Effective date: As of November 1, 2023 or the date the user accepts this policy (whichever comes first).

Welcome to the Xder Privacy and Cookies Policy (hereinafter, the “Policy”). All references in this policy to “Xder”, “we”, “us” or “our” refer to Xder. This Policy is intended to explain how Xder manages and provides you with control over your Personal Data. For Xder, “Personal Data” means any information that can identify you or is reasonably related to you, whether directly or indirectly. When we refer to the “processing” of Personal Data, we mean how we collect, use, share and retain this information. This policy covers these activities on all of our Platforms (“Platforms” or “Xder Platforms”).

• The Xder applications and related features (the “Xder Application” or “Application“), including https://www.xder.com (“Xder Website“) and mobile platforms and any related services (collectively the “Xder Services“),

Our commitment to privacy. As a global friends and dating platform, Xder gives you the opportunity to share information about yourself with us, with Xder service providers who help us offer our features, and with other Xder users. This includes precise details of your location, as well as information that in certain jurisdictions may be considered “sensitive” or “special category”, such as ethnicity, sexuality, or personal information. Our commitment is to provide you with the maximum possible control over the Personal Data you share through the Xder platform.

We recommend that you carefully read this Privacy and Cookies Policy, as well as our Terms and Conditions of Service. To support our ongoing commitment to transparency, in addition to regular updates to this Policy, when you use Xder services, we will occasionally display pop-up privacy notices. These notices are intended to help you understand the implications of your choices when using certain features or services within the platform. We’re here to give you the control and information you need to make informed decisions about your privacy on Xder.

If you are a resident of another country, please note that the levels of privacy protection may vary compared to your country of residence.

Required Age: The Xder Platforms are intended exclusively for persons who have reached the legal age of majority, which is generally eighteen (18) years of age or older. If you become aware that a minor has provided Personal Data on the Xder Platforms, we encourage you to contact us through the in-app reporting tool or by submitting a request outside of your Xder account.

United States Residents (as permitted by applicable laws): Please review your US state privacy rights for details on specific rights you may have under applicable US state privacy laws.

PERSONAL DATA WE COLLECT

When using the Xder Platforms, we collect Personal Data about you, most of which you provide voluntarily. We may also obtain data about your interactions, usage and experiences on our Platforms, as well as receive information from third parties.

Personal Data You Must Provide: When creating an account, you are required to provide a limited amount of Personal Data, such as an email address or phone number, along with your date of birth to verify that you are of legal age.

Personal Data You May Provide: You are free to decide what Personal Data you wish to include in your “Xder Profile”. This Personal Profile Data, known as “Profile Information”, is shared with other users of the Xder Services, i.e. the “Xder Community”. This includes options like sharing your location, photos and videos. However, please note that omitting certain data could affect the functionality of some Xder Services. You can also choose whether to provide Personal Data to provide feedback, use customer services, or participate in surveys. The types of data collected may vary depending on the survey.

Note on Sensitive Personal Data: In some jurisdictions and under certain regulations, Personal Data that may reveal a person’s racial or ethnic origin may be considered “sensitive” or “special category” Personal Data.

Notice About Location Information: We may collect your exact location (“Location”) to determine your distance from other users (“Distance Data”). Advanced users who use the Xder Services in an unauthorized manner or who change locations while you remain there may use Distance Information to determine your location and possibly your identity. You can choose to hide your distance information, but the Xder Services will still sort and display your profile based on your relative distance from other users. Even if you choose to hide this information, other people may still be able to determine your location. Additionally, you have the option to revoke this permission and disable location services on your device. On iPhone, you can do this from Settings > Privacy > Location Services > Xder, and on Android devices, from Settings > Location > Xder > Location Permissions, adjusting your browser settings.

Personal Data We Receive from Your Device When Using the Xder Platforms: In order to maintain and improve the Xder Platforms, we collect Personal Data such as user activity, hardware and software information, cookies and use other technologies, such as web beacons, software development kits (SDKs), local storage and log files.

Personal Data We Receive from Third Parties: Xder collects limited information from third parties, including obtaining Personal Data from payment processing services, website tracking and application usage information providers, authentication services (such as Google and Facebook), machine learning services and our consent management platform provider.

WHAT WE DO WITH YOUR PERSONAL DATA

The main reason we use your Personal Data is to enable Xder Functionalities, which includes the ability to use the fundamental functions of our services, provide you with technical support and ensure the security of the platform. We only process your Personal Data when necessary, following specific purposes and legal bases.

In general, we use your Personal Data for the following purposes:

1. Offer you the Services related to your Xder account.
2. Respond to your queries and provide you with technical assistance.
3. Contribute to the continuous improvement of our Platforms and guarantee the safety of users, making use of machine learning techniques and automated decision making.
4. Protect our interests as a company.
5. Allow you to enjoy various features of the Platform and the Service, including the implementation of machine learning and automated decision making;
6. Enable third-party advertising and marketing providers to use cookies and other technologies to display ads to users of the Services that are free of charge.
7. Conduct surveys and collect your opinion on a voluntary basis regarding our Platforms.
8. Respond to legal requests from law enforcement agencies, regulators and other third parties, in compliance with “Legal Obligations” (as defined below).

HOW WE SHARE YOUR PERSONAL DATA

In order to facilitate meaningful connections, Xder provides you with the ability to share information about yourself with the Xder Community and third parties in the context of our Platforms, as described in this Privacy Policy. Generally, we share your Personal Data in the following ways:

• Xder Community: The Xder Services are designed as a safe space for you to discover, interact and connect with other members of the Xder Community. In this sense, as part of the Services, Xder allows you to share your Profile Information, your location and other data with the Xder Community.
• Third Party Providers: Xder shares Personal Data with various third party providers in order to provide the to whom you may provide Personal Data directly (for example, Apple for chat backups and Stripe for payment processing).
• Business Transactions: In the event that another company acquires, or plans to acquire, our company, business or assets, such company will assume ownership of the Personal Data that we have collected and accept the rights and obligations related to that Personal Data, of in accordance with what is described in this Policy.
• Legal Obligations: We reserve the right to access, retain and disclose Personal Data in situations involving: (i) compliance with the Xder Terms and Conditions of Service; (ii) allegations related to content or conduct that may violate our policies or the rights of third parties; (iii) customer service requests; (iv) technical problems; (v) the protection of the rights, Property or personal safety of Xder, its users or the public; (vi) valid legal requests, including subpoenas, court orders or injunctions, or in connection with any legal process; (vii) establishing or exercising our legal rights or defending against legal claims; (viii) tax and accounting implications; or (ix) any other cause required by law, collectively known as “Legal Obligations”.

HOW LONG WE KEEP YOUR PERSONAL DATA

We retain your Personal Data for as long as strictly necessary to fulfill the purposes for which it was collected, as permitted by Legal Obligations, the Xder Terms and Conditions of Service, or the Xder Community Standards. Additionally, we retain a device identifier (IDFV and Android ID) and limited log data for a period of up to two years after account deletion, for the purpose of supporting internal reporting, analysis and statistics. In situations where there is a legal or security requirement, Personal Data may be retained for longer periods. For example, Xder may retain certain account information, a device identifier (VID and Android ID), and limited registration data for accounts that have been banned or that violate Xder’s Terms and Conditions of Service or Xder Community. In some circumstances, Xder may also retain chat messages used to report violating behavior that results in an account being banned.

Local and Server Storage: Xder is implementing chat message storage on its servers to support the use of the Xder Services, including enhanced security features and an optimized user experience across multiple platforms and devices. This transition involves longer data retention, in accordance with our data retention policy. However, it is important to note that chat messages, including images and recordings, may continue to be stored locally on users’ devices and may persist on the recipient’s device, even after this information is no longer available on the Xder servers.

YOUR OPTIONS AND RIGHTS

HOW WE PROTECT YOUR PERSONAL DATA

At Xder, the security and privacy of your Personal Data is of utmost importance to us. We maintain a rigorous focus on the integrity, confidentiality and availability of your data, including information of a sensitive nature. Our cybersecurity team works continuously to strengthen our defenses and protect your Personal Data and any sensitive information.

While we use our best efforts to provide robust security and privacy features, it is important to note that no method of data transmission over the Internet or electronic storage is completely foolproof. Therefore, although we implement robust measures, we cannot guarantee the absolute security of your Personal Data. Our security measures and privacy policies are provided “as is.” Consequently, we cannot ensure error-free effectiveness or absolute confidentiality and anonymity. We advise that if you have particular concerns about the protection of your data, you consider not using our Properties.

In the unlikely event that we are required by law to inform you of unauthorized access to your Personal Data, we will notify you in accordance with applicable legal provisions, either by electronic means or by written communication. Your security and privacy are fundamental to us, and we are committed to continuing to improve our practices to safeguard your Personal Data.

HOW TO CONTACT US OR FILE COMPLAINTS

CHANGES IN POLICY