// XR.ENGAGEMKTG Privacy Policy

Last update 20 july 2018

XR.ENGAGEMKTG system and its affiliates (“XR.ENGAGEMKTG” or “we”) respect the views and preferences you may have concerning the storage and use of your Personal Information we gather. This Privacy Policy (“Policy”) is meant to elaborate on the different ways your Personal Information is collected and used by XR.ENGAGEMKTG and its affiliates, as well as the ways you can control its use. The Policy also describes our methods and practice of collecting information from different XR.ENGAGEMKTG sites that are connected to this Policy (e.g.: websites, software application, both desktop and mobile, social media and email messages), as well as via marketing activities and offline sales channels (“Channels”).

The Channels may provide links to non-XR.ENGAGEMKTG services, websites, social networks or applications or an ability to connect to the said sites in a different manner. Enabling those connections of clicking on the said link may allow thirds parties to collect, use and share your Personal Information. We assume no responsibility for the methods and practices they employ; this is why we encourage you to read the privacy policies and terms of use of any non-XR.ENGAGEMKTG websites and services before disclosing your Personal Information to them.

Personal and Other Information We Collect

Personal Information is the information that can be used to identify, contact, or or locate an individual or to identify an individual in a certain context. XR.ENGAGEMKTG may gather Personal Information through your interaction with and/or use of our Channels. Personal Information may include, but is not limited to:
  • • Your name, email addresses, and telephone numbers
  • • Behavioral or demographic data in connection to personal identifiers.
  • • Past transactions and customer behavior on the Channels.
  • • Information on your interests obtained from third parties.
XR.ENGAGEMKTG may also collect Other Information through your interaction with and/or use of our Channels and non-XR.ENGAGEMKTG websites. Other Information does not reveal your specific identity or does not directly relate to you as an individual. Other Information may include, but is not limited to:
  • • Unique IDs such as a cookie placed on your computer, mobile or device IDs, and your Personal Information in an encoded md5hash form.
  • • Internet Protocol address (“IP address”) and information derived from your IP address, e.g.: your geographic location.
  • • Information about your devices such as contained in HTTPS Headers (see definition below) or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings.
  • • Behavioral data about your usage of the Channels, such as webpages clicked, websites visited and content areas viewed, date and time of said activities.
In some instances, XR.ENGAGEMKTG may combine Personal Information with Other Information (e.g.: your name and Internet Protocol address (“IP address”)). When combined with Personal Information, Other Information will be treated as Personal Information.
XR.ENGAGEMKTG not share any Sensitive Personal Information (e.g., political opinions, information about your ethnicity or racial origin, religious or other beliefs, criminal background, health state, or Social Security numbers).

How We Use and Share Information

Personal Information

XR.ENGAGEMKTG uses and shares the Personal Information it gathers (unless otherwise restricted by applicable law), to:
  • • Provide services or support: XR.ENGAGEMKTG may use your Personal Information to provide you services you may order or user support, to inform you of and provide you with product updates, patches and fixes, as well as conduct other similar operational communications.
  • • Function in accordance with your needs and requests: XR.ENGAGEMKTG may use your Personal Information to inform you about new products and services, and to advertise XR. ENGAGEMKTG’s products and services in accordance with this Policy. Your Personal Information may also be used to tailor your website experience, marketing experience, and communications to your interests. XR.ENGAGEMKTG reserves the right to use your Personal Information in order to respond directly to your information requests (including newsletter registrations or other specific requests). With your consent, XR.ENGAGEMKTG may also share your Personal Information with its partners that offer complementary products and/or services. Before giving your consent to interacting with the specific affiliates, please review their privacy policy.
  • • Post testimonials: some of the testimonials (social media) we post on our Channels may contain Personal Information. However, we will only do this if we obtain your consent to use your name and testimonial prior to posting. If you wish to update or remove your testimonial after it was posted, please contact us in any way you find convenient using the Contact Information below and request and update or removal. Be sure to include your name, testimonial posting location, and contact information into your request.
  • • Select content, upgrade quality, enable use of the Channels: XR.ENGAGEMKTG may use your Personal Information for the purposes of creation, personalization and improvement of content on our Channels. We may also use your Personal Information to enable your use of the Channels (e.g.: enable the navigation and the login process, avoid duplicate data entry, reinforce security, keep track of transactions and preserve order information between sessions), upgrade quality, monitor marketing campaign responsiveness (including online advertising and email marketing), and assess page response rates.
  • • Upgrade products, services, and user experiences. XR.ENGAGEMKTG may use your personal information to analyze, assess and upgrade our products and services, marketing practices and reinforce relationships with customers.
  • • Obtain third party services. We can share Personal Information with third parties who provide services XR.ENGAGEMKTG, such as analytics, website management, campaign management, credit card processing services, order fulfillment, customer service, auditing, and other related services. When XR.ENGAGEMKTG shares Personal Information with third party service providers, each party will be responsible for managing their own use of the Personal Information. We recommend you review the privacy policies of these third parties to address any questions you have regarding their handling of your information.
Other Information

XR.ENGAGEMKTG may use, transfer, and disclose Other Information we collect for any lawful purpose. When required under applicable law to treat Other Information as Personal Information, we will do so and only use Other Information in the same way that we are permitted to use and disclose Personal Information.

How We Collect Information

XR.ENGAGEMKTG and our third party service providers may collect both Personal Information and Other Information from various sources via:
  • • Direct Interactions with Users: we collect the information you provide us with while using our Channels, interacting with us through them, and performing other activities: submit registrations and forms, create accounts, send sales inquiries, complete transactions, etc.  
  • • Data Available to the Public/ Data from Third Parties: we gather data you may have made available to the public, such as posts on social media, or data provided by third party sources, such as marketing opt-in lists, or data aggregators, transaction history, online behavior, etc.
  • • Automated Interactions: we collect data from Automated Interactions on non-XR.ENGAGEMKTG websites and through the use of technologies such as electronic communication protocols, cookies, embedded URLs or pixels, or widgets, buttons and tools.
Although XR.ENGAGEMKTG may change the manner in which we use Automated Interactions over time or due to technological progress, the descriptions below are designed to explain to you the detail about our present approach to data collected from Automated Interactions.

Electronic Communications Protocols: 

When users visit XR.ENGAGEMKTG websites, we may automatically receive information from them as part of the communication connection itself, which often includes the data on where you came from and how you reached a certain website (network routing information), the type of browser and/or device you used, your IP address, which may be linked to your geolocation, and the time and date of your activity.

XR.ENGAGEMKTG may also automatically receive and record information about your interaction with the Channels: which XR.ENGAGEMKTG webpages you visited and how long you stayed on them, how often you used a certain Channel, as well as performance data, aggregate usage, or general geo-location data.

Widgets, Buttons, and Tools: Our electronic Channels may use interactive mini-programs called widgets that run on XR.ENGAGEMKTG websites to provide specific services from another company (e.g., links to bookmarked sites), along with buttons or other tools that link to other companies' services (e.g., a “Like” or “Share” button). The widget, button or tool may collect and automatically send Personal Information, such as your e-mail address, or Other Information (such as your browser information, or IP address), to a third party in an encoded form. Cookies may also be set or used by the widgets, buttons or tools to enable them to function properly or for other purposes, including but not limited to advertising. The collection, storage and use of Information collected or used by a widget, button or tool, including cookie settings and preferences, is subject to the privacy policy of the company that created the widget, button, or tool.

Physical Location: XR.ENGAGEMKTG may determine, collect and share the physical location of your device in compliance with this Policy in order to provide you with personalized services or content based on your geolocation. You may be permitted to allow or deny such use of your device's location. However, if you choose to deny such use, XR.ENGAGEMKTG may not be able to provide you with the applicable personalized location-based services or content. Registration Procedure, User Preferences, Opt-Out Mechanisms

Registration Procedure

XR.ENGAGEMKTG allows users to create and use an online profile for marketing communications in the Channels via XR.ENGAGEMKTG registration procedure. User profile can also be used to customize and control what information you receive customization and control. You may use the profile to customize your preferences for receiving electronic information, control and/or opt into or out of our newsletters, online communities, etc. You can adjust your preferences in your profile or modify your whole profile at any time. Please login to your profile in the usual manner and rely on the system’s prompts to update your profile and/or preferences.

User Preferences and Opt-Out Mechanisms.

Email Marketing. You may opt out of XR.ENGAGEMKTG marketing communications at any time. In order to opt out of email communications, you may modify your XR.ENGAGEMKTG profile using the instructions above or by following the automated unsubscribe link that is present in all of XR.ENGAGEMKTG marketing emails. You may request to out from other Channels of marketing communication by contacting XR.ENGAGEMKTG directly using the information in the Contact Us section of this Privacy Policy. If any of the unsubscribed mechanisms described above fail to yield the result or you do not understand how to use them, please contact us directly using the information in the Contact Us section of this Privacy Policy.

Use of Third Party Permission-Based Lists. On occasion, XR.ENGAGEMKTG may send communications about XR.ENGAGEMKTG products and services using lists that are maintained by third parties. These third-party lists include users eligible under applicable law to receive e-mails from other companies such as XR.ENGAGEMKTG. When using such lists, we will include mechanisms to opt out of receiving XR.ENGAGEMKTG marketing communications into out communications. If any of these opt-out mechanisms fails to yield result, or if you wish to report any issues related to a third-party mailing, please contact us directly using the information in the Contact Us section of this Privacy Policy.

For California Residents. Under California Civil Code Section 1798.83 (also known as S.B. 27), California residents whose business relationship with XR.ENGAGEMKTG’s established primarily for personal, family, or household purposes may request certain data regarding disclosure of Personal Information, if any, of Personal Information to third parties for the third-parties' direct marketing purposes. To make such a request, please contact us directly using the information in the Contact Us section of this Privacy Policy; you may make such a request up to once per calendar year. If appropriate, XR.ENGAGEMKTG will provide you, via email, with a list of the categories of your Personal Information that was disclosed to third parties for their direct marketing purposes within the immediately preceding calendar year, along with the third parties' names and addresses. Please note that not all Personal Information sharing is covered by S.B. 27's requirements.

Access to Personal Information, Profile Correction and Updates

If it is provided by applicable law, users may file a request to inspect, correct or update, suppress, modify, export or erasure any part of the Personal Information that they may have provided to XR.ENGAGEMKTG through the Channels. Users may also object to our use or processing of their Personal Information.

Users can update their XR.ENGAGEMKTG profile and the Personal Information it contains at any time. To perform an update, please login to your profile and follow the instructions to update your profile.

Should any questions concerning the use and modification of your account arise, please contact us directly using the information in the Contact Us section of this Privacy Policy and request assistance. If you are concerned about your privacy in connection to access to your Personal Information or the correction of it, please contact us directly using the information in the Contact Us section of this Privacy Policy.

In your assistance request, please specify what Personal Information you would like to update or otherwise modify, whether you would like to suppress any part of the Personal Information that you have provided to XR.ENGAGEMKTG from our database or limit our use of any part of your Personal Information that you have provided to us.

Please note that while most requests connected to Personal Information access or correction and Profile update can be handled quickly, there are instances when the requests are more complex and require time for research.

Retention and Deletion

XR.ENGAGEMKTG will retain your Personal Information for as long as your account is active; as may be necessary to provide you with products and services; as may be necessary to pursue the purposes explained in this Privacy Policy or at the time when the Personal Information is collected; as may be necessary to comply with XR.ENGAGEMKTG’s legal obligations, fulfill dispute resolution, and enforce agreements; or for any other reasons permitted by law.

As soon as the retention period ends, XR.ENGAGEMKTG will remove your Personal Information from its database and delete it in a manner that ensures that it cannot be reconstructed or read.

Advertising

XR.EngageMKTG may rely on advertising technologies and be part of advertising technology networks that gather Other Information from XR.EngageMKTG and non- XR.EngageMKTG websites and third-party sources. This information is gathered in order to show you XR.EngageMKTG-related advertisements on websites owned by XR.EngageMKTG and third parties. The said advertisements may be customized with the use of retargeting and behavioral advertisement technologies according to your interests (“Interest Based Advertising”). All Interest Based advertisements served to you will have information right on the ad or near it about the advertising partner and how to prevent such advertisements from being served to you. However, opting-out of viewing such advertisements will not mean that you will stop receiving any advertisements from XR.EngageMKTG altogether; you will only opt-out of viewing targeted ads from XR.EngageMKTG that were served to you based on your online behavior and activity across websites. There are tools based on cookies that allow you to opt-out of viewing Interest Based Advertisements. These cookie-based tools prevent XR.EngageMKTG and other participants of the advertising technology from serving interest-based advertisements to you on behalf of XR.EngageMKTG. Cookie-based tools will only work on the Internet browser where they are installed and only if the said Internet browser accepts third-party cookies. Since sometimes cookies are automatically removed or disabled, these opt-out tools may not be very reliable. You will need to repeat the opt-out process if you delete cookies, use a different browser, operating system, or computer.

Cross Border Transfer

XR.EngageMKTG operates in many countries of the world and has developed security practices that ensure the protection of your Private Information around the globe. Please note that Personal Information may be accessed, transferred, and stored internationally, as it is required in compliance with this Policy. XR.EngageMKTG complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the gathering, use, and retention. This framework is to be complied with when XR.EngageMKTG and a customer have contractually agreed upon the transfer of Personal Information from the European Economic Area (“EEA”) and subsequent processing pursuant to the Privacy Shield for the relevant services. When fulfilling those activities on behalf of its EEA customers, XR.EngageMKTG holds and/or processes Personal Information provided by the EEA customer at the direction of the customer. XR.EngageMKTG assumes responsibility for ensuring that third parties acting as an agent our behalf do the same. As for Personal Information received or transferred within the Privacy Shield Framework, XR.EngageMKTG is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. XR.EngageMKTG complies with to the underlying European privacy principles of the U.S.-Swiss Safe Harbor for the processing of Personal Information received from Switzerland when XR.EngageMKTG and a customer have contractually agreed that such information will be transferred and processed pursuant to the Safe Harbor.
XR.EngageMKTG obey and meet the new General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) requirements, thus we are to provide your Personal Information with the Privacy in accordance to the latest GDPR 2018 requirements not depending on what country and of what jurisdiction the data is collected and stored.

Security

XR.ENGAGEMKTG attaches great importance to the security of your Personal Information. We rely on physical, electronic, and administrative safeguards designed especially to protect your Personal Information and rule out loss, misuse, unauthorized access, disclosure, alteration and destruction. XR.ENGAGEMKTG uses appropriate legal, administrative, technical and physical security measures.
XR.ENGAGEMKTG stores its servers in a highly secure server environment, with surveillance, anti-virus protection and support to prevent unauthorized access and data security.
We also use encrypted data transmission to exchange the Personal Information - Secure locket layer (SSL) technology, HTTP Secure protocol (HTTPS),VPN technology.
Also, users is responsible for its secure use of the XR.ENGAGEMKTG, including securing its account authentication credentials, protecting the security of Personal Information when in transit to and from the XR.ENGAGEMKTG and taking any appropriate steps to securely encrypt or backup any Personal Information uploaded to the XR.ENGAGEMKTG.

Dispute Resolution

If you have any complaints regarding our compliance with this Policy, please contact us in any way you find convenient using the Contact Us section below. We will investigate your complaints and attempt to resolve disputes regarding gathering, storage, and use and disclosure of Personal Information in accordance with this Policy.

Minors

XR.ENGAGEMKTG is focused on serving businesses and their needs; therefore XR.ENGAGEMKTG’s Channels are not directed or intended for minors.
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA) and General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).
XR.ENGAGEMKTG do not knowingly collect personal information from children under 13.
If you believe that we have unintentionally or mistakenly gathered Personal Information from children under 13, without verification of parental consent, please notify us in any manner you find convenient using the Contact Us section below so that we may immediately delete the information from our servers and make further necessary corrections.
If you are a parent or legal guardian and believe that we might have any information from or about such child, please notify us and request removal of content or information posted to our Channels. Please note that requests to remove may not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user. Where applicable law raises the age range from 13 to 18, XR.ENGAGEMKTG complies with those laws.

Contact Us

If you believe your Personal Information has been used in violation of this Policy or in contradiction to your specified preferences, or if you have further questions related to this Policy, please reach us in any manner you find convenient using the contact information below:

EngageMKTG (tm)
3419 Virginia Beach Blvd #5060
Virginia Beach, VA 23452
Phone number - 877-635-4243
Fax number is (757) 498-4715
Email: letsrock@engagemktg.com

Privacy Policy Updates

We may update this Policy without prior notification. In the event we make material updates that change your rights or XR.ENGAGEMKTG obligations under this Policy, we will post an immediate notice in this section of this Policy notifying users about the time and date of the update.