FYXO INC (hereinafter referred to as the “Company”) needs to collect personal information to effectively carry out our everyday business functions and activities and to provide the products and services defined by our business type. Such data is collected from employees, customers, suppliers, and clients and includes (but is not limited to), name, address, email address, data of birth, IP address, identification numbers, private and confidential information, sensitive information, and bank/credit card details. In addition, we may be required to collect and use certain types of personal information to comply with the requirements of the law and/or regulations, however we are committed to processing all personal information in accordance with the General Data Protection Regulation (GDPR), US data protection laws and any other relevant standard data protection laws and codes of conduct (herein collectively referred to as “the data protection laws”).

The Company has developed policies, procedures, controls, and measures to ensure maximum and continued compliance with the data protection laws and principles, including staff training, procedure documents, audit measures and assessments. Ensuring and maintaining the security and confidentiality of personal and/or special category data is one of our top priorities and we are proud to operate a ‘Privacy by Design’ approach, assessing changes and their impact from the start and designing systems and processes to protect personal information at the core of our business.

Your privacy is important to us. This privacy statement explains the personal data FYXO INC processes, how FYXO INC processes it, and for what purposes. FYXO INC offers a wide range of products, including products used to help operate enterprises worldwide, devices you use in your home, and services developers use to create and host what is next. References to FYXO INC products in this statement include FYXO INC services, websites, apps, software, servers, and devices. Please read the product-specific details in this privacy statement, which provide additional relevant information. This statement applies to the interactions FYXO INC has with you and the FYXO INC products listed below, as well as other FYXO INC products that display this statement.

This policy has been created to ensure the organizations complies with the Data Protection Act 1998 and the new General Data Protection Regulation 2016. It is to ensure the organizations and all employees known, follow best practice to protect clients, colleagues, suppliers, and all other individuals whose data are held. This policy applies to all staff within the Company (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns, and agents engaged with the Company in U.S.A. or overseas). Adherence to this policy is mandatory and non-compliance could lead to disciplinary action.

FYXO INC collects personal data from you, through our interactions with you and through our products. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with our products. The data we collect depends on the context of your interactions with FYXO INC and the choices you make, including your privacy settings and the products and features you use. We may also obtain your publicly available data from other third parties.

If you represent an organization, such as a business or school, that utilizes Enterprise and Developer Products from FYXO INC, please see the Enterprise and developer products section of this privacy statement to learn how we process your data. If you are an end user of a FYXO INC product or an account provided by your organization of a FYXO INC product, please Enterprise and developer products section of this privacy statement.

You have choices when it comes to the technology you use and the data you share. When we ask you to provide personal data, you can decline. Many of our products require some personal data to provide you with a service. If you choose not to provide data required to provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you are using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you.

Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do. To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made.

Usage Data - We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time. When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. We may also obtain data from third parties including: Social networks, when you grant permission to us to access your data on one or more networks through our website. Service providers that help us determine a location based on your IP address in order to customize offerings and content to your location.

Tracking Cookies Data - We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Session Cookies.
We use Session Cookies to operate our Service.

Security Cookies.
We use Security Cookies for security purposes.

FYXO INC uses the data we collect to provide you with rich, interactive experiences. In particular, we use data to:

• Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
• Improve and develop our products.
• Personalize our products and make recommendations.
• Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.
• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues

We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research. In carrying out these purposes, we combine data we collect from different contexts (for example, from your use of two FYXO INC products) or obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.

To provide you with news, exclusive offers and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

If you are from the European Economic Area (EEA), FYXO INC legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

FYXO INC may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests, and it is not overridden by your rights

FYXO INC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

FYXO INC will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods..

Your information, including Personal Data, may be transferred to — and maintained on —computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

FYXO INC will take all the steps necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure for Law Enforcement

Under certain circumstances, FYXO INC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Legal Requirements

FYXO INC may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of FYXO INC
• To prevent or investigate wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We are using HTTPS (Hyper Text Transfer Protocol Secure) to secure your communications which wraps an encrypted layer around HTTP by Secure Sockets Layer (SSL) . Your communications using HTTP it is now secure because of the SSL wrapper.

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

Your data privacy and security are especially important to us. In support of the California Consumer Privacy Act (CCPA), we updated this Privacy Policy effective as of July 1, 2021. The CCPA is a new data privacy law that applies to certain businesses which collect personal information from California residents. The new law went into effect on July 1, 2004. We hope you will find these updates improve your experience and reinforce our commitment to your data privacy and security.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. FYXO INC aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data, we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where FYXO INC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used upon your discretion. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. You agree to be bound by all such obligations and restrictions as are made known to you, but we shall have no liability with respect thereto.

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Depending on the specific Service you are using or specific interactions you have with us, we may provide different or supplemental privacy statements that describe and govern how we use your personal information. When we do so, those different or supplemental privacy statements apply to that specific Service you are using or those specific interactions you have with us.

If there is any conflict between the English version of our Privacy Statement and a version translated in another language, the English version controls.

In the event that any obligation of ours is prevented or delayed by circumstances of natural disaster; We will be excused from any failure to perform any such obligation under this Agreement to the extent that such failure is caused by any such circumstances.

FYXO INC maintains, and shall continue to maintain throughout the term of this Agreement, disaster recovery capabilities which permit us to recover from a disaster within our scope of control and continue providing Services to Customers within a commercially reasonable period. An executive summary of the current disaster recovery plan, which may change from time to time, is available upon request

The Service Availability of the FYXO INC is intended to be 24/7/365 (subject to scheduled downtime for network maintenance). We set Service Availability goals and measures whether we have met those goals by tracking Attainment. For any legal concern/question, please contact us on legal@fyxo.global