, and website visitors and the way they use and interact with our Properties, including their user experience. XCome uses this information to provide a personalized experience, to implement the preferences you request, to improve quality and reliability, to diagnose issues with and improve the Properties and related user experiences, and to make recommendations.
Improve the Accuracy of our Records:
We may use the personal information we duly receive from you or third parties to better understand you and/or maintain and improve the accuracy of the records we hold about you.
XCome uses personal information and other data XCome collects from you (such as feedback, surveys, and data relating to your use of XCome Services), in combination with account-related information, to provide customers and users with both reactive and proactive support. Such support may be provided in-product or through XCome’s support team.
XCome may use personal information to post testimonials on its Online Properties. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. You can request your testimonial be updated or deleted at any time by sending a request with your name, testimonial location, and contact information.
XCome will use information it obtains from you, your interactions with XCome and the Properties, and from third party sources to provide you with marketing and promotional communications, to deliver targeted and relevant advertising and marketing news to you, to determine the effectiveness of our marketing and promotional campaigns, to better understand you and your preferences, and to position and promote our products and services. Our marketing will be conducted in accordance with your advertising/marketing preferences and as permitted by applicable law.
XCome may use personal information to help monitor, prevent and detect fraud, enhance security, monitor and verify identity or access, and combat spam or other malware or security risks.
Quality Control and Training:
XCome may use or access personal data for the purposes of quality control related to the Properties and staff training.
Third Party Social Networks:
Conferences and Events:
XCome and our partners may use personal information to communicate with you about our events or our partner events. After the event, XCome may contact you about the event and related products and services and may share information about your attendance with your company and our conference sponsors and partners, where legally permitted to do so. If a partner or conference sponsor directly requests your personal information at their conference booths or presentations, your personal information will be handled in accordance with their privacy practices. We recommend that you review the privacy practices of such partners and sponsors.
Provide Online Communities and Blogs:
We may use personal information and other information disclosed by you on our message boards, chat features, blogs and other services or platforms to which you are able to post information and materials for the purposes of providing you and our customers with a forum to discuss XCome Properties, responding to your request, providing you with support, improving our Properties or any other purposes set forth in this Privacy Notice. Any information that is disclosed in these forums becomes public information and may, therefore, appear in public ways, such as through search engines or other publicly available platforms, and maybe “crawled” or searched by third parties. It could also be read, collected or used by other users to send you unsolicited messages. Please do not post any information that you do not want to reveal to the public at large.
Education and Training:
If you sign up for an XCome training course or seminar, XCome will use your personal information to facilitate the delivery of such course or seminar. To the extent your organization has paid for your training course or seminar, XCome may provide the status of your course or seminar to your organization upon notice to you.
Protect our Employees and Facilities:
XCome may use personal information as necessary to protect the health and safety of our employees and visitors, our facilities and our property and other rights. If you visit one of our sites, you may be photographed or videotapes as part of maintaining the security of such sites.
Other Legitimate Business Purposes:
We may use your personal information when it is necessary for other legitimate purposes such as protecting XCome's confidential and proprietary information.
Whom WE SHARE YOUR INFORMATION WITH
XCome takes care to allow your personal information to be accessed only by those who really need access in order to perform their tasks and duties and to share with third parties who have a legitimate purpose for accessing it. We may share personal information about you with third parties in the following circumstances.
We may share your information with third parties, such as vendors, consultants, agents and other service providers who work on our behalf. Examples include vendors and service providers who aid with marketing, billing, processing credit card payments, data analysis and insight, technical support and customer service. Unless described in this Privacy Notice, we do not share, sell, rent, or trade any of your personal information with third parties for their own promotional and business purposes.
We may provide your information to our channel partners, such as distributors and resellers, to fulfill product and information requests, to effectively deliver unified support, and to provide customers and prospective customers with information about XCome and its products and services. Occasionally, XCome may engage in joint sales or product promotions with selected business partners. If you purchase or specifically express interest in a jointly-offered product, promotion or service, we may share relevant personal information with those partners.
Please be noted that XCome does not control our business partners’ use of such information. Our partners are responsible for managing their own use of the personal information collected in these circumstances, including providing information to you about how they use your personal information. We recommend you review the privacy policies of the relevant partner to find out more about their handling of your personal information.
We may disclose information where we believe it necessary in order to protect the vital interests of any person.
Compliance with laws or any competent law enforcement body, regulatory body, government agency, court or third party:
We may disclose information where we believe disclosure is necessary or required (1) by law or regulation, in order to comply with legal process or government requests (including in response to public authorities to meet national security or law enforcement requirements); or (2) to exercise, establish or defend our legal rights.
We may share or transfer your information in connection with, or during negotiations of, any merger, the sale of company assets, financing, acquisition, dissolution, corporate reorganization or similar event. We will inform any buyer that your information shall only be used in accordance with this Privacy Notice.
With your consent:
We may disclose your personal information for any purpose with your consent.
YOUR RIGHTS WITH RESPECT TO INFORMATION WE HOLD ABOUT YOU AS A CONTROLLER
If you are in the European Economic Area (EEA), you have the following rights with respect to information that XCome holds about you. XCome undertakes to provide you the same rights no matter where you choose to live.
Right to access:
You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared
Right to rectification:
You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
Right to erasure:
You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to the restriction of processing:
You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability:
You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
Right to object:
You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
Right to complain:
You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.
Retention of information
PART V: INFORMATION WE PROCESS ON BEHALF OF OUR CUSTOMERS
In the process of using our Services, XCome customers and their end-users may submit or upload information to XCome's Services for hosting or storage. This customer content is processed by XCome on behalf of the customer, and our privacy practices will be governed by the contract we have in place with our customers, and this Privacy Notice will not apply to any personal information contained in such customer content. In accordance with the terms of such contract, XCome will process customer content for the purposes of providing the relevant XCome Services and in accordance with our customer's instructions. If you have any questions or concerns about how such information is handled, you should contact the person or entity who has contracted with XCome to use the XCome Service to host or process this information (e.g. your employer or organization). We will aid our customers to address any concerns you may have in accordance with the terms of our contract with them.
PART VI: GENERAL
How secure is your information
At XCome, we have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us. If you have any concerns regarding the security of your data, we encourage you to check our Security Policy or write to us at firstname.lastname@example.org with any questions.
Data Protection Officer
Data Protection Officer, XCome Technology Ltd.
8F., No. 89, Section 4, Chongxin Road, Sanchong District, New Taipei City, Taiwan 241.
Locations and international transfers
We share your personal information and service data within XCome. By accessing or using our products and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within Taiwan, the United States of America, the European Economic Area (EEA) and other countries where XCome operates. Such transfer is subject to a group company agreement that is based on the EU Commission's Model Contractual Clauses.
Do Not Track (DNT) requests
Some internet browsers have enabled 'Do Not Track' (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don't wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.
External links on our websites
Blogs and forums
We offer publicly accessible blogs and forums on our websites. Please be aware that any information you provide on these blogs and forums may be used to contact you with unsolicited messages. We urge you to be cautious in disclosing personal information in our blogs and forums. XCome is not responsible for the personal information you elect to disclose publicly. Your posts and certain profile information may remain even after you terminate your account with XCome. To request the removal of your information from our blogs and forums, you can contact us at email@example.com
Social media widgets
Our websites include social media widgets such as Facebook "like" buttons and Twitter "tweet" buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.
Disclosures in compliance with legal obligations
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.
Enforcement of our rights
We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.
Notification of changes
Governing Law and Jurisdiction