USERX LLC and its affiliates (hereinafter as "UserX
We collect data regarding Visitors to our Site, regarding our Subscribers as well as data regarding their End Users. When you Visit our Site
we collect automatically generated data such as:
- non-identifying data regarding a device, operating system, browser version, IP addresses; locale and language settings used;
- the cookies and pixels installed on such device;
- your activity (clicks and other interactions) at our Site
Such data does not enable us to learn a person's identity or contact details. When you Sign Up for our Services
we collect the information you provide – that is your:
When you contacts us in any way
- E-mail address
- Phone number
- First and Last Names (if provided)
- Company name (if provided)
(such as via e-mail, chat or any contact forms) we will collect and record:
When UserX is integrated as a service
- Such communications
- Full Name (if provided)
- Company name and position (if provided)
- Contact details, such as e-mail, phone number (if provided)
we could collect the following information (the "End Users' Data) from the Subscribers' mobile applications:
- Subscriber's generated Unique User ID (if provided by Subscriber), UserX-generated Unique Device ID
- Technical information (device type and model, version of operation system, screen resolution, battery status, network status)
- Geographic location (Country only)
- Screens visited by the End User in the mobile app
- Screenshots from Subscribers' mobile apps
- Interaction patterns by the End User in the mobile app (screen actions, gestures: taps, scrolls, any other actions)
- Information provided by the Subscriber (except information Subscriber chooses to block from being sent to UserX)
- Data received via third party integrations.
Subscriber is solely responsible for ensuring the legality and safeguarding of data transferred to or from third party integrated services mentioned above.
We will not collect the End Users' full IP addresses, any keyboard stokes by the End Users, nor any information about other applications or programs that End Users are running on their devices.
We strictly adhere to a no-recording policy of any Personally Identifiable Information
(PII) and contractually prohibits recording of sensitive information including ePHI, PCI or PII information. In particular, Subscribers must refrain from providing UserX with any Personal Information of children under the age of 16; any health, financial, or insurance data; or other data which is subject to specific regulatory or statutory protection regimes (including "special category" data under the EU GDPR). We provide special API methods to hide all types of Personal Information mentioned above (available at https://console.userx.pro/console/docs/integration
The main purpose of information collection is to provide you with our Service. We use your information only for the following purposes:
- To allow you to register and set up an account and to access our Services
- To provide you with customer service, assistance and support
- Sending you updates about UserX
- To contact you with service-related messages (such as password-retrieval or billing) and promotional messages (such as newsletters, new features, etc.); to facilitate our sales and business development operations
- Asking from time to time how we're doing
- Supplying to you Services purchased through the website
- To further develop, customize and improve the Services and your user experience
- To keep our Site and Service secure and prevent fraud
- To comply with any applicable laws and regulatio
We use End Users' Data only for the following purposes:
3. DURATION OF DATA STORAGE
- To provide our Services to Subscribers
- For use on an anonymous basis, in the aggregate, to perform analysis of application uses and statistical reports, including to operate and improve our Services
We only store information on you for as long as you're using our service. As soon as you delete your account or send us a request to stop processing your information we delete it completely. We will also delete the data of your users. We have taken the necessary precautions to ensure that data deletion is conducted securely.
We will retain your personal data for as long as is required:
- to the extent that we are required to do so by law;
- if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)
Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you.
We retain End Users' Data we process on our Subscriber's behalf, for as long as we are providing them with the Services and for a reasonable time thereafter, according to our agreements with the Subscribers, or a longer period as legally required. 4. LOCATION OF DATA STORAGE
Your Personal Data may be maintained, processed and stored by our authorized affiliates and Service Providers in the Russian Federation, the European Union and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.
If you are accessing the Site and/or Services from the European Union, with laws or regulations governing personal data collection, use and disclosure that differ from Russian Federation laws, please note neither EU law nor GDPR requires hosting data in EU. Instead, what is required is that UserX must provide "appropriate safeguards" for data that it hosts and processes on its servers (see Art 46 of the GDPR). 5. THIRD PARTIES
To give you the most privacy guarantees and data protection assurance – we carefully reviewed and vetted our third parties. Our third-party service providers do not have any right to use the information we share with them beyond what is necessary to assist us. We have no control over, and are not responsible for, the privacy policies and practices of third parties. You have the right to know who these are so without additional requests:
- Email Marketing Solutions: Mailchimp
- Website Analytics: Google Analytics, Yandex.Metrika, Facebook Analytics
- Cloud Storage: IT-Lite LLC
- Payments: Paddle.com, Robokassa.ru
- Customer Messaging: Jivochat.com
- Customer Relationship Management: AmoCRM
- Marketing Platform: Google Ads, Facebook Ads
- Website Platform: Tilda Publishin
While using UserX, temporary files, known as Cookie files, can be stored and processed. By processing cookie files Personal Information might be collected and linked with the visitor. This personal information is used to improve our Services, to provide analytics, to enable advertisements delivery. UserX respects privacy of its users and visitors and while processing Cookie files we follow the privacy rules of the European Union.
You can prevent collection and storing of Cookie files by turning off Cookies in your browser, or browsing the web in Incognito (private) mode, where you remain anonymous. This mode is supported in all modern browsers. By doing so, the user acknowledges that UserX services might not work properly and that use of our Services can exhibit unexpected behavior. 7. DATA SECURITY
We protect personal information with use of the latest industry standards and security measures. UserX uses SSL/TLS encryption (secure sockets layer / transport layer security) for protection of user data and personal information. We perform staff training on the value of personal information and we also have internal data protection documents that everyone abides by. Rest assured, not all staff get access to data – only selected personnel with the highest admin privileges. When they do - it is to continue assisting you in making the most out of UserX. 8. DATA SUBJECT RIGHTS
If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR), to request access to, and rectification or erasure of your Personal Data held with UserX, or to restrict or object to such Personal Data's processing, or to port such Personal Data – please contact us by email at firstname.lastname@example.org
. We are required to get back to you within 20-30 days. We believe that's too long to wait for our users and will, accordingly, get back to you sooner than that.
Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request).
As further detailed above, UserX has no direct relationship with individual End Users. If you would like to make any requests or queries regarding Personal Data we process on our Subscriber's behalf, please contact them. For example, if you are an End User who wishes to access, correct, or delete data processed by UserX on behalf of a Subscriber, please direct your request to the relevant organization (who is the "Data Controller" of such data). 9. POLICY TOWARDS CHILDREN
UserX does not knowingly collect personal information from minors who are under the age of 16 through the Site and/or the Services. We reserve the right to request proof of age at any stage so that we can verify that persons under the age of 16 are not using the Services.
If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without his/her consent, then he or she should contact UserX as described below. If we become aware that a child under the age of 16 has provided us with personally identifiable information, we will prohibit and block such Subscriber from accessing the Services and will delete such information from our files. If you believe that we might have any such data, please contact us by email at email@example.com
. 10. LINKS
We may disclose any information in response to a legal request, such as a subpoena, court order, or government demand; to investigate or report illegal activity; or to enforce our rights or defend claims. We may also transfer your information to another company in connection with a corporate restructuring, such as a sale or merger.
. UserX's appointed Data Protection Officer may be reached by email at firstname.lastname@example.org
. For Data Subjects in the EU:
We appointed GDPR-Rep.eu as representative according to Art 27 GDPR. If you want to make use of your GDPR data privacy rights, please visit: https://gdpr-rep.eu/q/11522407
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o USERX LLC
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence:
GDPR-REP ID: 11522407 Who we are.
Company: USERX LLC
Company Registration No.: 1183668027751
Address: 10 Kropotkina street, office 205, Voronezh, Voronezh region, Russian Federation, 394030