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Privacy Policy

Effective as of January 30, 2021

This Privacy Policy describes and explains how XM ONLINE LLC (“XME DIGITAL”, “we”, “our”, “us”) as the data controller collects and processes information relating to individuals (“Personal Data”).

1. What is covered by this Privacy Policy? 

This Privacy Policy applies to and covers the processing of Personal Data which may be collected by XM ONLINE LLC (hereinafter "XME DIGITAL", “we”, “our”, “us”) when you visit and/or interact with our website (hereinafter - the “Website”); contact us via email or phone or in other cases as described below where we act as the controller of your Personal Data.

2. What Personal Data do we collect and how we use this information?

We may collect and process the following Personal Data about you and use such Personal Data as described below:

when you interact with us, contact us via correspondence, through our Website, otherwise, contact us or send us requests. When you fill and submit our “Contact Us” form or fill and submit any request/inquiry form via our Website you may be asked to provide the following information: name; email address or your phone number. This information will be used to reply to your request and contact you using the data you provided for those purposes. If you choose to contact us via our email we will use your email address to reply to your email.

when you subscribe to marketing emails. On our Website, you may choose to subscribe to our marketing communication. If you chose to subscribe to our marketing newsletter we will process the email address you provided to us to send you information about our products and services, events and news. You have the option to unsubscribe and withdraw your consent to the marketing communication at any time.

when you apply for a job. If you apply for a job using the application form at our Website or sending us your CV via email we will collect the information you send to us in your CV during the application process. We will use this information for the purposes of processing your job application and may further keep such Personal Data at our records upon your consent.

While interacting with our Website, applying for a job, please, be sure you do not send to us any special or sensitive categories of personal data (e.g. data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, etc). We do not collect any special or sensitive categories of Personal Data.

Purposes for which we process your Personal Data:

replying to your requests, following up on incoming requests from you; 

performing of direct sales activities in cases where you have expressed the interest in our Services and where the legitimate interest is established;

performing contractual obligations, providing our services to you;

sending marketing communications upon your consent;

processing of job applications if you have applied for a job at XME DIGITAL.

3. Legal basis for the processing of Personal Information we rely on.

We process Personal Data based on the following legal basis:

Consents. In cases we collect Personal Data based on consents, such collection of Personal Data will be made through consent forms specifying the specific purpose of the processing of your Personal Data. For example, we may ask you to give consent for sending marketing emails, news digests, etc. 

Performance of the contract. We may use and process Personal Data to the extent it is necessary for the performance of a contract between you and XME DIGITAL.

Legitimate interests. We may process Personal Data when such processing is necessary for the purposes of the legitimate interests pursued by us, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Compliance with legal obligations. In some cases, we may process Personal Data when the applicable law requires us to do so in order to comply with a legal obligation to which XME DIGITAL is subject.

4. Who do we share your Personal Data with?

We may share Personal Data with others exclusively when we are legally permitted to do so. We do not sell or trade your information with any third parties. We do not share your Personal Data with any third parties except as explicitly specified herein:

third-party service providers - when we use the services of third-party service providers that help us provide our services, run and manage our systems (e.g., storage services, customer relations management systems, cloud data services, etc). Personal Data may be submitted to, stored or accessed by such third party services providers exclusively to the extent necessary to provide us with the relevant services.

when required by law - we will disclose Personal Data  if such disclosure is required by law or necessary to comply with judicial proceedings, a court order or legal process;

with your consent - when you have given us an explicit and affirmative consent to share your data with third parties.

5. Storage and transfer of Personal Data

The Personal Data we collect will be processed by us in the countries and locations where XME DIGITAL is operating. Your Personal Data may be transferred to and stored by our third-party service providers as stated herein that may be located in other countries. Thus your Personal Data may be processed by us and our contracted services providers in locations and countries outside your country, your jurisdiction. We take steps to ensure that your Personal Data is being protected and processed according to the provisions of this Privacy Policy.

In cases your Personal Data is transferred outside European Economic Area, we will use appropriate legal mechanisms to safeguard the transfer. If required by applicable law we will ask you to provide the prior written consent for international transfer of your personal data outside your jurisdiction.

6. Children

Our Websites and services are not directed at children. We do not knowingly collect any Personal Data from children under 18.

7. How long do we keep your Personal Data?

We store Personal Data for a period of time necessary to fulfill the purposes for which the Personal Data was collected. Sometimes we need to store Personal Data for a period of time as required to comply with legal requirements under applicable laws.

When the Personal Data is no longer required it will be securely deleted. We may process aggregate data for statistical purposes, and in such cases information will be anonymized.

8. Your rights relating to your Personal Data  and how You can exercise them. 

Right of access to Personal Data. You have the right to obtain from XME DIGITAL the confirmation as to whether or not Personal Data concerning you is being processed by XME DIGITAL. You have the right to request a copy of your Personal Data that XME DIGITAL holds about you as the controller and obtain the relevant information about the purposes and the ways we process your Personal Data. 

Right to request rectification/correction of your Personal Data. In cases where the Personal Data is inaccurate or out of date (e.g. you have changed your email address) you have the right to obtain from us without undue delay the rectification or correction of inaccurate Personal Data concerning you.

Right to request the erasure or deletion of your Personal Data. You have the right to obtain from us the erasure or deletion of personal data we hold about you in certain cases.

Right to restrict the processing. You have the right to restrict our processing of your Personal Data in certain cases, to the extent permitted by law.

Right to withhold your consent in cases the processing of your Personal Data is based on your consent. For example, you have the right to opt-out of our marketing emails. To exercise this right you can either follow the unsubscribe link in the text of our marketing email or contact us at

Right to withhold your consent in cases the processing of your Personal Data is based on your consent.

Right to receive the Personal Data which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller to the extent possible (Right to data portability).

Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects. We do not use automated processing (automated decision making).

You may exercise all of those rights by emailing us at

If you have any queries with regard to your privacy rights, any complaints about our use of your Personal Data, please, contact us at

You may also file a complaint with the appropriate data protection authority if you consider your rights have been violated.

9. How we secure your Personal Data?

We take appropriate organizational, technical and administrative measures used in the industry to secure Personal Data we collect and process. Those measures are aimed to ensure the appropriate security of Personal Data processed and are aimed to safeguard the Personal Data against accidental loss, destruction or damage, unauthorized disclosure, unauthorized access. 


10. The use of cookies

Our Website may use cookies. Cookies are small text files placed on your device by the website you visit. Cookies and information contained in cookies may be used to make the websites perform more efficiently, understand how visitors use the website, detect and prevent security threats, etc.

We use the platform for hosting our website. Privacy Policy is available at  Information about types of cookies placed at websites built with and hosted at is available here: At our website the following types of cookies are placed: 

Analytical cookies. At our website, we use analytical cookies and Google Analytics as a third-party service provider. More information and privacy policy are available at
To disable Google Analytics at your browser, please, follow the link:


Most of the browsers allow you to manage and control your cookies. You can manage and administer your cookies settings at your browser. Please, note that disabling some types of cookies may prevent you from receiving access to some elements of our websites, or lead to some features being not available.

11. Changes to this Privacy Policy

We can modify this Privacy Policy from time to time. We encourage you to periodically review our Privacy Policy. We will notify you about any material changes to this Privacy Policy through the notice at our website or through email which address you provided.

12. Contacting us

To exercise your rights with regard to your Personal information or if you have any questions, complaints relating to this Privacy Policy, please, email us at

You can also contact us at:

26 Starokyivska Street,
Kyiv, Ukraine,
Postcode: 04116

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