Privacy Policy

Effective Date: 2025.02.01

Introduction

XON ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use the XON web-based crypto-like rewards platform (the “Service”). We comply with applicable data protection laws, including the European Union General Data Protection Regulation (GDPR). By using our Service, you agree to the collection and use of information in accordance with this Policy.

Data Controller and Contact Information

For the purposes of data protection law, XON operates as the data controller of your personal data collected via the Service. Our Service is hosted on the Wix.com platform, which acts as a data processor on our behalf. If you have any questions or wish to exercise your rights regarding your personal data, please contact us at xon.unvrse@gmail.com.

Personal Data We Collect

We collect different types of personal data from you when you interact with our Service:

• Account Information: When you register for XON, we collect information you provide, such as your email address, referral code and a password, We may also collect a username or display name if you choose to provide one. This information is necessary to create and maintain your account.

• Contact Information: If you communicate with us (for example, via support email or a contact form), we will collect any information you provide in that communication, such as your name, email address, and the content of your message.

• Automatically Collected Data: When you use the Service, certain data is collected automatically. This includes your Internet Protocol (IP) address and general location information (such as city or country inferred from your IP), device and browser type, operating system, unique identifiers (if any), and usage data such as pages viewed, actions taken on the site, and time spent. This information may be collected through cookies and similar tracking technologies as described below. For example, our servers (operated by Wix) automatically log IP addresses and certain device data when you access the site.

• Cookies and Tracking Data: We use cookies and similar technologies to operate and personalize the Service. Cookies are small text files placed on your device that help us remember your preferences, enable certain features, and collect analytics data. We also utilize cookies from third parties (described in a later section) for advertising and measurement. For more details, see Cookies and Tracking Technologies below.

We do not intentionally collect any sensitive personal data (such as race, religion, health, or financial information) through XON. We also do not knowingly collect personal data from children under the age of 18 (see Children’s Privacy below).

How We Use Your Personal Data

We use the collected data for the following purposes:

• Providing and Improving the Service: We process your personal data to create and manage your account, authenticate you at login, and enable you to earn and manage rewards on the platform. We also analyze usage data (generally in aggregated or anonymized form) to understand how our Service is used and to improve its functionality and user experience.

• Communication: We may use your email address to send important account or transactional communications. For example, we might email you to verify your account, notify you of technical or security updates, provide customer support, or inform you of changes to our Service or policies. We will not send you marketing emails unless you have given consent. If you have opted in to a newsletter or promotional updates, you can opt out at any time (see Your Rights below).

• Personalized Content and Advertising: With your consent, we (and our advertising partners) use cookies and tracking data to personalize the content and ads you see on XON. For instance, we use Google Ads on our site to display advertisements relevant to you. Google may use cookies to serve ads based on your prior visits to our site or other sites on the internet. You can adjust your Google ad settings to control personalized ads. (See Third-Party Services and Advertising and Cookies sections for more details.)

• Security and Fraud Prevention: We process certain data (such as IP addresses and activity logs) to help monitor, prevent, and address fraud, abuse, security incidents, and other harmful activity. This is necessary to protect the integrity of our platform and our user community.

• Legal Compliance: We may process personal data as required to comply with applicable laws, regulations, legal processes, or enforceable governmental requests. For example, we might retain certain information to satisfy tax, accounting, or law enforcement requirements, or to exercise or defend legal claims if necessary.

Legal Bases for Processing

Under the GDPR, we rely on specific lawful bases to process your personal data. The legal bases we use include:

• Contract: We process data that is necessary to provide you with the Service you requested – for example, the information needed to register your account and let you use the XON platform. This is considered processing necessary for the performance of our contract with you (the Terms & Conditions you agree to by using XON).

• Consent: We will rely on your consent for certain processing activities. Notably, we request your consent for the use of non-essential cookies and for showing you personalized ads. If we ever send you promotional emails or newsletters, it will be based on your explicit consent (which you can withdraw at any time). When consent is our legal basis, you have the right to withdraw it – see Your Rights below on how to do so.

• Legitimate Interests: We may process your data for our legitimate business interests, provided such processing is not overridden by your rights and interests. For example, it is in our legitimate interest to use certain basic analytics to improve our services, to secure our website, and to prevent fraud. When we rely on this basis, we carefully consider and balance our interests against your privacy rights. You have the right to object to processing based on legitimate interests in certain cases (see Your Rights).

• Legal Obligation: Where we are subject to a legal obligation, we may process personal data to the extent necessary to comply. For instance, we may retain transaction records or respond to lawful requests by public authorities if required by law.

We will clearly inform you of the legal basis for processing your data where required. If you have questions about the legal basis of how we process your personal data, contact us for more information.

How We Share Your Personal Data

We treat your personal data with care and confidentiality. We do not sell your personal information. However, we do share certain data with third parties in the following circumstances:

• Service Providers (Processors): We use third-party companies to operate and support our Service. Chief among these is Wix.com, the platform on which XON is built and hosted. Wix acts as our data processor, providing the infrastructure, data storage, and database services for running the website. Your data (such as account information and site usage data) is stored through Wix’s data storage and databases on secure servers behind firewalls. We have a Data Processing Agreement in place with Wix, ensuring that they handle personal data in compliance with GDPR and only according to our instructions.

• Advertising Partners: We partner with advertising networks like Google Ads to display ads on XON. If you consent to personalized advertising, these third parties may collect and process certain information from our site through cookies or similar means. For example, Google may collect cookie identifiers or device data when ads are displayed, in order to provide tailored ads. These third-party ad services operate under their own privacy policies. We encourage you to review Google’s Privacy Policy and advertising practices for more information on how they handle data. Please note that if you opt out of personalized ads, Google will still show ads but they will be non-personalized.

• Analytics Tools: Our website uses analytics tools to understand how users interact with XON. We primarily rely on Wix’s built-in analytics. In some cases, third-party analytics services might be used (for example, if we integrate Google Analytics or another tool in the future). Such third-party tools may set their own cookies and collect usage data (like page visits, clicks, and referring sites). Any third-party analytics provider will be obligated to handle data according to their privacy policy. (If we introduce a new analytics provider, we will update this Privacy Policy accordingly.)

• Legal Compliance and Protection: We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). We may also disclose information if we believe in good faith that it is necessary to investigate or prevent fraud, security issues, or potential violations of our Terms & Conditions or this Privacy Policy, or to protect the rights, property, and safety of XON, our users, or others as required or permitted by law.

• Business Transfers: In the unlikely event that XON is involved in a merger, acquisition, bankruptcy, or sale of assets, your personal data may be transferred to a successor or affiliated entity as part of that transaction. If such a transfer occurs, we will ensure the new owner uses your data in accordance with this Privacy Policy or provides notice of any changes.

Please note that when third-party services (such as Google Ads or any Wix App Market tools) collect information via our Service, they have their own privacy practices for handling that data. For example, any data collected by Google for ads or by an external app is governed by their policies, not this Privacy Policy. We do not control how these third parties use information they collect from your browser or device via their scripts or widgets on our site. However, we do our best to only partner with reputable companies that are GDPR-compliant or have adequate privacy safeguards.

Cookies and Tracking Technologies

Cookies: As noted, XON uses cookies and similar tracking technologies to provide and enhance the Service. When you first visit our site, you will see a cookie consent banner that allows you to accept or manage non-essential cookies, in compliance with EU ePrivacy directives and GDPR. There are different categories of cookies we use:

• Necessary Cookies: These cookies are essential for the website to function properly. They enable core features such as user login, account navigation, and security. Without these, the Service may not perform correctly. These cookies do not require consent.

• Preferences Cookies: These cookies allow our site to remember choices you make (such as language or region, if applicable) to provide a more personalized experience.

• Analytics Cookies: These cookies collect information about how visitors use our site, such as which pages are visited most often and any error messages encountered. We use this data to improve our Service’s performance and understand user engagement. We currently use Wix’s analytics for this purpose, which may set its own cookies or use similar technologies. Where possible, analytics data is anonymized or aggregated.

• Advertising Cookies: We use advertising cookies from third parties like Google to deliver ads that are relevant to you. These cookies can track your browsing habits on our site (and potentially across other sites) to serve you personalized ads. For example, Google’s advertising cookies enable it and its partners to serve ads to you based on your visit to our site and/or other sites on the Internet. Such cookies will be stored only if you consent via the cookie banner. If you do not consent, you will either not see ads on our site or will see only non-targeted ads. You can also manage and opt out of Google’s advertising cookies by visiting Google’s Ads Settings or using tools like www.youronlinechoices.eu (for EU users).

Cookie Disclaimer: For a full list of cookies in use on our site and their purposes, you can refer to our cookie banner settings.

Managing Cookies: Most web browsers allow you to control cookies through their settings (e.g., to block or delete cookies). However, please note that if you disable cookies in your browser settings, some features of the XON Service may not function properly. Through our site’s cookie banner, you can also withdraw consent for non-essential cookies at any time, which will prevent further data collection by those cookies (though it won’t remove cookies already set; you’d need to clear those via your browser).

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. In general:

• Account Data: Information associated with your XON account (such as your email, username, rewards balance, etc.) is kept for as long as your account is active. If you decide to delete your account or request deletion, we will remove or anonymize your personal data within a reasonable timeframe after the request, barring information we are required to keep for legal reasons.

• Communication Data: If you contact us, we may retain correspondence (emails, support tickets) for a period necessary to address your inquiry and as needed to establish a history of our communications, typically up to [time period, e.g., 1 year] unless further retention is required for legal purposes (for example, evidence of customer service).

• Analytics Data: Aggregated analytics information may be retained longer for historical analysis, but this data will not directly identify individual users. Raw usage logs (which may include IP addresses) are generally rotated or deleted periodically (for example, Wix might automatically delete server logs after a certain number of days).

• Legal Compliance: We may retain information for longer periods if required to by law or to protect our legal rights. For instance, if we banned an account for fraud or abuse, we might retain certain information about that account to prevent repeat abuse. Likewise, data necessary for resolving disputes or enforcing our agreements may be kept as long as needed for those purposes.

After the applicable retention period, we will securely delete or anonymize your personal data. When anonymized, the data will no longer be associated with you and may be used for analytical or statistical purposes indefinitely without further notice.

International Data Transfers

XON is accessible to users around the world. The personal data we collect may be stored and processed in various countries, including those outside the European Economic Area (EEA). In particular, our site is hosted on Wix’s servers which are distributed globally. Wix has data centers in multiple locations (including Europe and the United States) and utilizes cloud services like Amazon Web Services (AWS) and Google Cloud Platform. This means your data may be transferred to or stored on servers located in a country different from your own.

When we transfer personal data out of the EEA or your home jurisdiction, we take steps to ensure appropriate safeguards are in place to protect it. For example, transfers of EU users’ data to non-EU countries are conducted in compliance with GDPR requirements. Wix, as our data processor, adheres to international data protection standards and relies on mechanisms such as standard contractual clauses or other legal bases to lawfully transfer data from the EU to other countries. Likewise, any other third-party processors or partners we use are required to implement adequate protections for data they handle.

By using the Service, you acknowledge that your personal data may be transferred to facilities located in a different country and subject to that jurisdiction’s laws (which may differ from those of your country). However, our practices will continue to be governed by this Privacy Policy and the data protection safeguards described herein, regardless of where the data is processed.

If you have questions about international data transfers or require more information about the safeguards in place, please contact us.

Your Rights

As a user of XON, especially if you are in the EU or a jurisdiction with similar data protection laws, you have certain rights regarding your personal data. We are committed to upholding these rights. Subject to any conditions or exceptions provided by law, these include:

• Right to Access: You have the right to request a copy of the personal data we hold about you, as well as information about how we process it. We will provide this information, often called a “data subject access request,” within the legally required timeframe.

• Right to Rectification: If any personal data we have about you is incorrect or incomplete, you have the right to request that we correct or update it. For example, if you change your email address, you can update it in your account settings or ask us to do so.

• Right to Erasure: You have the right to be forgotten, meaning you can request that we delete your personal data under certain circumstances. This includes the ability to request deletion of your XON account and all associated data. We honor such requests unless we are required to keep specific data for legal reasons. When your account is deleted, we will remove your personal information from our active systems and stop processing it. (Some residual data may remain in backups for a short period, but will be purged according to our retention policy.)

• Right to Restrict Processing: You can ask us to restrict or suspend processing of your personal data in certain situations – for instance, if you contest the accuracy of the data or have objected to processing and we are evaluating your request. While processing is restricted, we will still store your data but not use it for the time being.

• Right to Data Portability: For data that you provided to us and that we process by automated means on the basis of consent or contract, you have the right to request a copy in a structured, commonly used, machine-readable format (for example, CSV or JSON). Where feasible, you may also request that we transfer this data directly to another service provider at your direction.

• Right to Object: You have the right to object to certain types of processing. You can object to processing of your personal data based on legitimate interests, on grounds relating to your particular situation. You also have an unconditional right to object to your personal data being used for direct marketing purposes. If you object, we will stop the processing for which the objection is made unless we have compelling legitimate grounds or legal reasons to continue.

• Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing that was done before you withdrew consent, but it means we will stop the specific activities you previously consented to (for example, if you withdraw consent for marketing emails, we will stop sending them). Withdrawing consent for cookies can be done via the cookie settings on our site or your browser, as described in Cookies above.

• Right Not to Be Subject to Automated Decisions: We do not make any decisions about you that are based solely on automated processing (without human involvement) that produce legal or similarly significant effects. However, if that changes, you would have the right to not be subject to such decision-making without your consent, and to request human review of any such decision.

• Right to Complain: If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. If you are in the EU, this would typically be the data protection authority in your country of residence or where our business is established. For example, in Hungary (where XON operates from), the supervisory authority is the Hungarian National Authority for Data Protection and Freedom of Information (NAIH). If you reside outside the EU, you may contact the relevant privacy regulator in your jurisdiction. We would, however, appreciate the chance to address your concerns directly before you do this – so please consider contacting us first, and we will do our best to resolve any issue.

Exercising Your Rights: You can exercise most of the rights above by contacting us at xon.unvrse@gmail.com. For certain requests (like accessing or deleting your data), we may need to verify your identity to ensure the security of your account. We will respond to your request within the timeframe required by law (generally within one month for GDPR requests, with extensions if necessary and permitted). There is no fee for making a request, unless it is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse the request (we will explain the reasons in such cases).

We are committed to respecting your rights and will not discriminate against you for exercising any of them.

Children’s Privacy

Our Service is not intended for children under the age of 18. We do not knowingly collect personal data from anyone under 18 years old. If you are under 18, you are not permitted to use XON or provide any personal information to us without verifiable parental consent. If we learn that we have inadvertently collected personal data from a child under 18, we will promptly take steps to delete such information.

Parents or guardians who believe that we might have information about a child under 18 should contact us immediately, and we will work to delete any such data. (In some jurisdictions, such as the United States, the minimum age for online data consent is 13; we abide by the stricter age where applicable, and will adjust this policy to compliance with relevant local laws.)

Changes to This Privacy Policy

We may update or modify this Privacy Policy from time to time. If we make material changes, we will notify you by updating the effective date at the top of the Policy and, if appropriate, by additional notice (such as on our website homepage or via email notification). We reserve the right to modify this Privacy Policy at any time, so please review it periodically. Changes will take effect immediately upon posting the revised Policy on this page, unless otherwise stated. Your continued use of the Service after any changes indicates your acknowledgment of the updated Policy.

If you do not agree with any updated terms of the Privacy Policy, you should stop using the Service and delete your account if you have one. We will always indicate the date of the latest revision so you know when it was last changed.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

Email: xon.unvrse@gmail.com

We will gladly assist you and take any necessary steps to address your inquiry. Your privacy is important to us, and we welcome your feedback.