ManageXValue / Privacy Policy

This Privacy Policy was last updated on Sunday, May 21, 2023.

Thank you for joining ManageXValue. We at ManageXValue ("ManageXValue", "we", "us") respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights regarding your personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use ManageXValue websites, APIs, or related services (the "Services").

By using the Services, you agree to the terms of this Privacy Policy. You shouldn't use the Services if you don't agree with this Privacy Policy or any other agreement that governs your use of the Services.

1. What Data We Get

We collect certain data from you directly, like information you enter yourself, data about your consumption of content, and data from third-party platforms you connect with ManageXValue. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using. All data listed in this section is subject to the following processing activities: collecting, recording, structuring, storing, altering, retrieving, encrypting, pseudonymizing, erasing, combining, and transmitting.

1.1 Data You Provide to Us

We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.

When you create an account and use the Services we collect any data you provide directly, including:

Personal Data Category	Description	Legal Basis For Processing
Account Data	In order to use certain features (like accessing content), you need to create a user account, which requires us to collect and store your email address, password, and account settings. Upon account creation, we assign you a unique identifying number.	Performance of contract Legitimate interests (service provisioning, identity verification, fraud prevention and security, communication)
Profile Data	You can also choose to provide profile information like a name, organization information, country, or other data. Your Profile Data may be publicly viewable by others when you provide comments or questions related to Accelerators or our Services.	Performance of contract Legitimate interests (enhanced platform functionality, convey content source information)
Shared Content	Parts of the Services let you interact with other users or share content publicly, including Accelerators you may share with other users, comments, questions related to the Services. Such shared content may be publicly viewable by others depending on where it is posted.	Performance of contract Legitimate interests (service provisioning, enhanced platform functionality)
Usage Data	When you access content, we collect certain data including which quantification functions you use or what information you provide to analytics (e.g., to a Risk Quantification Assessment). This information is part of the Activity Log function of the Services to provide you and your team information on how your Analytics was changed over time. We also analyse this information to improve our Services.	Performance of contract Legitimate interests (service provisioning, enhanced platform functionality)
Payment Data	We use a third party payment provider for any and all purchases. We share your name and email address with the third party payment provider to set up a customer instance and enable future payments. If you make purchases, we collect certain data about your purchase (such as your name, billing address, and ZIP code) as necessary to process your order and which may optionally be saved to process future orders. You must provide certain payment and billing data directly to our payment service providers, including your name, credit card information, billing address, and ZIP code. We may also receive limited information, like the fact that you have a new card and the last four digits of that card, from payment service providers to facilitate payments. For security, ManageXValue does NOT collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.	Performance of contract Legal obligation Legitimate interests (payment facilitation, fraud prevention and security, compliance)
Data About Your Accounts on Other Services	We may obtain certain information through your social media or other online accounts if they are connected to your ManageXValue account. If you log in to ManageXValue via Google, Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, account ID number, login email address. Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us. If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.	Legitimate interests (identity verification, user experience improvement)
Communications and Support	If you contact us for demo requests, support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, messages, location, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.	Legitimate interests (customer and technical support)

The data listed above is stored by us and associated with your account.

1.2 Data We Collect through Automated Means

When you access the Services (including browsing content), we collect certain data by automated means, including:

Personal Data Category	Description	Legal Basis For Processing
System Data	Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types.	Performance of contract Legitimate interests (service provisioning, customer and technical support, fraud prevention and security, communication, product improvement)
Usage Data	Usage statistics about your interactions with the Services, including content accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services.	Legitimate interests (service provisioning, user experience improvement, product improvement)
Approximate Geographic Data	An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.	Legitimate interests (user experience improvement, fraud prevention and security, compliance)

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the "Cookies and Data Collection Tools" section below. It is stored by us and associated with your account.

2. How We Get Data About You

We use tools like cookies, web beacons, and similar tracking technologies to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.

2.1 Cookies and Data Collection Tools

We use cookies, which are small text files stored by your browser, to collect, store, and share data about your activities across websites, including on ManageXValue. They allow us to remember things about your visits to ManageXValue and to make the site easier to use. To learn more about cookies, visit https://cookiepedia.co.uk/all-about-cookies.

ManageXValue and service providers acting on our behalf (like Vercel, Stripe, Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, "Data Collection Tools") when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.

2.2 Why We Use Data Collection Tools

ManageXValue uses the following types of Data Collection Tools for the purposes described:

Strictly Necessary

These Data Collection Tools enable you to access the site, provide basic functionality (like logging in or accessing content), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are required for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.

Functional

These Data Collection Tools remember data about your browser and your preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the Services.

Performance

These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources. These tools can help us test different versions of ManageXValue to see which features, analytics, or content users prefer.

Advertising

At this stage we do NOT collect or share with third parties any information for advertising purposes.

You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional. To learn more about managing Data Collection Tools, refer to Section 6.1 (Your Choices About the Use of Your Data) below.

3. What We Use Your Data For

We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, and as required by law or necessary for safety and integrity. We retain your data for as long as it is needed to serve the purposes for which it was collected.

We use the data we collect through your use of the Services to:

Provide and administer the Services, including to support Team work activity for higher level accounts, support activities about Accelerator creation, sharing and interactions, and facilitate communication with other users (Account Data; Shared Content; Usage Data);
Process payments for subscriptions and one time analytics function purchases (User Payment Data)
Communicate with you about your account by (Account Data; Shared Content; Promotions, and Surveys; System Data; Communications and Support):
- Responding to your questions and concerns;
- Sending you administrative messages and information, including notifications about changes to our Service; and updates to our agreements;
Manage your account and account preferences and personalize your experience (Account Data, System Data, Usage Data);
Facilitate the Services' technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse (Account Data; Payment Data; Communications and Support; System Data);
Verify the identity of Team members (Account Data);
Solicit feedback from users (Account Data; Communications and Support);
Market products, services, surveys, and promotions (Account Data; Usage Data; Cookie Data);
Market Subscription Plans to prospective customers (Account Data; Cookie Data);
Learn more about you by linking your data with additional data through third-party data providers and/or analyzing the data with the help of analytics service providers (Account Data; Data About Your Accounts on Other Services; Usage Data; Cookie Data);
Identify unique users across devices (Account Data; System Data; Cookie Data);
Improve our Services and develop new products, services, and features (all data categories);
Analyze trends and traffic, track purchases, and track usage data (Account Data; Communications and Support; System Data; Usage Data; Approximate Geographic Data; Cookie Data);
As required or permitted by law (all data categories); or
As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services (all data categories).

4. Who We Share Your Data With

We share certain data about you with our third party payment provider, companies performing services for us, ManageXValue affiliates, our business partners, analytics and data enrichment providers, your social media providers. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

With Other Users:
Depending on your settings, your shared content (e.g., Accelerators) and profile data may be publicly viewable, including to other users. If you ask a question or provide comment on an Accelerator or our Services, your information (including your name) may also be publicly viewable. (Account Data; Profile Data; Shared Content)
With Service Providers, Contractors, and Agents:
We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service. (All data categories)
With ManageXValue Affiliates:
We may share your data within our corporate family of companies that are related by common ownership or control to enable or support us in providing the Services. (All data categories)
With Business Partners:
We have agreements with other websites and platforms to distribute our Services and drive traffic to ManageXValue. Depending on your location, we may share your data with these trusted partners. (Account Data; Communications and Support; System Data)
With Analytics and Data Enrichment Services:
As part of our use of third-party analytics tools like Google Analytics, we share certain contact information or de-identified data. De-identified data means data where we've removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner. (Account Data; System Data; Usage Data; Cookie Data)
For Advertising:
At this stage, we do not use your data for advertising purposes. If we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1), to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and to undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks' behavioral advertising, see Section 6.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you'll continue to be served generic ads. (System Data)
For Security and Legal Compliance:
We may disclose your data (all data categories) to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
- Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
- Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of ManageXValue, our users, employees, members of the public, or our Services;
- We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy; or
- Required or permitted by law.
During a Change in Control:
If ManageXValue undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence). (All data categories)
After Aggregation/De-identification:
We may disclose or use aggregated or de-identified data for any purpose.
With Your Permission:
With your consent, we may share data to third parties outside the scope of this Privacy Policy. (All data categories)

5. Security

We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it's important to protect your password and to contact us if you suspect any unauthorized access to your account.

ManageXValue takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and ManageXValue, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties.

To help us protect Personal Data, where you have an account with ManageXValue, we encourage you to use a strong password, protect that password from unauthorized use and not use the same log-in credentials (e.g. password) for your ManageXValue accounts as you do with other services or accounts. For analyses (e.g., Risk Quantification Assessments) shared with your team members, we also encourage you to use the built in passcode functionality and change the passcode regularly. You should not share your password with any third party. If you have reason to believe that your interaction with us or with your Team members is no longer secure (e.g. you feel that the security of your ManageXValue account has been compromised), you should change your password immediately and contact our Support Team with any concerns.

6. Your Rights

You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain third parties. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. Anyone under 18 years of age should not set up an account or use our services. However, parents who believe we've unintentionally collected personal data about their underage child should contact us for help deleting that information.

6.1 Your Choices About the Use of Your Data

You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.

To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
If you're located in the European Economic Area, you may opt out of certain Data Collection Tools by clicking the "Cookie settings" link at the bottom of any page.
The browser or device you use may allow you to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control whether location or other data is collected and shared.
To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Digital Advertising Alliance (http://www.aboutads.info/choices/), or if you're located in the European Economic Area, visit the Your Online Choices (http://www.youronlinechoices.eu/) site. If you're located in Japan, visit the Digital Advertising Consortium (https://feedback.impact-ad.jp/login). To opt out of Google's display advertising or customize Google Display Network ads, visit the Google Ads Settings page (https://www.google.com/settings/ads).
To opt out of allowing Google Analytics to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout).
Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings on that platform.

If you have any questions about your data, our use of it, or your rights, contact us at managexvalue@managexvalue.com.

6.2 Accessing, Updating, and Deleting Your Personal Data

You can access and update your personal data that ManageXValue collects and maintains as follows:

To update data you provide directly, log into your account and update your account at any time.
To terminate your account:
- In your profile, at the bottom of the page, you should see a terminate account button. After you initiate the termination, you should provide your password, for security purposes. Please note, that termination of your account will delete all your assessments and other information and cannot be recovered.
- If you have any issues terminating your account, please contact our Support Team.
- Please note: even after your account is terminated, some or all of your data may still be visible to others, including without limitation any data that has been (a) copied, stored, or disseminated by other users (including comments on content); (b) shared or disseminated by you or others (including in your shared content); or (c) posted to a third-party platform.

7. Jurisdiction-Specific Rules

If you live in California, you have certain rights related to accessing and deleting your data, as well as learning who we share your data with. If you live in Australia, you have the right to make a formal complaint with the appropriate government agency. Users outside of the United States should note that we transfer data to the US and other areas outside of the European Economic Area.

7.1 Users in California

Users who are California residents have certain rights under the California Consumer Privacy Act, ("CCPA"). If you are an eligible California user, included in these rights are:

"Right to Know"
You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
"Right to Correction"
You have the right to have inaccurate personal information about you corrected.
"Right to Deletion"
You have the right to request deletion of personal information that we have collected about you.
"Right to Non-Discrimination"
If you choose to exercise any of your rights under CCPA, ManageXValue will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
"Right to Opt-Out"
You have the right to opt out of the sale of your personal information.

CCPA has a specific definition of a "sale" and while ManageXValue does not, in the traditional sense, sell your personal information or the personal information of any of our users, we do use cookies that make non-personally identifiable information available to select third-parties. To opt out of such a "sale", please contact our Support Team.

To exercise any of these rights under CCPA, please email managexvalue@managexvalue.com or write to us at ManageXValue Attn: Privacy, 1150 NW 72ND Ave, Tower I STE 455 #6350, Miami, FL 33126. CCPA allows you to designate an authorized agent to make these requests on your behalf. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify you and/or your agent's identity before fulfilling your request.

Additionally, for more information about the personal information we collect and how we collect it, please see the sections above entitled "What Data We Get" and "How We Get Data About You."

To learn about the business and commercial purposes for which your personal information is collected and the categories of service providers who have access to your personal information, please see the sections above entitled "What We Use Your Data For" and "Who We Share Your Data With."

As a California resident, you also have the right to request certain details about what personal information we share with third parties for those third parties' direct marketing purposes. To submit your request, send an email to managexvalue@gamil.com and include your mailing address, state of residence, and email address.

Since there is no widely accepted standard for the browser-initiated Do Not Track signal, we do not currently recognize or respond to Do Not Track signals.

7.2 Users in Nevada

ManageXValue does not sell its users' personal information or personal data.

Nonetheless, Nevada residents have the right to submit a request that we do not sell your covered personal information, which you can do by emailing managexvalue@managexvalue.com or writing to us at ManageXValue Attn: Privacy, 1150 NW 72ND Ave, Tower I STE 455 #6350, Miami, FL 33126.

7.3 Users in Australia

If you are an Australian resident and you have a complaint, you may refer it to the office of the Australian Information Commissioner ("OAIC"). You can contact OAIC by visiting www.oaic.gov.au; forwarding an email to enquiries@oaic.gov.au; telephoning 1300 363 992; or writing to OAIC at GPO Box 5218, Sydney NSW 2001. You may also contact us at managexvalue@managexvalue.com or writing to as at ManageXValue Attn: Privacy, 1150 NW 72ND Ave, Tower I STE 455 #6350, Miami, FL 33126 to make a complaint about a breach of the Australian Privacy Principles which will be responded to within 30 days.

7.4 Users in the European Economic Area ("EEA") and United Kingdom ("UK")

If you are located in the EEA or UK, you have the right to request access to your data in a portable format and to request the rectification, erasure, restriction of processing, or objection to processing of your personal data. You also have the right to obtain a free copy of the Standard Contractual Clauses referenced in this section. You may use the information in Section 6.1 to submit your request. Additionally, if you are located in the EEA, UK, or Switzerland, you also have the right to lodge a complaint with your supervisory authority.

Personal data is also processed outside of the UK, Switzerland, and the EEA by our ManageXValue group companies, or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 4. We use the Controller-to-Processor Standard Contractual Clauses adopted by the European Commission to facilitate transfers of personal data from the EEA to third countries and have entered into data processing agreements with our service providers and ManageXValue group companies to restrict and regulate their processing of your data. By submitting your data or using our Services, you consent to this transfer, storage, and processing by ManageXValue and its processors.

7.5 Users Outside of the U.S.

In order to provide the Services to you, we must transfer your data to the United States and process it there. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries.

8. Updates & Contact Info

When we make a material change to this policy, we'll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they're posted. Please contact us via email or postal mail with any questions, concerns, or disputes.

8.1 Modifications to This Privacy Policy

From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you through a notification posted on the Services. Unless stated otherwise, modifications will become effective on the day they are posted.

As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.

8.2 Interpretation

Any capitalized terms not defined in this policy are defined as specified in ManageXValue's Terms of Use. Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will control.

8.3 Questions

If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact us at managexvalue@managexvalue.com. You can also send postal mail to us at ManageXValue Attn: Privacy, 1150 NW 72ND Ave, Tower I STE 455 #6350, Miami, FL 33126.