Privacy Policy

Last Modified: May 28, 2018


This Privacy Policy describes how Prism Labs, Inc. collectively referred to as "XPO.Network" (or "we" or “us” or “our”) collects, uses, and handles your data when you use our website, products and services (“Services”). Please take the time to carefully read through this policy. As you use our Services, we want to be clear how XPO.Network uses your information and how your privacy is protected. By using the Services, you consent to the data practices detailed in this policy. This Privacy Policy does not apply to services offered by other companies or other sites linked from our Services.

What Information is Collected

When you use our Services, we may collect information you send us or information we receive from your use of our Services. We may collect information in the following ways:

  • Information you give us. We may collect information that you provide us through a web form, such as when you create a XPO.Network Profile, or when you otherwise correspond with us regarding our Services, such as when you contact our customer support team. The information you provide us may include your email address (such that we can send you email) and/or a bitcoin wallet address (such that you can receive bitcoin from XPO.Network).

    In addition, to create an account on XPO.Network, you must provide us with your name and email address, and agree to our Terms of Use and this Privacy Policy, which governs how we treat your information. You may provide additional information when creating a XPO.Network account, such as linking to your Blockstack, Facebook, LinkedIn, GitHub, Google, or Twitter accounts, to help build your XPO.Network Profile. You understand and acknowledge that by creating a XPO.Network account, we and others will be able to identify you by your XPO.Network Profile.

  • Device information. We may collect information about devices you use to access the Services and how you use the Services, such as your IP address and which websites you visited before accessing our Services.

  • Logs. Our servers automatically record information created by your use of our Services to help us diagnose and fix technical issues, and to improve the the overall quality and user experience of our Services. Logs may include information such as your IP address, browser type, operating system, details of how you used our Services (such as your commands at the command line), diagnostic information related to the Services (such as crash activity reports), the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. For users of the two1 developer tools, tou may opt out of command line analytics collection by setting "collect_analytics" to "false" in your two1.json configuration file.

  • Cookies. We use technologies like cookies and pixel tags to gather information about how you are interacting with the Services, which may include identifying your IP address, browser type, and referring page.

How is Collected Information Used

We collect and use information from you in order for us to provide, protect, and improve our Services, and to provide you with a personalized experience when using our Services. For example, when you provide XPO.Network with your email address, we may send you updates on new Services and security notices.

Much of the information you provide us through our Services is information that is designed to be made public, such as your XPO.Network Profile information, including your name, photo, and XPO.Network username.

Some specific examples of how XPO.Network may use your personal data are:

  1. to provide you with information about how you are using email;
  2. to customize, analyze, adjust and improve the site and services to better meet your needs;
  3. to facilitate communication between XPO.Network and you;
  4. to facilitate communication between you and other users;
  5. if you provide us with information about other software and services that you use, we may use your personal data to try to synchronize your emails with such other software and services;
  6. to provide you with information that may interest you, such as our newsletters or emails about our products and services (this information contains a subscriber link allowing you to opt out);
  7. to provide you with marketing and promotional information about products and services we believe may interest you (this information contains a subscriber link allowing you to opt out);
  8. to administer a survey (if you consent to participate in the survey via a response email);
  9. to send you a task in your Inbox (should you choose to accept it);
  10. in a customer testimonial posted on the site;
  11. to enforce XPO.Network’s agreements with you;
  12. to provide you with important administrative information regarding the site and services, such as changes to this Privacy Policy, our Terms of Use and our other policies;
  13. And to prevent fraud and other prohibited or illegal activities.

Single Sign-On / OAuth

You can log in to our site using Blockstack's sign-in service and also connect to other platforms like Coinbase, Google and LinkedIn. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address, for example.

How We Use Cookies

Like most online businesses, we use cookies and web beacons on our websites and marketing-related emails to gather and analyze non-personal information such as the visitor’s IP address, browser type, ISP, referring page, operating system, date / time, and basic geographic information. We use these technologies to provide, improve and protect our Services, for example to:

  • Customize our Services, such as remembering your username for the next time you use our Services;
  • Measure product and marketing effectiveness;
  • Collect information about your computing device to mitigate risk, help prevent fraud and promote trust and safety

You may set your browser to not accept cookies, but this may result in the Services not functioning properly for you.

Information We Share

We do not sell, exchange, transfer, or give your personal information to any other company or individual for any reason except as set forth below:

  • We will share personal information with companies or individuals when we have your consent to do so;
  • We may provide personal information to our trusted services providers to process it for us to assist us in providing Services to you, and only based on our instructions and in adherence with this Privacy Policy and applicable confidentiality and security measures;
  • If we are involved in a merger or acquisition, your information may be transferred as part of that transaction. In such event, we will require that your personal information be protected in accordance with this Privacy Policy. We will notify you of any change in applicable policy.
  • We will share personal information with law enforcement or other third parties if we: (1) are compelled to do so to comply with any applicable law or legal process; or (2) believe in good faith that disclosure is necessary to prevent physical harm, illegal activity, or harm to the rights, property, or safety of XPO.Network or our users.

We may share non-personally identifiable information publicly and with our partners. For example, we may share anonymized analytics information that reveal general trends about our Services.

How Do We Protect Your Information?

Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.

XPO.Network takes reasonable precautions, as described herein, to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We may store, process and transmit information in locations around the world -- we may process your personal information on a server located outside the country you live. Some information may also be stored locally on devices you use to interact with XPO.Network’s Services.

We protect information by maintaining physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We use firewalls and data encryption, we enforce physical access controls to our buildings and files, and we limit access to personal information only to those employees who need to know that information in order to process it for us.

Data Retention

We store information about your use of our Services for as long as we need it to provide you the Services. Note that we may retain your personal information as necessary in order to comply with our legal obligations, resolve disputes, or enforce our agreements to the extent permitted by law.

Changes To This Privacy Policy

We may amend this Privacy Policy at any time by posting the most current version on our website. If the changes materially reduce your rights, we will provide a more prominent notice (for example, for certain Services we will send email notification of significant changes). We recommend checking this page frequently for changes.

Will XPO.Network Share Any of the Personal Information it Receives?

We do not rent or sell your Personal Information in personally identifiable form to anyone. We may share your Personal Information with third parties as described in this section: Information that’s been de-identified. We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. For example, we use Segment's to perform analytics on the Services. If you would like to opt-out of Segment's automatic retention of data collected through the Services that integrate Segment's products/services, you can do so by emailing us at hello@xpo.network.

Contact Us

If you have questions or concerns regarding this policy or would like to access, change or delete your personal information, contact us on our support page or by emailing us at hello@xpo.network.

To create an account on XPO.Network, you must provide us with your name and email address, and agree to our Terms of Use and this Privacy Policy, which governs how we treat your information. You may provide additional information when creating a XPO.Network account, such as linking to your Facebook, LinkedIn, GitHub, Google, or Twitter accounts, to help build your XPO.Network Profile. You understand and acknowledge that by creating a XPO.Network account, we and others will be able to identify you by your XPO.Network Profile.

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. If XPO.Network is not processing your Personal Data on behalf of a third party, XPO.Network will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at hello@xpo.network.

How and With Whom Do We Share Your Data?

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

  • • Payment processors
  • • Analytics service providers (e.g. Segment)
  • • Messaging service providers (e.g. Intercom)

We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).

  • • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
  • • Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
  • • Maintain the security of our products and services

Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally

What Security Measures Do We Use?

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, we use encryption when sending and storing Personal Data. We do not sell Personal Data to third parties, and only allow third party access to Personal Data in order to improve the Services or for the purpose of analytics. We use OAuth to ensure a secure sign up and authentication process, SSL connections to manage the storage of Personal Data, and custom firewalls for additional protection of stored Personal Data.

What Rights Do You Have Regarding Your Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email hello@xpo.network. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging into XPO.Networko and viewing your account settings.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by accessing your account settings. You can correct some of this information directly by logging into XPO.Network and editing your information from the account settings page.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about XPO.Network’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data:

The Services are hosted and operated in the United States (“U.S.”) through XPO.Network and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to XPO.Network in the U.S. and will be hosted on U.S. servers, and you authorize XPO.Network to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, a copy of which can be obtained at https://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=celex%3A32010D0087.


Author(s)

The XPO.Network Team