1. WHAT INFORMATION DO WE COLLECT? Personal Information You Disclose to Us In Short: We collect personal information that you voluntarily provide to us and use it only as described in this policy. We collect personal information when you register on the Services, express interest in obtaining information about us or our Services, participate in activities on the Services, or otherwise contact us. Personal Information Provided by You The types of personal information we collect depend on your interactions with us and the Services, and the choices you make. This may include: Identifiers: Names, phone numbers, email addresses, usernames, passwords — used to manage your account and provide access to Services. Sensitive Information We do not collect or process any information classified as sensitive. Payment Data We may collect data necessary to process purchases, such as your payment instrument number and security code. All payment data is securely handled by our third-party payment providers, Stripe and Kowri. You may view their privacy policies at Stripe and Kowri. Application Data If you use our mobile application(s), we may collect the following with your permission: Geolocation Information: We may request access to location-based information from your mobile device to enable certain features. You can change access or permissions in your device's settings. We use this information to maintain the security of our applications, troubleshoot issues, and perform internal analytics. Accuracy of Information All personal information you provide to us must be true, complete, and accurate, and you should notify us of any changes to such personal information. Google API Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. 2. HOW DO WE PROCESS YOUR INFORMATION? In Short: We process your information to provide, improve, and manage our Services, communicate with you, ensure security, prevent fraud, and comply with legal obligations. We may also process your information for additional purposes, where permitted by law and with your consent. We process your personal information for various reasons, depending on your interactions with our Services, including: To facilitate account creation and authentication, and manage user accounts: We process your information to create and authenticate your account, enabling secure login and management. This includes maintaining accurate account information and ensuring your access to our Services. To deliver and facilitate the delivery of our Services to you: We process your information to provide requested features and services. This may include remembering your preferences, personalizing your experience, and delivering the content or features you choose to use within our app. To improve and enhance our Services: We analyze usage patterns and feedback to understand how our Services are used and where improvements are needed. This helps us add new features, enhance functionality, and resolve technical issues, ensuring a better user experience. To communicate with you: We use your information to send necessary account-related communications, respond to your inquiries, and provide updates regarding our Services. This may include sending notifications about account activity, changes to policies, or other relevant information. For security and fraud prevention: We process your information to detect, prevent, and respond to security incidents or unauthorized access attempts. This helps us protect the integrity of our Services, your account, and other users' data. To comply with legal requirements: In certain cases, we may need to process your information to meet legal or regulatory obligations. This could include responding to lawful requests from government authorities, fulfilling compliance requirements, or handling disputes as required by applicable law. 3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? In Short: We may share information in specific situations described in this section and/or with specific third parties to fulfill services, enhance functionality, and ensure compliance. We may need to share your personal information in the following situations: Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. This is done to ensure continuity of service and protect your data during transitions. Use of Google Maps Platform APIs: Our application may integrate with Google Maps Platform APIs (e.g., Google Maps API, Places API) to provide accurate geolocation-based services, such as directions and location-based content. In these cases, Google Maps may access your device’s GPS, Wi-Fi, and cell towers to estimate location. For more information on Google Maps' data practices, you can view their privacy policy. 4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? In Short: Yes, we use cookies and similar tracking technologies to enhance user experience, maintain security, and improve our Services. We and our service providers may use cookies, web beacons, pixels, and other tracking technologies to collect information when you interact with our Services. These technologies help us: Maintain the security and functionality of our Services and your account, Monitor performance to prevent crashes and fix bugs, Store and remember your preferences, Provide a seamless user experience by saving your session settings. We also allow trusted third parties and service providers to place cookies and similar tracking technologies on our Services. These are primarily used for: Analytics: To help us understand how our users interact with the Services and to enhance our offerings accordingly. Advertising: To manage, personalize, and display advertisements relevant to your interests, including on other websites. Shopping Cart Reminders: To send you notifications for abandoned shopping carts, depending on your preferences. You can control and manage cookies through your browser settings. For more information on the specific cookies we use, the purposes they serve, and how to manage your cookie preferences, please see our Cookie Notice. 5. Here’s an updated version that clarifies retention practices and strengthens compliance with data protection standards: 5. HOW LONG DO WE KEEP YOUR INFORMATION? In Short: We retain your information only for as long as necessary to fulfill the purposes outlined in this Privacy Notice or as required by law. We keep your personal information only as long as it is needed for the purposes described in this Privacy Notice, or as required by applicable law (for example, for tax, accounting, or other legal obligations). Generally, we retain personal information only for the duration of your account with us, unless a longer retention period is legally required or allowed. When we no longer have a legitimate business need to process your personal information, we will delete or anonymize it. If immediate deletion is not possible (for instance, because the data is stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is feasible. 6. HOW DO WE KEEP YOUR INFORMATION SAFE? In Short: We prioritize the protection of your personal information through a combination of organizational and technical security measures. We have implemented a range of security measures designed to safeguard the personal information we process. These include industry-standard technical measures, such as encryption and secure servers, as well as organizational practices that limit access to your information to authorized personnel only. While we are committed to securing your information, please be aware that no electronic transmission over the internet or data storage system can be guaranteed as entirely secure. This means we cannot assure that unauthorized parties will not circumvent our security protocols and gain improper access to your information. We will continue to enhance our security measures in line with technological advancements to minimize risks. By using our Services, you acknowledge that personal information transmitted to and from our platform is done at your own risk. We recommend accessing our Services within a secure environment. 7. WHAT ARE YOUR PRIVACY RIGHTS? In Short: You may review, change, or terminate your account at any time, with specific rights varying based on your location. Accessing, Updating, or Deleting Your Information: You have the right to access and update certain personal information or, if desired, to request deletion of your account. These options are available in your account settings or by contacting us directly. Withdrawing Your Consent: If we rely on your consent to process your personal information, you may withdraw this consent at any time by contacting us as described in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section. This will not impact the legality of any data processing carried out prior to your withdrawal. Additionally, where permitted by law, we may continue processing your information based on lawful grounds other than consent. Additional Rights: Depending on your jurisdiction, you may also have rights to data portability, restriction of processing, or objection to specific processing activities. To exercise these rights, please reach out to us using the contact information provided. Account Information If you wish to review, change, or terminate your account at any time, you can do so by: Logging into your account settings and updating your information, or Contacting us to request account termination. Upon your request for termination, we will deactivate or delete your account and personal information from our active databases. However, some information may be retained in our records as necessary to prevent fraud, troubleshoot issues, support ongoing investigations, enforce legal agreements, or comply with applicable legal requirements. For questions or comments about your privacy rights, please reach out to us at contact@xlayer.in. 9. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS? In Short: Depending on your country of residence, you may have additional privacy rights. Republic of South Africa Residents of South Africa have the right to request access to or correction of their personal information. To make such a request, please contact us using the details provided in the "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?" section. If you are unsatisfied with our handling of your personal information, you may contact the Information Regulator: The Information Regulator (South Africa) General inquiries: enquiries@inforegulator.org.za Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za, POPIAComplaints@inforegulator.org.za 12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? To request to review, update, or delete your personal information, or to withdraw consent to processing, please fill out and submit a data subject access request by contacting us at Data Subject Access Request Form or by reaching out to our customer service. We will respond to your request in accordance with applicable data protection laws. Please note that certain legal obligations may require us to retain specific data even after a request for deletion.