Legal Agreements
PRIVACY POLICY ============== This Privacy Policy will be effective as of May 23, 2018 for all new users and users in EU and EEA member countries. For all other users, this Privacy Policy will be effective on June 23, 2018. TABLE OF CONTENTS • About Us • Information Covered by this Privacy Policy • Information We Collect From You o Signing Up for Services; User Information o Use of Services, Website Visits and Support o Social Media o Other Sources • How We Use Your Information • Sharing of Information o Sharing within the Xeliux Corporate Family o Sharing with Partners o Sharing with Third Party Service Providers and Vendors o Corporate Reorganizations o Authorized Users o Legal Process • Security • Tracking Technologies and Online Advertising • Choice/Opt-out o Marketing Communications from Us Email Phone o Cookies o Information from Third Parties o Unauthorized Accounts • Retention of Personal Information • Your Rights o Access o Portability o Correction o Erasure o Restriction of Processing to Storage Only o Objection o Withdrawal of Consent • Third Party Links and Information Collection and Use by Our Users • Children • Data Transfer • Complaints • Notification of Changes ABOUT US ========= LCV GROUP SAC (“we,” “us” or “Xeliux”) is a leading provider of online tools for small businesses to establish and build their web presence, provides cloud-based solutions, including web hosting, domain name registration and related products and services, to businesses, individuals, non-profit organizations and others. Xeliux is able to provide a variety and range of products and services to help customers with their technology needs. We care about protecting the personal information of our customers and visitors who use our website, products or services (collectively, our “Users”). This privacy policy provides details about how your personal information is collected, shared and used by us. If you have any questions about this privacy policy or the practices described herein, you may contact support@xeliux.com. INFORMATION COVERED BY THIS PRIVACY POLICY ========================================== This privacy policy covers personal information, including any information we collect, use and share from you, as described further below. This privacy policy applies to our website, our products and services (collectively, the “Services”). This privacy policy does not cover how our Users may use or share data that they collect using our services. When you purchase a Service from us, your personal information will be collected, used, and shared consistent with the provisions of this privacy policy as well as the following addendums related to particular products and services offered by Xeliux, which are a part of this privacy policy: • Addendum for Users who purchased Domain Registration services INFORMATION WE COLLECT FROM YOU ================================= In the course of your use of the Services, we obtain the following information about you as described below. We collect this data for the purposes described under “How We Use Your Information” lines below. SIGNING UP FOR SERVICES; USER INFORMATION ========================================= • Information you provide prior to any registration process, such as your email when you provide it to us; • Information that you provide during any registration process, including in connection with a co-branded offer (such as your name, company name, email address, phone number, billing address or credit card information, geographic location and industry), when you call or email us (for support or otherwise) or when you use our products or services; and • Payment information that you provide to us (by way of our Services or otherwise) when you purchase some of our products and services, including credit card data. USE OF SERVICES, WEBSITE VISITS AND SUPPORT =========================================== • Data relating to your online activity on our websites with respect to our Services, including the following: IP address browser type and version geographic location pages you view how you got to our Services and any links you click on to leave our Services when you update your information, communicate with us, or order new Services metadata about your use and your contacts’ use of our Services and your emails you send (including clicks and opens) your interactions with any videos we offer issues you encounter requiring our support or assistance any device or other method of communication you use to interact with the Services We store this data we collect in a variety of places within our infrastructure, including system log files, back end databases and analytics systems. • Your telephone conversations with us (which we may monitor or record). SOCIAL MEDIA ============ • Information from third party social networking sites, including information that social networking sites provide to us if you use your credentials at such social networking sites to log into some of our Services (such as your name and email address to pre-populate our sign-up form). • The information you allow us to access varies by social networking site, and depends on the level of privacy settings you have in place at the social networking site. You can control and find out more about these privacy settings at the applicable social networking site. OTHER SOURCES =============== • Information you provide to us at seminars or to our partners; • Information you provide to us in surveys; • Information that is publicly available; and • Information you consent to us receiving from third parties. HOW WE USE YOUR INFORMATION ============================= We have a legitimate interest in running a successful and efficient business and in providing you with Services and useful content, and we use the information we collect, both on its own and combined with any other information we collect about you, for the following purposes: • To provide the requested Services to you; • To provide you with useful content; • To ensure the proper functioning of our Services • To offer and improve our Services; • To provide you with requested information or technical support • To facilitate your movement through our websites or your use of our Services; • To do a better job of advertising and marketing our Services (our use of your information to do this is performed with your consent where required by applicable law); • To advertise and market third party products and services (such advertisement is only performed with your permission where your consent is required by applicable law) • To diagnose problems with our servers or our Services; • In connection with our security and compliance programs; • To administer our websites; • To communicate with you; • To target prospective customers with our products or services (such targeting is only performed with your permission where your consent is required by applicable law); • To assist us in offering you a personalized experience or otherwise tailor our Services to you; and • As otherwise described in this privacy policy. We also use the information we receive in aggregated and anonymized formats to produce reports on trends and statistics, such as mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, our websites or evaluated or purchased our products and services. Payment information that you provide to us, including credit card data, will only be used to facilitate payment for our products and services. We also use recorded telephone conversations for quality control purposes, to train our employees and for our own protection. SHARING OF INFORMATION ======================= As further described below, we will only share certain personal information with: • LCV GROUP SAC corporate family; • our partners; • third party service providers and vendors; • in connection with a sale, merger, acquisition or corporate reorganization; • authorized users within your organization; and • for legal reasons. Further information about the third parties with whom we share personal information is available in the last pages of this privacy policy. SHARING WITHIN THE LCV GROUP SAC CORPORATE FAMILY ================================================== We share personal information with other members of the Xeliux corporate family to allow our corporate affiliates to contact you with offers, services or products that may be of interest to you and to provide you with their products and services. Any such corporate affiliate may use your information only according to the terms of this privacy policy. If you are located in a jurisdiction where such sharing requires your permission, we will only do so with your consent. SHARING WITH PARTNERS ====================== When we share personal information with certain third-party partners, including marketing and advertising partners, that information includes your name, email address and other information enabling partners to: • assist you in using our products and services, • contact you with offers, services or products that may be of interest to you, and • provide you with their products or services. If you are located in a jurisdiction where such sharing requires your permission, we will only do so with your consent. Please note that if you access our services through a tool that hides your location, such as through a virtual private network, you may not receive our request for permission because we were not able to identify you as being located in a jurisdiction where your permission is required. Further, our partners are prohibited from using your contact information for any purpose beyond those set forth above without your consent. We will not provide our partners with your credit card information. Further information about certain partners we share personal information with is available in the last pages of this privacy policy. In the event we collect information from you in connection with an offer that is jointly presented by us and a partner, we will let you know who is collecting the information and whose privacy policy applies, as well as any options you may have regarding use of your information. SHARING WITH THIRD PARTY SERVICE PROVIDERS AND VENDORS ======================================================== Occasionally, we enter into contracts with carefully selected third parties so that they can assist us in servicing you (for example, providing you with customer service, fraud detection and deterrence or access to advertising assets and providing us with information technology and storage services) or to assist us in our own marketing and advertising activities (including providing us with analytic information and search engine optimization services). Additional information about certain third-party service providers we share personal information with is available in this document. Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared. If you purchase a product or service from a third party through one of our brands, we will pass your personal information to such third party in order for them to fulfill your order. We also share non-personal information with certain third parties, including the media, industry observers, marketing and advertising partners, vendors, customers, potential customers or partners. For example, we disclose mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, our websites or evaluated or purchased our products and services. CORPORATE REORGANIZATIONS ============================ If we are involved in a merger, acquisition, a sale of all or a substantial portion of our assets, or other similar sale transaction, your information will be transferred as part of that transaction. We will notify you by email and/or a prominent notice on our website of any such transfer and any choices you may have regarding your information. AUTHORIZED USERS ================== All users authorized by you to have access to your account can view personal information stored in the account. A primary account holder can view personal information saved in subaccounts to which they have authorized access. We share information about authorized users only for legitimate purposes consistent with this privacy policy, including servicing your account and marketing products and services to you. LEGAL PROCESS ============== Lastly, if legally required to do so, or if we have a good faith belief that such disclosure is reasonably necessary, we may disclose your personal information to courts of law, law enforcement authorities and other relevant third parties, such as internet service providers, to conduct an investigation, respond to a third party or law enforcement subpoena or court order, bring legal action, prevent harm to others or pursue other relief when you or a third party are or may be: • violating our terms and conditions of use; • causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users, or third parties; or • violating federal, state, local, or other applicable law. This disclosure can include transferring your information to the U.S. and other countries outside the European Economic Area. To the extent we are legally permitted to do so, it is our policy to notify you in the event that we are required to provide your personal information to third parties in connection with a subpoena. SECURITY ========= The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification. When we collect financial account information, such as credit card numbers, we protect its transmission through the use of encryption such as the Transport Layer Security (TLS) protocol. The most of cases we use a third party and regulated credit card processor like Paypal which ensures that all your sensitive data is secure and protected. TRACKING TECHNOLOGIES AND ONLINE ADVERTISING ============================================== We use cookies, web beacons, pixels, tags, scripts and other similar technologies in the course of our business. Information about the technologies we use, why we use them (for example, in connection with online advertising), and how you can control them can be found in our Cookie Policy lines below. CHOICE/OPT-OUT MARKETING COMMUNICATIONS FROM US EMAIL ======================================================== You always have the opportunity to opt out of our marketing communications with you or change your preferences by following a link in the footer of all non-transactional email messages from us or by emailing us at support@xeliux.com. Some communications from us are considered transactional or service communications (for example, important account notifications and billing information), and your account(s) for Xeliux products and services are provided to you upon the condition that you receive these communications from us. You must cancel your account(s) for Xeliux products and services, as applicable, if you do not wish to receive any transactional or service communications. To cancel your Xeliux account(s), please follow the instructions found in the terms of service for the applicable Xeliux service. You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above. PHONE ====== We may contact you by telephone, with your consent where applicable, for marketing purposes (including by automatic dialer and/or prerecorded message). If you do not want to receive marketing calls, please contact support@xeliux.com. You do not need to agree to receive automated marketing phone calls or texts from us to use the Services. COOKIES ======== For information about how to manage and opt out from cookies, please visit our Cookie Policy lines below. INFORMATION FROM THIRD PARTIES =============================== To manage the information we receive about you from a social networking site or other third parties (if applicable), you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this privacy policy and the information the third party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third party site will not apply to our use of the information we have collected directly through our Services. UNAUTHORIZED ACCOUNTS ======================== If an account or profile was created without your knowledge or authorization, please contact support@xeliux.com to request removal of the account or profile. RETENTION OF PERSONAL INFORMATION =================================== We retain your personal information to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for no more than seven years following the later of (i) the date on which you terminate your use of the Services or (ii) May 25, 2018, unless we are otherwise required by law or regulation to retain your personal information for longer. YOUR RIGHTS ============ Where the European Union’s General Data Protection Regulation 2016/679, or GDPR, applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. To exercise any of your rights, please visit the Privacy Center. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case. ACCESS ======= You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with. PORTABILITY =========== You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal information to another party. If you wish for us to transfer the personal information to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal information or its processing once received by the third party. CORRECTION =========== You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below. ERASURE ======== You may request that we erase the personal information we hold about you in the following circumstances: • where you believe it is no longer necessary for us to hold the personal information; • we are processing it on the basis of your consent and you wish to withdraw your consent; • we are processing your data on the basis of our legitimate interest and you object to such processing; • you no longer wish us to use your data to send you marketing; or • you believe we are unlawfully processing your data. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. RESTRICTION OF PROCESSING TO STORAGE ONLY =========================================== You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances: • You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate; • We wish to erase the personal information as the processing we are doing is unlawful but you want us to simply restrict the use of that data; • We no longer need the personal information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or • You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information. OBJECTION ========== You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose. WITHDRAWAL OF CONSENT ======================= Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by writing us to support@xeliux.com. THIRD PARTY LINKS AND INFORMATION COLLECTION AND USE BY OUR USERS ================================================================== Some of our Services provide links to other websites. Because we do not control the information policies or practices of these third party sites, you should review their privacy policies to learn about how they collect and use personal information. You may also log in to some of our Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you with the option to share certain personal information with us, such as your name and email address to pre-populate our sign up form. For example, if you take advantage of certain of our social media features, such as the Facebook Like button, and widgets, such as the “Share This” button or interactive mini-programs that run on our site, the applicable social networking sites may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable it to function properly. CHILDREN ========= Our Services are not directed to persons under 18. We do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian’s consent, he or she should contact us. If we become aware that a child under 18 has provided us with personal information, we will delete such information from our files. DATA TRANSFER ============== In order for us to provide the Services to you, your personal information will be transferred to, and stored at/processed in the United States. Your personal data is also processed by staff operating outside the European Economic Area (EEA), such as in India and the Philippines, who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy. For transfers of personal information within the Xeliux corporate family, such transfer will be under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU. For transfers of data to third parties, such transfers will either (i) be under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU; or (ii) rely on the EU-US Privacy Shield Framework. You can contact the Data Protection Officer listed below to obtain a copy of the data transfer agreement or more information regarding the relevant safeguard we put in place. For more information about the EU-US Privacy Shield Framework, please visit the U.S. Department of Commerce’s Privacy Shield website. COMPLAINTS =========== In the event that you wish to make a complaint about how we process your personal information, please contact our Data Protection Officer at support@xeliux.com and we will try to deal with your request. This is without prejudice to your right to raise a complaint with the Dutch Supervisory Authority (Autoriteit Persoonsgegevens) by contacting: Autoriteit Persoonsgegevens Postbus 93374 2509 AJ DEN HAAG Telephone: (+31) – (0)70 – 888 85 00 Fax: (+31) – (0)70 – 888 85 01 NOTIFICATION OF CHANGES ======================== We reserve the right to modify this privacy policy at any time, so please review it frequently. If we decide to change this privacy policy in any material way, we will notify you here, by email, or by means of a notice on www.xeliux.com prior to the change becoming effective. In all cases, your continued use of any Services constitutes acceptance to any such changes. DOMAIN REGISTRATION SERVICES PRIVACY POLICY ADDENDUM ====================================================== Effective May 23, 2018 The following privacy policy addendum, together with the Xeliux Privacy Policy (the “Privacy Policy”), is applicable to you if you purchased domain registration services from us. Please review the below in addition to the Privacy Policy. INFORMATION COLLECTION ======================= When you purchase Domain Registration services for top level domains (“TLDs”), as the domain registrar, we are required to collect the following personal information from you (collectively, “Personal Information”): Registrant Name Registrant Organization (where applicable) Registrant Address Registrant Email Registrant Fax (where applicable) Registrant Phone number Administrative Contact Administrative Contact Organization (where applicable) Administrative Contact Address Administrative Contact Email Administrative Contact Fax (where applicable) Administrative Contact Telephone Number Technical Contact Technical Contact Organization (where applicable) Technical Contact Address Technical Contact Email Technical Contact Fax (where applicable) Technical Contact Telephone Number Billing Contact Billing Contact Organization (where applicable) Billing Contact Address Billing Contact Email Billing Contact Fax (where applicable) Billing Contact Telephone Number Our collection of Personal Information is necessary to comply with contractual obligations we have with the Internet Corporation for Assigned Names and Numbers (“ICANN”) and with certain TLD registries (“Registries”) so that you can validly register your domain name. In addition to Personal Information, our contracts with some Registries may require us to collect other personal information for the registration of a TLD such as certain professional affiliations, identification or other qualifiers (“Additional Personal Information”). DISCLOSURE OF INFORMATION =========================== • Public Whois. Our contracts with ICANN and other Registries require us to make certain domain name information (“WHOIS Information”) available and accessible to the public through a searchable port 43 “WHOIS” Service via a public webpage operated by the applicable registrar of record (“WHOIS Site”). The WHOIS Site is a publicly accessible database that lists WHOIS Information, including a particular domain name, the name server(s) to which the domain name points, and the domain name’s creation and expiration date. Except for EU/EEA natural persons (as described below), your Personal Information could be displayed on the WHOIS Site. • EU/EEA natural persons. Notwithstanding the foregoing, pursuant to the European Union’s General Data Protection Regulation 2016/679, or GDPR, if you are a EU/EEA natural person (as defined by the GDPR), other than as specified in this addendum, our publication of WHOIS Information will not contain any Personal Information. Accordingly, we will not display Personal Information of a EU/EEA natural person on the WHOIS Site. • Transfer Out. If you initiate a transfer out of a domain name away from us as the registrar of record, pursuant to our contract with ICANN, we may need to publish your registrant email address obtained from your Personal Information on the WHOIS Site for a period of approximately five (5) calendar days. After this period and assuming a valid transfer has occurred, you would cease to be our customer for that domain name and your WHOIS Information would be managed by the gaining registrar. • Certain Registries. Registries are third party providers of TLDs that are independent of domain registrars. If required by contract with a particular Registry, we may be obligated, as a domain registrar of domains provided by the Registry, to provide Personal Information and Additional Personal Information to such Registry to successfully complete your domain name registration. If we provide your Personal Information and Additional Personal Information to a Registry, the Registry has its own obligation to comply with applicable data privacy laws. • Data Escrow. Our contract with ICANN requires us to deposit the Personal Information collected with a secure third-party escrow provider who acts solely as a holder of the data. • Permitted Disclosures. We may also disclose your Personal Information when required by the rules, regulations and policies of ICANN, including but not limited to the Uniform Domain-Name Dispute-Resolution Policy (UDRP). LIST OF THIRD PARTY DATA CONTROLLERS AND SUBPROCESSORS ======================================================== Last Updated May 23, 2018 The below list describes the third parties to whom Xeliux sends personal information, as further described in the Xeliux Privacy Policy. • Sitelock • Comodo • Absolute Shredding • Admax • AffinityX • Akamai • Amazon Web Services • American Express • Aprimo • Arbor • ArcGate • Aria • Ariba • Aress • Automattic – JetPack • Avalara • Basekit • BigCommerce-HS • BlueZone • Cart32 annual invoice • Clicktale • Cloudflare • CM4All • CodeGuard • Commission Junction • Comodo • cPanel • DNS.Com • DocuSign • E-Hawke • Ecwid • eGiftCart • Evergage • Facebook • FDMS • Fortifi • Getty Images (Thinkstock) • Glowtouch • GoMobi • Google Adwords • Google Domains • Google gSuite • Google Maps API – Quarterly HS • GroupSpark • Hotjar • Impact Radius • Intermedia • Iron Mountain • Kabbage • Kount • Kumo Commerce • Marchex – HS • MarketGoo • Mashery/TIBCO • Media Highway – HS • Monetate • Neustar – HS (Localeze, WebListings) • OpenxChange • PaymentSphere • PayPal • PowerPay/eOnline Data • ProPay • Qualtrics • Salesforce • Sitelock • Shopsite • Social Made Simple • SPAM Experts • SPi • Stripe • SubmitNet • SubmitNet Local • Ubersmith • Universal Shredding • Vantiv/Digital River World Payments • Verizon • Vindicia • Weebly • WePay • WHMCS • WP Beginner • WP Forms • Yahoo/Bing • Yext • Certain third-party vendors who provide other services, including the following: o Customer service activities o Fraud detection and deterrence services o Access to advertising assets o Information technology services o Storage services o Marketing and advertising activities o Analytics and analysis o Search engine optimization services COOKIE POLICY ============= Effective May 23, 2018 This Cookie Policy describes how and why Xeliux use cookies, web beacons, pixels, tags, scripts and other similar technologies in the course of our business, including through websites and apps that link to this Cookie Policy. It also explains your rights to control our use of these tracking technologies. For additional information about our privacy practices, please review our Privacy Policy. WHAT ARE COOKIES? ================== Cookies are small data files placed on your computer or other internet-enabled device that enable our features and functionality. They allow us to record information when you visit or interact with our websites, products and services (collectively, our “Websites”). Other tracking technologies, such as web beacons and pixels work similarly to cookies, placing small data files on your device that monitor your Website activity. HOW DO WE USE COOKIES? ======================== We use cookies and other tracking technologies to make our Websites easier to use and to better tailor them to your interests and needs. We use the information we obtain from cookies and other tracking technologies to carry out profiling activities in order to learn more about you and offer you tailored advertising based on your behavior on our Websites. We also use these technologies to compile anonymous, aggregated information that allow us to better understand our customers and visitors. WHAT KINDS OF COOKIES AND TRACKING TECHNOLOGIES DO WE USE? ============================================================= PERSISTENT AND SESSION COOKIES We use two categories of cookies: Persistent cookies and session cookies. Persistent cookies are cookies that help us recognize you. They are stored on your device in between browser sessions, allowing us to remember your preferences and actions across multiple sites and on multiple visits. Session cookies expire at the end of your browser session, allowing us to link your actions during a particular browsing session. THIRD PARTY COOKIES ===================== In addition to the first party cookies set by us, we also use third party cookies. Third party cookies are cookies that are set by others, enabling the third party’s features or functionalities to be provided through the Website you are using. The third party setting these cookies can recognize your device both when it visits our Website and when it visits certain other websites or services. For example, our paid endorsers, or affiliates, may use third party cookies to identify you as a referral so they can be compensated if you sign up for services from us as a result of visiting one of our paid endorsers. The service providers of third-party cookies have their own privacy policies, and may use their cookies to target advertising to you. CROSS-DEVICE TRACKING ======================= We perform cross-device tracking which allows us to provide more relevant advertising to you on multiple devices. We do this by identifying browsing activity on your smartphones, tablets, desktop computers and other devices connected to the same IP address or logged into the same account to better understand the products and services that might be of interest to you. LOCAL STORAGE OBJECTS ======================= We also use Local Storage Objects (LSOs), such as HTML5, to, among other things, optimize screen presentation, video and other preference information. GOOGLE ANALYTICS ================== We use Google Analytics which is a web analytics tool that helps us understand how users engage with our Websites. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our Website. This information is used to compile reports and to help us improve our Websites. The reports disclose website trends without identifying individual visitors. WHY DO WE USE COOKIES? ======================== We generally use cookies that are necessary or essential to the functioning of our Websites, cookies that help us improve the performance or customize the functionality of our Websites, and cookies that help us serve you relevant advertisements. The types of cookies described below may be set by us or by a third party service provider assisting us in performing the below functions. Specifically, we use cookies for the following reasons: • Strictly Necessary: These cookies and tracking technologies let you navigate our Websites and use essential features, including secure areas and shopping baskets. Without these technologies, we are unable to deliver core functionality of our Websites, products and services to you. • Performance: These cookies and tracking technologies help us understand how customers and visitors interact with our Websites. They provide us with information about areas of our website visited, time spent on our Websites and any error messages you receive, allowing us to improve the performance of our Websites. They do not collect any information that could identify you. • Functional: These cookies and tracking technologies are used to provide certain services or to remember settings that will improve your visit, but are not essential to your use of our Websites. They may include personal information that you have disclosed to us. • Targeting or Advertising: These cookies and tracking technologies allow us to deliver content, including advertisements, relevant to your specific interests. This content may be delivered in our Websites or on third party websites or services. They allow us to understand and improve the relevancy of our advertisements. They may track personal information, including your IP address. • Social Media Cookies: These cookies are set by third parties, including Facebook and Twitter, and allow you to share what you’ve been doing on our Websites on social media. HOW CAN I CONTROL COOKIES? ============================ If you visit our Websites from Europe, only strictly necessary cookies and other tracking technologies will be used on our Websites by default. Other cookies and tracking technologies will only be used when you consent by visiting each Website’s Cookie Management Center at http://preferences-mgr.truste.com/, where available. Where you visit our Website from outside Europe, the cookies and similar tracking technologies mentioned above will be used by default Internet browsers allow you to change your cookie settings via the “options’ or “preferences” menu in your browser. Please note that if you set your browser to refuse or block all cookies, certain features or functionalities of our Websites will be limited or unavailable to you. Some internet browsers include the ability to transmit “do not track” signals. Because no industry standard has yet been developed with respect to “do not track,” our Websites do not currently process or respond to such “do not track” signals. You can opt out of Google Analytics without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout. To learn how to manage privacy and storage settings for Flash cookies, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. Further information about deleting and blocking cookies can be found at http://www.allaboutcookies.org. Further information about our advertisers’ use of cookies can be found at: • European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/ • Internet Advertising Bureau (US): https://www.iab.com/ • Internet Advertising Bureau (EU): https://www.iabeurope.eu/ HOW CAN I GET FURTHER INFORMATION? =================================== If you have any questions about our use of cookies or other tracking technologies, please email us at support@xeliux.com. Last modified May 24, 2018 ©2018 LCV GROUP SAC – XELIUX.