Privacy Policy

Last updated: Nov. 5, 2024

Notice

SHENZHEN XCCAM TECHNOLOGY CO., LTD. (“XCCAM”, “we”, or “us”) believes that protecting the security and privacy of your personal information is important. This Privacy Policy (“Policy”) has been designed to inform you how XCCAM collects, stores, uses and shares your personal information within its application scope. Please review this Policy before using any XCCAM services available on website of www.XCCAM.com (“Service”).

This Policy is applicable to all XCCAM websites that link to it (collectively, the “Site”). For certain features or services of our Site, additional privacy notice or addendum for such features or services may apply. XCCAM Site may contain links to third party websites. Your personal information might be collected by third parties when you are using their services, therefore, XCCAM encourages you to learn about the privacy practices of those third parties carefully.

If the personal information you submitted to us contains other individuals’ information, you warrant that you have obtained the approval of such individuals.

The Policy may be modified from time to time and will be posted on this page. By accessing the Site, you acknowledge that you have agreed to our process of your personal information in accordance with the Policy.

Collection of Your Information

When you use the Site, XCCAM may collect certain information about you as described in this Policy. The information can be divided into information that you actively and voluntarily provide and information that has been generated by us in connection with your use of the Service. As permitted by applicable law or after obtaining your prior consent, we may further collect personal information that is necessary for your use of Service provided by third party.

The personal information that we collect depends on your use of the Service. Here are more details on the categories of personal information we collect when you using XCCAM Service:

• Your contact information, including name, e-mail address and telephone number, as well as the company information where you work for or with which you have a relationship including business type/role, location, contact details, industry, postcode, that you provide by filling in forms of accessing the features like Subscribe Newsletter, Technical Support, User Center, etc. The information you submit may vary per the features you use;
• Information of feedback question, email content and/or suggestion, submitted as part of a support request, survey or online chat channel;
• Information on your interaction with our Service, including your device, information on your operating system, sites and services accessed during your visit, the date and time of each visitor request;
• Certain information is automatically received and stored whenever you interact with us, e.g. IP address and information through cookies, including the visitor volume, access time, and user preference.

Cookies

We also use cookies and other technologies to keep records, store your preferences, improve our advertising, and collect certain non-identifying information, like log data and device data. This allows us to better understand how you use our Service, diagnose and troubleshoot any problems you’re having, and otherwise administer and improve our Service. The use of cookies also helps you to smoothly navigate our websites. You can set your browser to detect and reject cookies.

Please see more information in our Cookie Policy (https://www.XCCAM.com/cookie-policy).

Use of Personal Information

XCCAM uses personal information for the following purposes:

(1) To perform the agreement we have with you

a.    to respond to your enquiries;

b.    to provide the Service you engage;

c.    to ensure your normal use of XCCAM Service, maintain the normal operation of the Service, improve and optimize our service experience, and ensure the security of your account (if any).

(2) For XCCAM’s legitimate interest

a.    to increase the safety of the Service, such as user authentication, security protection, fraud detection, filing and backups;

b.    to perform data analytics, audit and conduct research.

(3) To meet XCCAM’s legal obligation

a.    to ensure compliance with our legal obligations (such as record keeping as required by country specific regulations) and due diligence, and industry standards.

(4) With your consent

a.    to send electronic communications about new products and services;

b.    to use certain non-essential cookies to better understand your behavior, in order to optimize user experience, perfect function design, or to provide better services;

c.    we may also engage one or more third party service providers to serve online advertisements on our behalf via the Service, as further described in our Cookie Policy. They may use a pixel tag or other similar technology to collect information about your visit to the Service, and they may use that information to target advertisements for XCCAM products and services.

Sharing of Personal Information

We do not sell any personal information to third parties and we never will.

XCCAM may share personal information with third parties on the basis of non-disclosure agreements. You hereby consent that we may disclose personal information to these third parties:

• We share your personal information with XCCAM affiliates, who are required to use that information in accordance with the purposes described in this Policy.
• We use service providers, vendors, technicians and other third-parties to help us process, store, and protect some of your data and otherwise help us administer our Service effectively, provide a better user experience, and increase the quality of our Service. These third-parties are forbidden from using your personal information for non-XCCAM purposes and are required to protect your information in accordance with this Policy and applicable laws.
• We may provide information to third-parties if we believe in good faith that we are required by mandatory law to do so. For example, to comply with legal orders and government requests; response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts; to protect the interests of our customers and users of XCCAM Service; to respond to claims that any content posted or displayed using XCCAM Service violates the rights of third parties; in an emergency protect the health and safety of users of XCCAM Service or the general public; or to enforce compliance with our General Terms of Use.
• If XCCAM and/or all or part of our assets are ever sold or transferred, your personal information may be among the items sold or transferred. Under such circumstance, we will notify you by the email address specified in your account or by means of notice on website of (i) the identity and contact information of the purchaser or transferee, (ii) your right to revoke your consent to the provision of personal information, and (iii) the means by which you may revoke such consent.
• We share information to protect our own legitimate business interests when we believe in good faith that we are required or permitted by law to do so. For example, we may share your personal information as needed to support auditing, compliance, and corporate governance functions; to combat fraud or criminal activity; to protect our rights or those of our affiliates and users; or as part of legal proceedings affecting XCCAM.

We may also disclose non-personal information (for example, aggregated or anonymized data) publicly or with third-parties, provided those data have been rendered anonymous in such a way that the data subject is no longer identifiable. For example, we may share non-personal information:

• for the same reasons we might share personal information;
• to better understand how users interact with XCCAM Service, in order to optimize your experience, or provide better services;
• for our own research and data analytics; or
• to our vendors for their own analysis and research.

Securing Your Personal Information

XCCAM has implemented commercially reasonable administrative, technical, and physical security controls that are designed to safeguard personal information. We also conduct periodic reviews and assessments of the effectiveness of our security controls.2

Notwithstanding the above, no data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we use appropriate technical and organizational measures to protect the information we hold for you, we cannot guarantee the security of any information you transmit over the internet with the existing security technology. 

However, we handle personal data breaches as required by applicable data protection law which includes, where required, notifying the breach to the relevant data protection supervisory authority and data subjects. If you have any further questions about the security of our XCCAM Service, Please contact us.

Accessing, Correcting and Retention of Your Personal Information

XCCAM stores your personal information on XCCAM’s servers, which are established upon AWS in Singapore, until you delete or edit it, or for as long as you remain a XCCAM user in order to provide you with the most relevant Service. 

Depending on where you are located and subject to limitations in applicable law, you have certain rights in respect to your personal information, such as a right of access, rectification, restriction, opposition, and portability. In order to exercise your rights please contact us at the contact information below. You also have the right to withdraw your consent at all times, free of charge. You can do this by opting out from direct marketing and by rejecting the use of cookies through your browser settings.

Transfer of Personal Information Outside of Your Jurisdiction

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies or third party service providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You will have the right to be informed and receive a copy of the appropriate safeguards taken by XCCAM for this transfer of your personal information.

Currently we have data center in Singapore. The law, regulation, and standard of the country in which your information is stored or processed may be different from those of your own country. You have understood that the risks under applicable data protection laws are different and we may transfer to and store your personal information at our overseas facilities. However, this does not change any of our commitments to safeguard your personal information in accordance with this Policy.

Children’s Privacy

XCCAM does not intend that any portion of its XCCAM Service will be accessed or used by children under the age of 18, or equivalent minimum age in the relevant jurisdiction and such use is prohibited. XCCAM Service are designed and intended for adults. By using XCCAM Service, you represent that you are at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction and understand that you must be at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction in order to use XCCAM Service. If we obtain actual knowledge that a user who is under the age of 18 years old, or equivalent minimum age in the relevant jurisdiction, we will promptly delete information associated with that user. If you are a parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction and believe he or she has disclosed personal information to us please contact us immediately through the contact information available below. A parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction may review and request deletion of such child’s personal information as well as prohibit the use thereof. 

Contact Us

If you have questions or concerns about XCCAM’s use of your personal information, you can contact us at data_protection@XCCAM.com. We will response to your inquiry within the time limited required by the applicable laws. Please provide: (i) your name (or nickname), your country/region of residence and your preferred method of contact; and (ii) the details of your request or comment along with any corresponding website links.

EU/UK Addendum

If you are located in the European Economic Area (“EEA”) and UK, Please note,

i) For purposes of EU data protection legislation, XCCAM Europe B.V., located at Dirk Storklaan 3, 2132 PX Hoofddorp, Netherlands acts as EU representative for personal information processing activities covered in this Privacy Policy. You may contact the EU representative using the details in Contact Us.

ii) You have the right to object to processing of your personal information where the processing is carried out for our legitimate interests. Subject to limitations in applicable data protection laws, you have certain rights in respect to your personal information, such as a right of access, rectification, erasure, restriction, objection, portability and the right not to be subject to decisions based solely on automated processing, including profiling. In order to exercise your rights, please contact us. You also have the right to withdraw your consent at all times, free of charge. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal. If you have concerns about how we handle your personal information, please contact us at any time for enquiries or you could have the right to lodge a complaint with a data protection authority.

iii) Whenever XCCAM shares your personal information with a third party outside the EEA/UK, or transfers such personal information to a third party outside the EEA/UK, XCCAM will put in place contractual protections, approved by the European Commission, to secure your personal information.

US Addendum

California Consumer Privacy Act Notice

California residents have additional privacy rights under the California Consumer Privacy Act, which is described in the California Consumer Privacy Act Notice (https://www.XCCAM.com/us-addendum).

Brazil Addendum

Whenever XCCAM shares personal information originating in Brazil with a third party, which may or may not be a XCCAM entity, that is outside of Brazil, we will do so on the basis of standard contractual clauses or any other safeguards provided for in the LGPD.