Privacy Policy

Last updated: 27 June 2021

Introduction

Cold Email Studio (“Company,” “we,” “our,” or “us”) is committed to respecting and protecting the privacy of our users. This Privacy Policy (“Policy”), describes how we collect, use, and disclose information that we obtain about visitors to our website, https://www.coldemail.studio/ (the “Site”), our platforms, and the services available through our Site, products and platforms (collectively, the “Services''). In addition to this Policy, if you are a California resident, please also read the Additional Information for California Residents section below, or if you are an EEA/UK resident, please also read the Additional Information for EEA/UK Residents section below.

For users outside the EEA/UK: Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes.

Cold Email Studio processes information, including personal information, in different situations and for different purposes. In some cases we process personal information to provide services that our business customer has requested. In those cases, we act as a processor, and process personal information solely on behalf of our business customers in connection with our provision of services to them and in accordance with written service agreements we have in place with them.

When you visit our Site and submit your personal information to us, such as through a contact submission form, or when we collect information about you during your visit to the Site, or from third party sources, such as service providers, marketing partners, data analytics providers, advertising networks and data aggregators, we will be the controller of your personal information. This means that we are responsible for deciding how we use that personal information. As described more fully below, we generally act as controller when promoting our Services to you, or collecting information about you to provide Services to our customers.

If you have any questions about this Policy or whether any of the following applies to you, please contact us at privacy@xoxo.vc or using the details provided at the end of this Policy.

The Information We Collect About You

We collect information about you directly from you, from third parties, and automatically through your use of our Services.‍

Information We Collect Directly from You. The information we collect from you depends on how you use our Services. Information we collect may include:

When you request or purchase products or services from us, we may collect your name, email address, company name, job title, phone number, and payment information.
We collect the information you provide us when you fill out a survey, questionnaire, or other type of form through the Services.
If you contact us, we collect records and copies of your correspondence, including email addresses and other contact information.
When you subscribe to receive updates from us about new features available through the Services, we collect contact information from you, such as your name, company name, job title, email address, or telephone number.
While you are navigating the Site or using the Services, we may also collect your search queries or information about your viewing history.
We collect any information you choose to email or communicate to us while using the Services.

Information We Collect Automatically. We automatically collect information about your use of our Services through cookies, web beacons, and other technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section Our Use of Cookies and Other Tracking Mechanisms below for more information.

When you use our Services, we may collect your browser type and operating system, web pages you view, links you click, your IP address, device identifier, and geolocation information. We may also collect information about the length of time you spent visiting our Site and/or using our Services, and the referring URL, or the web pages that led you to our Site.

Information We Collect from Other Entities. To provide the Services, we may collect information, including personal information, about you from third-party sources, such as business customers, service providers, marketing partners, data analytics providers, advertising networks, data brokers, data aggregators, or other third parties. Information we collect may be combined with other information we have collected about you in order to provide our Services, complete requests you have made, or facilitate transactions you have initiated via the Services.

We store the information that we receive from third parties with other information that we collect from you or receive about you. The third-party platform controls the information it collects from you. For information about how third-party platforms may use and disclose your information, including any information you make public, please look at their respective privacy policies. We have no control over how any third-party uses or discloses the personal information it collects about you.

How We Use Your Information

We use your information, including your personal information, for the following purposes:

To provide and maintain our Services. This involves collecting information about you during your visit to the Site, or from third party sources, such as service providers, marketing partners, data analytics providers, advertising networks and data aggregators, in order to provide our customers information about your professional profile and preferences, so that they can market to you more effectively and offer products and services that are more likely to interest the company you work for or represent.
To provide you with information, products, or services that you request from us.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, such as for billing and collection.
To notify you about changes to our Services, or any products or services we offer or provide though the Services.
To communicate with you about your use of our Services, to respond to inquiries and complaints, and for other customer service purposes.
To tailor the content, information, and recommendations that we may send or display to you, including customized product recommendations, to offer location customization, personalized help and instructions, and to otherwise personalize your experiences while using the Services.
To contact you via email or text messages regarding services you have requested from us.
To verify that you meet the eligibility requirements for purchasing or receiving our Services.
For marketing purposes, whether to promote our Services or those of our customers, including to provide you with special offers, promotions, news, and newsletters, and for other marketing, advertising, and promotional purposes.
To better understand how users access and use our Services, both on an aggregated and individualized basis, and for research and analytics purposes.
To administer surveys and questionnaires, such as for market research or user satisfaction purposes.
For research and analytics purposes, including analyzing data, identifying trends and issues and creating statistical reports, analyzing the accuracy and effectiveness of our Services, including administering, troubleshooting, and enhancing and improving the Services, so that we and our customers may more effectively market to you.
To comply with legal obligations, as part of our general business operations, and for other business administration purposes, such as maintaining customer records, monitoring compliance with our contracts, collecting debts owed to us, and safeguarding our business interests.
To effect commercial transactions such as acquisitions, mergers, investments or asset sales, whether as part of a bankruptcy or insolvency proceeding or otherwise.
To comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
To exercise or defend our rights in legal proceedings.
Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, and in situations involving potential threats to the safety of any person or violations of our Terms of Use or this Privacy Policy.
For any other purpose with your consent, and notably where required by law to send you direct marketing materials or to track your online behavior using cookies or other tracking mechanisms.

How We Share Your Information

We may share your information, including personal information, as follows:

Vendors, Service Providers, and Other Processors. We may disclose the information we collect from you to vendors, service providers, contractors, agents, or other processors who perform functions on our behalf. For example, we share your information with IT services providers, data storage providers, and technical support providers. We also share your information with service providers who host our Site, analyze aggregate information about our customers, assist us in detecting and deterring fraud, security incidents, or other unlawful activity, and for other business purposes as described in the How We Use Your Information section.

Subsidiaries and Affiliates. We may disclose the information we collect from you to any current or future parent company, affiliate, subsidiary, or division.

Analytics Providers/Advertisers. As set forth above, we share information with analytics providers and advertisers to assist us in implementing and evaluating relevant advertising. Often, the information that we share is collected from you through cookies and other tracking technologies on our Site. See the section Our Use of Cookies and Other Tracking Mechanisms for more information.

Others for Business Purposes. We may also share your personal information by disclosing it to a third party for a business purpose, including the business purpose of directly or indirectly enabling or effecting commercial transactions. We make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purposes except performing the contract.

We also disclose information in the following circumstances:

Business Transactions. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.

In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena. We may also disclose your information in connection with legal proceedings, such as when we are defending our rights in court.

To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.

Aggregate and De-Identified Information. We may also use and share aggregate or de-identified information about users with third parties for marketing, advertising, research, or other purposes.

Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf). For users in the EEA/UK: Please read our Cookie Policy for additional information about cookies and tracking mechanisms.

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Flash Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.

Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers may also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve the performance of our Site and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track Signals. Please note that our Site does not recognize or respond to any signal which your browser might transmit through the so-called “Do Not Track” feature your browser might have. If you wish to disable cookies on our Site, you should not rely on any “Do Not Track” feature your browser might have. For more information about do-not-track signals, please click here.

Ad Networks. We use network advertisers to serve advertisements on non-affiliated websites or other media (e.g., social networking platforms). This enables us and these network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, pixels, LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity’s specific privacy policy, not this one. We may provide these advertisers with information, including personal information, about you.

Users may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising. Please be advised that opting out of ad networks will opt you out from certain companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Additional information is available on the DAA’s websites at www.aboutads.info and https://youradchoices.com/appchoices.

Third-Party Links

Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Security of Your Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust, unique password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Access Your Personal Information

You may modify or delete personal information that you have submitted through use of the Services by contacting us via the information provided in the Contact Us section below.

Your Choices Regarding Our Use of Your Personal Information

We may send periodic promotional emails to you, with your consent where required by law. You may opt-out of promotional emails by following the opt-out instructions contained in the email. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

Notice Concerning Children

Our Services are not designed for children under thirteen (13). If we discover that a child under thirteen (13) has provided us with personal information, we will delete such information from our systems.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at:

XO Capital Outbound Services LLC, DBA Cold Email Studio
8605 Santa Monica Blvd PMB 41571
West Hollywood, CA 90069-4109

Additional Information for California Residents

In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.

Our Role as a Service Provider Under the CCPA

When we operate as a service provider under the California Consumer Privacy Act (“CCPA”), we process or maintain Personal Data on behalf of our business customers that provide personal information to us in compliance with written contracts that we enter into with our business customers directly. In accordance with the CCPA, we will only use and disclose Personal Data we receive from our business customers as necessary to provide the Services to our business customers, to retain or employ another service provider where that service provider meets the requirements of a service provider under the CCPA, for our internal use to build and improve the quality of our Services as permitted under the CCPA, to detect security incidents or protect against fraudulent or illegal activity, and for the purposes enumerated under CCPA Civil Code section 1798.145(a)(1) through (a)(4) or as otherwise required by the CCPA.

In general, when we operate as a service provider, we will handle requests on behalf of our business customers as they require under our agreement, which allows us to comply with the CCPA by acting on their behalf according to their instructions or by responding to a consumer that the request cannot be acted upon because the request has been sent to a service provider.

Categories of Personal Information Under the CCPA

In this section we describe, generally, how we have collected and disclosed personal information about consumers in our role as a business in the prior twelve (12) months.

Sources of Personal Information. As further described in the Information We Collect About You and How We Collect It section above, we may collect personal information from the following sources:

directly from the individual
advertising networks
data analytics providers
data aggregators
data brokers
social networks
internet service providers
operating systems and platforms
government entities
business customers/clients

Categories of Personal Information Collected and Disclosed. In the table below, we identify the categories of personal information (as defined by the CCPA) we have collected and disclosed for a business purpose, and/or “sold” as defined by the CCPA, as well as the categories of third parties to whom we may disclose and/or sell such personal information. For more information about the business and commercial purposes for which we may disclose and sell, as defined by the CCPA personal information, please see the How We Share Your Personal Information section above.

Sales of Personal Information to Third Parties. We may share your personal information by selling it to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. We may also make certain categories of personal information available in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Sites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. For more information about sales of personal information, please see the Categories of Personal Information Under the CCPA section below.

Your Consumer Rights Under the CCPA

Right to Request Disclosure. You have the right to request, free of charge, that we disclose information about our collection and use of your personal information over the past twelve (12) months, including:

The categories of personal information we collect about you;
What personal information we collect, use, or disclose about you;
The categories of sources of the personal information we collect about you;
Our business or commercial purpose for collecting the personal information;
For each category of personal information, the categories of third parties with whom it was disclosed; and
The specific pieces of personal information we collect about you.

For more information on how to request information about our collection, use, and disclosure of your personal information, please see the Submitting CCPA Requests section below.

Right to Request Deletion. You have the right to request the deletion of your personal information that we collected. For more information on how to request deletion, please see the Submitting CCPA Requests below. Once we receive your request and verify your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or de-identify personal information not subject to an applicable exception from our records and will direct our service providers to take similar action.

You do not need to create an account with us to exercise your deletion rights. We will only use personal information provided in a deletion request to review and comply with the request.

Right to Request Opt-Out of the Sale of Your Personal Information. If you are age 16 or older, you have the right to direct us to not sell your personal information at any time. We do not sell the personal information of consumers we actually know are less than 16 years old.

To exercise the right to opt-out, you or your authorized representative may submit an opt-out request by following the procedures specified in the Submitting CCPA Requests section below. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by contacting us via the information in the Contact Us section below.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Right of Non-Discrimination. You have the right to be free from discriminatory adverse treatment for exercising these rights. We will not discriminate against you for exercising any of your CCPA rights.

Submitting CCPA Requests

Requests to Know or Delete. To exercise your rights to know or delete described above, you may submit a request by contacting us through the Contact Us section below.

Requests to Opt-Out of Sales of Your Personal Information. To exercise your right to opt-out of sales of your personal information, you may also submit a request by emailing us at: privacy@xoxo.vc.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Verification of Requests. Only you, or an individual legally authorized to act on your behalf, may make a request to know, delete, or opt-out related to your personal information. To designate an authorized agent, please contact us by using the contact information above.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or that the requestor is your authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may request information from you in order to verify your identity. Additionally, we may require that authorized agents provide proof of their authorization. We cannot respond to your request or provide you with personal information if we are unable to verify your identity, your authority to make a request on behalf of another person, or if we cannot confirm that the personal information relates to you. In general, we will verify your request and your identity by matching the information you provided with the information we have in our records.

You do not need to create an account with us to submit a request to know, or to submit a request to delete your personal information or opt-out of sales of your personal information.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Additional Information for EEA/UK Residents

Legal Bases for Processing Your Personal information
We will only use your personal information where we have a legal justification to do so (a ‘legal basis’). The purposes of our processing of your personal information, and the corresponding legal bases, are described below:

Legal Basis: To perform a contract with you or take steps to enter into a contract with you

To provide and maintain our Services, by collecting information about you during your visit to the Site, or from third party sources, such as service providers, marketing partners, data analytics providers, advertising networks and data aggregators, in order to provide our customers information about your professional profile and preferences, so that they can market to you more effectively and offer products and services that are more likely to interest the company you work for or represent.
To provide you with information, products, or services that you request from us.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, such as for billing and collection.
If you use our Services, to notify you about changes to our Services, or any products or services we offer or provide though the Services.
To communicate with you about your use of our Services, to respond to inquiries and complaints, and for other customer service purposes.
To contact you via email or text messages regarding services you have requested from us.
To verify that you meet the eligibility requirements for purchasing or receiving our Services.

Legal Basis: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

To tailor the content, information, and recommendations that we may send or display to you, including customized product recommendations, to offer location customization, personalized help and instructions, and to otherwise personalize your experiences while using the Services. Our legitimate interest is to conduct and develop our business activities with you and others, and to improve our products and services in order to operate our business efficiently and profitably.
For marketing purposes, whether to promote our Services or those of our customers, including to provide you with special offers, promotions, news, and newsletters, and for other marketing, advertising, and promotional purposes. Our legitimate interest is to promote our business activities, to improve our revenues and profitability.
To better understand how users access and use our Services, both on an aggregated and individualized basis, and for research and analytics purposes. Our legitimate interest is to conduct and develop our Services with you and others, and to improve our products and services in order to operate our business efficiently and profitably.
To administer surveys and questionnaires, such as for market research or user satisfaction purposes. Our legitimate interest is to conduct and develop our Services with you and others, and to improve our products and services in order to operate our business efficiently and profitably.
For research and analytics purposes, including analyzing data, identifying trends and issues and creating statistical reports, analyzing the accuracy and effectiveness of our Services, including administering, troubleshooting, and enhancing and improving the Services, so that we and our customers may more effectively market to you. Our legitimate interest is to develop and promote our Services with you and others, and to improve our products and services in order to operate our business efficiently and profitably.
To comply with non-EEA or non-UK legal obligations, as part of our general business operations, and for other business administration purposes, such as maintaining customer records, monitoring compliance with our contracts, collecting debts owed to us, and safeguarding our business interests. Our legitimate interest is to conduct and develop our business efficiently and profitably.
To effect commercial transactions such as acquisitions, mergers, investments or asset sales, whether as part of a bankruptcy or insolvency proceeding or otherwise. Our legitimate interest is to operate our business efficiently and profitably.
Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, and in situations involving potential threats to the safety of any person or violations of our Terms of Use or this Privacy Policy. Our legitimate interest is to operate our business in compliance with the law and protect our reputation.
To comply with non-EEA or non-UK law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena. Our legitimate interest is to operate our business in compliance with the law and protect our reputation.
To exercise or defend our rights in legal proceedings. Our legitimate interest is to operate our business in compliance with the law and protect our stakeholders, assets and reputation

Legal Basis: To comply with an EEA or UK legal obligation

To comply with EEA or UK legal obligations, as part of our general business operations, and for other business administration purposes, such as maintaining customer records, monitoring compliance with our contracts, collecting debts owed to us, and safeguarding our business interests.
To comply with EEA or UK law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

Legal Basis: Where you provide your consent

For any other purpose with your consent, and notably where required by law to send you direct marketing materials or to track your online behavior using cookies or other tracking mechanisms.

Your Rights
Subject to the conditions set forth in applicable law, you are entitled to certain legal rights in relation to your personal information.

Access, rectification and erasure/deletion – you have the right to request access to and obtain a copy of your personal information that we hold, to request correction of any inaccurate data relating to you, and to request the deletion of your Personal information under certain circumstances.
Data portability – you have the right to request the transfer of your personal information to you or a third party you have chosen, in a structured, commonly used, machine-readable format. This right only applies to personal information processed by automated means, which you initially provided consent for us to use or where we used the information to perform a contract with you.
Restriction of processing – you may have the right to ask us to suspend our processing of your personal information in the following scenarios:

you want us to establish the accuracy of the personal information;
where the processing is unlawful, but you do not want us to erase the personal information;
you ask us to retain the personal information even if we no longer require it because you need it for the establishment, exercise or defense of legal claims; or
you have objected our use of your personal information, but we need to verify whether we have overriding legitimate grounds to use it.

Where your personal information is subject to restriction, we will only process it with your consent, for the establishment, exercise or defense of legal claims, or otherwise as may be permitted by applicable law.

Withdraw consent – you have the right to withdraw your consent to processing of your personal information where we rely on your consent as a legal basis. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Object to processing – you have the right to object to our processing of personal information, where we are relying upon legitimate interests to process your personal information, on grounds based on your particular situation.

You also have the right to object to our processing where we are processing your data for direct marketing purposes. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal information for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

If you would like to exercise one or more of these rights above, please contact us as described in the Contact Us section below.

Lodge a complaint – you have the right to lodge a complaint with the relevant EEA or UK data protection supervisory authority.

Transfers of Personal Information

As part of the Services, and during our ordinary business operations, information about you (including personal information) may be transferred to countries outside your home country, and to our headquarters, servers, databases, and service providers in the United States, as well as to service providers in Mexico, Ukraine and India. The United States [and Mexico, Ukraine and India are not considered by the European Commission to provide adequate protection to personal information. The European Commission has determined that Mexico, Ukraine and India provide adequate protection to Personal information. Transfers are made on the basis of European Commission-approved standard contractual clauses (and we will provide you a copy of those upon request sent to privacy@xoxo.vc), or where necessary to perform a contract with you or in your interest, to take pre-contractual steps at your request, or with your explicit consent.

Retention of Your Personal information

We apply a general rule of keeping personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain personal information for other periods of time, for instance where we are required or permitted to do so in accordance with legal requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required. We typically retain certain elements of your personal information for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of your dealings with us, such as pursuant to a contract so that we can raise or defend a legal claim. In some circumstances We may also retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

If You Fail to Provide Personal Information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that personal information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a product or service you have with us.

Contact Us

For all matters pertaining to our Privacy Policy in EEA and UK, or to contact our Data Protection Officer representative you may contact us at:

XO Capital Outbound Services LLC, DBA Cold Email Studio
8605 Santa Monica Blvd PMB 41571
West Hollywood, CA 90069-4109

Email: privacy@xoxo.vc