Secu365 Privacy Notice

Last modified: October 10, 2023

 

1. Introduction

Xthings and our affiliates ( "Company" or "We" ) respect your privacy. This Privacy Notice describes the types of personal information we collect from you or that you may provide when you visit websites https://Xthings.com, https://community.Xthings.com, and https://air.ultraloq.com (our " Website") and in connection with the products and services we provide (our “Services”). This Privacy Notice also describes our practices for collecting, using, protecting, and disclosing your personal information, and the rights and choices you have regarding our use of the personal information.

This policy applies to information we collect:

• On our Website.

• In email, text, and other electronic messages between you and this Website.

• When you use our non-browser applications or applications hosted on third-party sites.

• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Notice.

• When you interact with us offline.

This Notice does not apply to personal information collected from job applicants or employees.

Please read this Privacy Notice carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Notice. This Privacy Notice may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Notice periodically for updates.

2. Children Under the Age of 13

Our Website and Services are not intended for children under 13 years of age. We do not knowingly collect personal information online from children under 13.

3. Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website and Services, including:

• Information you provide during device setup, such as your name, email address, phone number, your photo, and the location of each device.

• Your account log in, such as your user name and password.

• Information necessary to complete a purchase from our Website, and other information necessary to complete your transaction, such as your name, email address, physical address and payment information as well as any other information that you choose to provide to us when making a purchase.

• For Android phone users, Android phone Device ID may be collected to enable android phone NFC unlocking feature for some product models.

• Your location data if you enable features using location-based data. Under these circumstances, we will use information about your Wi-Fi routers and phone cell IDs of the towers closest to you. We use this information to facilitate the features including Auto Unlock, Magic Shake and Knock to Open and for customer support. You may disable location services within your phone’s settings menu.

• Your name and email address from the Xthings user that invited you if you are invited to create an account. Your email address and other account details will be obtained directly from you during the setup process, provided that you accept the invitation.

• Information you provide when you subscribe to any of our Services, such as your name and email address.

• Information about your internet connection, the equipment you use to access our Website, and usage details.

Notice and User Acknowledgment Regarding Biometrics and Device Information

• The following sets forth Xthings’s statement regarding biometric identifiers and information associated with its Products.

• Xthings’s Products use a unique encryption algorithm to decompose finger scan image data to create template data that is then used to trigger the Product’s locking mechanism, this data cannot be reversed to a fingerprint image and cannot be used by a third party. Xthings Products do not capture, collect, obtain, or record users’ fingerprints and no information stored within the Products are transmitted outside the Products and will never be shared to any third party.

• Certain legislative bodies have enacted laws governing the commercial use of biometric-facilitated transactions. Although Xthings does not perform or control the collection of such data, customers who use Xthings Products including for commercial transactions may be responsible for adhering to those laws.

• You acknowledge and agree that any notice, disclosure, consent, or other obligations that may be applicable to the use of Xthings Products under laws governing biometric-facilitated transactions are your responsibility, not that of Xthings; You further agree to release and hold harmless Xthings from any liability associated with any notice, disclosure, consent, or other obligation that may be applicable to the Products with respect to alleged biometric identifiers and biometric information. Nothing in this provision limits the applicability of the “Our Limitation of Liability,” “Disputes with Xthings,” or any other provision in these Terms.

4. How Xthings Collects Your Information

If you have filled out forms on our website, signed up on our mobile app or contacted us by phone or email, you may be providing us with information about you, which may include personal information. This includes information you provide when you register on the Xthings website or mobile app, register or return a Xthings product, subscribe to any of our services, search for a product, place an order on our website, downloaded software and apps, reported a problem with the Xthings website or our products, or requested support.

We may automatically collect information when you use the Xthings website or mobile app, such as technical information, including the IP address used to connect your computer or other device to the Internet, browser type and version, time zone setting, operating system and platform and language preferences. This information is all normally provided by your web browser or smartphone, and we do not specifically request it. Other information collected include data regarding your visit to the Xthings website, including the URL clickstream to, through and from our website, products you viewed or searched for, page response times, length of visits to certain pages, videos watched, and methods used to browse away from the page.

5. Cookies, Other Web Tools

We use automatic data collection tools like cookies, embedded web links and widgets. These tools collect information that your browser or your mobile device sends to the Xthings website, such as computer IP address, browser type, and service provider. We may use web tools to identify the user's country and language and distinguish you from other visitors to the Xthings website. We also use web tools to save your registration information for future use on our website. To optimize your browsing experience by preloading certain features of our website and services on future visits to make loading times faster and more efficient. These tools help us customize and provide you with a more personal experience when visiting the Xthings website. Web tools help us analyze website traffic, such as number of visitors.

Xthings’s website may contain links to websites operated by third parties. If you leave the Xthings website, your activities are governed by the terms of use and privacy policies of the third party websites and online services. Xthings is not responsible for the privacy practices or the content of these websites and online services, and we encourage you to carefully read the terms of use and privacy policies of any website and online service you visit.

It may be necessary for legal purposes for Xthings to disclose your personal information. We may also disclose information about you if we determine that for purposes of law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose your information if we determine that disclosure is necessary to enforce our terms and conditions. Furthermore, in the event of a corporate merger, company restructure, or sale we may transfer any and all personal information we collect to the relevant third party.

6. How Xthings Uses Your Information

We collect the information identified above and use it for the following purposes:

• Provide you user services and improve the Xthings Product functionality and user experience.

• To fulfill orders and process payments for the sale of Products or Services from our Site.

• Administer your account and back-up your data.

• Record log entries for your information and troubleshooting issues with your device.

• Send you notifications through the Xthings app. You can manage your preferences within the mobile app settings.

• Send you marketing communications, where permitted by applicable law.

• To conduct research and analysis to better understand how users access and use our Site and Products, both on an aggregated and individualized basis, in order to improve our Site, our Products, create new features, provide you new offerings, respond to user preferences, and to protect your data.

• Respond to your questions and concerns and provide customer support.

You also may provide information to be published or displayed (hereinafter," posted" ) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively," User Contributions" ). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

We don’t collect your fingerprints. Xthings’s Products use a unique encryption algorithm to decompose finger scan image data to create template data that is then used to trigger the Products’ locking mechanism, this data cannot be reversed to a fingerprint image and cannot be used by a third party. Xthings Products do not capture, collect, obtain, or record users’ fingerprints and no information stored within the Products are transmitted outside the Products and will not be shared to any third party.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Speed up your searches.

• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Web Beacons. Pages of our Website [and our emails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

7. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

8. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To provide you with services and improve our product functionality and user experience.

• To fulfill orders for sale of products or services from our Site.

• To present our Website and its contents to you.

• To provide you with information, products, or services that you request from us.

• To send you marketing communications where you have consented or have not opted out.

• To fulfill any other purpose for which you provide it.

• To carry out our obligations and enforce our rights.

• To notify you about changes to our Website or any products or services we offer or provide though it.

• To allow you to participate in interactive features on our Website.

• Estimate our audience size and usage patterns.

• Speed up your searches.

• Recognize you when you return to our Website.

9. Disclosure of Your Information

We may disclose personal information that we collect, or you provide as described in this Privacy Notice:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Xthings assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Xthings about our Website and product users is among the assets transferred.

• For any other purpose disclosed by us when you provide the information.

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.

• To enforce or apply our terms of use.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Xthings, our customers, or others.

10. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own products or services, you can opt-out by sending us an email stating your request to privacy@Xthings.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

11. Accessing and Correcting Your Information

You can access to your personal information that is being processed by us. You can also review and update your personal information by logging into your account profile page. You may also change and delete your User Account information from your account in our Apps or on the Website. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users.

12. Your State Privacy Rights

California, Colorado, Connecticut, Virginia, and Utah each provides their state residents with rights to:

• Confirm whether we process their personal information.

• Access and delete certain personal information.

• Data portability.

• Opt-out of personal data processing for targeted advertising and sales.

• Correct inaccuracies in their personal information.

• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects

• Be free of being discriminated against for exercising your rights.

To exercise any of these rights please contact us by using the contact details at the bottom of this Privacy Notice. To appeal a decision regarding a consumer rights request, please submit your appeal at privacy@Xthings.com. We will take steps to verify your identity, including validating your name and the email you use when interacting with us. You may also authorize another person or third party to submit a request to exercise your rights by providing written permission in conjunction with the submission of the requested information.

13. How We Protect Your Information

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, and products and services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

14. Retention of Your Information

We retain your information to fulfill the purposes for which it was collected or as required for legitimate business purposes as described in this Privacy Notice or otherwise as permitted by law.

15. Changes to Our Privacy Notice

We may update this Notice periodically to describe new products, processes, or changes to our practices. You can see when we last updated this Notice by referring to the “Last Modified” date at the top of this Notice.

If we make significant changes to this Notice, we will notify you by email address specified in your account. If you do not agree with the privacy practices disclosed in the Notice, we recommend you stop using our Website, and products and services.

16. Contact Information

To ask questions or comment about this Privacy Notice and our privacy practices, contact us at privacy@Xthings.com or by mail to:

Xthings Group Inc.

32920 Alvarado-Niles Rd Ste 220

Union City, CA 94587