In the case of End Users, (a person who uses a Client's application or website that incorporates the Xirsys Service) Xirsys has no direct relationship with such End User and Xirsys will not collect their Personal Data directly from them. In the event an End User seeks to access, correct, amend or delete data, the End User should contact the Client directly.
If you are a person who has directly signed up with Xirsys for the use of Xirsys' Services and you seek to access, correct, amend, or delete data, you should contact Xirsys directly. If requested to remove data under either scenario, Xirsys will respond within a reasonable timeframe.
2. What Personal Data is Collected by Xirsys?
The Personal Data we collect may include, but is not limited to, your full name, email address, phone number, account log-in credentials, billing address, credit card information, IP address and any information you choose to include in your correspondence to Xirsys.
In the case of an End User, if End User utilizes a Client's website or application that incorporates Xirsys' Service, we may receive and store such End User's IP address from Client. Depending on how the Client has implemented our Service, Client may also collect further Personal Data from such End User and we may also receive such Personal Data to transmit across our Service on behalf of the Client. In this case, the End User should direct all requests regarding the Personal Data collected directly to the Client. It is the Client's responsibility to obtain express consent of End Users to transfer their Personal Data to Xirsys. Xirsys may store the aforementioned Personal Data upon the request of Client and applies the same security measures as described in Section 7 to End User's Personal Data received from Client.
3. How is Personal Data Collected by Xirsys?
Xirsys directly collects and logs the time, duration, session count, and the amount of bytes transferred to and from our TURN servers when the Xirsys Service is accessed by an End User. In the case of Clients, we collect, maintain, transmit and/or use Personal Data provided by you in your account, including without limitation, your full name, Xirsys identification number, billing data and contact information.
Xirsys also collects anonymous usage information on Visitors to its website through use of Google Analytics. Google Analytics may employ third party tracking cookies to gather anonymous browser, operating system, geographic, and website navigation information.
Xirsys also uses AdRoll who may place cookies on Visitor's browsers for targeted advertising purposes. If you would like to opt out of having your information collected by or submitted to AdRoll, please email privacy@xirsys.com.
Use of the Xirsys Dashboard interface requires the acceptance of cookies for login session management purposes. Xirsys will likely place a cookie on your hard drive during the web visit. A cookie is a unique alphanumeric identifier that Xirsys uses to determine the number of unique Visitors that view its website, whether or not those Visitors are repeat Visitors, and the source of the visits. Cookies cannot be executed as code or used to deliver a virus. Other servers cannot read cookies and personal information cannot be gathered from cookies. Cookies are simply an identifier shared between you and Xirsys to allow Xirsys to improve the services Xirsys offers to you through its website. If you do not wish cookies to be placed on your computer, then they can be disabled in your web browser. The option to do so is normally found in your browser's "security settings" section. However, please note, permanently disabling cookies in your browser may hinder your use of Xirsys' website as well as other website and interactive services.
A web beacon, also known as a web bug, is a small graphic (usually 1 pixel x 1 pixel), that is embedded in a web advertisement, email, or page on Xirsys' website, which is invisible to you. When you view a page on Xirsys' website, an e-mail or an advertisement, your web browser will request the web beacon from a web server, which in turn will set a cookie in your web browser containing a unique identifier. This unique identifier will be linked to log information that is used to track your usage of Xirsys' website in order to determine the effectiveness of content and advertising campaigns.
4. Why Does Xirsys Collect Personal Data?
Xirsys may use your Personal Data to handle orders, process your service requests, deliver products and services, process payments, communicate with you about orders, provide access to secure areas of Xirsys' website, and to enable Xirsys to review, develop and continually improve the products and services that it provides. Xirsys also uses this information to prevent or detect fraud or abuses of Xirsys' website and to enable third parties to carry out technical, logistical or other functions on its behalf.
Xirsys uses Personal Data to send information about Xirsys to Visitors and to contact them when necessary. Visitors have discretion as to whether to grant information to Xirsys upon Xirsys' request for information.
Xirsys may ask Clients to enter credit card or account information in order to process orders for services placed with Xirsys. Financial information provided via its website is transferred over a secure connection via Stripe, Inc., a payment processing company. Xirsys does not collect this information and will not authorize the release of the information to anyone not directly involved in processing the transaction. This information may be encrypted and stored for logging purposes by Stripe, Inc.
Credit card numbers are used by Stripe, Inc. only for processing payments and are not used for any other purposes. Xirsys will ensure that appropriate security and confidentiality measures are in place in safeguarding your personal data.
• Xirsys uses a Visitor's IP address to help diagnose problems with its servers, and to administer its website.
• Xirsys uses web beacons to count the number of times that its advertisements and web-based e-mail content are viewed. Xirsys combines web beacon information with cookies to track activity on its website originating from advertisements and web-based e-mail content.
Xirsys uses information that you provide to it via telephone calls, chat, e-mail, web forms and other communications to correspond with you about services you may be interested in purchasing. If you elect to purchase a service online using a web form, Xirsys will use the information to establish your account. Information you submit in writing, such as chat, e-mail, and web form information is archived and may be tied to information that Xirsys collects about your web visits.
• If you breach the Terms of Service or other applicable Service Level Agreement, or if Xirsys is under a duty to disclose or share your personal data in order to comply with any legal obligation, Xirsys may disclose your information to a relevant authority. Disclosure may include, but is not limited to, exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. In particular, Xirsys may release the information it collects to third parties when Xirsys believes that it is appropriate to comply with the law, to enforce its' legal rights, to protect the rights and safety of others, or to assist with industry efforts to control fraud, spam or other undesirable conduct.
Subject to applicable law, you have the choice to and right to limit, restrict or deny Xirsys' ability to share your Personal Data with third parties or use of your Personal Data for a purpose that is materially different from the purpose for which it was originally collected or authorized by you. In order to exercise your right to choose, please contact us at privacy@xirsys.com, or via postal mail or facsimile using contact information found on Xirsys' Contact page. Please note, in the absence of any notice to the contrary, you expressly grant Xirsys permission to share your Personal Data at Xirsys' discretion.
Xirsys intends to protect and secure Personal Data, including End User Personal Data that you may transmit through our Service, in accordance to the terms of this Privacy Statement and the Terms of Service, and has implemented physical, administrative and technical measures designed to protect Personal Data from unauthorized access, use or disclosure. These industry-standard safeguards include without limitation encryption of password and/or cryptographic key-based authentication controls on servers which house personal information, browser-based secure sockets layer encryption, and other storage system access control mechanisms to protect the integrity of internal databases and prevent unauthorized access.
It is also your responsibility to ensure authorized access to Personal Data by selecting and protecting your password appropriately and limiting access to your Xirsys account.
Xirsys requires all Xirsys business partners and vendors to provide the same or greater protections for any Personal Data that is disclosed by Xirsys in furtherance of our provision of the Xirsys Service to you. To learn more about Xirsys' contractor requirements, please contact us at privacy@xirsys.com.
Xirsys retains your Personal Data, including End User IP addresses we may receive, as long as we provide Service to you. We retain Personal Data after we cease providing Service to you, even if you close your Xirsys account to the extent necessary to comply with our legal and regulatory obligations. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
You control access to Personal Data maintained or stored by you via Xirsys' web-based interface for account management. You may update your information at any time. You may cancel your account at any time and may request that your personal information be deleted from Xirsys' databases, with the exception of: network access logs, which may be stored for any duration of time at Xirsys' discretion, cases where financially fraudulent or otherwise illegal activity is deemed to have occurred (as determined by Xirsys management or law enforcement officials), in which case personal information may be retained indefinitely for purposes of ongoing investigation and prevention of fraud recurrence, or cases where a violation of the Terms of Service and applicable Service Level Agreement has resulted in cancellation of your account (as defined by revocation of your permission to utilize Xirsys' services), in which case personal information may be retained indefinitely for purposes of prevention of further use of Xirsys' services in the future by the offending individual.
Upon request, Xirsys will grant you reasonable access to Personal Data maintained by Xirsys about you. In addition, we will take reasonable steps to correct, amend or delete information that is demonstrated by you to be inaccurate, incomplete or processed in violation of applicable law. Unless required by law, Xirsys will not permit you to access the Personal Data of any data subject other than yourself.
If you have any concerns or suspect unauthorized activities associated with your account, please contact us at privacy@xirsys.com. Xirsys will respond to all requests regarding Personal Data within a reasonable timeframe.
Xirsys is headquartered in the United States of America (the "US") and provides its Service internationally. By utilizing the Xirsys Service, you expressly consent to Xirsys' access, maintenance, transmission and/or use of your Personal Data outside of your country of residence, regardless of location or jurisdiction.
In addition to its obligations under US law, Xirsys supplements the protection of the international transfer of your Personal Data by observing numerous industry best practices of data encryption.
Xirsys will not intentionally collect or maintain, and requests that you do not provide, any information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs or other sensitive information. If you store any data or information that is sensitive and/or violates any other law or regulation, such information and compliance with applicable privacy laws remains solely your responsibility. Xirsys is not responsible for any sensitive information stored by you on its system.
Xirsys' services are not designed for or directed to children under thirteen (13) years of age and Xirsys will not intentionally collect or maintain information about anyone under thirteen (13) years of age.
You are solely responsible for ensuring compliance with any and all applicable privacy guidelines and regulations for all jurisdictions in which you may operate with respect to appropriate practices for the collection, storage, and dissemination of personal information using the Xirsys Service. In no event shall Xirsys be held liable for your failure to adopt and/or practice appropriate measures for safeguarding personal information stored within or transmitted through the Xirsys Service.
"Terms of Service" means the Xirsys data processing and Terms of Service published here, as amended at Xirsys' sole and absolute discretion from time to time.
"Personal Data" means any information relating to a data subject that you directly or indirectly provide to us as part of the Xirsys Services or any data subject's use of any Xirsys Service.
"Visitor" or "Visitors" means any individual(s) or entity(ies) that accesses, maintains, transmits, develops, acquires, operates or otherwise uses any Xirsys Service but is not a Client.
This policy was last modified January 7, 2019.