This privacy policy (“Privacy Policy”) applies to TheXNode and its affiliated companies (hereafter referred to as “XNode”, “we”, “us” or “our”). We, at XNode, know you (“you” or the “User”) care about how your personal information is used and shared – and we take your privacy seriously.


    This Privacy Policy applies to all of your activities on www.thexnode.com, www.thexnode.cn, jp.thexnode.com. This Privacy Policy describes and governs our practices regarding the collection, processing and usage of information we collect from Users (“Personal Data”). Data we collect from Users (“Personal Data”), is used, disclosed and protected according to this Privacy Policy.


    By using or accessing the Service in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby agree that we may collect, use, and share your information as set forth below. For purposes of this Privacy Policy, the term “includes” or “including” means including without limitation.


    We periodically update this Privacy Policy and will post any changes to this Privacy Policy on this page. Thus, we encourage you to review this Privacy Policy periodically.


    If you do not agree with any of the terms in this Privacy Policy, you should not use the Service.


    If you have any questions about this Privacy Policy, please contact us by email or mail using the contact information provided in Section 13.

    1. Personal Data We Collect




    We collect Personal Data from you when you use the Service, including when you register for access to the Service, contact us with inquiries, use our mobile applications, respond to one of our surveys or browse any of our websites.

    The Personal Data we may collect includes:

    1. basic information: including name, date of birth, gender, address, personal phone number and email address;
    2. network identification information: including IP address;
    3. personal Internet access records: including website browsing records, software usage records and click records;
    4. information on computer equipment: including the hardware model, device MAC address and operating system;
    5. employment and background information: including current employer, industry, current job title, and professional training background; and
    6. information specific to you that may be assigned by our partners: including your advertising ID assigned by our partners.

    identification information: including ID card and passport information;


    Our mobile applications may or may not include location-based services, including on-site services at events. To provide such location-based services through mobile applications, we collect, use and share precise location data, including the real-time geographic location of your mobile device. If you permit one of our mobile apps to access location services through the permission system used by your mobile operating system, we may collect the precise location of your device when the app is running in the foreground or background. Using your mobile device settings, you can control the location information you share.


    Whenever you interact with the Service, we may automatically receive and record information on our server logs from your browser or device, which may include your IP address, device identification information, Cookie information, the type of browser and/or device you’re using to access the Service, and the page or feature you requested (“Usage Data”). We may also transfer small files to your browser or device (“Cookies”) that allow us to collect certain information. We also use third-party services to collect usage information to better understand and improve the user experience. Usage information collected using third-party services is stored on the servers of the third-party service providers.

    2. XNode’s Use of Personal Data

    XNode may use your Personal Data for purposes including the following:


    1. to operate and maintain the Service (including for the purposes of fixing malfunctions and testing our security systems);
    2. to provide you with the features, functions and benefits of the Service;
    3. to enhance, improve and further develop the Service (including creating new features or functions, refining the user experience, and increasing Service technical performance);
    4. to provide you with notices related to your use of the Service;
    5. to provide you with promotional and marketing emails (you can opt-out of receiving certain types of promotional and marketing emails – but in such case you may not receive the full benefit of the Service; opting-out can be done under Settings when you are logged in to your Service account);
    6. to help personalize the Service experience for you (including remembering your information so you will not have to enter it each time you use the Service);
    7. to show you ads for our products that we think may interest you;


    We may also contract with third-party advertising networks that collect IP addresses and other information from web beacons on our websites, from emails and on third-party websites. Advertising networks may follow your online activities over time and across different websites or other online services by collecting device and usage data through automated means, including through the use of Cookies. These technologies may recognize you across the different devices you use, such as a desktop or laptop computer, smartphone or tablet. Third parties use this information to provide advertisements about products and services tailored to your interests. You may see their advertisements on other websites or mobile applications on any of your devices. This process also helps us manage and track the effectiveness of our marketing efforts.


    Aggregated Personal Data.


    In an ongoing effort to understand and serve our Users better, we often conduct research on our customers’ demographics, interests and behavior based on Personal Data that we have collected. This research is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it is no longer Personal Data.


    If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected, and we will obtain your consent for any such use.

    3. Sharing, Transfer and Disclosure of Personal Data


    We will not share your Personal Data with companies, organizations or individuals other than XNode and its affiliates, except in the following circumstances:


    1. Sharing with explicit consent. We will share your Personal Data with other parties with your explicit consent.
    2. Sharing as required by laws or contractual obligations. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with any law or court order; enforce or apply our Terms of Service and other agreements, or protect the rights, property, or safety of XNode, our employees, our users, or others. 
    3. Sharing with our affiliates. Your Personal Data may be shared with our affiliates. We will only share necessary Personal Data (for example, in order to facilitate your use of the products or services of our affiliate with your XNode account, we will share your account information as necessary with such affiliate), and if we intend to share your Sensitive Personal Data, or if the affiliate changes the purpose of using and processing your Personal Data, we will obtain your authorization and consent again. (“Sensitive Personal Data”) includes, without limitation, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, personal biometric information, genetic data, bank account numbers, financial information, transaction information, and personal information of children age 14 and under. 
    4. Sharing with authorized partners. Certain services of ours will be jointly provided together with our authorized partners solely for the purposes stated herein. We may share certain Personal Data of yours with our partners to provide better customer service and user experience. We may also share your Personal Data with our partners so they can provide you with their services. We will only share your Personal Data for lawful, proper, necessary, specific and explicit purpose to the extent required for providing partner services. Our partners have no right to use the shared Personal Data for any other purposes other than providing their products or services to you.


    We may anonymize your Personal Data so that you are not individually identified, and provide that information to our partners. We may also provide aggregate usage information to our partners, who may use such information to understand how often and in what ways people use the Service, so that they, too, can provide you with an optimal online experience. However, we will never disclose aggregate information to any third party in a manner that would identify you personally, as an individual.


    Except for the purposes described above, we will not transfer your Personal Data to any company, organization or individual, except in the following circumstances:

    1. we may transfer your Personal Data to other parties with your explicit consent; or
    2. in case of any acquisition, merger, insolvency or liquidation of XNode, if the transfer of Personal Data is involved, we will require the new company, organization or individual in possession of your Personal Data to continue to be bound by this Privacy Policy, or we will require such company, organization or individual to obtain your authorization and consent for any use of your Personal Data.


    We will disclose your Personal Data to the public only under the following circumstances:


    1. you have explicitly authorized us to disclose your Personal Data; 
    2. disclosing your Personal Data is in the interest of national security; public health, or another major public interest; 
    3. your Personal Data is relevant to any criminal investigation, prosecution, judgment, or enforcement;
    4. disclosing your Personal Data is necessary to protect yours or another individual’s life, property or other major lawful right;
    5. Personal Data is disclosed voluntarily by you to the public;
    6. Personal Data is collected from public channels, such as news reports or from public government documents.


    Pursuant to applicable laws, sharing and transfer of aggregated data which cannot be recovered by the recipient to re-identify individual Personal Data does not constitute sharing, transfer and disclosure of Personal Data, and therefore it may be stored and processed without notice to you and without your consent.

    4. User Rights to Personal Data


    If you are a registered user of the Service, we provide you with tools to access or modify your Personal Data and other profile information.


    Subject to the limitations of applicable laws, where processing Personal Data is necessary for entering into or performing our obligations under a contract with you or is processed with your consent, you may request that your Personal Data be transferred to you or another designated party (where technically feasible).


    To the extent you have authorized us to collect and process your Personal Data, you may withdraw that authorization by deleting information, turning off device functions, or changing privacy settings on our website or in our software. You may also stop using the Service so that we cannot continue collecting your Personal Data. Please note that some parts of the Service may not function properly if you remove our authorization to collect your Personal Data. For any Personal Data that you have authorized the Organizers directly, you should contact the Organizers to withdraw such authorization.

    5. Security

    We take various precautions to protect your Personal Data from loss, misappropriation and misuse, and from being accessed, disclosed, modified or destroyed without permission. In order to ensure the safety of your Personal Data, we have established strict information security provisions and procedures to protect your Personal Data.


    In the event of any Personal Data security breach, we will, in accordance with the requirements of applicable laws and in all cases within 30 days, notify you of the basic information and possible consequences of such security breach, actions we have taken or will take in response to the breach, suggestions on how you may prevent and reduce risks on your own, and actions we will take on your behalf. We will notify you of the relevant information through email, letter, phone, or push notification, or by publishing an announcement to our websites. Any such notice will be issued in compliance with all applicable laws.

    6. International Transfers of Personal Data


    1. Personal Data collected and generated within the People’s Republic of China (“PRC”) will be primarily stored at hosting facilities located in the PRC. 
    2. These facilities are either operated by XNode or our third-party providers. By using the Service, you are consenting to have this data stored, transferred and processed according to this Privacy Policy.
    3. XNode is a global company. Subject to applicable laws, we may transfer your Personal Data to any XNode affiliate worldwide when processing that data for the purposes described in this Privacy Policy. We may also transfer your Personal Data to our third party service providers, who may be located in a country or area outside the European Economic Area (“EEA”). 


    Under California Civil Code Sections 1798.83-1798.84, California residents may request a notice identifying the categories of Personal Data that we share with our affiliates and/or third parties for marketing purposes, and be provided with contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: contact@thexnode.com.


    1. The EU General Data Protection Regulation (“GDPR”): In May 2018, a new data privacy law known as the EU General Data Protection Regulation became effective. The GDPR requires us to tell you about the legal grounds we are relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data in conjunction with the Service will be that: (i) you provided your consent; (ii) the processing is necessary for our contractual relationship; (iii) the processing is necessary for us to comply with our legal or regulatory obligations; or (iv) the processing is in our legitimate interest in providing you with the Service.
    2. Transfers of Personal Data: XNode is a global company; thus, we may need to transfer your Personal Data outside of the country from which it was originally collected. This may be intra-group or to third parties that we work with who may be in jurisdictions outside the EEA, Switzerland and the UK, that have no data protection laws or laws that are less strict than those in the EEA, Switzerland and the UK. Whenever we transfer Personal Data outside of the EEA, Switzerland or the UK, we take all legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data.
    3. Personal Data Retention/Rights: We retain your Personal Data for as long as necessary to provide you with the Service, comply with applicable laws, resolve disputes and enforce our agreements. If you have an account with us, we will typically retain your Personal Data for a period of 90 days after you have requested that your account is closed, or for up to seven years after your account becomes inactive but is not closed.  Data protection laws provide you with rights in respect to Personal Data that we hold about you, including the right to request a copy of the Personal Data, the right to request that we rectify, restrict or delete your Personal Data, and the right to unsubscribe from marketing communications.  You can exercise these rights by contacting us using the contact information set out in Section 12. If you have a complaint about how we handle your Personal Data, please contact. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.
    4. XNode as a Data Controller and a Data Processor: 


    EU data protection law distinguishes between organizations that process Personal Data for their own purposes (known as "data controllers") and organizations that process personal data on behalf of other organizations or individuals (known as "data processors"). If you have any questions or complaints about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.


    XNode may act as either a data controller or a data processor with respect to your Personal Data, depending on the circumstances. We will be a data controller of any information you submit to us in order to create a User account or an Organizer account. However, once a User submits Personal Data to an Organizer in conjunction with use of the Services, XNode becomes a data processor with respect to the Organizer Collected Personal Data.

    7. Changes to this Privacy Policy

    This Privacy Policy was last updated on the date set forth at the top of this Privacy Policy. We will alert you to any future updates to this Privacy Policy by placing a notice on our website, by sending you an email, by notifying you when you logon to the Service, and/or by some other means. We will also edit the date at the top of this policy to reflect the date of the changes. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), our legal notices (including this Privacy Policy) will still govern your use of the Service, and you are still responsible for reading and understanding them. Use of Personal Data we collect is subject to the Privacy Policy in effect at the time such Personal Data is collected. If you use the Service after any updated Privacy Policy has been posted, that means that you agree to all the changes made with respect to all Personal Data, whether collected previously or in the future.

    8. Minors

    We do not knowingly collect or solicit personal information from anyone under the age of 14. If you are under 14, please do not attempt to register for the Service or send any personal information about yourself to us. If we learn that we have collected personal information from a child under 14, we will delete that information as quickly as possible. If you believe that a child under 14 may have provided us with personal information, please contact us at contact@thexnode.com.

    9. Contacting Us

    If you have any questions or concerns regarding our privacy policies, please send us a detailed message by email to contact@thexnode.com.

    10. Requests to Delete Personal Data and other issues


    You can delete your account by contacting the XNode system administrator at contact@thexnode.com. If a User initiates a data deletion request, to the extent permitted under applicable law, XNode is authorized to delete or anonymize Personal Data of the requesting User from the Service. However, if you are a User, you understand that even if XNode deletes or anonymizes your Personal Data upon your request or pursuant to this Privacy Policy, your Personal Data may still be available in the Organizer's own databases if transmitted to the Organizer prior to XNode taking action to delete or anonymize your Personal Data.


    Even after you remove information from your profile or delete your account, Personal Data may be retained by us on back-up servers indefinitely, subject to and in compliance with applicable laws. We may retain your Personal Data for a period of time consistent with the original purpose of collection. We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).


    We may also indefinitely retain and use any aggregated data derived from or incorporating your Personal Data, but not in a manner that would identify you personally.

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