Privacy Policy

XAIRO Privacy Policy

Effective Date: August 21, 2018

Our commitment is to put users first. We strive to be transparent about how we collect and use information from our users, to keep the information we collect secure, and to provide users meaningful choices. Since our founding in 2018, XAIRO has intentionally avoided collecting data that identifies specific individuals (such as name, email address, physical address, GPS or phone number) to the extent possible. XAIRO has appointed a Data Protection Officer to ensure XAIRO maintains safe and consistent practices regarding your data and privacy.

Our Privacy Pledge

Our commitment is to put users first. We strive to be transparent about how we collect and use information from our users, to keep the information we collect secure, and to provide users meaningful choices. Since our founding in 2018, XAIRO has intentionally avoided collecting data that identifies specific individuals (such as name, email address, physical address, GPS or phone number) to the extent possible. XAIRO has appointed a Data Protection Officer to ensure XAIRO maintains safe and consistent practices regarding your data and privacy.

Collection of Information

We collect the following types of information when you interact with our Services:

Device Identifiers. When you interact with our Services, we do not require you to provide information that identifies you personally. Instead, we collect and identify your device primarily using your mobile device advertising identifier, e.g. Apple’s iOS Identifier for Advertising (IDFA) or Google’s Android Advertising ID, as well as other identifiers.

User Names. If you would like to participate in our leaderboards, keep track of your game progress or play our multiplayer games, we may ask you to provide a username. To help protect your privacy, please do not choose a username which could be used to personally identify you, e.g. “JimSmith” or “Jsmith”.

Other Information You Provide to Us. We collect the information that you provide to us, for example when you communicate with others or post, upload or store content, contact our Technical Support team, or provide billing information.

Log Information. We automatically collect information about your use of our Services and your device, including your IP Address, device model, browser version, operating system type, operating system version, mobile network information, device settings, and software data.

Location Information. We derive information about your general location (city, country) from your IP Address. XAIRO does not collect precise location data, such as GPS coordinates, that could be used to pinpoint your physical location.

Information from Cookies and Other Technologies. We collect information using web beacons, cookies, and similar technologies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, count visits, and understand how users interact with ads. Web beacons are electronic images that may be used in our Services and help deliver cookies, count visits, and understand usage and campaign effectiveness.

Information from Others. We collect information about you when we receive it from other users, third parties, and affiliates. For example, when you connect your account to third-party services or sign in using a third-party partner (like Google Play Game Services, iOS Game Center or Facebook), we collect information in accordance with the privacy policies and authorization procedures determined by those services.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by XAIRO and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through apps used for interest-based advertising purposes.

Use of Information

We collect the following types of information when you interact with our Services:

Personalize the Services and provide advertisements, content, or features that are targeted toward your interests;

Save and associate your activity across our Services and your different devices as well as associate any accounts you may use across XAIRO Services together. We may associate activity and accounts under a single user ID;

Carry out or support promotions;

Create analytics and reports for external parties, including partners, publishers, advertisers, apps, third-parties and the public regarding the use of and trends within our Services and ads, including showing trends to partners regarding general preferences, the effectiveness of ads and information on user experiences;

Sharing of Information

We share the information we collect within the XAIRO family of brands. We do NOT sell, license or share information that individually identifies our users with companies, organizations or individuals outside of XAIRO unless one of the following circumstances applies:

With Affiliated Brands. XAIRO shares information within its affiliated brands.

With Your Consent. We will share information with companies, organizations or individuals outside of XAIRO when we have your consent to do so.

With Service Providers. We provide user information to trusted partners who work on our behalf based on our instructions and in compliance with appropriate confidentiality measures.

For Legal and Other Purposes.We may access, preserve, and disclose information to investigate, prevent, or take action in connection with: (i) legal process and legal requests; (ii) enforcement of our Terms of Service; (iii) claims that any content violates the rights of third parties; (iv) protecting the rights, property or personal safety of XAIRO, its users, or the public; (v) establishing or exercising our legal rights or defending against legal claims; or (vi) as otherwise required by law.

New Ownership. If the ownership or control of all or part of XAIRO or specific Services changes as a result of a merger, acquisition or sale of assets, we may transfer your information to the new owner.

Your Choices

Accounts. In most cases, you can easily delete your data at any time by deleting the app and/or resetting your Advertiser ID. We can no longer associate any stored data with you. If you have linked a social account (e.g. FaceBook or GameCenter), then you can unlink the app with those social providers to disassociate yourself with any stored data. If you do this, your unique username and game play may no longer be retrievable. If you have any further questions regarding remove of data, please contact support@todo.help.

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies; however, the Services may not function properly if you do so.

Notifications. You have the ability to turn application notifications on and off by adjusting the settings of your mobile device. If you wish to allow or discontinue receiving Push Notifications or Local Notification, please consult the settings on your mobile device.

Information Security

XAIRO has adopted commercially reasonable technical, administrative and physical safeguards in place to help protect against unauthorized access, use or disclosure of customer information we collect or store.

Data Retention

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.

Data Transfers

XAIRO is based in the Republic of Moldova and we process and store information in the RM. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.

Contact Information

If you have questions, suggestions, or wish to make a complaint, please contact us at:

XAIRO, LLC
176 Munchesti, Suite 90
Chisinau, MD 2002
Republic of Moldova
support@todo.help