Xinspire Hosted Service
Privacy Policy

Last Modified May 23, 2018

Xinspire, LLC (“Xinspire”) provides this notice (“Privacy Policy”) explaining its online information practices for its hosted mentoring service (the “Service”) and the website located at xinspire.com (the “Website”) and the way personal information is collected and used in connection with the Service and the Website. If you do not agree with the practices explained in this Privacy Policy, you should not use the Service or the Website. By using the Service or the Website, you agree to accept the practices and terms set forth in this Privacy Policy.

Sponsoring Organizations and Your Rights

Xinspire emphasizes that this Privacy Policy does not address the practices or policies of its Service customers (“Sponsoring Organizations”). Each Sponsoring Organization uses the Service to collect and process personal data for the legitimate interest of enabling mentoring relationships among individuals associated with the Sponsoring Organization. Certain Sponsoring Organizations may also base their collection and processing of personal data on your consent.

Xinspire is solely a technology and tools provider to Sponsoring Organizations. The collection, retention, processing and other uses of personal data by Sponsoring Organizations, whether or not in connection with the Service, is governed by their own privacy policies and applicable laws, rules, or regulations. Xinspire does not control those Sponsoring Organization activities. Each Sponsoring Organization is the data controller with respect to all such personal data, and the applicable data protection officer (if any) will be someone appointed by the Sponsoring Organization.

Under the applicable laws of various countries, you may have certain rights concerning your personal data, such as under EU law, the right to access to, rectification or erasure of, and/or restriction of processing or objection to processing of your personal data, and the right to data portability. If you believe that a Sponsoring Organization has collected or processed your personal data (other than Analytic Data, as described below), and you have any questions or want to exercise any of your rights with respect to your personal data, you should contact them directly. If you have trouble reaching the relevant Sponsoring Organization directly, please contact Xinspire at the email address below. Before we process any request, we may request personal information to verify your identity where allowed by law. Where permitted by local law, we may reject requests that are unreasonable or impractical.

If you are a resident in the European Union, you also have the right to at no cost to lodge a complaint with EU data protection authorities. This right may also exist in other countries. If you have questions please ask the relevant Sponsoring Organization or the data protection authority in your country.

What information do we collect on our customer’s behalf?

We collect personal data necessary for you to establish an account under the relevant Sponsoring Organization’s agreement with us, any information that you volunteer within the Service or communicate to us in connection with your use of the Service, and associated information we use to administer and secure the Service on behalf of the Sponsoring Organization (e.g., logging access attempts under user login IDs). Each Sponsoring Organization requires different information and suggests volunteering different information. All such information is collected and processed on behalf of the relevant Sponsoring Organization.

You can also register with our Service and create a Service account via certain third-party services such as Google and LinkedIn (each, an “SSO Account”), if and when such functionality is available. If you choose to create a Service account through one of your SSO Accounts, you may have to provide us with your username (or user ID) so that your identity can be authenticated by the SSO Account. When the authentication is complete, we’ll be able to link your account with the SSO Account. That linking may allow us to access certain personal data, such as your name and email address, your user ID for the SSO account, data tokens used to implement single sign-on and connect with your SSO account profile, and other personal data that your privacy settings on the SSO Account permit us to access, in connection with creating your Service account. We don’t receive or store passwords for any of your SSO Accounts.

What information do we collect on our own behalf?

We collect personal data when you communicate directly with us through our email address or Website contact form. When you visit the Service and / or the Website, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting. For most users accessing the Internet from an Internet service provider, the IP address will be different every time you log on. We use Log Data to monitor use of the Service and Website and for the technical administration of the Service and Website.

We also collect information using the tracking tools described under “Do we use cookies or other tracking tools” below. That information, together with the Log Data, is “Analytic Data”.

However, it is important to note that, except as stated in this Privacy Policy, Xinspire will never disclose or associate with your site usage any of the personal data you provide within the Service. You should be aware, however, that the provision of the Service requires that your sponsoring Organization and its delegated administrators (“Organization Admins”) will have access to some or all of this information, and Xinspire cannot control the uses of that information by your Sponsoring Organization or Organization Admins.

Do we use cookies or other tracking tools?

Yes.

Cookies are small files that a site or its service provider transfers to a computer hard drive through a Web browser (if the user allows the browser to do so) that enables the sites or service provider’s systems to recognize the browser and capture and remember certain information.

We use cookies to save your login status, to allow us to serve pages to you more efficiently, and to understand and save your preferences for future visits. We may also use tracking pixels. Tracking pixels are small graphic images, which are used in email messages to determine whether the messages were opened and the links were clicked. We do not use tracking pixels to collect personally identifiable information. However, IP addresses and other Log Data are collected by the use of tracking pixels.

We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. Presently, the only third-party analytics service provider we use is Google Analytics, which is enabled by default, although we allow your Sponsoring Organization to determine whether or not to use Google Analytics. Both Xinspire and your Sponsoring Organization are able to view Google Analytics information which may be related to your use of the Service. However, while Google Analytics may collect personal data to derive the information that it shows to Xinspire and your Sponsoring Organization, we cannot view Google Analytics information identifiable to you.

For Google’s privacy practices see http://www.google.com/analytics/learn/privacy.html.

Finally, the Sponsoring Organization may also use other analytics providers and/or place content in the Service which uses cookies or collects data directly (e.g., by serving content from an embedded URL, often called a “hotlink”). In order to learn what providers your Sponsoring Organization uses or what content the Sponsoring Organization has placed in the Service and whether that content has associated cookies or data collection, you must contact them.

Opting Out

If you prefer, you can change your browser settings to have your browser provide a warning each time a cookie is being sent, you can choose to turn off only third party cookies (that is, cookies that are placed by a domain other than xinspire.com or whatever domain you’re currently viewing), or you can choose to turn off all cookies.

You may also disable tracking pixels by disabling HTML images in your email program, which may also affect other images in emails you receive.

To opt out of data recording and analysis by Google Analytics, see https://tools.google.com/dlpage/gaoptout.

In order to learn how to opt out of tracking by any other analytics providers your Sponsoring Organization uses, you must contact them.

How do we use your information?

Any of the information we collect from you may be used in one of the following ways:

On behalf of the Sponsoring Organization:

  1. To deliver the Service and send email notices and requests (e.g., survey or feedback requests) related to the Service and your account. This includes allowing you access to the Service, fulfilling your requests, providing administrative notices, and facilitating communications among you and other users through the Service. We do not send notices to ordinary users except according to the rules set for us by Organization Admins, so if you are an ordinary user of the Service, and have concerns about the notices you are receiving, you must contact your Sponsoring Organization. We also send Organization Admins administrative and operational notices which we believe are necessary for their effective use of the Service; we do not presently allow opt-out from those notices.
  2. To personalize user experiences (user information helps us to better respond to each user’s individual needs).
  3. To improve customer service (user information helps us to more effectively respond to customer service requests and support needs).
  4. To administer a survey or other Service features.

On Our Own Behalf:

  1. We use information you provide to us directly through our email address or our contact form to manage our business and our relationship to you, and respond to your inquiries.
  2. We use Analytic Data to collect, create and analyze non-identifiable metadata about the use of the Service and Website in order to improve our products and determine possible features to be offered to our customers.
  3. We will not disclose to any third party any Analytic Data or communications from you when associated with your personal data except as set forth in this Privacy Policy.

How do we protect your information?

We implement a variety of security measures to maintain the safety of personally identifiable information when a user enters, submits, or accesses their personal information.

We offer the use of a secure server for the Service. All personally identifiable information supplied by you to us via the Service is transmitted via Secure Socket Layer (SSL) or similarly secure technology. We allow personally identifiable information to be accessed only by persons with specified rights to do so (which persons may include the Organization sponsoring your use of the Service and its Organization Admins).

Due to the open nature of communication through the Internet, we cannot guarantee that communications between you and the Service and Website, or between you and us directly, will be free from unauthorized access by third parties, nor that third parties will not be able to circumvent the safeguards we have put in place. Users of the Service do so at their own risk. We cannot absolutely guarantee the security of any information that is disclosed or transmitted online.

You should also be aware that your Sponsoring Organization may be able to track and review your Internet use when you use certain of the Sponsoring Organization’s resources (i.e., from your office, using the Sponsoring Organization’s network, or using a laptop or device furnished or provisioned by the Sponsoring Organization). We cannot control these activities and are not responsible for any such activities by the Sponsoring Organization.

How long do we retain your information?

We will retain your personal data that we process in connection with the provision of the Service to your Sponsoring Organization for as long as needed to provide Service to that Sponsoring Organization or until they direct us to delete it. We will retain this personally identifiable information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We will retain other personal data we collect independently only for as long as necessary in our business. We retain such as aggregated or anonymized Analytic Data not identifiable to any person for as long as we believe it to be useful in our business.

Do Not Track

We do not respond to the Do Not Track setting in your browser. We use only session, authentication and preference cookies as described above. We do not otherwise use cookies to collect personally identifiable information or track users’ online activities over time. We do not use cookies to track personally identifiable information or users’ online activities across different web sites. For information regarding Do Not Track mechanisms, see http://allaboutdnt.com.

Do we disclose any information to outside parties?

We do not sell, trade, or otherwise transfer personal data to outside parties except as expressly stated in this Privacy Policy.

We may disclose personal data (including as associated with Analytic Data) to trusted third party vendors working for us in connection with the operation of our Service and our business, so long as those parties agree to use this information only to provide services to us, and to keep this information confidential. We may also release personal data and associated Analytic Data when we believe release is appropriate in order to respond to a law enforcement agency request, subpoena, court order or other such request by a legal authority, or to otherwise establish or exercise our rights, or defend against legal claims, to investigate, prevent and take action regarding fraud or misuse of the Service, to comply with the law, situations involving potential threats to the physical safety of any person, or if otherwise required by law to do so (such as a subpoena).

Personal data, including associated Analytic Data, may be provided to a third party if there is a transfer of the assets or ownership of Xinspire or if Xinspire files for bankruptcy, or if your Sponsoring Organization elects to use a different provider for the Service Xinspire provides.

Xinspire, its partners, and each of their contractors and employees may view your personal data and the content that you upload to the Service in order to provide the Service and otherwise perform the tasks set forth in this Privacy Policy.

Your Sponsoring Organization and the Organization Admins have the ability to access and download your personal data stored in the Service, and further, have the contractual right to do so under the agreement between the Sponsoring Organization and Xinspire. Xinspire does not control any use or processing of your personal data by the Sponsoring Organization or the Organization Admins and is not responsible for any such activities except to the limited extent required by law.

Finally, any information that you may reveal in your user profile, in communication with other users, and in any content that you upload, provide to your Sponsoring Organization or Organization Admins, or may reveal in other online discussions or forums is intentionally visible to other persons and is not in any way private unless otherwise indicated. You should think carefully before publicly disclosing any personally identifiable information. Anything you make public may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.

Inquiries

Upon request, we will provide you with information about your personal data included in Analytic Data. To request this information please contact us at the address at the end of this Privacy Policy. We will use reasonable efforts to respond within a reasonable time frame, and in any case, we will respond within any period of time mandated by applicable law.

International Transfer

Your personal data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your personal data to us, we may transfer your personal data to the United States and process it there.

Children

We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act). Further we do not knowingly collect or process any information from anyone under 13 years of age (16 in the EU). Our Service is directed to organizations serving people who are at least 13 years old or older (16 in the EU).

Reasonable Efforts

We will use reasonable efforts to comply with this Privacy Policy and to take prompt corrective action when we learn of any failure to comply with our Privacy Policy. We sometimes release beta versions of our products and services, which are further refined before the release of the final version. Because these products and services are still in a test phase, we may not always catch an unintended privacy issue, despite our efforts to do so. As such, we welcome feedback on any privacy concerns. In light of the above and because of the complex and constantly changing nature of our technology and business, and the security risks associated with using the Internet, we do not guarantee error-free performance under this Privacy Policy. TO THE EXTENT PERMISSIBLE UNDER LAW, XINSPIRE SHALL NOT BE LIABLE FOR ANY INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES RELATING TO THIS PRIVACY POLICY.

Changes to our Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If you have established an account for the Service, we will attempt to inform you of any modifications to this Privacy Policy that affect your obligations to us or our obligations to you: (a) by a message displayed at the time you log into the Service, and / or (b) by such other means as we deem reasonably likely to reach you. If you do not agree with any such modifications, the sole remedy is the termination of your account, which in each case may be requested by contacting your Organization Admin, or if that option fails to accomplish the termination of your account, by sending an email to privacy@xinspire.com. Your continued use of the Service after receiving notice of any modifications indicates your acceptance of the modified Privacy Policy as to your personal data.

If you have not established an account for the Service, any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service, and your continued use of the Service after any modifications indicates acceptance of the modified Privacy Policy. You agree to review this Privacy Policy periodically so that you are aware of any modifications.

Contacting Us

If there are any questions regarding this privacy policy we may be contacted using the information below.

Xinspire, LLC
4306 Collins Ct. #101
Mountain View, CA 94040
United States of America
Email: privacy@xinspire.com