Privacy Policy

Last modified: April 1, 2019

Felix Analytics Inc. DBA Xyla ("us", "we", or "our") operates the xyla.io website (hereinafter referred to as the "Service").

This Privacy Policy informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which incorporate this Privacy Policy by reference and is available here.

If you do not agree with our policies and practices, do not use the Service.

Definitions

Service

Personal Data

Usage Data

Cookies

Data Controller

Data Processors (or Service Providers)

Data Subject (or User)

Information We Collect and How We Collect It

We collect several different types of information from and about users of the Service, including:

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information is collected when you enter it into the Service, connect an account to the Service, or direct us to connect your account(s) to the Service, and may include, but is not limited to:

• Email address;
• First name and last name;
• Credit card, bank, and/or other billing information if you sign up for a paid subscription
• Data from your MMP (“Mobile Measurement Partners”) account, Apple Search Ads account, Facebook, Google, and other accounts to which you connect your Service account to enable the functionalities of the Service;
• Data from your website(s) and/or mobile application(s) that are connected to your Service account; and/or
• Additional information that you voluntarily enter, such as company name and advertising campaign details, that may include personally identifiable information.

Usage Data

We may also collect information on how the Service is accessed and used automatically as you navigate and use the Service ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device automatically as you navigate and use the Service. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies: We use Session Cookies to operate our Service.
• Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
• Security Cookies: We use Security Cookies for security purposes.

In some countries, including countries in the EEA, the information referenced above may be considered personal information under applicable data protection laws. If you do not want us to collect this information, do not use the Service.

Our Use of Your Data

Xyla uses the collected data for various purposes:

• To develop, provide, and maintain our Service
• To provide you with information, products, or services you request from us
• To notify you about changes to our Service
• To provide you with notices about your account and/or subscription
• To power surveys and research studies using aggregated user data
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the EEA Xyla’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Xyla may process your Personal Data because:

• We need to perform a contract with you (meaning you have subscribed to the Service or we have otherwise signed a contract together)
• You have given us permission to do so by voluntarily entering your information into the Service or agreeing to this Privacy Policy and using the Service
• The processing is in our legitimate business interests and it is not overridden by your rights
• To comply with the law

Retention of Data

Xyla will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Xyla will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Xyla will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Service users is among the assets transferred.
• For any other purpose disclosed by us when you provide the information.
• To third party contractors in order to analyze the Service performance and user behavior and/or to improve the Service.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.
• In the event that you enter into a separate agreement with us restricting certain of our employees from accessing your personal information, such an agreement will override this Privacy Policy.

Security of Data

We have implemented measures designed to secure your personal information from unauthorized access. For example, access by a user to his or her personal information is available through a password and unique customer ID. This information is encrypted through the Service with Secure Socket Layer technology (SSL) and is also encrypted when it is stored by us to prevent unauthorized parties from viewing such information. All of our employees are required to adhere to our security and confidentiality procedures and undergo training related to maintaining the security of user personal information. Additionally, when you provide your credentials so we can obtain your data from an API, we store this data in a secure, password-protected Amazon Redshift Multi-Node cluster that contains a database schema dedicated to your user account with Xyla.

The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of the Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and be careful about giving out information in public areas of the Service.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Service. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Service.

Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a user in the EEA, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we have relied on your consent to process your personal information. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 18.

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

If you are based in the European Economic Area (“EEA”) you may only use the Service if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of the Service has been provided to us.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: support@xyla.io