Privacy Policy & Terms of Service
Appropriate Email Practices
Every email sent using service must contain an unsubscribe link allowing the subscriber to opt-out of receiving further emails. You are required to maintain a link that is available to the subscriber for at least thirty days. You agree that you will not attempt or disable or remove the unsubscribe link from any and all emails sent. All email lists contained and sent to using service must be permission-based subscriptions. It is never acceptable or allowable to use a list that has been purchased, rented or from a third-party. It is your responsibility to monitor and maintain unsubscribe requests for your list that are outside of the functionalities of Xclusive Living. Emails sent unsolicited will receive abuse complaints that will be reflected on your account. It is your responsibility to maintain abuse results lower than the industry standard. It is at Xclusive Livings's sole discretion to determine if abuse complaints are in excess of industry standards. Xclusive Living reserves the right to terminate any account that it finds in violation of its terms of service and privacy by receiving abuse complaints higher than allowed, without refund.
Anti-Spam Policy
Xclusive Living does not authorise the harvesting, mining or collection of e-mail addresses or other information from or through the services. Xclusive Living does not permit or authorise others to use the services to collect, compile or obtain any information about customers or subscribers, including but not limited to subscriber e-mail addresses. Use of the services is also subject to the applicable privacy statement and terms of service and privacy. If Xclusive Living believes that unauthorised or improper use is being made of any service, it may, without notice, take such action as it, in its sole discretion, deems appropriate, including blocking messages from a particular internet domain, mail server or IP address. Xclusive Living may immediately terminate any account on any service which it determines, in its sole discretion, is transmitting or is otherwise connected with any e-mail that violates this policy. Unauthorised use of the services in connection with the transmission of unsolicited e- mail, including the transmission of e-mail in violation of this policy, may result in civil, criminal, or administrative penalties against the sender and those assisting the sender.
Privacy
When a client applies for the account with the company or has got it opened already, we gather personal information about the client for business purposes, in order to evaluate financial needs of the client, process his/her requests and transactions, inform the client about products and services provided by the company. Such information may include: Application Information - Information the client provides the company with in applications and other forms, such as name, contact info, e-mail address, date of birth, type of occupation, assets and income level. Transaction Information - Information about the client related to transactions with the company and affiliates as well as information about communication between the client and the company. Examples include account balances, trading activity, inquiries of the client and responses of the company. Verification information - information provided by the client to the company in order to verify identity of the client, such as passport or ID document. Examples also include background information about the client received from public records or from other entities not affiliated with the company. The anti-money laundering policy requires the company to gather the information and take necessary measures in order to verify identity of the client.
Security
Xclusive Living is responsible for taking care of clients’ privacy and personal information. Any information used in application of investment shall be fully protected and would never be released from the internal operation of the company. Investors ́ profile will be filed and stored in the data storage with consideration of investors future confirmation and conveniences. However, investors should take full care of the personal profile and important information while personal account login and other investment related actions. Once an unfamiliar occasion is noticed during operation, you may contact our customer service team immediately for directions.
Third Party Involved Confirmed
Xclusive Living does not disclose personal information of the client to third parties, except the cases described in this policy. The information may only be disclosed to non- affiliated companies providing support services to account of the client or facilitating transactions of the client with the company, including companies providing professional, legal or accounting advice. Non-affiliated companies that assist the company in providing services to the clients are required to maintain the confidentiality of such information to the extent they receive it and to use personal information of the client exclusively within the framework of providing such services and only with the purposes indicated by the company. We have the right to aggregate data about its client on an anonymous basis and disclose such information to third parties. We have the right to disclose personal information of the client to third parties in order to fulfil instructions of the client.
Regulatory Disclosure
Under certain circumstances, Xclusive Living has the right to disclose clients personal information to a third party legal authorities or law enforcement representatives for collaboration issues. However, the company shall not use personal information of the client for any other purposes unless the client describes how such information shall be used while providing it to the company or obtaining the respective permission by the company.
OPT Out
The client is not required to submit any personal information that is not required by the company. However, the shortage of applied information may possibly cause failure or inability of the company to maintain and keep up with the guaranteed quality of services to the clients. The company will take clients involvement in every investment considerably cautiously in order to assist our clients to pursuit the best profit and satisfaction.
Xclusive Living Privacy Notice
We process information and personal data relating to you and/or any Related Person of yours (Related Person(s) and you, together the hereinafter "Data Subject(s)"). In substance, we do so in connection with our existing and/or prospective business relationships, including your use of our websites (together hereinafter the "Business Relationship"). We can do so either as controller or as joint controller (hereinafter the "Controller").
In this context, we ask that you liaise with and transmit to any and all of your Related Persons this Privacy Notice, respectively the information contained therein.
We are subject to certain confidentiality and/or secrecy obligations, e.g., arising under data protection, contract, professional or banking secrecy, as the case may be. Personal data we process are also subject to said obligations.
This Privacy Notice deals with the way we process (i.e., collect, use, store, transmit or otherwise handle or process, collectively defined hereinafter as the "Processing" or "Processing Operations") personal data. This Privacy Notice does not replace, and is subject to, our applicable contractual terms and conditions.
We may conduct our Processing Operations either directly or indirectly, through other parties which process personal data on our behalf (hereinafter the "Processors"). We are responsible only for the Processing of personal data as per this Privacy Notice.