Privacy Policy

Definitions#

"Xobin," "we," "us," or "our" shall refer to Xobin, with its corporate address at 2810 N Church St, Wilmington, Delaware 19802-4447.

"Customer", "you", shall refer to the paying clients that avail the Services of Xobin.

"Candidate" shall refer to the individual applying for jobs or the employees of the Customer who are evaluated through the Services provided by Xobin.

"Services" shall mean the services provided by Xobin.

Introduction#

At Xobin, we are committed to safeguarding your privacy and ensuring a secure, trustworthy experience on our website, xobin.com, and across all our services.

This Privacy Policy explains how we collect, use, and protect the personal information of any user ("you" or "your"), whether you are a Customer using our platform or a Candidate taking an assessment.

"Personal Data" means any information that can be used to identify an individual, such as your name, email address, job title, postal address, or other personally identifiable information (PII).

This Privacy Policy governs any personal information collected, used, or processed by Xobin, Inc. ("Xobin", "we", "our" or "us") through our website (xobin.com and all its subdomains, referred to as the "Site") or while using our services, products, and any applications developed or provided by us (collectively referred to as the "Services").

By accessing or using our Site or Services, you acknowledge and agree to the practices described in this Privacy Policy.

Comprehensive PII (Data Collection Section)#

1. Personal Information Provided Directly by You

• Identification Information: Full name, email address, phone number, and any other contact details provided when creating an account or engaging with our services.
• Professional Information: Employment details such as job title, company name, and work experience. This also includes educational background, CV submissions, and any responses provided during assessments or interviews conducted through the platform.
• Content Submission: Information you submit, including responses to assessments, videos from interviews, and other job-related data that you provide when using our platform.

2. Data Collected from Your Use of Our Services

• Device Information: IP address, browser type, and version, operating system, and device identifiers.
• Usage Data: Browsing activity on our website, including the pages you visit, the time spent on pages, click-throughs, and referral URLs.
• Assessment Data: Results and performance in skills assessments or psychometric evaluations that are processed as part of our recruitment and assessment services.

3. Information Provided by Third Parties

• If your account is created through an organization, such as an employer, we may receive your job title, work contact information, and any other data shared by that organization necessary for the provision of our services.

Scope of this Privacy Policy#

This Privacy Policy applies to all Xobin websites that link to it. It also applies to the products and services provided by Xobin through these websites, our mobile applications, and applications posted by Xobin on Xobin's online marketplace and in other third-party online marketplaces. This Privacy Policy does not apply to any of our websites, products or services that have a separate privacy policy.

This Privacy Policy is divided into three parts:

Part I. Information Xobin collects and controls: This part deals with how Xobin collects and uses information about website visitors, potential customers, users of Xobin's products and services, and others who contact Xobin through forms or email addresses published on or linked to our websites.

Part II. Information that Xobin processes on your behalf: This part deals with how Xobin handles data that you entrust to Xobin when you use our products and services, or when you share any personal or confidential information with us while requesting customer support.

Part III. General: This part deals with topics that are relevant to both Parts I and II, and other general topics such as Xobin's security commitments and how we will inform you when we change this Privacy Policy.

What information Xobin collects#

We collect information about you only if we need the information for some legitimate purpose. Xobin will have information about you only if

1. you have provided the information yourself,
2. Xobin has automatically collected the information, or
3. Xobin has obtained the information from a third party.

Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.

Information that you provide us#

i. Account signup: When you sign up for an account to access one or more of our services, we ask for information like your name, contact number, email address, company name and country to complete the account signup process. You'll also be required to choose a unique username and a password for accessing the created account. You may also provide us with more information such as your photo, time zone and language, but we don't require that information to sign up for an account. After signing up, you will have the option of choosing a security question and an answer to the security question. If you provide these, they will be used only while resetting your password.

ii. Event registrations and other form submissions: We record information that you submit when you (i) register for any event, including webinars or seminars, (ii) subscribe to our newsletter or any other mailing list, (iii) submit a form in order to download any product, whitepaper, or other materials, (iv) participate in contests or respond to surveys, or (v) submit a form to request customer support or to contact Xobin for any other purpose.

iii. Payment processing: When you buy something from us, we ask you to provide your name, contact information, and credit card information or other payment account information. When you submit your card information, we store the name and address of the cardholder, the expiry date and the last four digits of the credit card number. We do not store the actual credit card number. For quick processing of future payments, if you have given us your approval, we may store your credit card information or other payment information in an encrypted format in the secured servers of our Payment Gateway Service Providers.

iv. Testimonials: When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at [email protected].

v. Interactions with Xobin: We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.

Information that we collect automatically#

i. Information from browsers, devices and servers: When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites.

ii. Information from first-party cookies and tracking technologies: We use temporary and permanent cookies to identify users of our services and to enhance user experience. We embed unique identifiers in our downloadable products to track usage of the products. We also use cookies, beacons, tags, scripts, and other similar technologies to identify visitors, track website navigation, gather demographic information about visitors and users, understand email campaign effectiveness and for targeted visitor and user engagement by tracking your activities on our websites. We only use first-party cookies and do not use third-party cookies or other third-party tracking technologies on our websites. We also use first-party Local Storage Objects (LSOs) such as HTML5 to store content information and preferences to provide certain features.

iii. Information from application logs and mobile analytics: We collect information about your use of our products, services and mobile applications from application logs and in-house usage analytics tools, and use it to understand how your business use and needs can improve our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.

Information that we collect from third parties#

i. Signups using federated authentication service providers: You can log in to Xobin Services using supported federated authentication service providers such as LinkedIn, Microsoft and Google. These services will authenticate your identity and give you the option to share certain personal information with us, such as your name and email address.

ii. Referrals: If someone has referred any of our products or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at [email protected] to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.

iii. Information from our reselling partners and service providers: If you contact any of our reselling partners, or otherwise express interest in any of our products or services to them, the reselling partner may pass your name, email address, company name and other information to Xobin. If you register for or attend an event that is sponsored by Xobin, the event organizer may share your information with us. Xobin may also receive information about you from review sites if you comment on any review of our products and services, and from other third-party service providers that we engage for marketing our products and services.

iv. Information from social media sites and other publicly available sources: When you interact or engage with us on social media sites such as Facebook, Twitter, Google+ and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our products, or better understand user reactions and issues. We must tell you that once collected, this information may remain with us even if you delete it from the social media sites. Xobin may also add and update information about you, from other publicly available sources.

Purposes for using information#

In addition to the purposes mentioned above, we may use your information for the following purposes:

1. To communicate with you (such as through email) about products that you have downloaded and services that you have signed up for, changes to this Privacy Policy, changes to the Terms of Service, or important notices;
2. To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;
3. To ask you to participate in surveys, or to solicit feedback on our products and services;
4. To set up and maintain your account, and to do all other things required for providing our services, such as enabling collaboration, providing website and mail hosting, and backing up and restoring your data;
5. To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;
6. To provide customer support, and to analyze and improve our interactions with customers;
7. To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Xobin, Xobin's users, third parties and the public;
8. To update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you;
9. To analyze trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;
10. To monitor and improve marketing campaigns and make suggestions relevant to the user.

Legal bases for collecting and using information#

Legal processing bases applicable to Xobin: If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it.

Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of Xobin or a third party that are not overridden by your data protection interests, or (iii) your consent.

Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.

Withdrawal of consent: Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.

Legitimate interests notice: Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.

Your choice in information use#

Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the 'unsubscribe' function included in all such messages. However, you will continue to receive notices and essential transactional emails.

Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.

Optional information: You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.

Who we share your information with#

We do not sell any personal information. We share your information only in the ways that are described in this Privacy Policy, and only with parties who adopt appropriate confidentiality and security measures.

Employees and independent contractors: Employees and independent contractors of all Xobin entities have access to the information covered in Part I on a need-to-know basis. We require all employees and independent contractors of Xobin entities to follow this Privacy Policy for personal information that we share with them.

Third-party service providers: We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.

Domain registrars: When you register a domain through Xobin from domain name registrars, we share your name and contact information such as your physical address, email address and phone number with them as per the ICANN domain registration rules.

Reselling partners: We may share your personal information with our authorized reselling partners in your region, solely for the purpose of contacting you about products that you have downloaded or services that you have signed up for. We will give you an option to opt out of continuing to work with that partner.

Other cases: Other scenarios in which we may share the same information covered under Parts I and II are described in Part III.

Your rights with respect to information we hold about you as a controller#

If you are in the European Economic Area (EEA), you have the following rights with respect to information that Xobin holds about you. Xobin undertakes to provide you the same rights no matter where you choose to live.

Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared.

Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.

Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.

Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.

Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.

Right to complain: You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.

Retention of information#

Xobin has a standard data retention policy of 7 years. Sometimes, we may retain your information for longer periods as permitted or required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

Information entrusted to Xobin and purpose#

Information provided in connection with services: You may entrust information that you or your organization (henceforth referred to as "you" or "the client") control, to Xobin in connection with use of our services or for requesting technical support for our products. This includes information regarding your customers and your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are a processor). The data may either be stored on our servers when you use our services, or transferred or shared to us as part of a request for technical support or other services.

Information from mobile devices: When you elect to allow it, some of our mobile applications have access to the camera, call history, contact information, photo library, and other information stored on your mobile device. Our applications require such access to provide their services. Similarly, when you elect to provide access, location-based information is also collected for purposes including, but not limited to, locating nearby contacts or setting location-based reminders. This information will be exclusively shared with our mapping providers and will be used only for mapping user locations. You may disable the mobile applications' access to this information at any time by editing the settings on your mobile device. The data stored on your mobile device and their location information to which the mobile applications have access will be used in the context of the mobile application, and transferred to and associated with your account in the corresponding services (in which case the data will be stored on our servers) or products (in which case the data will remain with you unless you share it with us).

(All the information entrusted to Xobin is collectively termed "service data")

Ownership and control of your service data#

We recognize that you own your service data. We provide you complete control of your service data by providing you the ability to (i) access your service data, (ii) share your service data through supported third-party integrations, and (iii) request export or deletion of your service data.

How we use service data#

We process your service data when you provide us instructions through the various modules of our services. For example, when you generate an invoice, information such as the name and address of your customer will be used to generate the invoice; and when you use our campaign management service for email marketing, the email addresses of the persons on your mailing list will be used for sending the emails.

Push notifications#

If you have enabled notification on our desktop and mobile applications, we will push notifications through a push notification provider such as Apple Push Notification Service, Google Cloud Messaging or Windows Push Notification Services. You can manage your push notification preferences or deactivate these notifications by turning off notifications in the application or device settings.

Who we share service data with#

Employees and independent contractors: We may provide access to your service data to our employees and individuals who are independent contractors of the Xobin entities involved in providing the services (collectively our "employees") so that they can (i) identify, analyze and resolve errors, (ii) manually verify emails reported as spam to improve spam detection, or (iii) manually verify scanned images that you submit to us to verify the accuracy of optical character recognition. We ensure that access by our employees to your service data is restricted to specific individuals, and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the Xobin.

Collaborators and other users: Some of our products or services allow you to collaborate with other users or third parties. Initiating collaboration may enable other collaborators to view some or all of your profile information. For example, when you edit a document that you have shared with other persons for collaboration, your name and profile picture will be displayed next to your edits to allow your collaborators to know that you made those edits.

Third-party integrations you have enabled: Most of our products and services support integrations with third-party products and services. If you choose to enable any third-party integrations, you may be allowing the third party to access your service information and personal information about you. We encourage you to review the privacy practices of the third-party services and products before you enable integrations with them.

Other cases: Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.

Retention of information#

We hold the data in your account as long as you choose to use Xobin Services. Once you terminate your Xobin user account, your data will eventually get deleted from active database during the next clean-up that occurs once in 6 months. The data deleted from active database will be deleted from backups after 3 months.

Data subject requests#

If you are from the European Economic Area and you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.

Children's personal information#

Our products and services are not directed to individuals under 14. Xobin does not knowingly collect personal information from children who are under 14 years of age. If we become aware that a child under 14 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 14 years has provided personal information to us, please write to [email protected] the details, and we will take the necessary steps to delete the information we hold about that child.

Your Data Rights#

As a data subject, you have specific rights regarding the personal data we process. These rights ensure that you have control over your personal information and how it is used. You can exercise the following rights under applicable data protection laws:

1. Right to Access: You have the right to request access to the personal data we hold about you, including details on how and why we process your information.
2. Right to Rectification: If any of the personal data we have is inaccurate or incomplete, you have the right to request its correction.
3. Right to Erasure: In certain circumstances, you may request the deletion of your personal data. This is also known as the 'right to be forgotten,' subject to any legal obligations requiring the retention of the data.
4. Right to Restrict Processing: You can request that we limit the processing of your personal data, for example, while we verify its accuracy or if you have objected to its processing.
5. Right to Object: You have the right to object to the processing of your personal data for specific purposes, including direct marketing or if the processing is based on our legitimate interests.
6. Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format, and have the right to transfer this data to another service provider.

DPDPA Update#

As a Data Principal under the Digital Personal Data Protection Act, 2023, you have the right to:

1. Request access to information about your personal data processed by us.
2. Request correction or erasure of your personal data, where applicable.
3. Withdraw consent provided for the processing of your personal data.
4. Raise grievances regarding the processing of your personal data.
5. Nominate an individual to exercise your rights in the event of your death or incapacity.

Consent Management#

For certain types of data processing, particularly those involving sensitive data, we will obtain your explicit consent before proceeding. By using our services, you agree to the collection and processing of your personal data as described in this Privacy Policy.

Managing Your Consent#

We provide a clear process for managing your consent, allowing you to:

1. Provide Consent: When submitting your information on our platform, you will be prompted to provide explicit consent for the collection and processing of your data, where necessary.
2. Modify Consent: You can modify your consent preferences at any time, should your preferences or circumstances change.
3. Withdraw Consent: You have the right to withdraw your consent for specific processing activities. Upon receiving your withdrawal request, we will stop processing your data unless required by law to continue doing so.

How secure is your information#

We have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us.

Data Breach Notification#

Xobin is committed to ensuring the security and protection of your personal data. In the event of a data breach that compromises your personal information, we have a comprehensive data breach response plan in place to minimize harm and prevent further risks.

In Case of a Data Breach

If a data breach occurs, we will:

1. Immediate Action: Conduct an immediate assessment to determine the nature and extent of the breach.
2. Notification: If the breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay. We will also inform the relevant data protection authorities in accordance with applicable legal requirements and within the stipulated timeframe.
3. Preventative Measures: Following the breach, we will investigate the root cause and take necessary measures to prevent future incidents.

Our commitment to transparency ensures that affected individuals will be informed promptly, with clear instructions on steps they can take to protect themselves.

Data Protection Officer#

We have appointed Amrit Acharya as our Data Protection Officer to oversee our management of your personal information in accordance with this Privacy Policy. If you have any questions or concerns about our privacy practices with respect to your personal information, you can reach out to our Data Protection Officer by sending an email to [email protected].

Locations and international transfers#

We share your personal information and service data within the Xobin. By accessing or using our products and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the United States of America, the European Economic Area (EEA) and other countries where Xobin operates. Such transfer is subject to a group company agreement that is based on EU Commission's Model Contractual Clauses.