Privacy Policy

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect may include: names, phone numbers, email addresses, mailing addresses, usernames, passwords, contact preferences, billing addresses, and contact or authentication data.

Sensitive information. We do not process sensitive information.

Payment data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by PayPal. You may find their privacy notice here: paypal.com/us/legalhub/privacy-full.

Social media login data. We may provide you with the option to register with us using your existing social media account details. If you choose to register in this way, we will collect the information described in section 6 ('How do we handle your social logins?').

If you use our application(s), we may also collect the following information if you choose to provide us with access or permission:

• Geolocation information. We may request access to track location-based information from your mobile device to provide certain location-based services. You may change our access in your device's settings.
• Mobile device access. We may request access to certain features from your mobile device, including your camera, contacts, SMS messages, WhatsApp, and other features. You may change our access in your device's settings.
• Mobile device data. We automatically collect device information such as your device ID, model, manufacturer, operating system, browser type, hardware model, IP address, and system configuration information.
• Push notifications. We may request to send you push notifications regarding your account or application features. You may turn these off in your device's settings.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes.

In short: Some information — such as your IP address and browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, and location. The information we collect includes:

• Log and usage data. Service-related diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, including IP address, device information, browser type, and activity in the Services.
• Device data. Information about your computer, phone, tablet, or other device used to access the Services, including IP address, device and application identification numbers, location, browser type, hardware model, and operating system.
• Location data. Information about your device's location, which can be either precise or imprecise. You can opt out by refusing access or disabling your Location setting on your device.

In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user enquiries/offer support to users. We may process your information to respond to your enquiries and solve any potential issues you might have with the requested service.
• To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• To deliver Services. To deliver Services in respect of adding and controlling devices sold by us to you, and viewing their statistics and settings.

In short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, including to diagnose problems and/or prevent fraudulent activities, and to control devices we have manufactured.
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, consultants, and other third-party service providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf. We have contracts in place with our third parties which are designed to help safeguard your personal information. The categories of third parties we may share personal information with include:

• Cloud computing services
• Data analytics services
• User account registration & authentication services

We also may need to share your personal information in the following situations:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Business partners. We may share your information with our business partners to offer you certain products, services, or promotions.

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

In short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider, which may include your name, email address, friends list, and profile picture, as well as other information you choose to make public.

We will use the information we receive only for the purposes described in this privacy notice. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information.

In short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or securely store your personal information and isolate it from any further processing until deletion is possible.

In short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. You should only access the Services within a secure environment.

In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@xplug.co.uk.

In short: In some regions, such as the EEA and UK, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right to: (i) request access and obtain a copy of your personal information; (ii) request rectification or erasure; (iii) restrict the processing of your personal information; and (iv) if applicable, data portability. In certain circumstances, you may also have the right to object to the processing of your personal information.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority. Contact details can be found at ec.europa.eu. For Switzerland, contact details are available at edoeb.admin.ch.

Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the details in section 14 below. Please note this will not affect the lawfulness of processing before its withdrawal.

Opting out of marketing and promotional communications. You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in our emails, updating your preferences in the app, or by contacting us using the details in section 14 below.

Account information. If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies. Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies, though this could affect certain features or services. If you have questions or comments about your privacy rights, you may email us at support@xplug.co.uk.

Most web browsers and some mobile operating systems and applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in section 14 below.

If you are under 18 years of age, reside in California, and have a registered account with our Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information in section 14 below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely removed from all our systems (e.g. backups).

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) at:

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at support@xplug.co.uk or submit a data subject request at xplug.co.uk/data-request.