Privacy Policy

Last Updated 2023-05-14

This Privacy Policy ("Policy") outlines how and why XULU.TECH LLC ("Company", "we," "us," or "our") might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

  • Visit our website at https://xulu.tech, or any website of ours that links to this privacy notice
  • Download or use any mobile applications that are distributed by the Company, such as Selene Wallet or any other application of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events

This Policy may be updated without notice at any time. If you do not agree with our policies and practices, please do not use our Services.

If you have any questions or concerns, please contact us by email at contact@xulu.tech.

1. WHAT INFORMATION DO WE COLLECT?

We only collect or process data that you voluntarily provide to us, and only when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

When you engage with our Services, such as when accessing any of our websites, or using any of our mobile applications, we may collect the following information may collect information about your usage of our Services:

  • Log and Usage Data. Log and Usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about how and when you use our Services, and other technical information.
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address, device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

2. HOW DO WE PROCESS YOUR INFORMATION?

The limited information we collect is used for a variety of reasons, depending on how you interact with our Services, including:

  • Improving our website, products, or services based on usage trends.
  • Ensuring the functionality and security of our systems.
  • Responding to your inquiries, requests, or support needs.
  • Complying with applicable laws, regulations, or legal processes.
  • Protecting our rights, property, or safety, and that of our users or others.

3. WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION?

We do not share or disclose any collected information with third parties unless explicitly authorized by you or as required by law.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

We retain the information we collect for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required by law.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

6. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at contact@xulu.tech.

7. OUR OBLIGATIONS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

This section only applies to users located in the UK or EU.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
    • Analyze how our Services are used so we can improve them and to engage and retain users
    • Diagnose problems and/or prevent fraudulent activities
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

8. OUR OBLIGATIONS TO RESIDENTS OF CANADA

This section only applies to users located in Canada.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally required under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

9. YOUR RIGHTS

As a user, you have the right to access, correct, or delete your limited personal information that we hold. To exercise these rights, please contact us at contact@xulu.tech.

10. COOKIES AND SIMILAR TECHNOLOGIES

We may use cookies or similar technologies to enhance user experience and gather certain information about your interactions with our website or applications. You may manage your preferences regarding cookies through your browser settings.

11. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us by email at contact@xulu.tech.