Privacy Policy

We care about your privacy and we want you to know how we process your personal data.

Client's data is used to provide the Service and improve it. This Privacy Policy is compliant with General Data Protection Regulation (GDPR further on).

Current Privacy Policy is valid for INXY.COM and INXY.HOSTING websites, as well as everything we refer to as "Services" in this policy.

We offer several solutions for our clients:

• INXY.COM - Subscription Manager
• iOS Subscription manager app
• INXY.HOSTING - Hosting Marketplace;

Definitions

Here are main terms and definitions used in this document:

INXY Ltd ('INXY') - company that provides Services to Client. INXY Ltd - acting as a data controller - collects, uses, shares, retains and protects your personal data.

Information about INXY Ltd - 919 North Market St, Suite 950. Wilmington, DE 19801, USA, email: subscriptions@inxy.com

Client - individual (at least 18 years old) or company using INXY services.

Personal Data Subject - INXY client

Personal data - means any information relating to an identified or identifiable person that clearly allows to identify him ('data subject').

Account - unique access to Service that is created for Client

Website - refers to INXY.COM

Services - means subscription tracking service that is provided by INXY, as well as marketplace of hosting services;

Service provider - means any person who processes user data on behalf of INXY. For GDPR purposes should be considered as Data Processor

Cookies - placed on Client's device to track browsing history on INXY website

By registering on INXY.COM Client creates unified account on INXY platform that will allow authorization on all INXY projects using the same login credentials.

Registration on INXY.COM means that Client agrees that INXY collects and processes his personal information. INXY demands all clients to be at least 18 years old. INXY does not deliberately search or gather any personal information or data about people who have not achieved this age.

Please take the time to read this Privacy Policy carefully, it is very important to us that you fully understand it.

The Obtaining of Data

How we obtain data:

• during general website navigation. Client can get access some components of our services even without account creation. In this case, only IP address, country of origin and other non-personal information about Client's computer or device (browser type, search engine, time and date of queries, URL, operating system, history of access) may be registered with INXY among any other information. This is needed to prevent unauthorized use of information and/or content.
• as a result of registration on INXY platform. In this case all data INXY collects, stores and processes is received from Client/Personal Data Subject in the process of using website/app
• with the help of integrated services, such as Google and Apple when Client uses their data for authorization. Please read their respective terms of use and privacy policy carefully to learn what data they share in this case prior to using them.
• information from other partners (e.g. Plaid) that provide INXY with information about your transactions by your consent to store, process and present as subscriptions.
• information from our partners (e.g. Microsoft) that is provided to INXY when the Client binds his MS Teams account to INXY account.

Cookie Files, Metadata and Activity on Our Website

We use cookie files and other anchors and information for storage of your important information such as domain name, the lifetime of such file as well as randomly generated number in order for you not to need to provide it again when you access our website for the second and all future times, as well as to provide you with personal content and information, to track the effectiveness of the provision of service for us and to gather such statistics as the number of visitors or number of page views ets.

Cookie file is a small element of computer code that will remain on your computer and contain information that will help to identify your search engine. When you access the website as well as applications and program instruments, cookie files check your identity for your id to enter the system. We use the information that was gathered with cookie files to identify your search engine to ensure that the next time you access our website the procedure was faster and more smooth because the website has already stored information about you.

If you don't want us to use cookies you can prevent it by simply changing the preferences of your search engine. If you do not allow to use cookie files, some or all websites or other instruments can be not accessible for you. Sometimes the information that you upload is provided with embedded metadata. If you don't want us to use metadata you should remove it before you upload information to our website or to our other applications and programs.

Types of User Information INXY Collects When You Use Our Service:

1. account credentials: login and password;
2. personal data - (first and last names, phone number, avatar image)
3. your transaction and subscription data that you track and manage with the help of INXY Subscription Manager - service name, payment date, payment amount, currency, subscription type (life-time, recurring), subscription start date (next payment date), subscription user notes if Customer chooses to provide them, payment method (in case of card only last 4 digits are stored for payment method identification purposes.
4. Messenger-related data - Facebook psid, Slack workspace name, Slack access token, Slack channel name, Telegram chat ID, Telegram first name, Telegram last name, Telegram username, Telegram token, Viber user ID, Viber username, Phone number, MS Teams channel ID, MS Teams conversation ID, MS Teams tenant ID, MS Teams name, MS Teams conversation type;
5. technical data — information about Client's device (type, OS, ID, browser type, cookies, IP, geolocation and timezone data, ISP data, connection type).
6. should Client use INXY-provided subscription collaboration tool or share subscription list by using INXY internal sharing mechanism, information about this person is also stored.
7. technical support request data: date and time of request, request reason, data that Client shares with tech support for solving issues, communication history and result.
8. financial data — invoices from INXY, details of transactions in INXY favor (date of transaction, amount paid, currently, payment method.

INXY tries to minimize the amount of stored data.

We Process Your Data for the Following Purposes:

• to provide services and needed security level during use of INXY Subscription manager;
• to manage Client's account. Provided personal data will grant Client access to various parts of Service that are visible only for registered users.
• to make INXY website work better for you and to improve our service;
• to communicate with Client, including notifications and reminders for subscriptions, system notifications, including changes in Privacy Policy and Terms and Conditions, as well as security matters when needed.
• to provide Client with news, special offers and for direct marketing purposes if Client has not refused to receive such information.
• to improve any part of our website, to conduct statistical analysis related to the use of our website or applications and programs, to conduct the polls that will help us understand user satisfaction which is needed to keep our clients and to perform needed marketing events. This may include email, mass media and other means of communication. Such info is also needed for sales purposes, including the analysis of data and use of our services to make improved marketing proposals to make the satisfaction rate higher;
• to perform any financial actions, including payments, receiving of payments, invoice generation and processing of financial transactions regarding the purchased service;
• to provide the opportunity to purchase service via website or other means of communications. You may also be forwarded to the secure gateway for payment. We will NOT gather any sensitive information about your credit/debit/payment card or any other mean of the payment, INXY doesn't store this information in any way. Such information will be passed to third-party payment systems and is controlled by their own respective privacy policy.
• to contact Client regarding our service and to answer support requests;
• to follow the laws, Terms and Conditions and Privacy Policy as well as other natural rights or something that may be required due to existing regulations and legislation as a result of any trial or government institute, including the privacy laws;.

Client's Personal Data Can Only Be Processed if Any of the Following Conditions are True:

• consent - Client provides explicit consent for processing Personal Data
• contractual obligations - provision of Personal Data for the interest of fulfilling contract obligations
• legal matters protection of vital, public and legitimate interests

If Client decides not to provide INXY with your information, he may be unable to use INXY Subscription Manager in some parts or totally.

INXY does not allow any automated decisions on Clients, including profiling.

3rd Party Services and Platforms

Current Privacy Policy is not applicable to 3rd party apps or software that are integrated by 3rd party services.

INXY Website and Service may contain hyperlinks to websites of commercial partners and other 3rd party services. Following these links mean that Client is redirected to those respective resources where INXY.COM Privacy Policy is not applied. INXY advise to examine Privacy settings and Privacy Policies of those resources, since INXY are not responsible for 3rd party Privacy Policies, preservation of personal data, its processing and usage in those cases.

INXY.COM use 3rd party platforms for payment processing. Those platforms are regulated by their own safety and security standards, policies and usage conditions. INXY is not responsible for their work, safety and security and functionality. INXY do not gather or store any confidential financial data.

INXY uses authorization protocols through 3rd party services, such as Google, Apple, Facebook etc.

Client can bind other services, such as MS Teams, Viber, Telegram, Facebook, WhatsApp, etc. in order to receive notifications from INXY within those services. Client should always check Privacy Policy, privacy settings and notification setting in those respective services.

Storage and Transmission of Personal Data

INXY keeps personal data for no longer than is strictly necessary for the purposes for which INXY collects and uses them. INXY stores information for the whole period of usage of Service, apart from certain cases and information types mentioned below.

The specific periods of time for which we retain your personal data are specified below:

• In case Client wants to delete personal data or makes a request for such deletion, the data is permanently deleted after 90 days since receiving of such request.
• Cookies are stored for 24 months
• Technical data associated with Client's account is stored for 3 years.

INXY Can Share the Data About You With:

• partners and INXY employees that take part in providing service to Client
• hosting and storage platform providers
• security solution and service providers
• payment solution and service providers
• data analytics and computing solution providers
• parent company
• subsidiaries and affiliates
• legal successors
• security agencies, regulatory organizations, courts or other government institutes in the portion really needed by the law

Personal Data is processed by geographically spread INXY employees that means that it may be transferred to devices outside your city, country or continent, and this may be different from Client's jurisdiction. By registering on INXY Website Client agrees to such transfer.

INXY does not disclose your personal data to third parties with exception to the cases when it goes along with this Privacy policy or is needed by the law. Client agrees to give INXY the right to use gathered personal information to achieve any goals stated in this Privacy Policy.

INXY will not disclose your personal information unless it will be demanded by law or trial orders as well as any other legislation in order for INXY systems to be functioning properly, to protect INXY and other users and clients and unless it will be needed according to any other lawful grounds. In this case, INXY will immediately notify Client about such circumstances before processing Client data according to the applicable laws if those laws do not forbid such notification.

Personal Data the Client Shares

By using INXY service, Client can share data with other users, including subscription data and ability to collaborate on them.

How INXY Protects Your Personal Data

INXY has measures in place to protect Client's personal data against unauthorized access, use, or disclosure including, without limitation, the following measures:

• INXY implements and maintains sophisticated technical measures to ensure that Client's personal data is confidentially and securely recorded and used;
• INXY restricts and limits access to Client's personal data, and monitor who accesses, uses, and transfers Client's personal data;
• Employees who have access to Client's personal data are required to comply with our data privacy and confidentiality requirements;
• Business partners and third-party service providers with whom INXY shares Client's personal data are required to comply with any applicable data privacy and confidentiality requirements.

Regarding Personal Data Client Has the Following Rights:

• Restrict or object to its processing;
• to opt out of receiving marketing information;
• In some circumstances, require the transfer of personal data to himself or a third party;
• withdraw consent to process personal data and demand to delete it in accordance with GDPR;
• generation of complaint to supervisor

Some of these rights can be exercised directly in Client settings, such as the rights to rectification and removal of your personal data, or the right to unsubscribe from receiving of marketing information.

As for the exercise of Clients other rights (access to and portability of personal data, restriction or objection to the processing of personal data, please contact INXY via email: subscriptions@inxy.com.

Please note that INXY reserves the right to check identity before responding to any request. INXY fully respects Client's confidentiality and protects it with this Privacy Policy and EU laws

If Client is not fully satisfied with the response, he can also complain about INXY processing of his personal data to the relevant data protection authority.

Changes to Privacy Policy

We regularly revise our Privacy Policy (at least once per year), in particular to ensure that it complies with new laws and regulations regarding data protection.

If you have any requests or questions about Privacy Policy, Personal Data collection and processing, contact us via email: subscriptions@inxy.com