PRIVACY POLICY
XKELET

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1. Introduction

Thank you for choosing XKELET. This is our Privacy Policy. Before going into detail, we would like to highlight some of its key principles. These principles are important to us because we know they are important to you.
The Privacy Policy exists for three reasons.
1. Explain how we use the information you share with us in order to create a great product and give you a great experience with it; 2. Ensure that you understand what information we collect with your permission and what we do (and do not do) with it; 3. Assume the responsibility to protect your rights and your privacy under this policy.
All information we collect is related to XKELET service provider and applications.
Generally, there are two categories of information we collect: 1) information we must have in order for you to use XKELET; And 2) information that we may use to provide you with additional applications and enhanced experiences if you choose to share such information.
The first category includes.
- Registration information, including your name, date of birth, address and other information you provide when you join XKELET.
- Generalized and non-specific location, derived from your IP address. Our licenses to provide XKELET content are location-specific, so we need to know which country you are in. This also allows us to make suggestions based on your generalized location.
- Technical and sensor information required for the operation of XKELET. This includes the type of navigator and device you use, touch screen data as well as information from the accelerometer sensors and the gyroscope of your device.
The second category includes information that allows us to offer you additional benefits. We never receive any information from the following unless you expressly choose to share it with us; It is that simple. These are some examples.
- Your specific location: We will never collect or use the specific location of your device without first receiving your express permission. This information allows us to create collaborative experiences (only with others who have also given their authorization) and to provide even better recommendations on how to use your device.
- Your photos: We will only access the images you select specifically and will never scan or import your gallery or photo reel. You can stop sharing photos and revoke access at any time.
- Your contacts: We will never scan or import your contacts unless you ask us to do so.
If you choose to do so, we will only use your contact information to help you find other professionals or contacts who use XKELET.
- Your microphone: We will never access your microphone or use it unless you give us your express permission.
This could allow you to control XKELET with your voice and you will always have the ability to disable access to the microphone.
The difference between these two categories is important. The information in the first category is the information you must provide in order to use XKELET. When you accept our Privacy Policy you give us the right to collect this information and to use it for the purposes described. The information in the second category is one that we collect only if you give us your express permission to do so in the future. For this second category of information we ask for your permission before you access it for the first time, we describe how we will use it if you give us permission, we only use the information for the purposes described and you always have the ability to change your mind and revoke that consent .
We will express clearly with you about how and when we could share the information.
We hope this helps you understand our privacy commitments to you.
Here are the details, but remember that this introduction is part of the Privacy Policy itself, is our promise to you. If you ever have a question or concern, let us know at legal@xkelet.com.
In this Privacy Policy we mean the XKELET Service or the Service. These terms are defined in our Terms and Conditions of Use (the "Terms and Conditions of Use").

2. Elementos clave de su consentimiento

By using the Service, or by interacting with the Service, you authorize the following.
1. Use cookies and other technologies.
2. Transmit your information outside of your country of residence.
3. Collect, use, share and otherwise process your information, including for advertising purposes (as described in the rest of this Privacy Policy, we encourage you to continue reading).
4. Publish and manage your information, as described in the Shared Information section.
In each case, it authorizes the processing of the data by the organizations described in this Privacy Policy, including XKELET, as data controller, referred to at the end of this document (collectively, "XKELET", "us", "us ", "our"). In the Your Preferences section, we describe the important controls and settings related to your XKELET account. If you do not agree with the terms of this Privacy Policy, do not use the Service.

3. Information we collect

We may collect and store the following information.

3.1 REGISTER DATA

By registering for the Service, we may request information such as username, password, email address, date of birth, gender, address, zip code and country. If you use the Service with third-party application credentials (as defined in the Terms and Conditions of Use section).
We may also collect other information that is available in or through your third-party application account, such as your name, profile photo, country, city of residence, email address, date of birth, and The names and profile photos of friends and networks.
You can also voluntarily include in your profile other information such as your mobile phone number and mobile phone service provider.

3.2 USE, REGISTRATION DATA AND COOKIES

By using the Service, or interacting with it, we may use different technologies that collect information about the use of the service and access to it. We may collect the following information.
1. Information on the type of subscription and its interactions with the Service,     2. Details of inquiries you have made, and date and time of your inquiry.
3. User Content (as defined in the Terms and Conditions of Use) that you post to the Service, 4. Technical data, such as URL information, cookie data, your IP address, the type of device you use for Access or connect to the XKELET service, unique device identification, device characteristics, type of network connection (eg, wifi, 3G, LTE) and provider, network and device performance, Type of browser, language, digital rights management information, operating system, and version of the XKELET application.
5. Data generated by the movement or data generated by the orientation of your mobile sensors (eg accelerometer or gyroscope).
You can integrate your XKELET account with third-party applications. If you do, we may receive similar information regarding your interactions with the Service in the third party application and information about your public activity in the third party application. This includes, for example, "likes" and posts on Facebook.
We may use cookies and other technologies to collect such information. For more information on using the information, see the Information about Cookies, Other Technologies, and Third Party Data Collection section of this Privacy Policy.

3.3 YOUR MOBILE DEVICE / TABLET

We may provide applications that rely on the use of additional information on your mobile device / tablet or require access to certain services on your mobile device that will enhance your XKELET experience but are not required to use the Service. (In other words, information that belongs to the second category described in the Introduction of this Policy.) For example, we may allow you to upload photos to your profile, connect with friends, or allow you to use voice commands to control the Service. Granting access to us does not mean that you grant us unlimited access to that information or that we have access to specific information without your consent. On the contrary, for each type of information listed in this section, we will ask permission before accessing the information or applications on your mobile device. If you grant it, we will collect the information for the specific purposes explained when requesting your authorization. You do not have to give us such authorization in order to use XKELET, and acceptance of this Privacy Policy does not mean that you have granted us permission to access this information.
In particular.
- Photos and Camera: We will not access your photos or your camera without first obtaining your express consent, and we will never scan or import your gallery or your photo reel. If you grant us permission to access photos or your camera, we will only use the images that you specifically decide to share with us. (You may use our application to select the photo or photos you want to share, but we will never import the photos you review except those that you expressly share.) - Location: We will not collect or use specific information about the location of your mobile device Using, for example, GPS or Bluetooth) without first obtaining your express authorization. And if you choose to share information about your location but later change your mind, you will always have the ability to stop sharing. Note that this does not include an IP address. We will continue to use your IP address as described earlier in Section 3.2 to determine, for example, which country you are in and comply with our license agreements.
- Voice: We will not access your microphone without first obtaining your express consent. You can always deactivate access to the microphone.
- Contacts: We will not scan or import your contacts stored on your phone without first obtaining your express permission. We will only use the contact information to help you find professionals or contacts who use XKELET if you choose. And we will not use contact information for any other purpose without first getting your express permission separately. Local laws may require you to request the consent of your contacts to provide your personal information to XKELET, who may use such information for the purposes set forth in this Privacy Policy.

- TrueDepth API: We are collecting the point cloud from body parts to generate a mesh.
- Information from TrueDepth API: We collect this information to generate personalized immobilization products. We scan the limbs using the TrueDepth API and we use that mesh to design the personalized immobilizations.
- Third parties and storage: Our third parties behind our app can visualize the scanner but cannot download or modify.The scanners are stored in our Google Cloud Storage.

3.4 PAYMENT DATA

If you sign up for the trial subscription (as defined in the Terms and Conditions of Use section), you acquire any of our paid subscriptions (as defined in the Terms and Conditions of Use section) or make any other purchases through our Service, we and the payment processors with whom we work may collect and store your credit or debit card information (such as the type of card and the expiration date), as well as other financial information we need to process your payment. We may also collect limited information, such as your zip code, mobile phone number, and details about your transaction history; All data necessary to provide the Service. In addition, payment processors generally provide limited information from you, such as the unique token that allows you to make additional purchases using the information they have stored, information about the expiration date, credit card type, and certain digits of your credit card number. card.
If you pay by invoice, XKELET may have to collect and store additional information, such as your name, date of birth and telephone number, and give this information to the payment processors with whom we work to issue the invoice in order to perform Credit checks and send you the invoice.
BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY AUTHORIZE XKELET TO USE OR SHARE THE INFORMATION YOU PROVIDED TO XKELET, EVEN IF SUCH INFORMATION IS PROTECTED BY LOCAL SECRETARY BANK LAWS, WITH OTHER XKELET GROUP COMPANIES, WITH CERTAIN COMMERCIAL PARTNERS AND SUPPLIERS OF TRUST SERVICES THAT MAY BE OUTSIDE THEIR COUNTRY OF RESIDENCE (INCLUDING COUNTRIES THAT DO NOT OFFER THE SAME LEVEL OF PROTECTION IN THE PROCESSING OF PERSONAL DATA AS OFFERED BY THE COUNTRY OF RESIDENCE). YOU ACKNOWLEDGE AND ACCEPT THE IMPORTANCE OF SHARING THIS INFORMATION FOR THE PROVISION OF THE XKELET SERVICE; YOU ALSO AGREE THAT BY ACCEPTING THIS PRIVACY POLICY, WHERE APPLICABLE, AND TO THE EXTENT PERMITTED BY APPLICABLE LAW, EXPRESSLY DISCLAIMS YOUR RIGHTS PURSUANT TO SUCH BANK SECRECY LAWS REGARDING XKELET, ANY COMPANY OF THE XKELET GROUP, ANY BUSINESS PARTNER AND PROVIDER OF TRUST SERVICES THAT MAY BE OUTSIDE YOUR COUNTRY OF RESIDENCE. THIS CONSENT WILL BE VALID WHILE DURING YOUR RELATIONSHIP WITH XKELET.

3.5 DRAWINGS, CONTESTS AND SURVEYS

We can offer you the opportunity to participate in promotions such as sweepstakes, contests, offers and surveys ("Special Promotions") through the Service. The Special Promotions will be governed by a privacy policy or by the additional and independent terms and conditions of this Privacy Policy and the Terms and Conditions of use. If the provisions of the privacy policy and the terms and conditions of the Special Promotion conflict with this Privacy Policy or with the Terms and Conditions of use, additional or independent provisions will prevail. If you participate in a Special Promotion, we may request certain additional information from the one specified in this Privacy Policy, including personal information.
Such additional information may be combined with information from another account, and may be used and shared as provided in this Privacy Policy.

3.6 XKELET PARTNERS AND SERVICE PROVIDERS

We may also receive information about you from our partners and service providers; Information that we will use to personalize your XKELET experience, evaluate the quality of advertising and the response to it, as well as show advertising that is relevant to you. We also use this information as explained in the How We Use the Information We Collect section below.

4. How We Use the Information We Collect

We may use the information we collect, which includes your personal information, pursuant to the authorizations you give us, for the following.
1. Provide, customize and improve your experience with the Service, products, services and advertising (including third-party products and services) available through or outside the Service (included in other sites you visit), for example by offering recommendations, features , Advertising and personalized content, adapted or located through or outside the Service.
2. Guarantee the technical functionality of the Service, develop new products and services, and analyze its use of the Service, including its interaction with the applications, advertising, products and services offered or are available through or linked to the Service.
3. Contact you for research or service related issues, via emails, notifications, text messages or other messages, which you agreed to receive.
4. To contact you, either directly or through one of our partners, for commercial and promotional purposes through emails, notifications or other messages according to the established permissions (eg, through the settings of your XKELET account). In the Your Preferences section below, you will find information about the options you have to stop receiving certain messages.
5. Use, if you expressly authorize us to do so, your mobile phone number to send you informative, commercial and promotional text messages through an automatic dialing system; Your consent is not a condition to be able to register for XKELET services.
6. Permitir y promocionar el Servicio y otros servicios y productos, ya se dentro o fuera del Servicio, como características y contenido del servicio XKELET, así como productos y servicios que estén disponibles a través del Servicio.
Permit and promote the Service and other services and products, whether inside or outside the Service, such as features and content of the XKELET service, as well as products and services that are available through the Service.
8. To execute this Privacy Policy, the Terms and Conditions of use and other terms that you have accepted, including protecting the rights, property or security of XKELET, its users, or any other person or the content of the Service protected by copyright.
9. Offer features, information, advertising or other content depending on your location and location in relation to other XKELET users.
10. As provided in this Privacy Policy.

5. Shared Information

In this section we describe how you or we may share the information collected or generated by using the XKELET service.

5.1 INFORMATION YOU SHARE

Keep in mind that certain information will always be in the public domain, that is, third-party applications can access this information through our application programming interface (API) and development tools. You can share certain additional information with third-party applications and with others through third-party applications, depending on your permissions settings. We may use your public information to promote the Service and to help others find and follow you or XKELET content, including through Facebook and third-party applications and on websites that integrate XKELET widgets. You may use your information to notify others, within the Service, via email and through Facebook and third-party applications, about your use of the Service (e.g.
ej., Who enrolled in XKELET or on the activity related to a profile of XKELET). If you expressly authorize us, we may notify other users of your location. Likewise, if other XKELET users expressly authorize us, we may notify you of the location of other users. We could offer you the ability to share this information to create shared experiences.
For information on how to manage notifications, public information, and what you share with other users, see the Your Preferences section below.

5.2 INFORMATION SHARED XKELET

5.2.1 MARKETING AND PUBLICITY

We may share information with advertising partners to send you promotional information about XKELET or to show you more personalized content that includes relevant advertising about products or services that may interest you and to understand how users interact with advertising. We share the information in an anonymous format (for example, through the use of hash) that does not reveal its identity.
Please refer to the Information on Cookies, Other Technologies and Third Party Data Collection section below for information on cookies and other technologies that we use, both us and third parties, to provide you with your most relevant options and advertising.

5.2.2 SERVICE PROVIDERS AND OTHERS

We may from time to time share your information with service providers to execute and process user data and provide our Service in accordance with this Privacy Policy. For example, we work with service providers hosting our XKELET support community site and analytics service providers to help us better understand the use of our Services. If a third party processes user data in our name (eg, a site hosting service provider), you are subject to the security and confidentiality obligations that comply with this Privacy Policy and current law. If a third party processes user data in their name, processing is subject to their own Privacy Policy and current law.

5.2.3 OTHER SHARED INFORMATION

In addition to the above, we may also share your information with third parties for the following specific purposes.
- Allow the merger, acquisition or sale of our assets, either in whole or in part.
- Respond to legal proceedings (for example, a resolution or subpoena), if we consider in good faith that it is necessary to do so, to comply with the requirements of the current law, to protect the safety of any person, to protect the rights and property Of XKELET, including compliance with the Terms and Conditions of use and other terms you have agreed to meet, to solve technical, fraud or security problems.
- Inform researchers about the objectives, which include statistical analysis and academic studies, but only in anonymous format.
- Publish the information on the use of the XKELET service anonymously or separately.
- Allow other companies in the XKELET group to use your information in accordance with the provisions of this Privacy Policy.

6. Your preferences​​​​​​​

With the configuration options we offer, you can choose what type of communication you want us to send you, manage your public information and set shared information preferences. However, as explained in the Information section that you share, certain information is set as public for others by default. And if you share information in a third-party application, that information can be viewed on XKELET, regardless of your privacy settings.
To change what information you want to be set to public, access your account settings. Read the instructions for making relevant settings on the XKELET website.
Because other people will be able to use, re-share or link public information on the Service or on the web, use XKELET carefully and keep in mind your configuration options.
Also remember that other information added to your profile may include personal information, such as your user name, by which other people can find it on the XKELET service or other services.

7. Transmission to other countries​​​​​​​

XKELET transmits, processes and stores user information through servers located in different countries. Therefore, XKELET may share your information with other XKELET group companies in order to carry out the activities specified in this Privacy Policy. XKELET may also subcontract the processing of information or share it with third parties located in countries other than their country of residence. Therefore, your personal information may be subject to privacy laws different from those of your country of residence. The third parties identified above may transmit and process information compiled in the European Economic Area (EEA) and Switzerland; These third parties may be in a country outside the EEA and Switzerland where you may have less legal rights to your information.
The XKELET group will process your information as provided in this Privacy Policy.

8. Related Links​​​​​​​

We may display third-party advertising and other content that links to third-party websites. We do not control or be responsible for the content and privacy practices of third parties. Read the third-party privacy policies to find out how they collect and process your personal information.

9. Security​​​​​​​

We are committed to protecting the information of our users. Because your password protects your user account, you should use a unique and secure password, limit access to your computer and browser, and log out after using the XKELET service. Although we implement measures to protect the data, no action is totally safe, and we do not guarantee the security of user information.

10. Minors​​​​​​​

XKELET service is not intended for children under 18 years of age. (In some countries there may be stricter limits.
See our Terms and Conditions of Use). We do not knowingly collect personal information from children under the age of 18 or within the applicable age limit (the "Age Limit"). If you are less than the established Age Limit, do not use the Service or provide us with personal information. If you are a parent of a child below the established Age Limit and you learn that your child has provided personal information to XKELET, write to legal@xkelet.com and you may request exercise of your applicable access, rectification, cancellation, or objection rights.

11. Access and update of user information​​​​​​​

You can view and modify much of the information we get from you through your account and profile pages. If you have questions regarding your privacy on the Service, this Privacy Policy or about the information we have about you, write to legal@xkelet.com. You can also contact a Privacy Officer by sending a letter to XKELET, to the attention of: Privacy Officer, Calle MARQUES DE CALDES DE MONTBUI, 102 - 17003 Girona (SPAIN). We will respond to your request within a reasonable period of time after verifying your identity in accordance with local laws. We suggest you include documents that show your identity and a clear and precise description of the information you want to access.

12. Changes to the Privacy Policy​​​​​​​

Occasionally and at our discretion, we may implement changes to the Contracts. If we implement significant changes in the Contracts, we will notify you in a way that we deem most appropriate; For example, we will display a prominent notice on the Service or send you an email. In some cases we will notify you in advance, and your continued use of the Service once the changes are implemented will constitute your acceptance of the changes. Therefore, be sure to read the notice carefully. If you do not wish to continue using the Service under the new Contract, you may terminate the Contracts and contact us through the Customer Service contact form.

13. Information on cookies, other technologies and data collection​​​​​​​

For more information on the use of cookies, go to the Cookies Policy section on the XKELET website

Thank you for reading our Privacy Policy. We hope you enjoy XKELET.

Data controller.
XKELET HOLDINGS LIMITED
Calle MARQUES DE CALDES DE MONTBUI, 102
GIRONA 17003
B55244420
© XKELET HOLDINGS LIMITED


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