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Privacy Policy

Effective date: September 21, 2020

At Xio, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Xio's Services is at all times subject to our Terms of Use and Education Institution Terms (collectively, the “Related Terms”), which incorporate this Privacy Policy. “Education Institution” means any user who is a member of a school, school district, or related entity or organization, including but not limited to administrators, instructors, and professors who access or use the Services on their behalf. Any terms we use in this Policy without defining (for example, “Services”) them have the definitions given to them in the Related Terms.

Privacy Policy Table of Contents

What this Privacy Policy Covers

Personal Data

    • Categories of Personal Data We Collect Your Use of Our Services (other than collections by the Chrysler device)
    • Categories of Personal Data We Collect from Your Use of the Chrysler device
    • Categories of Sources of Personal Data
    • Our Commercial or Business Purposes for Collecting Personal Data

How We Share Your Personal Data

Data Security and Retention

Personal Data of Children

California Resident Rights

Other State Law Privacy Rights

Changes to this Privacy Policy

Contact Information

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services including Chrysler (as defined below). “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Xio operates from the United States and the Services are intended for use only in the United States. If you are located outside the United States, the information you provide to us is transmitted and processed in the United States, and will be protected subject to this Privacy Policy, our Related Terms and applicable laws, which may not be as protective as the laws in your country. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Personal Data

Categories of Personal Data We Collect from Your Use of Our Services (other than collections by the Chrysler device)

This chart details the categories of Personal Data that we collect and have collected over the past 12 months from your use of our website(s) and application(s):

Category of Personal Data

Examples of Personal Data We Collect

Categories of Third Parties With Whom We Share this Personal Data:

Profile or Contact Data

  • First and last name
  • Email
  • Unique identifiers (i.e., username and password)

 

  • Service Providers
  • Analytics Providers
  • Parties You Authorize, Access or Authenticate

 

Device/IP Data

  • IP address
  • Device ID
  • Domain server
  • Type of device/operating system/browser used to access the Services
  • User internet bookmarks (for easy retrieval of bookmarks)

 

  • Service Providers
  • Analytics Partners

 

Web Analytics

  • Web page interactions
  • Referring webpage/source through which you accessed the Services
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and the Services

 

  • Service Providers
  • Analytics Partners

 

Professional or Employment-Related Data

  • Education Institution’s classes
  • Teachers’ class and title

 

  • Service Providers
  • Analytics Partners

 

Non-Public Education Data

  • Student class rosters
  • Service Providers
  • Analytics Partners

 

Geolocation Data

  • IP-address-based location information

 

  • Service Providers
  • Analytics Partners

 

Other Identifying Information that You Voluntarily Choose to Provide

  • Identifying information in emails or letters you send us
  • Service Providers
  • Analytics Partners
  • Parties You Authorize, Access or Authenticate

 

 

Categories of Personal Data We Collect from Your Use of the Chrysler device

Chrysler” is a voice-enabled classroom solution designed by Xio to provide educators with hands-free internet access and browsing control through voice command. Chrysler is one of our Services; it uses a device to collect data. This chart details the categories of Personal Data that we collect and have collected over the past 12 months from your use of the Chrysler device:

Category of Personal Data

Examples of Personal Data We Collect

Categories of Third Parties With Whom We Share this Personal Data:

Profile or Contact Data

  • First and last name
  • Email
  • Unique identifiers (i.e., the personalized Activation Word (as defined below) or personalized utterances for any users)

 

  • Service Providers
  • Analytics Partners
  • Parties You Authorize, Access or Authenticate

 

Device/IP Data

  • IP address
  • Device ID
  • Domain server
  • Type of device/operating system/browser used to access the Services
  • User internet bookmarks (for easy retrieval of bookmarks through use of Chrysler)

 

  • Service Providers
  • Analytics Partners

 

Web Analytics

  • Web page interactions
  • Referring webpage/source through which you accessed the Services and/or Chrysler
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and Chrysler

 

  • Service Providers
  • Analytics Partners

 

Geolocation Data

  • IP-address-based location information

 

  • Service Providers
  • Analytics Partners

 

Sensory Data

  • Audio recordings of your environment (including speech transcripts, grammatical patterns in language, topics discussed and background noise when Chrysler is activated)
  • Speech data (to allow for speech to text transcription with high accuracy)
  • Speech transcripts (with identifiable voice data removed)
  • Touch recordings of your use of Chrysler or the accompanying remote control

 

  • Service Providers
  • Analytics Partners
  • Parties You Authorize, Access or Authenticate

 

 

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

  • You
    • When you provide such information directly to us.
      • When you create an account or use our interactive tools and Services.
      • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
      • During the onboarding process for Chrysler, we capture the user’s voice while speaking the word that is used to activate Chrysler (“Activation Word”). We do this to ensure that only the authorized user voice (“Authorized User”) is able to activate Chrysler.
      • If an Education Institution has installed the optional internet browser extension for student devices, they will also be asked to provide us with student first and last names and email addresses.  This information is used to allow the Education Institution to connect students to the educator’s account and manage student accounts.  At their discretion, the Education Institution may also choose to allow students to interact with Chrysler.
      • When you send us an email or otherwise contact us. 
    • When you use the Services and such information is collected automatically.
      • If you use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
      • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
    • When you use Chrysler and such information is collected automatically.
      • Chrysler is activated when the Authorized User speaks the Activation Word in close proximity to Chrysler. Prior to that, Chrysler will capture sound, including voices, so that it can “hear” the Activation Word.
      • Once the Authorized User has delivered the Activation Word, Chrysler automatically records the voice of the Authorized User. Chrysler may also record background noise, including student voices. In all cases, identifiable voice data captured by Chrysler is used only to respond to the request made by the Authorized User.
      • We may also collect your browsing history, location, websites you have stored in the bookmarks or similar sections of your browser, speech transcripts, including grammatical patterns in language and topics discussed, and background noise that is captured when Chrysler is activated.
  • Third Parties
    • Vendors
      • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
    • Education-Related Social Networks
      • If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

 

Our Commercial or Business Purposes for Collecting Personal Data

  • Providing, Customizing and Improving the Services
    • Creating and managing your account or other user profiles.
    • Processing orders or other transactions.
    • Providing you with the products, services or information you request.
    • Meeting or fulfilling the reason you provided the information to us.
    • Providing support and assistance for the Services.
    • Improving the Services, including testing, research, internal analytics and product development.
    • To make recommendations through Chrysler, provide Authorized Users with the most relevant results to their questions asked to Chrysler, improve the way Chrysler performs in noisy environments and improve the way Chrysler is able to respond to Authorized Users’ commands.
    • Personalizing the Services, website content and communications based on your preferences.
    • Doing fraud protection, security and debugging.
    • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
  • Marketing the Services
    • Marketing and selling the Services.
  • Corresponding with You
    • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Xio and/or the Services.
    • Sending emails and other communications according to your preferences or that display content that we think will interest you.
  • Meeting Legal Requirements and Enforcing Legal Terms
    • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
    • Protecting the rights, property or safety of you, Xio or another party.
    • Enforcing any agreements with you.
    • Responding to claims that any posting or other content violates third-party rights.
    • Resolving disputes.

 

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

 

How We Share Your Personal Data

 

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

 

  • Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
    • Hosting, technology and communication providers.
    • Security and fraud prevention consultants.
    • Support and customer service vendors.
    • Product fulfillment and delivery providers.
  • Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
    • Companies that track how users found or were referred to the Services.
    • Companies that track how users interact with the Services.
  • Business Partners. These parties partner with us in offering various services. They include:
    • Education Institutions you have a relationship with.
  • Parties You Authorize, Access or Authenticate
    • Third parties you access through the services.
    • Education-related social networks for account login purposes (e.g., ClassLink or Clever).
    • Other users.

 

Legal Obligations

 

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

 

Business Transfers

 

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

 

Data that is Not Personal Data

 

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you. 

 

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

The Children’s Online Privacy Protection Act (“COPPA”) requires parental consent before online service providers knowingly collect personally identifiable information online from children who are under thirteen (13) years of age. We do not knowingly collect or solicit personally identifiable information from a child under thirteen (13) except when an Education Institution has agreed to obtain verifiable consent from that child’s parent or guardian (“Parental Consent”) prior to using the Services in classrooms with students under thirteen (13) years of age, in accordance with this Privacy Policy and the Related Terms, and consistent with applicable law. If we learn we have collected personal information from a child under thirteen (13), we will delete that information as quickly as possible. If you believe that a child under thirteen (13) years of age has provided us with Personal Data without Parental Consent, please contact us at hixio@xioresearch.com. We do not condition participation in our Services on disclosure of more Personal Data from a child under thirteen (13) years of age than is reasonably necessary for that participation, and we do not retain Personal Data from children under thirteen (13) years of age longer than is reasonably necessary in order to fulfill the purpose for which it was disclosed.

If you are a parent or guardian of a user of our Services who is under thirteen (13) years of age, you may contact us at any time to ask that (a) we stop collecting Personal Data from such user, (b) we delete any Personal Data already collected from such user (although note that we may further retain information in an anonymous or aggregated form where that information would not identify such user personally), or (c) we stop disclosing Personal Data collected from such user to third parties, but continue to allow for collection and use of Personal Data collected from such user in connection with the Services.

State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at hixio@xioresearch.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at hixio@xioresearch.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by sending you an email and/or by some other means. 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), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

  •  hixio@xioresearch.com
  • 405 Lexington Avenue, New York, New York 10174