Privacy policy XPBLY

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Privacy Policy

Controller

The controller responsible for data processing on this website is:

XPBLY LLC FZ
United Arab Emirates (UAE)
E-mail: ximena@xpbly.com

General Information on Data Processing

We process personal data of users only insofar as this is necessary to provide a functional website, our content, and our services. The processing of personal data generally takes place only with the user’s consent or where processing is permitted by applicable law.

We have adopted this Privacy Policy to explain how we process the information collected by XPBLY and the reasons why certain personal data may need to be collected. By using this website, you acknowledge that you have read this Privacy Policy.

We take the protection of your personal data seriously and are committed to ensuring its confidentiality and security.

Legal Bases for Processing

Where we obtain the consent of the data subject for processing personal data, the legal basis is Article 6(1)(a) GDPR.

Where processing of personal data is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract, the legal basis is Article 6(1)(b) GDPR.

Where processing is necessary for compliance with a legal obligation to which we are subject, the legal basis is Article 6(1)(c) GDPR.

Where processing is necessary for the purposes of legitimate interests pursued by our company or by a third party, and such interests are not overridden by the interests or fundamental rights and freedoms of the data subject, the legal basis is Article 6(1)(f) GDPR.

Data Processing When Visiting the Website

When you visit our website, we automatically collect certain information about your device and your interaction with the website. This may include:

browser type and version
operating system
internet service provider
IP address
date and time of access
time zone
referring website or search terms
websites or pages viewed on our site
interaction with the website
installed cookies on your device

This data is stored in the log files of our system. This data is not stored together with other personal data of the user in a way that directly identifies the individual.

The legal basis for the temporary storage of such data and log files is Article 6(1)(f) GDPR.

Personal Information We Collect

In addition to automatically collected information, we may collect personal data that you voluntarily provide to us, including but not limited to:

first name
last name
e-mail address
telephone number
city of residence
organization or company name
address
payment information
any other information you submit through forms, registrations, newsletter subscriptions, or direct communication

We collect such data only to the extent necessary to fulfill the relevant purpose, including the performance of a contract, responding to inquiries, or providing requested services.

Purpose of Data Processing

We process your personal data for the following purposes:

to provide and maintain the website
to ensure the technical functionality and security of the website
to identify potential misuse or abuse
to generate statistical information regarding website usage
to respond to inquiries and communicate with you
to provide newsletters or other requested information
to perform contractual obligations or pre-contractual measures
to comply with legal obligations
to protect our legitimate business interests
to analyze website performance and user behavior
to measure the effectiveness of advertising campaigns
to improve our website, services, and marketing activities

Our priority is data minimization. We process only such personal data as is necessary for the respective purpose.

Contact

If you contact us by e-mail or through any contact form available on the website, the personal data transmitted by you will be stored and processed for the purpose of handling your request.

The legal basis for processing the data is Article 6(1)(a) GDPR where consent has been given, Article 6(1)(b) GDPR where your request is related to a contract or pre-contractual measures, or Article 6(1)(f) GDPR where processing is based on our legitimate interest in responding to inquiries.

Cookies and Similar Technologies

Our website uses cookies and similar technologies. Cookies are text files that are stored in the internet browser or by the internet browser on the user’s device.

We use cookies to make our website more user-friendly and to enable certain website functions. Some elements of our website require that the browser can be identified even after a page change.

The legal basis for the processing of personal data using technically necessary cookies is Article 6(1)(f) GDPR.

The legal basis for the processing of personal data using analytics, marketing, or other non-essential cookies is your consent pursuant to Article 6(1)(a) GDPR.

Consent Management

We may use a consent management tool to manage your consent preferences regarding cookies and similar technologies.

The legal basis for the processing of personal data in connection with consent management is Article 6(1)(c) GDPR, insofar as such processing is necessary to comply with legal obligations relating to the documentation and management of consent.

Google Tag Manager

We use Google Tag Manager, a tag management system provided by Google Ireland Limited. Google Tag Manager itself does not store personal data or set cookies for its own purposes. It serves only to manage and trigger other tags that may collect data.

Google Analytics 4 (GA4)

We use Google Analytics 4, a web analytics service provided by Google Ireland Limited.

Google Analytics 4 helps us analyze how users interact with our website. In this context, information such as pages visited, time spent on the website, interactions, technical device information, approximate location, and IP-related data may be processed in order to evaluate website usage and compile reports.

Google Analytics 4 is used only on the basis of your consent pursuant to Article 6(1)(a) GDPR, where required.

Google Ads and Conversion Tracking

We use the online advertising program Google Ads and, in this context, Google Conversion Tracking, provided by Google Ireland Limited.

If you reach our website through a Google advertisement, Google may place a cookie on your device. This allows us to determine whether users have performed certain actions on our website after clicking on an advertisement.

The legal basis for the use of Google Ads and Conversion Tracking is your consent pursuant to Article 6(1)(a) GDPR.

Google Consent Mode

We use Google Consent Mode to adjust the behavior of Google services depending on the consent choices you have made.

If you do not consent to certain cookies, Google services may still receive limited, aggregated, and non-personal signals to support measurement and improve functionality in a privacy-oriented manner.

Where personal data is processed in this context, the legal basis is your consent pursuant to Article 6(1)(a) GDPR, where required.

Meta Pixel and Meta Advertising

Within our online offering, we use the Meta Pixel and related marketing technologies of Meta Platforms Ireland Limited for Facebook and Instagram advertising purposes.

This allows us to measure the effectiveness of our advertising campaigns, understand user behavior after interactions with ads, and create target groups for future advertising measures.

The legal basis for the use of the Meta Pixel and related Meta marketing tools is your consent pursuant to Article 6(1)(a) GDPR.

WhatsApp Communication

If you contact us via WhatsApp, we process your telephone number and the content of the messages you send us in order to respond to your inquiry and, where applicable, to initiate or perform contractual relationships.

Please note that WhatsApp may process communication metadata independently. WhatsApp is a service of WhatsApp Ireland Limited.

The legal basis for such processing is Article 6(1)(b) GDPR where the communication is related to contractual or pre-contractual matters, or Article 6(1)(f) GDPR based on our legitimate interest in providing fast and efficient communication channels.

WhatsApp Button

Our website may include a WhatsApp button or Click-to-Chat function. If you click this button, you will be redirected to WhatsApp or WhatsApp Web. In this context, personal data such as your IP address or other technical connection data may be transmitted to WhatsApp.

The use of this function is based on your consent pursuant to Article 6(1)(a) GDPR or, where applicable, on our legitimate interest pursuant to Article 6(1)(f) GDPR in offering an easy and direct communication option.

Newsletter and Forms

If you subscribe to our newsletter or submit information via forms on the website, we process the data you provide in order to deliver the requested information or service.

The legal basis for such processing is generally your consent pursuant to Article 6(1)(a) GDPR, or Article 6(1)(b) GDPR where the request is contract-related.

You may choose not to provide personal data, but in that case you may not be able to use certain website features.

Links to Other Websites

Our website may contain links to websites that are not owned or controlled by us. We are not responsible for the privacy practices of such other websites or third parties.

We encourage you to review the privacy statements of every website that may collect personal information when you leave our website.

Recipients and Categories of Recipients

Within our company, access to your personal data is granted only to those persons who need such access for the performance of contractual, legal, or operational obligations.

We may also use external service providers and processors for these purposes, such as:

hosting providers
IT service providers
newsletter or communication providers
payment service providers
analytics and marketing providers
Google Ireland Limited
Meta Platforms Ireland Limited
WhatsApp Ireland Limited

Such service providers process data only in accordance with applicable data protection laws and, where applicable, our instructions.

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Union or the European Economic Area, including the United Arab Emirates, Canada, and the United States.

This may also occur when using services provided by Google, Meta, or WhatsApp.

If you are a European resident, such transfers may take place for the performance of a contract, for pre-contractual measures, based on your explicit consent, or where otherwise permitted by applicable law.

Where required, data transfers are based on appropriate safeguards or on the exceptions provided by Article 49 GDPR.

Please note that countries outside the EU or EEA may not provide the same level of data protection as within the EU.

Storage Period

We process and store your personal data only for as long as necessary to fulfill the purposes for which it was collected, including the performance of contractual and legal obligations.

If the data is no longer required for these purposes, it will generally be deleted unless further storage is necessary due to statutory retention obligations or other lawful grounds.

Your Rights

If you are a resident of the European Union or otherwise protected by applicable data protection law, you may have the following rights regarding your personal data:

the right to be informed
the right of access
the right to rectification
the right to erasure
the right to restrict processing
the right to data portability
the right to object
rights related to automated decision-making and profiling
the right to withdraw consent at any time with effect for the future
the right to lodge a complaint with a competent supervisory authority

To exercise any of these rights, please contact us at: ximena@xpbly.com

Obligation to Provide Data

As part of our business relationship, you may need to provide those personal data that are necessary for entering into and performing a contract, or that we are legally required to collect.

Without such data, we may not be able to conclude or perform a contract, provide requested services, or respond adequately to your inquiry.

No Automated Decision-Making

As a rule, we do not use fully automated decision-making within the meaning of Article 22 GDPR.

Profiling does not take place unless expressly stated otherwise in a specific context.

Information Security

We protect the information you provide by using appropriate technical and organizational measures to safeguard it against accidental or intentional manipulation, loss, destruction, or unauthorized access.

Our servers and systems are maintained in a controlled and secure environment. We use reasonable administrative, technical, and physical safeguards to protect personal data.

However, no transmission of data over the Internet or wireless network can be guaranteed to be completely secure.

Legal Disclosure

We may disclose any information we collect, use, or receive if required or permitted by law, for example:

to comply with a subpoena or similar legal process
to comply with legal obligations
to protect our rights
to protect your safety or the safety of others
to investigate fraud
to respond to a government request

Changes to This Privacy Policy

We reserve the right to amend this Privacy Policy at any time so that it always complies with current legal requirements or reflects changes to our services.

The version of the Privacy Policy published on the website at the time of your visit shall apply.