Privacy Policy

Is the xchng.io website intended for persons under thirteen years of age?

No. The xchng.io website is not intended for the use of persons under thirteen years of age. Kochava Labs SEZC (“Kochava”) does not knowingly solicit or collect personally identifying information (“PII”) from or about children, nor does Kochava knowingly market its products or services to children.

Does this Privacy Policy apply to linked websites?

No. Although the xchng.io website may contain links to other sites, Kochava is not responsible for the content, security, or privacy practices employed by those sites. Kochava neither owns nor controls the third-party websites; thus, this Privacy Policy does not apply to information provided to or gathered by them.

What type of information does Kochava collect from users of the xchng.io website?

By way of industry-standard web log files and similar tools, each time a user visits the xchng.io website, Kochava collects the URL from which the user visited, the pages visited, the computer’s browser information, and the IP address.

Does Kochava use web cookies on the xchng.io website?

Yes. Kochava uses web cookies to track the pages viewed during each visit to the xchng.io website. Kochava uses this information to help improve the user’s experience and to better understand how users use the site. Kochava does not attempt to link web cookie data to PII.

Is a user able to block Kochava from placing web cookies on its computer?

Yes. A user may set its browser to refuse web cookies before accessing the xchng.io website. In doing so, however, certain features of the site may not function properly and the user assumes all responsibility for any resulting loss of functionality.

Is Kochava a participant in the EU-U.S. Privacy Shield program?

Kochava’s parent company, Kochava Inc., is a participant in the EU-U.S. Privacy Shield program. Kochava adheres to all of the principles of the EU-U.S. Privacy Shield program. For more information regarding the program and its principles, visit https://www.privacyshield.gov/. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will govern.

Does Kochava collect any PII from website visitors?

No, unless it is voluntarily provided by the visitor. Kochava does not collect any PII when a user visits the xchng.io website unless the user voluntarily provides such information as a result of submitting a request to open a user account or participating in a token sale. Such PII may include, among other information, a user’s full name, physical address, email address, date of birth, passport information, phone number, company name, and website URL. Users are under no obligation to provide Kochava with PII of any kind; however, refusal to do so may prevent the user from using certain features of the website.

How does Kochava use the PII it receives from website visitors?

Kochava may use a visitor’s PII to: (a) verify the user’s identity; (b) verify the user is qualified to participate in a token sale; or (c) directly communicate with the user regarding the use of the website or offerings. By using the forms found on the xchng.io website, the visitor consents to the use of PII as described in this paragraph.

Does Kochava share the PII it receives from website visitors with third-parties?

Kochava shares a visitor’s PII to: (a) verify the user’s identity and (b) verify the user is qualified to participate in a token sale. These partners are contractually obligated to treat the PII with at least the same level of confidentiality as does Kochava. Despite taking these precautionary measures, Kochava may be liable in some circumstances for transferring personal information to a third party that violates the Privacy Shield Principles.

How may a website visitor opt-out from receiving communications from Kochava?

A user may opt-out from receiving communications from Kochava by contacting Kochava via email (info@xchng.io).

Is a website visitor able to limit the use or disclosure of its PII?

Yes. A visitor may instruct Kochava to limit the use of its data and PII to that which is strictly necessary for Kochava to directly service the visitor. A visitor may also instruct Kochava to limit the use of its data and PII to the express reason Kochava provided for such use. A visitor may also instruct Kochava to permanently delete its PII in the event the visitor no longer desires any communication from Kochava. Furthermore, a visitor may instruct Kochava to withhold disclosure of its PII to third-parties. A visitor may request the above limitations by contacting Kochava via email (info@xchng.io).

Is a website visitor able to access its PII?

Yes. A visitor may request access to all of its Kochava-collected PII by contacting Kochava via email (info@xchng.io).

How should a website visitor lodge a privacy complaint against Kochava?

How should a website visitor lodge a privacy complaint against Kochava?

Must Kochava disclose PII in response to lawful requests by public authorities?

Yes, in accordance with the Privacy Shield Principles, Kochava may be required under certain circumstances to disclose PII in response to lawful requests by public authorities.

To whom should a user direct its questions regarding this Privacy Policy?

A website visitor may direct its questions regarding this Privacy Policy to the legal department via email (info@xchng.io)

This Website Visitor Privacy Policy was last updated April 30, 2018.