XcooBee Privacy Policy

Effective August 24, 2018

Our Services connect people in the most privacy conscious way we could derive.  XcooBee is a privacy-focused data exchange network with a mission to protect the digital rights and privacy of consumers and businesses alike.

Privacy and the right-to-be-forgotten are core values to us and we strive to build services that reflect it. For example, we will remove transaction and user history as soon as legally allowed. We also remove related electronic fingerprints across our systems.
Our goal is to give our users tools that allow them to create a different kind of connection free of exposure and stress with the notion that we treat them as we ourselves want to be treated.

You have the right to XcooBee !

What & Why

We collect and use the following information to provide, improve, and protect our Services:

Account information. We collect, and associate with your account, the information you provide to us when you do things such as sign up for your account, upgrade to a paid plan, and set up two-factor authentication (like your name, email address, phone number, payment info, and physical address). Some of our Services let you access your accounts and your information via other service providers.

Your Stuff. Our Services are designed to make it simple for you to store your user-data, documents, photos, consents, messages, and so on (“Your Stuff”), collaborate with others, and work across multiple devices. To make that possible, we store, process, and transmit Your Stuff as well as information related to it. This related information includes your profile information that makes it easier to collaborate and share Your Stuff with others, as well as things like the size of the file, the time it was uploaded, recipients, and usage activity. Our Services provide you with different options for sharing Your Stuff.

Usage information. We collect information related to how you use the Services, including actions you take in your account (like sending, editing, viewing, and moving documents or folders). We use this information to improve our Services, develop new services and features, and protect XcooBee users.

Device information. We also collect information from and about the devices you use to access the Services. This includes things like IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services.

Cookies and other technologies. We use technologies like cookies to provide, improve, protect, and promote our Services. For example, cookies help us with things like remembering your XcooBee ID for your next visit, understanding how you are interacting with our Services, and improving them based on that information. You can set your browser to not accept cookies, but this may limit your ability to use the Services.

Marketing. We give users the option to use some of our Services free of charge. These free Services are made possible by the fact that some users upgrade to one of our paid Services. If you register for our free Services, we will, from time to time, send you information about upgrades when permissible. Users who receive these marketing materials can opt out at any time. If you do not want to receive marketing materials from us, simply click the ‘unsubscribe’ link in any email, or update your preferences in the Notifications section of your personal account. By default these are not enabled.

We also sometimes contact people who do not have a XcooBee account. For recipients in the EU, we or a third party will obtain consent before contacting you. If you receive an email and no longer wish to be contacted by XcooBee, you can unsubscribe and remove yourself from our contact list via the message itself.

Bases for processing your data. We collect and use the personal data described above in order to provide you with the Services in a reliable and secure manner. We also collect and use personal data for our legitimate business needs. To the extent we process your personal data for other purposes, we ask for your consent in advance or require that our partners obtain such consent.

With Whom

We may share information as discussed below, but we won’t sell it to advertisers or other third parties.

Others working for and with XcooBee. XcooBee uses certain trusted third parties (for example, providers of customer support and IT services) to help us provide, improve, protect, and promote our Services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information per our instructions. Currently, the only third parties we use are Auth0 for authentication processing, Intercom for user support messaging, and Amazon Web Service (AWS) for compute and infrastructure. As we add more third parties we will update this list.

Other users. Our Services display information like your name, city, country, and profile picture, to other users in places like your user profile and sharing notifications. You can control most of this directly in your personal settings section of the application. You can also share Your Stuff with other users if you choose. When you register your XcooBee account with an email address on a domain owned by your employer or organization, we may help recipients and administrators find you and your team by making some of your basic information—like your name, team name, profile picture, and email address—visible to other users on the same domain.

Certain features let you make additional information available to others. We will inform you when you turn these features on that this is the case.

Other applications. You can also give third-party providers access to your information and account—for example, via XcooBee APIs. Just remember that their use of your information will be governed by their privacy policies and terms.

XcooBee Business Admins. If you are a user of a business team (e.g., XcooBee Business, XcooBee Enterprise, or XcooBee Network/White Label plans), your administrator may have the ability to access and control your XcooBee account. Please refer to your organization’s internal policies if you have questions about this. If you are not a business team user but interact with a business team user (by, for example, exchanging messages in consent center with a business user), members of that organization may be able to view the name, XcooBee Id, and profile picture that was associated with your account at the time of that interaction.

Law & Order and the Public Interest. We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of XcooBee or our users; (d) protect XcooBee’s rights, property, safety, or interest; or (e) perform a task carried out in the public interest.

Stewardship of your data is critical to us and a responsibility that we embrace. We believe that your data should receive the same legal protections regardless of whether it’s stored on our Services or on your home computer’s hard drive. We’ll abide by the following Government Request Principles when receiving, scrutinizing, and responding to government requests (including national security requests) for your data:

  • Be transparent,
  • Fight blanket requests,
  • Protect all users, and
  • Provide trusted services.

 

How

Security. We are dedicated to keeping your information secure and testing for vulnerabilities. We also continue to work on features to keep your information safe in addition to things like two-factor authentication, encryption of files at rest and in motion, and allowing you to manage your own encryption keys. We deploy automated technologies to detect abusive behavior and content that may harm our Services, you, or other users.

User Controls. You can access, amend, download, and delete your personal information by logging into your XcooBee account and going to your account settings page. You can also limit the way we collect and use your data on the user-data page of your XcooBee account.

Retention. When you sign up for an account with us, we’ll retain information you store on our Services for only as long as your account is in existence or as long as we need it to provide you the Services. If you delete your account, we will initiate deletion of this information after 30 days. But please note: (1) there might be some latency in deleting this information from our servers and back-up storage; and (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

Where

Around the world. To provide you with the Services, we may store, process, and transmit information in the United States and locations around the world—including those outside your country. Information may also be stored locally on the devices you use to access the Services.

Complaints

XcooBee complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. XcooBee has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, XcooBee commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact XcooBee in the following manner:

If you do have a complaint and do not wish to use the online XcooBee complaint system we ask that you first submit any such complaints directly to us via privacy @ xcoobee.com or our external Data Privacy Officer (DPO) via the contact us page.

XcooBee has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. In the event your concern still isn’t addressed by JAMS, you may be entitled to a binding arbitration under Privacy Shield and its principles.

XcooBee is subject to oversight by the U.S. Federal Trade Commission. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance—free of charge to you.

Changes

If we are involved in a reorganization, merger, acquisition, or sale of our assets, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

We may revise this Privacy Policy from time to time, and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.

Your Right to Control and Access Your Information

You have control over your personal information and how it is collected, used, and shared. For example, you have a right to:

  • Erase or delete all or some of Your Stuff in your XcooBee account. You can use your account settings to remove all data and delete pre-shared data in your user consent center.
  • Change or correct personal data. You can manage your account and the content contained in it, as well as edit some of your personal data, through your account settings page.
  • Access and take your data. You can download a copy of Your Stuff in a machine readable format. You can also ask us for a copy of personal data you provided to us. You can do so from your account settings page.

 

Contact

Your personal information is controlled by XcooBee LLC.

Have questions or concerns about XcooBee, our Services, and privacy? Contact our Data Protection Officer at privacy @ xcoobee.com. If they can’t answer your question, you have the right to contact your local data protection supervisory authority.