Privacy Policy

Updated 24 September 2021

Thanks for downloading the XALI App.

It is important that you understand how your personal data may be collected, stored and used and your rights in relation to that process.

Along with the XALI Terms of Use, this Privacy Policy makes up Our agreement with you as a user of our App.

1. Introduction

In this Privacy Policy and the Terms of Use when we refer to ‘‘XALI’’, ‘We’, ‘Us’ or ‘Our’ we are referring to Re-dux Definition Pty Ltd (trading as “XALI”) of Level 16, 1 Market Street, Sydney NSW 2000, email: [email protected], the “Data Controller” for this Service.

We collect and process information using the official XALI Application (and related website used to support account management and sharing of posts on social media and other platforms), referred to in this Policy as “the Service” or “the App”.

The Data Controller is responsible for determining the purpose of collecting, processing and storage of your personal data, and the content and related services or features which are made available to you from using the Service.

2. What is the Purpose of the Service?

The purpose of the Service is to host XALI content and provide a platform for the XALI community to connect with each other.

3. Where do we collect personal data about you from?

We collect personal data about you directly from you. This is information you have voluntarily provided whilst entering your personal details on the Service. We do not collect personal data about you from any other agency or third party unless you authorise them to access your account on the Service.

4. What Information Do We Collect, why and how do We use it?

We will only ever collect the information We need to enable Us to undertake the specific information processing activities noted later in this section. We collect and process two distinct kinds of information: 

* Non-personal information such as the pages you have accessed, helping Us to determine how many people use Our Service, how many people visit on a regular basis, and how popular each of Our pages are. This information does not tell Us anything about who you are or where you live. It simply allows Us to monitor and improve the Service. All such information has been anonymised before its use. 

* Personal but non sensitive information such as your IP address, email address, username, password, approximate location and any optional information you may choose to provide to Us as part of your experience within the Service (e.g. text, photograph, meme). 

* Personal and potentially sensitive information such as your height, weight, lifestyle choices and medical information.

When you first open the App, you will be required to register before you can use the App. During registration we ask for the following information:

  • Email address – We use this to send you a welcome email, and any Service related communications such as resetting your password or verifying your email address. On registration you will be asked to indicate whether or not you authorise Us to send you any marketing or third-party messages.
  • Your name/username – We ask for a username so that if you make any posts or comments on the Service that these are attributable to you. Other users will also be able to search for you by name, and it will be shown on your public profile page. Many people adopt derivative or anonymised nicknames as a username. You do not have to use your real name, although we generally encourage it.
  • A photo – this is optional, but if you add a photo this will be shown next to any posts and comments you make, as well as on your public profile page on the Service.
  • A password – We store this in a secure one-way encrypted system. If you forget your password, you may request that it be reset, and We will send an email to you with instructions on how to do so.
  • Information relevant to the App – Given the nature of the App, We will collect, store and process personal information about you including but not limited to your age, gender, weight, height, dietary preferences, fitness level and medical history. This information is used by Us to provide the Service to you and for research and marketing but only once such information is anonymised.

Once registration is complete, and you have verified your email you may, if you choose, post, and comment in the App. Please bear in mind that any posts and comments you make are in the public domain and may be viewed by non-registered users in the App and on public web pages for marketing purposes.

You may also send friend requests to other users and, should they accept, you will have the ability to send one-to-one and group messages to them. These messages are completely private between you and any other recipients and are not monitored.

As you use the App We will keep track of what sections you have visited, so that We can highlight sections or content to you that you may have missed. We also use this data in an aggregated form to understand how popular the App and its different sections are so that We can improve the Service. This data is never shared with anyone and is only used for Our internal purposes.

We record the last IP address you accessed the Service from so that We can protect the Service from malicious access. As part of this We may look up the approximate location of the IP address such as country and city.

Your decision to disclose your personal information to Us is entirely voluntary. However, if you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, you may not be able to access or use the App.

We will only retain the identifying details of your personal information for as long as you are a registered user of the Service. We comply with all legislative and regulatory information retention requirements and will securely and permanently delete your identifying personal information when: (a) there is no justification for its further retention, or (b) you have asked Us to delete it,

although an anonymised version of the data will be retained for statistical purposes.

We may release Your information to third parties and/or government authorities when we are legally compelled or obligated to do so. 

5. Children’s Personal Data

The Service, and any services available from it, are not directed to users under the age of 18. If you learn that a user under the age of 18 has provided Us with their personal information without having parental or guardian consent, please contact Us (see Section 20) immediately so We can take appropriate action.

6. User Data Rights

If you are based in the EU, under the General Data Protection Regulation you have rights connected to the provision of your personal information to Us from using the Service and We comply with the Regulation and with the Australian Privacy Principles whether or not we qualify as an AAP Entity.

7. The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how We use your information and your rights. This is why We ask you to read this Privacy Policy.

8. The right of access

You have the right to obtain access to your personal information (if We are processing it), and certain other information such as the reasons why We are processing or storing it. This allows you to check that the information is accurate and that We are using your personal information in accordance with data protection legislation and Our agreement.

9. The right to rectification

You are entitled to request that your personal information is promptly corrected if it is inaccurate or incomplete.

10. The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information under certain circumstances where there is no compelling reason for Us to keep using it. This is not a general right to erasure and there are exceptions.

11. The right to restrict processing

You have rights to ‘block’ or suppress further use of your personal information. When processing is restricted We can still store your information but may not be able to process it further. We maintain lists of people who have asked for further use of their personal information to be ‘blocked’ to make sure the restriction is respected in future.

12. The right to data portability

You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between Our IT systems and theirs safely and securely, without affecting its usability.

13. The right to object to processing

You have the right to object to certain types of personal data processing, including processing for direct marketing activities.

14. The right to lodge a complaint

You have the right to lodge a complaint about the way We have handled or processed your personal data with your national data protection regulator.

15. The right to withdraw consent

If you have given your consent to anything We do with your personal data, you have the right to vary or withdraw your consent at any time (although if you do so, it does not mean that anything We have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw your consent to Us using your personal data for marketing purposes. We usually act on validated requests and provide the requested information or activity free of charge, but by law we are allowed to charge a reasonable fee to cover Our administrative costs of providing the information for: * baseless or excessive/repeated requests, or * further copies of the same information.

Alternatively, there are reasons why We may be entitled to refuse to act on the request.

Please carefully consider your request before submitting it. We will respond as soon as reasonably practicable. Generally, this will be within one month from when We receive your validated request but, if the request is going to take longer to deal with, We will let you know. To contact Us please see section 20 below. If We do not address your request within a reasonable time or fail to provide you with a valid reason why We are unable to do so, you have the right to contact your national data protection regulator.

16. International Transfers of Personal Data

As We have described above, to be able to provide you with the Service We may transfer your personal data to partners in different countries. These countries’ privacy laws may be different from those in your home country.

Should We transfer data to a country which has not been deemed to provide adequate data protection standards We always have security measures and approved model clauses in place to protect your personal data.

If you are based in the EU, by voluntarily submitting your personal data to Us you consent to these international transfers. If you later wish to withdraw your consent, please contact the Data Controller using the details in Section 20.

17. Use of Cookies

Cookies are small text files sent by websites to your web browser which allows information to be sent back each time you access or use the site, and which may be necessary for the site to function. The information collected is unique to you or your web browser and may contain personally identifiable information as well as technical information (e.g. your device manufacturer and model, screen resolution, internet service provider, browser, and geo-location data). Session-based cookies last only while your browser is open and are automatically deleted when you close the browser. Persistent cookies last until you or your browser delete them, or until they expire. When using the Service, please note that while the App element of the Service does not use cookies, We do maintain recognition of Log In, but this is not managed by cookies. Third-party websites which we, or other users, may link to might however include cookies. These are outside of Our control and We cannot guarantee their behaviour. These sites may use both session-based and persistent cookies, depending upon the functionality in those sites.

However, when posts are shared from the App into social media, the webpages in the Service that support this feature do use cookies to anonymously gather metrics on which pages are the most popular.

Further information about cookies can be found at Interactive Advertising Bureau or Out-Law’s.

18. External Links

The Service includes relevant hyperlinks (posted by Us or App users) to external websites which are not directly controlled by Us. Whilst all reasonable care has been exercised in selecting and providing such links, you are advised to exercise caution before clicking any external links. We cannot guarantee the ongoing suitability of external links, nor do We continually verify the safety or security of the contents which may be provided to you or for any content you provide on external websites. You are advised, therefore, that your use of external links is at your own risk and We cannot be responsible for any damages or consequences caused by your use of them.

19. Changes to this Privacy Policy

We may change this Privacy Policy from time to time, and if We do so, you will be notified at your next available interaction with the Service, at which time you will be provided with the updated Privacy Policy to review and consent to before you are able to continue using the Service.

20. Contacting the Data Controller

If you have any questions about this Privacy Policy, would like to exercise any of your rights or wish to make a complaint or provide any other feedback, please write to:

XALI Level 16, 1 Market Street Sydney NSW 2000 Email: [email protected]

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