Thank you for using Xlink! We respect your concerns about privacy and appreciate your trust and confidence in us.
Here is a summary of the information contained in this privacy policy ("Privacy Policy"). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections in the Privacy Policy.
When you register for a Xlink account, we will need your mobile number and an alias. You can further refine and populate your profile with additional information. If you use certain functions available within Xlink (such as posting photos to your Moments), we will process your information to provide these functions.
We use your information to provide Xlink to you, allow you to communicate with other users, allow you to use the features available on Xlink, and to improve and support your Xlink experience. If you are a parent or guardian who has granted permission for your child to use Xlink then we retain the contact information you have provided to ensure we can validate any requests or queries you may have in relation to your child's Xlink account.
We do not share your information with third parties, except where we need to in order to provide the service (e.g., SMS, location and mapping service providers) or if we are instructed to by a court, authority or compelled by law. We use these third party services solely to process or store your information for the purposes described in this Privacy Policy . Any third party with whom we share user data is required to provide the same or equal protection of user data as stated in this Privacy Policy.
Our servers are located in Dubai. We also have support, engineering and other teams that support the provision of Xlink to you, located around the world, who will have access to your information. Rigorous internal control measures are in place to strictly limit access to your data by designated personnel.
How long we retain information for depends on the type of information – for example, log-in data is retained for up to 90 days from the date the data is collected. We do not retain your information for longer than the time period prescribed by law.
Depending on where you live, you may have special rights over your data and how we can use it. These include how you can access the data, erase the data, restrict how your data can be used, object to our use, and get a copy of your information.
If there are any significant changes to this Privacy Policy, we will update it here and notify you before the change becomes effective.
Welcome to Xlink!
When you use the Xlink mobile app, desktop app, or the websites www.Xlink.com or help.Xlink.com (together, "Xlink"), certain of your Personal Information (defined below) will be collected and processed by us.
This Privacy Policy explains the when, how and why when it comes to processing of your Personal Information in connection with Xlink, and sets out your choices and rights in relation to that Personal Information.
Any capitalised terms used in this Privacy Policy have the same meaning as the equivalent defined terms in the Xlink Terms of Service, unless they are defined otherwise in this Privacy Policy.
If you have any questions or complaints regarding this Privacy Policy or the use of your Personal Information, please contact our team via email at [email protected]. or via postal mail at 1104, Peak Performance Technology, Park Place Tower, Dubai 000000.
By using Xlink you agree to the processing of your Personal Information in accordance with this Privacy Policy. If you do not agree to the processing of your Personal Information in the way this Privacy Policy describes, please do not provide your Personal Information when requested and stop using Xlink.
"Location Data" is information that is derived from your GPS (GPS coordinates), WiFi (approximate city location), IP address (country location), or public posts that contain location information (the location you geo-tag). Location Data will be disclosed (either to us, to other users, or both:
"Log Data" is information that is automatically collected when you use Xlink, including
"Personal Information" is any information, or combination of information, that relates to you, that can be used (directly or indirectly) to identify you, which we process in connection with your use of Xlink. Please see the section entitled "How do we use your information?" below for examples.
This section provides more detail on the types of Personal Information we collect from you, purpose of processing, and retention periods for each type of Personal Information.
For users resident in a Relevant Jurisdiction, it also identifies the legal basis under which we process your data. For the purposes of this Privacy Policy, a "Relevant Jurisdiction" includes the EEA, UK, Switzerland, Brazil, Thailand, and Turkey.
We do not retain Personal Information for longer than is necessary unless we are required to do so under applicable laws. For further details on how long we keep your data, please refer to the retention periods set out below. If we are required to retain your Personal Information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of Personal Information. Aggregated registration data (which does not contain Personal Information) is retained for spam prevention and system security purposes.
| Information | Purpose of Processing | Retention Period |
|---|---|---|
Registration data and log in data. Your name, alias, Apple ID, IP address, mobile number, region, Facebook account, email address used to register a Xlink account and date of registration. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to create your Xlink profile and provide Xlink services. | - To set up your Xlink account and facilitate your log in; - to facilitate communication between users of Xlink; - to facilitate your use of features; - to enforce our terms, conditions, and policies; - to place VoIP calls using Xlink; - to communicate with you to notify you about changes to Xlink; - to provide you with personalised user support; - to develop new and improve existing services; - to provide language and location customisation; - to protect any rights, property or safety of ours, our affiliate companies, or other users of Xlink; and - to administer Xlink and for troubleshooting, data analysis, testing, research, security, fraud-detection, account management, and survey purposes. | account is deleted.Log in data is retained for a period of 3 months from the date of such log in. |
Shared Information - profile data. Any information that you include in your publicly-visible Xlink profile, which includes your Xlink ID, name, gender, region, and photo.Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide your Xlink profile and provide Xlink services. | - To allow your profile data to be shared with other Xlink users; - to allow you to use your Xlink ID to log in to or otherwise connect with third party services; - to facilitate your use of features; - to provide you with personalised user support; - to provide language and location customisation; - to develop new and improve existing services and app experience; - to maintain and administer the Xlink platform; and - for troubleshooting, data analysis, testing, research, security, fraud-detection and account management. | Until you request removal of the Shared Information or your account is deleted, whichever is earlier (however, the data may be cached on third party services and retained in accordance with their own privacy policies). |
Shared Information – profile media. This comprises all of the information you make available to other users or information about you that is made available by other Xlink users, including Moments and Status posts. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide your Xlink profile and provide Xlink services. | - To allow your profile media to be shared with other Xlink users; - to provide location customisation; - to develop new and improve existing services and app experience; - to maintain and administer the Xlink platform; and | removal of the Shared Information or your account is deleted, whichever is earlier (however, the data may be cached on third party services and retained in accordance with their own privacy policies). |
Information for additional account security (if you choose to secure your account). Password, Emergency Contacts, Managed Devices, email address, and Xlink ID. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide and secure your Xlink account. | To provide additional security for your account. | Until you request removal of the information or your account is deleted, whichever is earlier. |
Chat data. Content of communications between you and another user or group of users. We do not permanently retain chat data on our servers and it only passes through our servers so that it can be distributed to your intended recipients. Chat data is only stored on your device and the devices of the users that you have sent communications to, unless your recipient adds any of your communications to their Favorites or it is a message that the owner or administrator of your group chat added as a Group Notice.Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide the chat services of Xlink. | To provide our communication service. | Chat messages are automatically and permanently deleted from our servers within 3 hours of delivery to the recipient's device, and in any event, permanently deleted after 72 hours of you sending them. Chat media such as images, audio, videos, and files are automatically and permanently deleted from our servers after 120 hours of you sending them. |
Contacts list. Your on-device contact list.Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide Xlink and connect you with your friends. | - To connect you with other Xlink users; and - to facilitate your use of Xlink Out. | Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier. |
Log Data. See definition above. Legal Basis (Relevant Jurisdictions only): It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services. | - For troubleshooting, data analysis, testing, research, security, fraud detection, and account management. | Permanently deleted 3 months from the date of collection. |
Location Data. See definition above. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide Xlink location-based services. Please note that your use of location-based services is subject to the terms of use and privacy policies of third party service providers that power the location-based services of such services, such as Foursquare. | - To facilitate your use of location-based services such as: - sharing your real time location via chat, which relies on your GPS; - manually geo-tagging a location in a Moments or Status post; - People Nearby, which rely on your GPS; - for security, fraud detection and account management; and - to provide language and location customisation. | - Location data used for location-based services: - Location data shared via chat is permanently deleted after 72 hours from the time of your sharing. - Moments and Status: retained until you delete such post or your account is deleted, whichever is earlier. - People Nearby and Shake: permanently deleted after 1 hour from the time of you leaving the function. Location data used for all other purposes is retained for a period of 3 months from the date of collection. |
Payment card information – parental/guardian consent. In order to comply with laws protecting children, payment card information of a parent/guardian is collected to verify parental/guardian consent where a Child attempts to create a Xlink account, and the payment card information is verified via a third party payment processing service. After a verification request has been performed by the third party payment processing service, Xlink only retains the date of verification and hashed payment card number.Legal Basis (Relevant Jurisdictions only): We process this data in accordance with our obligations under applicable laws. | To verify parental/guardian consent where a Child attempts to create a Xlink account. | Until the parent/guardian or user requests removal of the payment card information and only if the user has reached the age of majority under relevant local laws. |
Customer Support Information Communications with and any information that you or other users provide to our customer support team. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide and support Xlink. | - To investigate the issue and provide customised customer support; - to develop new and improve existing services and app experience; and - for security, fraud detection, and account management. | Until your account is deleted, unless otherwise required by law. |
Access tokens. Access tokens that facilitate the linkage of your Xlink account with your third party social media accounts.Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide Xlink services. | If you connect third party social media accounts to your Xlink account, we process access tokens to facilitate your log ins and your sharing of content between these accounts. | Until you unlink your Xlink account from these third party social media accounts. |
Marketing preferences. Whether you would like to receive or be excluded from marketing (including personalised advertisements) Legal Basis (Relevant Jurisdictions only): Consent. | To ensure we deliver marketing in accordance with your preferences. | Until your account is deleted. |
Your interests, derived from your in-app behaviour. This only applies to users in jurisdictions where personalised advertisements are available within Moments. | We use this information to deliver advertisements that we think are of interest to you. | Until your account is deleted. |
We may also pseudonymise or aggregate Personal Information for analytical purposes. This helps us develop new and improve existing services, conduct fraud detection and account safety analysis, analyse usage trends, and provide third party service providers with basic statistics about how their service is being used by Xlink users.
In some jurisdictions, certain types of Personal Information, such as information about your race, religious, political or philosophical views, sexual orientation, and health, are characterised as sensitive and are subject to stricter regulation than other types of Personal Information.
Xlink does not require you to provide sensitive Personal Information to use the service. By posting or communicating any sensitive Personal Information within Xlink, you consent to such information being available within the privacy controls you have selected.
You can control which Shared Information is made public to other users of Xlink via the privacy settings in Xlink. After you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us. Please consider carefully what you post and communicate through Xlink.
If any of your Personal Information comprises Your Content (as defined in the Xlink Terms of Service), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the "Your Content" section of the Xlink Terms of Service.
We will not transfer your Personal Information to third parties except as specified below, or where you consent to such transfer.Only where necessary will we share your information with selected recipients, including:
Xlink is a global platform. Our engineering, technical, and other support teams are based in our offices around the world (including Singapore and the Netherlands), and may have incidental access to certain of your information, for example, in order to fix technical issues that you report. The Personal Information that we collect from you will be transferred to, stored at, or processed in Dubai. We may collect information about the other applications installed on your device for the purpose of improving the performance and functionality of our app. This information is used to tailor the user experience, provide personalized content, and optimize the app's features and functionality. We do not share this information with any third parties and only collect what is necessary to improve the user experience.
We are committed to maintaining the privacy and integrity of your Personal Information no matter where it is stored or accessed. We protect your Personal Information through the use of information security and access policies that limit unauthorized access to our systems, and technological protection measures such as encryption that ensure confidentiality of your Personal Information during transmission and in storage.
We do not permanently retain chat data between you and other users on our servers. Chat data only passes through our servers so that it can be securely distributed to your intended recipients. Chat data is only stored on your device and the devices of the users that you have sent communications to, unless your recipient adds any of your communications to their Favorites or it is a message that the owner or administrator of your group chat added as a Group Notice.
Although we will implement and maintain reasonable measures to protect your Personal Information, please note that as any transmission of information via the internet is never completely secure.
You may choose to stop receiving personalised advertising from us by following the opt out instructions included in the Settings section of Xlink or by contacting us at [email protected].
We may send you service-related announcements via Xlink, email, or SMS when necessary, such as when we temporarily suspend Xlink for maintenance, or security, or privacy reasons. You may not opt-out from these service-related announcements which are not promotional in nature.
Children under the age of 16 (or such applicable age of majority under relevant local laws of the user) ("Child") must not use Xlink for any purpose without first obtaining parental/guardian consent to and acknowledgment of this Privacy Policy (both for themselves and on their Child's behalf). In certain jurisdictions, you may be required to provide your date of birth; this is only processed on your device and not sent to our servers. We do not knowingly collect Personal Information from any Child without such consent and acknowledgment. Please contact our Data Protection Officer if you believe we have any Personal Information from any Child without such parental/guardian consent and acknowledgment so that we can promptly investigate and remove such Personal Information.
Please note that in order to protect your information, we will need to verify your identity before responding to any request to exercise your rights ("DSR Request").
For users in a Relevant Jurisdiction, we will respond to your DSR Request without undue delay and in any event within one month (although this may be extended by a further two months in certain circumstances, such as where the request involves substantial volumes of information or is otherwise complex).
You have the right to request access to your Personal Information we hold about you, how we use it, and who we share it with. We may not be able to provide you with certain Personal Information if providing it to you would interfere with another person's rights (e.g. where providing the Personal Information we hold about you would reveal information about another person).
You also have the right to correct that information if it is inaccurate or incomplete.
You can access and correct your Personal Information by logging into your Xlink account at any time. For example, you can delete certain Location Data via your device settings or the "Clear Location" option within Xlink.
Where we agree to correct your Personal Information, we will use reasonable steps to inform any third party to whom we have disclosed the relevant Personal Information so that they can rectify the Personal Information too.
You have a right to require us to stop processing your Personal Information other than for storage purposes in certain circumstances. However, we may process it if there are other valid legal grounds for us to do so (e.g., for the defence of legal claims or for another's protection).
Where we agree to stop processing the Personal Information, we will use reasonable steps to inform any third party to whom we have disclosed the relevant Personal Information so that they can stop processing it too.
You may request we stop processing and just store the Personal Information we hold about you where:
You have the right to receive a copy of certain of your Personal Information in a structured, commonly used and machine-readable format. This comprises any Personal Information we process on the basis of your consent (e.g., Shared Information and content saved to Favorites) or pursuant to our contract with you (e.g., profile data), as described in the section "How do we use your information?".
You also have the right to request that we transfer that Personal Information to another party. If you wish for us to transfer the Personal Information to a third party, please ensure you provide details of such party. Note that we can only make such transfers where it is technically feasible. We are not responsible for the security of the Personal Information or its processing once received by the third party.
You may object to our use of your Personal Information that we use on the basis of our legitimate interests (e.g., when we use your Personal Information to ensure account security).
We may from time to time revise this Privacy Policy. We will update the revised version here along with the "last updated" date, and notify you via Xlink or other means, as appropriate, before the change becomes effective.
We have provided translations of this Privacy Policy, but in the event of any conflict between the local language version and the English version, unless otherwise prescribed by applicable laws, the English version shall prevail.