Marketing66 Limited (“the Company” or “Marketing66” or “we”) is the owner of the website www.marketstip.co (“the
Website”) and the Markets Tip mobile application (“the App”; collectively and separately known as “the
Service”). Marketing66 is committed to protecting your privacy and we understand you want to keep your
information private, safe and discrete. This Privacy Policy is designed to help you decide whether to use the
Service and in what manner, and it describes how we collect, store and use information on individuals who use
the Service. The Services hereunder are offered by Marketing66 Limited, registered at: Marketing66Ltd., Bezalel
Bazrawi 24, Jerusalem ISRAEL
Consent to use Information
This Policy is a legally binding agreement between you (“you” or “user”) and us. By visiting, accessing or
using the Website or App, or providing information to us in any other format, you agree to and accept the terms
of this Privacy Policy, as amended from time to time, and you consent to the collection and use of information
in the manner set out in this Policy. We encourage you to review this Policy carefully and to periodically refer
to it so that you understand it and its subsequent changes if any. IF YOU DO NOT AGREE TO THE TERMS OF THIS
PRIVACY POLICY, PLEASE STOP USING THE SERVICE IMMEDIATELY AND WHERE RELEVANT UNINSTALL. The definitions in
the Terms and Conditions apply to this Privacy Policy unless stated otherwise. IN ADDITION TO THIS POLICY,
PLEASE REVIEW OUR TERMS AND CONDITIONS AND COOKIE POLICY WHICH ARE INCORPORATED HEREIN BY REFERENCE, TOGETHER
WITH SUCH OTHER POLICIES OF WHICH YOU MAY BE NOTIFIED OF BY US FROM TIME TO TIME. What Information Do We
Collect? We collect two types of data and information from you:
(1) Non-Personal Information – We retain some non-personally identifiable information (“Non-Personal
Information”), such as your approximate geo-location, your web request, browser type, browser language, web
pages you visit before or after visiting our Website or using the App, URLs, platform type, click numbers,
landing pages, viewed pages and the order of those pages and time spent on pages. This information is collected
and retained for security reasons and so that we can audit and statistically track usage, audit our affiliates,
and calculate payments to third parties. “Cookies” - Non-Personal Information is collected, inter alia,
through the use of cookies, so when accessing or using the Website, we may use one or more cookies. Cookies are
small text files, placed on a user's device, which enable a website to remember user preferences. Detailed
information about cookies and how we use them on the Website and other websites implementing our web tools may
be found in our Cookie Policy, which also describes how you can turn off cookies or control them. Web
Beacons - We also use a software technology called “clear gifs” (also known as Web Beacons). Web Beacons are
small pieces of code placed on a website to monitor the behavior and collect data about the visitors viewing a
web page. For example, web beacons can be used to count the users who visit a web page or to deliver a “cookie”
to the browser of a visitor viewing that page.
(2) Personal Information - “Personal Information” is information that may be of a private or sensitive
nature, including your name, gender, phone number, e-mail address or mailing address, payment information and IP
address. We collect your IP address as part of your use of the Service. We also collect the following Personal
Information from you when you create an account (“Account”) on the Website which is required to access certain
parts of the Service: your full name, email address, password, and phone number.
You are not required to provide us with this information in order to use the service. If you choose to
provide us with this information, we will retain it in our records and process it only in accordance with the
provisions of this Privacy Policy. Please refer to the Who Else Receives this Information? section of this
Privacy Policy to learn about sharing of Personal Information. As an alternative, you are also able to
create an Account using your credentials with a designated third party website or service such as Facebook,
Google+ or Twitter (“Third Party Account”). Doing so will enable you to login to your Account via your Third
Party Account. If you choose this option, a Third Party Account pop-up box will appear at the time of creating
your Account which you will need to approve in order to proceed with the Account opening, and which will
describe the types of information that we will obtain from and the types of activities that we may perform in
connection with your Third Party Account. Such information may include (but not be limited to) your Personal
Information stored on this Third Party Account, such as your user name, email address, profile picture, gender,
date of birth and any other information which you have chosen to make profile on such Third Party Account.
Please note that once your Account has been opened, the Personal Information we have access to via a Third Party
Account is also dependent on your individual privacy settings in such Third Party Account and any privacy
policies which are maintained by the providers of such Third Party Accounts. We treat any Non-Personal
Information which is specifically connected or linked to any Personal Information as Personal Information. We
collect and process the Personal Information referred to above based, where applicable, on your consent, where
the processing is necessary for the performance of a contract between you and the Company or where the
processing is necessary for the purpose of fulfilling a legitimate interest pursued by us. What is the
Purpose of Collecting this Information? In order to access our services, users may be asked to fill in a
form, providing some personal information to the Company. Answers to questions on Personal Information are not
mandatory unless the fields are marked with an asterisk. Provision of the information requested in the optional
fields of the registration form is not mandatory in order to receive the services and information that we
provide through the Site (unless otherwise indicated in the registration form). However, failure to complete
mandatory fields or providing incorrect Personal Information may prevent us from fully providing the requested
information or services. Please note that you are under no legal obligation to provide us with your Personal
Information, however you may not be able to enjoy our services or access the Site if you fail to do so. The
collection and processing of Personal Information is aimed at providing you with the Service (including setting
up your account), to send you marketing offers on products or services we think may be relevant to you, and to
fulfill other purposes as provided in this privacy policy. Non-Personal Information is collected for
research and statistical purposes, to enable us to develop, customize and improve the Service, based on your
preferences, usage and interactions with the Service, to process your requests for information, and to provide
you with the most relevant services and offers. We use cookies in conjunction with third parties to collect
user information. Your Personal Information is collected to enable us to provide you with features,
capabilities, offers and marketing materials we or our marketing partners think you may be interested in. In
addition to the above, your Personal Information allows us to provide you with technical assistance and
support.
Who Else Receives this Information? We may share or transfer information, including Personal
Information, internally within our group of companies, for the purposes outlined above. These companies may be
located in countries that may provide a different level of protection of privacy than in your jurisdiction. We
also share Personal and Non-Personal Information with trusted third parties, when this is required in order to
provide, maintain or improve our services and operation. This is the case with third party advertisements and
affiliates; we share your information with third parties for the purpose of providing you with advertisements
and offers we or third parties think you may be interested in. These third parties may be located in countries
that may provide a different level of protection of privacy than in your jurisdiction. We share your
Personal and Non-Personal Information with (i) third parties which provide services to the Company in order to
allow or enable us to provide you with our Service, including analytics, email services providers and data
verifiers; (ii) third parties who provide the Company services in relation to the operation of the Website;
(iii) any auditors, contractors or other advisers auditing any of the Company’s business processes; and (iv) any
potential purchasers or investors in the Company. If you choose to open a member card, other users of the
Website may be able to view the following personal information about you (to the extent that you have provided
it to us): your name, picture and general geographic location (country). If you have chosen to share
Personal Information with us through one of our forms, we may share it with any or all of our third party
providers, which may provide you with a loan offer. Please note that this third party may be considered a
“controller” of your Personal Information and the processing of such Personal Information will be subject to
such provider's privacy policy. Any processing performed by any of our third party service providers
(“Recipients”) will, where required by law, be governed by a data processing agreement in the form required by
law, preserving any and all of your statutory data protection rights and obligating the Recipients to respect
the Personal Information and handle it in accordance with the relevant laws. If a Recipient is located outside
the EEA, we will transfer your data only to such countries as approved by the European Commission as providing
adequate level of data protection, or ensure that the legal agreements governing the data transfer provide an
adequate level of data protection. The Recipients are required to maintain the confidentiality of such
information and to use your Personal Information only in the course of providing the aforementioned services and
only for the purposes that Marketing66 dictates. We may also share your Personal Information and other
information in special cases if we have a good reason to believe that it is necessary to: (i) comply with law,
regulation, subpoena, request by an applicable authority or court order; (ii) detect, prevent or otherwise
address fraud, security, violation of our policies or technical issues; (iii) enforce the provisions of this
Privacy Policy or any other agreements between you and Marketing66, including investigation of potential
violations thereof; or (iv) protect against harm to the rights, property or safety of the Company, its partners,
its affiliates, users or the public.
Advertisements We may use a third-party advertising technology to serve advertisements when you
access the Site. This technology uses your information with regards to your use of the Services to serve
advertisements to you (e.g., by placing third-party cookies on your web browser).
Direct Marketing
We may share your full name, email address and phone number with certain broker(s) (the “Broker”) in the
event that you have granted permission to receive promotional materials from such Broker at the time of
registration. The Broker may periodically use your full name, email address and phone number for the purpose of
providing you with promotional materials if your permission was granted at the time of registration and you have
not unsubscribed at a later time in accordance with the provisions hereof. At any time, you may request to
discontinue receiving these offers or xosignals.com's marketing emails by clicking on the unsubscribe link
in the email's footer or by following the on-page instructions at https://www.xosignals.com/unsubscribe . If
you unsubscribe we will remove your full name, email address and phone number from our marketing distribution
lists and from any future lists we may share with the Broker. However, you may need to also separately
unsubscribe from marketing offers sent by the Broker. Please note that in order to send you promotional
materials, the Broker may assign you with a username and password which will allow you access to the
Broker's site through an account. You may contact the Broker at any time to remove the account.
User Rights and Retention You have the right to access, correct, update or object to the use of your
Personal Information by making a written request to Marketing66 by using our Contact Us page. Your requests will
be dealt with in a prompt and professional manner and in accordance with applicable law.
For EU users:
Legal basis for processing Processing of Personal Information is necessary for the performance of our
contractual obligations towards you and providing you with our services, to protect our legitimate interests and
to comply with our legal obligations. Where we rely on your consent to process your Personal Information,
you have the right to withdraw or decline consent at any time – However, if we have shared your Personal Data
based on your consent, you would need to address the entity with whom your data was shared to withdraw your
consent. Where we rely on our legitimate interests to process your Personal Information, you have the right to
object. If you have any questions about or need further information concerning the legal basis on which we
collect and use your Personal Information, please contact us through the contact details available below.
Since we operate globally, it may be necessary to transfer data, including Personal Information, to
countries outside the European Union. In these instances, we will transfer your data only to such countries as
approved by the European Commission as providing adequate level of data protection or enter into legal
agreements ensuring an adequate level of data protection.
Please note that the following rights specifically apply regarding your personal information: (1) Receive
confirmation as to whether or not personal information concerning you is being processed, and access your stored
personal information, together with supplementary information; (2) Receive a copy of personal information you
directly volunteer to us in a structured, commonly used and machine-readable format; (3) Request rectification
of your personal information that is in our control; (4) Request erasure of your personal information; (5)
Object to the processing of personal information by us; (6) Request to restrict processing of your personal
information by us; (7) Lodge a complaint with a supervisory authority.
If you wish to exercise any of the abovementioned rights or raise a complaint on how we have handled your
Personal Information, please contact us directly at: contact@marketing66.com.
Last Revised: August 9, 2021
Introduction This notice (“Privacy Notice”) addresses the specific disclosure requirements under the
California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100–1798.199) and the California Consumer
Privacy Act Regulation by the Attorney General (collectively, “CCPA”). Any terms defined in the CCPA have the
same meaning when used in this Privacy Notice. Marketing66 Limited (“we”, “us”, “our” or the “Company”)
provides disclosures for the 12 months preceding the date the Privacy Notice was last revised, as required by
the CCPA vis-à-vis California residents. This Privacy Notice outlines our practices with respect to the
information we collect from you when you use the investing website (www.xosignals.com) and mobile app
(“Service”), the manners in which we use such information and the choices available for you. By accessing,
downloading or using our Service, you acknowledge that you have read and understood the terms of this Privacy
Notice. If you disagree to any term provided herein, please do not install or use the Service. In addition
to this policy, please also review our Privacy Policy(should be clickable) and Terms and Conditions(SHould be
clickable), which this Privacy Notice is incorporated thereto by reference, along with such other policies of
which you may be notified of by us from time to time. In our Privacy Notice, you will learn about: What
Information We Process Sources of Personal Information Business/Commercial Purpose for Collection Sharing
Personal Information Selling Personal Information User Rights Under the CCPA Non
Discrimination Do Not Track Signals Record Keeping Children's Information Updates or
Amendments to the Privacy Notice How to Contact Us If you have a visual disability, you may be able to
use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Privacy
Notice.
What Information We Process? We may collect and process certain information that identifies an
individual or may with reasonable effort identify an individual (“Personal Information”). We treat information
that is specifically connected or linked to any Personal Information – as long as such connection or linkage
exists – as Personal Information. We may also disclose Personal Information we have collected with our
service providers for a business purpose (as further detailed in “Business/Commercial Purpose for Collection”
section below), subject to a contract that describes the purpose and restricts the use of Personal Information
disclosed, or with other third parties for a commercial purpose, which may be considered a sale under the CCPA,
as detailed in the following chart: In the 12 preceding months, we have collected, disclosed and/or sold
the following categories of Personal Information:
Category of Personal Information Collected Personal Information Collected Categories of service
providers to whom Personal Information was disclosed Categories of third parties to whom Personal
Information was sold Identifiers Full name, email address, physical address, IP, social media
credentials and identifiers Affiliate Companies Ad networks Data analytics providers Email
and cloud providers Auditors and advisors Other users Ad networks Data analytics
providers
Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code §
1798.80(e)) Telephone number Affiliate Companies Email and cloud providers Auditors and
advisors
Internet or Other Electronic Network Activity Information Browsing history, search history,
information on a consumer’s interaction with a website, application, or advertisement. Affiliate
Companies Ad networks Data analytics providers Email and cloud providers Auditors and
advisors Ad networks Data analytics providers
Geolocation Data Approximate geolocation Affiliate Companies Ad networks Data
analytics providers Email and cloud providers Auditors and advisors Ad networks Data
analytics providers
We may share or transfer Personal Information to third parties as assets that are part of a merger,
acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of the
Company. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a
sale of Personal Information under the CCPA.
Sources of Personal Information In the 12 preceding months, we have collected the above-mentioned
categories of Personal Information from the following categories of sources: Consumer directly; Advertising
networks; Data analytics providers; Operating Systems; Social Networks;
Business/Commercial Purpose for Collection Company only collects and processes Personal Information
in a way that is compatible with and relevant for the purpose for which it was collected or authorized. As a
general matter, for all categories of data we collect, we may use the information we collect (including Personal
Information, to the extent applicable) to: provide, operate, maintain, improve, and promote the Service; enable
you to access and use the Service; send transactional messages, including responses to your comments,
questions, and requests; provide customer service and support; and send you technical notices, updates, security
alerts, and support and administrative messages; send commercial communications, in accordance with your
communication preferences, such as providing you with information about products and services, features,
surveys, newsletters, offers, promotions and events about us and our partners; and send other news or
information about us and our partners. monitor and analyze trends, usage, and activities in connection with
the Service and for marketing or advertising purposes; comply with legal obligations as well as to
investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal
activities; personalize the Service, including by providing features, content or ads that match your
interests and preferences; and process for other purposes for which we obtain your consent.
User Rights under the CCPA The CCPA provides consumers with specific rights regarding their Personal
Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Personal Information You may request, up to two times each year, that we disclose to you
the categories and specific pieces of Personal Information that we have collected about you, the categories of
sources from which your Personal Information is collected, the business or commercial purpose for collecting
your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any
categories of Personal Information about you that we sold, the categories of third-parties with whom we have
shared your Personal Information, and the business or commercial purpose for selling your Personal Information,
if applicable.
Deletion Requests You have the right to request that we delete any Personal Information collected
from you and retained, unless an exception applies. Once we receive and confirm your verifiable consumer
request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your
Personal Information, unless an exception applies.
Right to Opt-Out of the Sale of Personal Information In the event that we sell your Personal
Information, you have the right to submit a request to opt-out of the sale of your Personal Information. You may
change your decision at any time and permit us to sell your Personal Information. If you do not want us to
sell your Personal Information to third parties, please submit your request to our email address:
contact@marketing66.com After you opt-out, we may continue to share some Personal Information with our
partners (who will function as our service providers in such instance) to help us perform business-related
functions such as, but not limited to, providing the Service, ensuring that the Service is working correctly and
securely, providing aggregate statistics and analytics and/or preventing fraud. If you access our Service from
other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to
the Personal Information collected when you use those devices or browsers.
Exercising Your Rights You can exercise your rights (such as access and deletion) by submitting a
verifiable consumer request to our email address: contact@marketing66.com Only you or a person authorized
to act on your behalf may make a consumer request related to your Personal Information. The request
must: Provide sufficient information to allow us to reasonably verify you are the person about whom we
collected Personal Information or an authorized representative. Describe your request with sufficient
details to allow us to properly understand, evaluate, and respond to it. We cannot respond to your request
or provide you with Personal Information if we cannot verify your identity or authority to make the request and
confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to
create an account with us. We will only use Personal Information provided in a verifiable consumer request to
verify the requestor's identity or authority to make the request. We will only use Personal
Information provided in a verifiable consumer request to verify the requestor's identity or authority to
make the request. You may only request a copy of your data twice within a 12-month period. If you have
any general questions about the Personal Information that we collect about you how we use it, please contact us
at contact@marketing66.com.
Response Timing and Format Our goal is to respond to a verifiable consumer request within 45 days of
its receipt. If we require more time, we will inform you of the reason and extension period in writing within
the first 45 days' period. We will deliver our written response, by mail or electronically, at your option.
Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we
will provide your Personal Information in a format that is readily useable and should allow you to transmit the
information without hindrance. We do not charge a fee to process or respond to your verifiable consumer
request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a
fee, we will tell you why we made that decision and provide you with a cost estimate before completing your
request. In case of rejection, the response we provide will explain the reasons for which we cannot comply
with your request. Please note that these CCPA rights are not absolute and requests are subject to any
applicable legal requirements, including legal and ethical reporting or document retention obligations.
Designating Agents You can designate an authorized agent to make a request under the CCPA on your
behalf if: The authorized agent is a natural person or a business entity registered with the Secretary of
State of California; and You sign a written declaration that you authorize the authorized agent to act on
your behalf. If you use an authorized agent to submit a request to exercise your right to know or your
right to request deletion, please mail a certified copy of your written declaration authorizing the authorized
agent to act on your behalf using the contact information below. If you provide an authorized agent with
power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps
and we will respond to any request from such authorized agent in accordance with the CCPA.
Non-Discrimination
You have a right not to receive discriminatory treatment for exercising your privacy rights under the CCPA. Unless
permitted by the CCPA, we will not: Deny you goods or services. Charge you different prices or rates
for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide
you a different level or quality of goods or services. Suggest that you may receive a different price or
rate for goods or services or a different level or quality of goods or services.
Record Keeping We will maintain records of consumer requests made pursuant to the CCPA and our
responses to said requests for a minimum period of 24 months. Such information will be used for any other
purpose other than records keeping requirements under the CCPA or other legal requirements such as law, court
order, subpoena, warrant or other legal judicial process. Below are metrics about the number of requests we
received and the median number of days it took us to respond to such requests: Type of Request Number
of Requests Median Number of Days to Respond Right to Know
Right to Delete
Right to Opt-Out of a Sale
Children's Information Our Service is not intended for minors below the age of 16 years or
otherwise below the legal age for providing consent that is not subject to authorization by the holder of
parental responsibility, in accordance with the laws in the jurisdiction your reside (“Age of Consent”), and we
will not knowingly collect Personal Information from children. If we become aware that a user is under the age
of Age of Consent, we will remove their information from our files. We reserve the right to request proof of age
at any stage so that we can verify that children are not using the Service.
Updates or Amendments to the Privacy Notice We reserve the right to change this Privacy Notice at any
time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy
Notice on the Service and/or we will send you an e-mail regarding such changes to the e-mail address that you
volunteered. Such substantial changes will take effect seven (7) days after such notice was provided on any of
the above-mentioned methods. Otherwise, all other changes to this Privacy Notice are effective as of the stated
“Last Revised” date, and your continued use of the Service after the Last Revised date will constitute
acceptance of, and agreement to be bound by, those changes.
How to Contact Us If you have any questions (or comments) concerning this Privacy Notice, you are
welcome to contact our Data Protection Officer here: contact@marketing66.com or through the following contact
details: Marketing66 Ltd., Bezalel Bazrawi 24, Jerusalem ISRAEL We will make an effort to
reply within a reasonable timeframe. Please feel free to reach out to us at any time.
For Brazilian users: The processing of your personal information is not a condition for the use our
Service. However, certain parts of our Service may not be available without processing of personal
information. If you reside in Brazil, under the Brazilian Data Protection Law (Lei Geral de Proteção de
Dados) you have the following rights regarding your Personal Information: (1) Receive confirmation as to whether
or not Personal Information concerning you is being processed; (2) Access to your stored Personal Information;
(3) Request correction of incomplete, inaccurate or out-of-date Personal Information; (4) Request anonymization,
blocking or deletion of unnecessary, excessive Personal Information; (5) Request data portability to another
service provider or product, upon express request, as may be provided by the appropriate law; (6) Request
deletion of Personal Information processed with your consent; (7) Obtain information about the public or private
entities with whom we share your Personal Information; (8) Request information on the possibility of you not
providing consent, as well as being informed about the consequences should consent not be given; (9) Revocation
of your consent. If you wish to exercise any of the abovementioned rights or raise a complaint on how we
have handled your Personal Information, please contact us directly at: contact@marketing66.com. We will
retain your personal information for the duration required to provide our Services, and as necessary to comply
with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined
taking into account the type of information that is collected and the purpose for which it is collected, bearing
in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the
earliest reasonable time. Under applicable regulations, we will keep records containing personal data,
communications and anything else as required by applicable laws and regulations. We may rectify, replenish
or remove incomplete or inaccurate information, at any time and at our own discretion. Security and
Confidentiality The Company treats your Personal Information in strict confidentiality, and the server in
which this data is to be stored includes the necessary industry-standard security measures to prevent accidental
or unlawful destruction, loss, alteration, unauthorized disclosure or access. However, we cannot completely
guarantee the security of your information, which might be accessed, disclosed, modified, or destroyed, and it
should be emphasized that you share this information at your own risk.
Links to Other Websites This Privacy Policy applies only to the Service, and to our web tools which
are integrated or implemented in other third party websites. The Policy does not apply to third party websites,
linked to our Website. Third party websites or services may have their own privacy policies and we advise you to
read them carefully. Inclusion of a link to a third party website or service is not a recommendation of such a
website or service. Third party sites may contain information or services that are illegal or that some people
may find inappropriate or offensive. Before using third party sites and services or before making a purchase, we
recommend that you read and understand the privacy policies and terms and conditions of such third party
websites and services, and the warranties for purchased products. You are knowingly and voluntarily assuming all
risks of using third party sites to purchase products and services. You acknowledge and agree that we shall have
no liability whatsoever with respect to such third party sites and your use of them.
Assignment Subject to applicable law, we may transfer or assign your information, without any notice,
and without a need to receive your consent, to any third party as a result of change of control, consolidation,
merger, acquisition or reorganization. You acknowledge that in the event of bankruptcy, insolvency or
receivership, we may have no control over the use and transfer of your Personal Information.
Updates to this policy This Privacy Policy is subject to modifications. Please check the “Last
Modified” heading at the bottom of this document to see when this Privacy Policy was last updated. Any changes
to this Privacy Policy will become effective when we post the revised Privacy Policy on the Website. In case of
material changes to this Privacy Policy, we will provide a notice in the Website. Your use of the Website or the
Service, or your provision of personal information following any changes means that you accept the updated
Privacy Policy.
Privacy Policy
Marketing66 Limited (“the Company” or “Marketing66” or “we”) is the owner of the website www.marketstip.co (“the
Website”) and the Markets Tip mobile application (“the App”; collectively and separately known as “the
Service”). Marketing66 is committed to protecting your privacy and we understand you want to keep your
information private, safe and discrete. This Privacy Policy is designed to help you decide whether to use the
Service and in what manner, and it describes how we collect, store and use information on individuals who use
the Service. The Services hereunder are offered by Marketing66 Limited, registered at: Marketing66Ltd., Bezalel
Bazrawi 24, Jerusalem ISRAEL
Consent to use Information
This Policy is a legally binding agreement between you (“you” or “user”) and us. By visiting, accessing or
using the Website or App, or providing information to us in any other format, you agree to and accept the terms
of this Privacy Policy, as amended from time to time, and you consent to the collection and use of information
in the manner set out in this Policy. We encourage you to review this Policy carefully and to periodically refer
to it so that you understand it and its subsequent changes if any. IF YOU DO NOT AGREE TO THE TERMS OF THIS
PRIVACY POLICY, PLEASE STOP USING THE SERVICE IMMEDIATELY AND WHERE RELEVANT UNINSTALL. The definitions in
the Terms and Conditions apply to this Privacy Policy unless stated otherwise. IN ADDITION TO THIS POLICY,
PLEASE REVIEW OUR TERMS AND CONDITIONS AND COOKIE POLICY WHICH ARE INCORPORATED HEREIN BY REFERENCE, TOGETHER
WITH SUCH OTHER POLICIES OF WHICH YOU MAY BE NOTIFIED OF BY US FROM TIME TO TIME. What Information Do We
Collect? We collect two types of data and information from you:
(1) Non-Personal Information – We retain some non-personally identifiable information (“Non-Personal
Information”), such as your approximate geo-location, your web request, browser type, browser language, web
pages you visit before or after visiting our Website or using the App, URLs, platform type, click numbers,
landing pages, viewed pages and the order of those pages and time spent on pages. This information is collected
and retained for security reasons and so that we can audit and statistically track usage, audit our affiliates,
and calculate payments to third parties. “Cookies” - Non-Personal Information is collected, inter alia,
through the use of cookies, so when accessing or using the Website, we may use one or more cookies. Cookies are
small text files, placed on a user's device, which enable a website to remember user preferences. Detailed
information about cookies and how we use them on the Website and other websites implementing our web tools may
be found in our Cookie Policy, which also describes how you can turn off cookies or control them. Web
Beacons - We also use a software technology called “clear gifs” (also known as Web Beacons). Web Beacons are
small pieces of code placed on a website to monitor the behavior and collect data about the visitors viewing a
web page. For example, web beacons can be used to count the users who visit a web page or to deliver a “cookie”
to the browser of a visitor viewing that page.
(2) Personal Information - “Personal Information” is information that may be of a private or sensitive
nature, including your name, gender, phone number, e-mail address or mailing address, payment information and IP
address. We collect your IP address as part of your use of the Service. We also collect the following Personal
Information from you when you create an account (“Account”) on the Website which is required to access certain
parts of the Service: your full name, email address, password, and phone number.
You are not required to provide us with this information in order to use the service. If you choose to
provide us with this information, we will retain it in our records and process it only in accordance with the
provisions of this Privacy Policy. Please refer to the Who Else Receives this Information? section of this
Privacy Policy to learn about sharing of Personal Information. As an alternative, you are also able to
create an Account using your credentials with a designated third party website or service such as Facebook,
Google+ or Twitter (“Third Party Account”). Doing so will enable you to login to your Account via your Third
Party Account. If you choose this option, a Third Party Account pop-up box will appear at the time of creating
your Account which you will need to approve in order to proceed with the Account opening, and which will
describe the types of information that we will obtain from and the types of activities that we may perform in
connection with your Third Party Account. Such information may include (but not be limited to) your Personal
Information stored on this Third Party Account, such as your user name, email address, profile picture, gender,
date of birth and any other information which you have chosen to make profile on such Third Party Account.
Please note that once your Account has been opened, the Personal Information we have access to via a Third Party
Account is also dependent on your individual privacy settings in such Third Party Account and any privacy
policies which are maintained by the providers of such Third Party Accounts. We treat any Non-Personal
Information which is specifically connected or linked to any Personal Information as Personal Information. We
collect and process the Personal Information referred to above based, where applicable, on your consent, where
the processing is necessary for the performance of a contract between you and the Company or where the
processing is necessary for the purpose of fulfilling a legitimate interest pursued by us. What is the
Purpose of Collecting this Information? In order to access our services, users may be asked to fill in a
form, providing some personal information to the Company. Answers to questions on Personal Information are not
mandatory unless the fields are marked with an asterisk. Provision of the information requested in the optional
fields of the registration form is not mandatory in order to receive the services and information that we
provide through the Site (unless otherwise indicated in the registration form). However, failure to complete
mandatory fields or providing incorrect Personal Information may prevent us from fully providing the requested
information or services. Please note that you are under no legal obligation to provide us with your Personal
Information, however you may not be able to enjoy our services or access the Site if you fail to do so. The
collection and processing of Personal Information is aimed at providing you with the Service (including setting
up your account), to send you marketing offers on products or services we think may be relevant to you, and to
fulfill other purposes as provided in this privacy policy. Non-Personal Information is collected for
research and statistical purposes, to enable us to develop, customize and improve the Service, based on your
preferences, usage and interactions with the Service, to process your requests for information, and to provide
you with the most relevant services and offers. We use cookies in conjunction with third parties to collect
user information. Your Personal Information is collected to enable us to provide you with features,
capabilities, offers and marketing materials we or our marketing partners think you may be interested in. In
addition to the above, your Personal Information allows us to provide you with technical assistance and
support.
Who Else Receives this Information? We may share or transfer information, including Personal
Information, internally within our group of companies, for the purposes outlined above. These companies may be
located in countries that may provide a different level of protection of privacy than in your jurisdiction. We
also share Personal and Non-Personal Information with trusted third parties, when this is required in order to
provide, maintain or improve our services and operation. This is the case with third party advertisements and
affiliates; we share your information with third parties for the purpose of providing you with advertisements
and offers we or third parties think you may be interested in. These third parties may be located in countries
that may provide a different level of protection of privacy than in your jurisdiction. We share your
Personal and Non-Personal Information with (i) third parties which provide services to the Company in order to
allow or enable us to provide you with our Service, including analytics, email services providers and data
verifiers; (ii) third parties who provide the Company services in relation to the operation of the Website;
(iii) any auditors, contractors or other advisers auditing any of the Company’s business processes; and (iv) any
potential purchasers or investors in the Company. If you choose to open a member card, other users of the
Website may be able to view the following personal information about you (to the extent that you have provided
it to us): your name, picture and general geographic location (country). If you have chosen to share
Personal Information with us through one of our forms, we may share it with any or all of our third party
providers, which may provide you with a loan offer. Please note that this third party may be considered a
“controller” of your Personal Information and the processing of such Personal Information will be subject to
such provider's privacy policy. Any processing performed by any of our third party service providers
(“Recipients”) will, where required by law, be governed by a data processing agreement in the form required by
law, preserving any and all of your statutory data protection rights and obligating the Recipients to respect
the Personal Information and handle it in accordance with the relevant laws. If a Recipient is located outside
the EEA, we will transfer your data only to such countries as approved by the European Commission as providing
adequate level of data protection, or ensure that the legal agreements governing the data transfer provide an
adequate level of data protection. The Recipients are required to maintain the confidentiality of such
information and to use your Personal Information only in the course of providing the aforementioned services and
only for the purposes that Marketing66 dictates. We may also share your Personal Information and other
information in special cases if we have a good reason to believe that it is necessary to: (i) comply with law,
regulation, subpoena, request by an applicable authority or court order; (ii) detect, prevent or otherwise
address fraud, security, violation of our policies or technical issues; (iii) enforce the provisions of this
Privacy Policy or any other agreements between you and Marketing66, including investigation of potential
violations thereof; or (iv) protect against harm to the rights, property or safety of the Company, its partners,
its affiliates, users or the public.
Advertisements We may use a third-party advertising technology to serve advertisements when you
access the Site. This technology uses your information with regards to your use of the Services to serve
advertisements to you (e.g., by placing third-party cookies on your web browser).
Direct Marketing
We may share your full name, email address and phone number with certain broker(s) (the “Broker”) in the
event that you have granted permission to receive promotional materials from such Broker at the time of
registration. The Broker may periodically use your full name, email address and phone number for the purpose of
providing you with promotional materials if your permission was granted at the time of registration and you have
not unsubscribed at a later time in accordance with the provisions hereof. At any time, you may request to
discontinue receiving these offers or xosignals.com's marketing emails by clicking on the unsubscribe link
in the email's footer or by following the on-page instructions at https://www.xosignals.com/unsubscribe . If
you unsubscribe we will remove your full name, email address and phone number from our marketing distribution
lists and from any future lists we may share with the Broker. However, you may need to also separately
unsubscribe from marketing offers sent by the Broker. Please note that in order to send you promotional
materials, the Broker may assign you with a username and password which will allow you access to the
Broker's site through an account. You may contact the Broker at any time to remove the account.
User Rights and Retention You have the right to access, correct, update or object to the use of your
Personal Information by making a written request to Marketing66 by using our Contact Us page. Your requests will
be dealt with in a prompt and professional manner and in accordance with applicable law.
For EU users:
Legal basis for processing Processing of Personal Information is necessary for the performance of our
contractual obligations towards you and providing you with our services, to protect our legitimate interests and
to comply with our legal obligations. Where we rely on your consent to process your Personal Information,
you have the right to withdraw or decline consent at any time – However, if we have shared your Personal Data
based on your consent, you would need to address the entity with whom your data was shared to withdraw your
consent. Where we rely on our legitimate interests to process your Personal Information, you have the right to
object. If you have any questions about or need further information concerning the legal basis on which we
collect and use your Personal Information, please contact us through the contact details available below.
Since we operate globally, it may be necessary to transfer data, including Personal Information, to
countries outside the European Union. In these instances, we will transfer your data only to such countries as
approved by the European Commission as providing adequate level of data protection or enter into legal
agreements ensuring an adequate level of data protection.
Please note that the following rights specifically apply regarding your personal information: (1) Receive
confirmation as to whether or not personal information concerning you is being processed, and access your stored
personal information, together with supplementary information; (2) Receive a copy of personal information you
directly volunteer to us in a structured, commonly used and machine-readable format; (3) Request rectification
of your personal information that is in our control; (4) Request erasure of your personal information; (5)
Object to the processing of personal information by us; (6) Request to restrict processing of your personal
information by us; (7) Lodge a complaint with a supervisory authority.
If you wish to exercise any of the abovementioned rights or raise a complaint on how we have handled your
Personal Information, please contact us directly at: contact@marketing66.com.
Last Revised: August 9, 2021
Introduction This notice (“Privacy Notice”) addresses the specific disclosure requirements under the
California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100–1798.199) and the California Consumer
Privacy Act Regulation by the Attorney General (collectively, “CCPA”). Any terms defined in the CCPA have the
same meaning when used in this Privacy Notice. Marketing66 Limited (“we”, “us”, “our” or the “Company”)
provides disclosures for the 12 months preceding the date the Privacy Notice was last revised, as required by
the CCPA vis-à-vis California residents. This Privacy Notice outlines our practices with respect to the
information we collect from you when you use the investing website (www.xosignals.com) and mobile app
(“Service”), the manners in which we use such information and the choices available for you. By accessing,
downloading or using our Service, you acknowledge that you have read and understood the terms of this Privacy
Notice. If you disagree to any term provided herein, please do not install or use the Service. In addition
to this policy, please also review our Privacy Policy(should be clickable) and Terms and Conditions(SHould be
clickable), which this Privacy Notice is incorporated thereto by reference, along with such other policies of
which you may be notified of by us from time to time. In our Privacy Notice, you will learn about: What
Information We Process Sources of Personal Information Business/Commercial Purpose for Collection Sharing
Personal Information Selling Personal Information User Rights Under the CCPA Non
Discrimination Do Not Track Signals Record Keeping Children's Information Updates or
Amendments to the Privacy Notice How to Contact Us If you have a visual disability, you may be able to
use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Privacy
Notice.
What Information We Process? We may collect and process certain information that identifies an
individual or may with reasonable effort identify an individual (“Personal Information”). We treat information
that is specifically connected or linked to any Personal Information – as long as such connection or linkage
exists – as Personal Information. We may also disclose Personal Information we have collected with our
service providers for a business purpose (as further detailed in “Business/Commercial Purpose for Collection”
section below), subject to a contract that describes the purpose and restricts the use of Personal Information
disclosed, or with other third parties for a commercial purpose, which may be considered a sale under the CCPA,
as detailed in the following chart: In the 12 preceding months, we have collected, disclosed and/or sold
the following categories of Personal Information:
Category of Personal Information Collected Personal Information Collected Categories of service
providers to whom Personal Information was disclosed Categories of third parties to whom Personal
Information was sold Identifiers Full name, email address, physical address, IP, social media
credentials and identifiers Affiliate Companies Ad networks Data analytics providers Email
and cloud providers Auditors and advisors Other users Ad networks Data analytics
providers
Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code §
1798.80(e)) Telephone number Affiliate Companies Email and cloud providers Auditors and
advisors
Internet or Other Electronic Network Activity Information Browsing history, search history,
information on a consumer’s interaction with a website, application, or advertisement. Affiliate
Companies Ad networks Data analytics providers Email and cloud providers Auditors and
advisors Ad networks Data analytics providers
Geolocation Data Approximate geolocation Affiliate Companies Ad networks Data
analytics providers Email and cloud providers Auditors and advisors Ad networks Data
analytics providers
We may share or transfer Personal Information to third parties as assets that are part of a merger,
acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of the
Company. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a
sale of Personal Information under the CCPA.
Sources of Personal Information In the 12 preceding months, we have collected the above-mentioned
categories of Personal Information from the following categories of sources: Consumer directly; Advertising
networks; Data analytics providers; Operating Systems; Social Networks;
Business/Commercial Purpose for Collection Company only collects and processes Personal Information
in a way that is compatible with and relevant for the purpose for which it was collected or authorized. As a
general matter, for all categories of data we collect, we may use the information we collect (including Personal
Information, to the extent applicable) to: provide, operate, maintain, improve, and promote the Service; enable
you to access and use the Service; send transactional messages, including responses to your comments,
questions, and requests; provide customer service and support; and send you technical notices, updates, security
alerts, and support and administrative messages; send commercial communications, in accordance with your
communication preferences, such as providing you with information about products and services, features,
surveys, newsletters, offers, promotions and events about us and our partners; and send other news or
information about us and our partners. monitor and analyze trends, usage, and activities in connection with
the Service and for marketing or advertising purposes; comply with legal obligations as well as to
investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal
activities; personalize the Service, including by providing features, content or ads that match your
interests and preferences; and process for other purposes for which we obtain your consent.
User Rights under the CCPA The CCPA provides consumers with specific rights regarding their Personal
Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Personal Information You may request, up to two times each year, that we disclose to you
the categories and specific pieces of Personal Information that we have collected about you, the categories of
sources from which your Personal Information is collected, the business or commercial purpose for collecting
your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any
categories of Personal Information about you that we sold, the categories of third-parties with whom we have
shared your Personal Information, and the business or commercial purpose for selling your Personal Information,
if applicable.
Deletion Requests You have the right to request that we delete any Personal Information collected
from you and retained, unless an exception applies. Once we receive and confirm your verifiable consumer
request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your
Personal Information, unless an exception applies.
Right to Opt-Out of the Sale of Personal Information In the event that we sell your Personal
Information, you have the right to submit a request to opt-out of the sale of your Personal Information. You may
change your decision at any time and permit us to sell your Personal Information. If you do not want us to
sell your Personal Information to third parties, please submit your request to our email address:
contact@marketing66.com After you opt-out, we may continue to share some Personal Information with our
partners (who will function as our service providers in such instance) to help us perform business-related
functions such as, but not limited to, providing the Service, ensuring that the Service is working correctly and
securely, providing aggregate statistics and analytics and/or preventing fraud. If you access our Service from
other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to
the Personal Information collected when you use those devices or browsers.
Exercising Your Rights You can exercise your rights (such as access and deletion) by submitting a
verifiable consumer request to our email address: contact@marketing66.com Only you or a person authorized
to act on your behalf may make a consumer request related to your Personal Information. The request
must: Provide sufficient information to allow us to reasonably verify you are the person about whom we
collected Personal Information or an authorized representative. Describe your request with sufficient
details to allow us to properly understand, evaluate, and respond to it. We cannot respond to your request
or provide you with Personal Information if we cannot verify your identity or authority to make the request and
confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to
create an account with us. We will only use Personal Information provided in a verifiable consumer request to
verify the requestor's identity or authority to make the request. We will only use Personal
Information provided in a verifiable consumer request to verify the requestor's identity or authority to
make the request. You may only request a copy of your data twice within a 12-month period. If you have
any general questions about the Personal Information that we collect about you how we use it, please contact us
at contact@marketing66.com.
Response Timing and Format Our goal is to respond to a verifiable consumer request within 45 days of
its receipt. If we require more time, we will inform you of the reason and extension period in writing within
the first 45 days' period. We will deliver our written response, by mail or electronically, at your option.
Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we
will provide your Personal Information in a format that is readily useable and should allow you to transmit the
information without hindrance. We do not charge a fee to process or respond to your verifiable consumer
request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a
fee, we will tell you why we made that decision and provide you with a cost estimate before completing your
request. In case of rejection, the response we provide will explain the reasons for which we cannot comply
with your request. Please note that these CCPA rights are not absolute and requests are subject to any
applicable legal requirements, including legal and ethical reporting or document retention obligations.
Designating Agents You can designate an authorized agent to make a request under the CCPA on your
behalf if: The authorized agent is a natural person or a business entity registered with the Secretary of
State of California; and You sign a written declaration that you authorize the authorized agent to act on
your behalf. If you use an authorized agent to submit a request to exercise your right to know or your
right to request deletion, please mail a certified copy of your written declaration authorizing the authorized
agent to act on your behalf using the contact information below. If you provide an authorized agent with
power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps
and we will respond to any request from such authorized agent in accordance with the CCPA.
Non-Discrimination
You have a right not to receive discriminatory treatment for exercising your privacy rights under the CCPA. Unless
permitted by the CCPA, we will not: Deny you goods or services. Charge you different prices or rates
for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide
you a different level or quality of goods or services. Suggest that you may receive a different price or
rate for goods or services or a different level or quality of goods or services.
Record Keeping We will maintain records of consumer requests made pursuant to the CCPA and our
responses to said requests for a minimum period of 24 months. Such information will be used for any other
purpose other than records keeping requirements under the CCPA or other legal requirements such as law, court
order, subpoena, warrant or other legal judicial process. Below are metrics about the number of requests we
received and the median number of days it took us to respond to such requests: Type of Request Number
of Requests Median Number of Days to Respond Right to Know
Right to Delete
Right to Opt-Out of a Sale
Children's Information Our Service is not intended for minors below the age of 16 years or
otherwise below the legal age for providing consent that is not subject to authorization by the holder of
parental responsibility, in accordance with the laws in the jurisdiction your reside (“Age of Consent”), and we
will not knowingly collect Personal Information from children. If we become aware that a user is under the age
of Age of Consent, we will remove their information from our files. We reserve the right to request proof of age
at any stage so that we can verify that children are not using the Service.
Updates or Amendments to the Privacy Notice We reserve the right to change this Privacy Notice at any
time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy
Notice on the Service and/or we will send you an e-mail regarding such changes to the e-mail address that you
volunteered. Such substantial changes will take effect seven (7) days after such notice was provided on any of
the above-mentioned methods. Otherwise, all other changes to this Privacy Notice are effective as of the stated
“Last Revised” date, and your continued use of the Service after the Last Revised date will constitute
acceptance of, and agreement to be bound by, those changes.
How to Contact Us If you have any questions (or comments) concerning this Privacy Notice, you are
welcome to contact our Data Protection Officer here: contact@marketing66.com or through the following contact
details: Marketing66 Ltd., Bezalel Bazrawi 24, Jerusalem ISRAEL We will make an effort to
reply within a reasonable timeframe. Please feel free to reach out to us at any time.
For Brazilian users: The processing of your personal information is not a condition for the use our
Service. However, certain parts of our Service may not be available without processing of personal
information. If you reside in Brazil, under the Brazilian Data Protection Law (Lei Geral de Proteção de
Dados) you have the following rights regarding your Personal Information: (1) Receive confirmation as to whether
or not Personal Information concerning you is being processed; (2) Access to your stored Personal Information;
(3) Request correction of incomplete, inaccurate or out-of-date Personal Information; (4) Request anonymization,
blocking or deletion of unnecessary, excessive Personal Information; (5) Request data portability to another
service provider or product, upon express request, as may be provided by the appropriate law; (6) Request
deletion of Personal Information processed with your consent; (7) Obtain information about the public or private
entities with whom we share your Personal Information; (8) Request information on the possibility of you not
providing consent, as well as being informed about the consequences should consent not be given; (9) Revocation
of your consent. If you wish to exercise any of the abovementioned rights or raise a complaint on how we
have handled your Personal Information, please contact us directly at: contact@marketing66.com. We will
retain your personal information for the duration required to provide our Services, and as necessary to comply
with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined
taking into account the type of information that is collected and the purpose for which it is collected, bearing
in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the
earliest reasonable time. Under applicable regulations, we will keep records containing personal data,
communications and anything else as required by applicable laws and regulations. We may rectify, replenish
or remove incomplete or inaccurate information, at any time and at our own discretion. Security and
Confidentiality The Company treats your Personal Information in strict confidentiality, and the server in
which this data is to be stored includes the necessary industry-standard security measures to prevent accidental
or unlawful destruction, loss, alteration, unauthorized disclosure or access. However, we cannot completely
guarantee the security of your information, which might be accessed, disclosed, modified, or destroyed, and it
should be emphasized that you share this information at your own risk.
Links to Other Websites This Privacy Policy applies only to the Service, and to our web tools which
are integrated or implemented in other third party websites. The Policy does not apply to third party websites,
linked to our Website. Third party websites or services may have their own privacy policies and we advise you to
read them carefully. Inclusion of a link to a third party website or service is not a recommendation of such a
website or service. Third party sites may contain information or services that are illegal or that some people
may find inappropriate or offensive. Before using third party sites and services or before making a purchase, we
recommend that you read and understand the privacy policies and terms and conditions of such third party
websites and services, and the warranties for purchased products. You are knowingly and voluntarily assuming all
risks of using third party sites to purchase products and services. You acknowledge and agree that we shall have
no liability whatsoever with respect to such third party sites and your use of them.
Assignment Subject to applicable law, we may transfer or assign your information, without any notice,
and without a need to receive your consent, to any third party as a result of change of control, consolidation,
merger, acquisition or reorganization. You acknowledge that in the event of bankruptcy, insolvency or
receivership, we may have no control over the use and transfer of your Personal Information.
Updates to this policy This Privacy Policy is subject to modifications. Please check the “Last
Modified” heading at the bottom of this document to see when this Privacy Policy was last updated. Any changes
to this Privacy Policy will become effective when we post the revised Privacy Policy on the Website. In case of
material changes to this Privacy Policy, we will provide a notice in the Website. Your use of the Website or the
Service, or your provision of personal information following any changes means that you accept the updated
Privacy Policy.
Privacy Policy
Marketing66 Limited (“the Company” or “Marketing66” or “we”) is the owner of the website www.marketstip.co (“the
Website”) and the Markets Tip mobile application (“the App”; collectively and separately known as “the
Service”). Marketing66 is committed to protecting your privacy and we understand you want to keep your
information private, safe and discrete. This Privacy Policy is designed to help you decide whether to use the
Service and in what manner, and it describes how we collect, store and use information on individuals who use
the Service. The Services hereunder are offered by Marketing66 Limited, registered at: Marketing66Ltd., Bezalel
Bazrawi 24, Jerusalem ISRAEL
Consent to use Information
This Policy is a legally binding agreement between you (“you” or “user”) and us. By visiting, accessing or
using the Website or App, or providing information to us in any other format, you agree to and accept the terms
of this Privacy Policy, as amended from time to time, and you consent to the collection and use of information
in the manner set out in this Policy. We encourage you to review this Policy carefully and to periodically refer
to it so that you understand it and its subsequent changes if any. IF YOU DO NOT AGREE TO THE TERMS OF THIS
PRIVACY POLICY, PLEASE STOP USING THE SERVICE IMMEDIATELY AND WHERE RELEVANT UNINSTALL. The definitions in
the Terms and Conditions apply to this Privacy Policy unless stated otherwise. IN ADDITION TO THIS POLICY,
PLEASE REVIEW OUR TERMS AND CONDITIONS AND COOKIE POLICY WHICH ARE INCORPORATED HEREIN BY REFERENCE, TOGETHER
WITH SUCH OTHER POLICIES OF WHICH YOU MAY BE NOTIFIED OF BY US FROM TIME TO TIME. What Information Do We
Collect? We collect two types of data and information from you:
(1) Non-Personal Information – We retain some non-personally identifiable information (“Non-Personal
Information”), such as your approximate geo-location, your web request, browser type, browser language, web
pages you visit before or after visiting our Website or using the App, URLs, platform type, click numbers,
landing pages, viewed pages and the order of those pages and time spent on pages. This information is collected
and retained for security reasons and so that we can audit and statistically track usage, audit our affiliates,
and calculate payments to third parties. “Cookies” - Non-Personal Information is collected, inter alia,
through the use of cookies, so when accessing or using the Website, we may use one or more cookies. Cookies are
small text files, placed on a user's device, which enable a website to remember user preferences. Detailed
information about cookies and how we use them on the Website and other websites implementing our web tools may
be found in our Cookie Policy, which also describes how you can turn off cookies or control them. Web
Beacons - We also use a software technology called “clear gifs” (also known as Web Beacons). Web Beacons are
small pieces of code placed on a website to monitor the behavior and collect data about the visitors viewing a
web page. For example, web beacons can be used to count the users who visit a web page or to deliver a “cookie”
to the browser of a visitor viewing that page.
(2) Personal Information - “Personal Information” is information that may be of a private or sensitive
nature, including your name, gender, phone number, e-mail address or mailing address, payment information and IP
address. We collect your IP address as part of your use of the Service. We also collect the following Personal
Information from you when you create an account (“Account”) on the Website which is required to access certain
parts of the Service: your full name, email address, password, and phone number.
You are not required to provide us with this information in order to use the service. If you choose to
provide us with this information, we will retain it in our records and process it only in accordance with the
provisions of this Privacy Policy. Please refer to the Who Else Receives this Information? section of this
Privacy Policy to learn about sharing of Personal Information. As an alternative, you are also able to
create an Account using your credentials with a designated third party website or service such as Facebook,
Google+ or Twitter (“Third Party Account”). Doing so will enable you to login to your Account via your Third
Party Account. If you choose this option, a Third Party Account pop-up box will appear at the time of creating
your Account which you will need to approve in order to proceed with the Account opening, and which will
describe the types of information that we will obtain from and the types of activities that we may perform in
connection with your Third Party Account. Such information may include (but not be limited to) your Personal
Information stored on this Third Party Account, such as your user name, email address, profile picture, gender,
date of birth and any other information which you have chosen to make profile on such Third Party Account.
Please note that once your Account has been opened, the Personal Information we have access to via a Third Party
Account is also dependent on your individual privacy settings in such Third Party Account and any privacy
policies which are maintained by the providers of such Third Party Accounts. We treat any Non-Personal
Information which is specifically connected or linked to any Personal Information as Personal Information. We
collect and process the Personal Information referred to above based, where applicable, on your consent, where
the processing is necessary for the performance of a contract between you and the Company or where the
processing is necessary for the purpose of fulfilling a legitimate interest pursued by us. What is the
Purpose of Collecting this Information? In order to access our services, users may be asked to fill in a
form, providing some personal information to the Company. Answers to questions on Personal Information are not
mandatory unless the fields are marked with an asterisk. Provision of the information requested in the optional
fields of the registration form is not mandatory in order to receive the services and information that we
provide through the Site (unless otherwise indicated in the registration form). However, failure to complete
mandatory fields or providing incorrect Personal Information may prevent us from fully providing the requested
information or services. Please note that you are under no legal obligation to provide us with your Personal
Information, however you may not be able to enjoy our services or access the Site if you fail to do so. The
collection and processing of Personal Information is aimed at providing you with the Service (including setting
up your account), to send you marketing offers on products or services we think may be relevant to you, and to
fulfill other purposes as provided in this privacy policy. Non-Personal Information is collected for
research and statistical purposes, to enable us to develop, customize and improve the Service, based on your
preferences, usage and interactions with the Service, to process your requests for information, and to provide
you with the most relevant services and offers. We use cookies in conjunction with third parties to collect
user information. Your Personal Information is collected to enable us to provide you with features,
capabilities, offers and marketing materials we or our marketing partners think you may be interested in. In
addition to the above, your Personal Information allows us to provide you with technical assistance and
support.
Who Else Receives this Information? We may share or transfer information, including Personal
Information, internally within our group of companies, for the purposes outlined above. These companies may be
located in countries that may provide a different level of protection of privacy than in your jurisdiction. We
also share Personal and Non-Personal Information with trusted third parties, when this is required in order to
provide, maintain or improve our services and operation. This is the case with third party advertisements and
affiliates; we share your information with third parties for the purpose of providing you with advertisements
and offers we or third parties think you may be interested in. These third parties may be located in countries
that may provide a different level of protection of privacy than in your jurisdiction. We share your
Personal and Non-Personal Information with (i) third parties which provide services to the Company in order to
allow or enable us to provide you with our Service, including analytics, email services providers and data
verifiers; (ii) third parties who provide the Company services in relation to the operation of the Website;
(iii) any auditors, contractors or other advisers auditing any of the Company’s business processes; and (iv) any
potential purchasers or investors in the Company. If you choose to open a member card, other users of the
Website may be able to view the following personal information about you (to the extent that you have provided
it to us): your name, picture and general geographic location (country). If you have chosen to share
Personal Information with us through one of our forms, we may share it with any or all of our third party
providers, which may provide you with a loan offer. Please note that this third party may be considered a
“controller” of your Personal Information and the processing of such Personal Information will be subject to
such provider's privacy policy. Any processing performed by any of our third party service providers
(“Recipients”) will, where required by law, be governed by a data processing agreement in the form required by
law, preserving any and all of your statutory data protection rights and obligating the Recipients to respect
the Personal Information and handle it in accordance with the relevant laws. If a Recipient is located outside
the EEA, we will transfer your data only to such countries as approved by the European Commission as providing
adequate level of data protection, or ensure that the legal agreements governing the data transfer provide an
adequate level of data protection. The Recipients are required to maintain the confidentiality of such
information and to use your Personal Information only in the course of providing the aforementioned services and
only for the purposes that Marketing66 dictates. We may also share your Personal Information and other
information in special cases if we have a good reason to believe that it is necessary to: (i) comply with law,
regulation, subpoena, request by an applicable authority or court order; (ii) detect, prevent or otherwise
address fraud, security, violation of our policies or technical issues; (iii) enforce the provisions of this
Privacy Policy or any other agreements between you and Marketing66, including investigation of potential
violations thereof; or (iv) protect against harm to the rights, property or safety of the Company, its partners,
its affiliates, users or the public.
Advertisements We may use a third-party advertising technology to serve advertisements when you
access the Site. This technology uses your information with regards to your use of the Services to serve
advertisements to you (e.g., by placing third-party cookies on your web browser).
Direct Marketing
We may share your full name, email address and phone number with certain broker(s) (the “Broker”) in the
event that you have granted permission to receive promotional materials from such Broker at the time of
registration. The Broker may periodically use your full name, email address and phone number for the purpose of
providing you with promotional materials if your permission was granted at the time of registration and you have
not unsubscribed at a later time in accordance with the provisions hereof. At any time, you may request to
discontinue receiving these offers or xosignals.com's marketing emails by clicking on the unsubscribe link
in the email's footer or by following the on-page instructions at https://www.xosignals.com/unsubscribe . If
you unsubscribe we will remove your full name, email address and phone number from our marketing distribution
lists and from any future lists we may share with the Broker. However, you may need to also separately
unsubscribe from marketing offers sent by the Broker. Please note that in order to send you promotional
materials, the Broker may assign you with a username and password which will allow you access to the
Broker's site through an account. You may contact the Broker at any time to remove the account.
User Rights and Retention You have the right to access, correct, update or object to the use of your
Personal Information by making a written request to Marketing66 by using our Contact Us page. Your requests will
be dealt with in a prompt and professional manner and in accordance with applicable law.
For EU users:
Legal basis for processing Processing of Personal Information is necessary for the performance of our
contractual obligations towards you and providing you with our services, to protect our legitimate interests and
to comply with our legal obligations. Where we rely on your consent to process your Personal Information,
you have the right to withdraw or decline consent at any time – However, if we have shared your Personal Data
based on your consent, you would need to address the entity with whom your data was shared to withdraw your
consent. Where we rely on our legitimate interests to process your Personal Information, you have the right to
object. If you have any questions about or need further information concerning the legal basis on which we
collect and use your Personal Information, please contact us through the contact details available below.
Since we operate globally, it may be necessary to transfer data, including Personal Information, to
countries outside the European Union. In these instances, we will transfer your data only to such countries as
approved by the European Commission as providing adequate level of data protection or enter into legal
agreements ensuring an adequate level of data protection.
Please note that the following rights specifically apply regarding your personal information: (1) Receive
confirmation as to whether or not personal information concerning you is being processed, and access your stored
personal information, together with supplementary information; (2) Receive a copy of personal information you
directly volunteer to us in a structured, commonly used and machine-readable format; (3) Request rectification
of your personal information that is in our control; (4) Request erasure of your personal information; (5)
Object to the processing of personal information by us; (6) Request to restrict processing of your personal
information by us; (7) Lodge a complaint with a supervisory authority.
If you wish to exercise any of the abovementioned rights or raise a complaint on how we have handled your
Personal Information, please contact us directly at: contact@marketing66.com.
Last Revised: August 9, 2021
Introduction This notice (“Privacy Notice”) addresses the specific disclosure requirements under the
California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100–1798.199) and the California Consumer
Privacy Act Regulation by the Attorney General (collectively, “CCPA”). Any terms defined in the CCPA have the
same meaning when used in this Privacy Notice. Marketing66 Limited (“we”, “us”, “our” or the “Company”)
provides disclosures for the 12 months preceding the date the Privacy Notice was last revised, as required by
the CCPA vis-à-vis California residents. This Privacy Notice outlines our practices with respect to the
information we collect from you when you use the investing website (www.xosignals.com) and mobile app
(“Service”), the manners in which we use such information and the choices available for you. By accessing,
downloading or using our Service, you acknowledge that you have read and understood the terms of this Privacy
Notice. If you disagree to any term provided herein, please do not install or use the Service. In addition
to this policy, please also review our Privacy Policy(should be clickable) and Terms and Conditions(SHould be
clickable), which this Privacy Notice is incorporated thereto by reference, along with such other policies of
which you may be notified of by us from time to time. In our Privacy Notice, you will learn about: What
Information We Process Sources of Personal Information Business/Commercial Purpose for Collection Sharing
Personal Information Selling Personal Information User Rights Under the CCPA Non
Discrimination Do Not Track Signals Record Keeping Children's Information Updates or
Amendments to the Privacy Notice How to Contact Us If you have a visual disability, you may be able to
use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Privacy
Notice.
What Information We Process? We may collect and process certain information that identifies an
individual or may with reasonable effort identify an individual (“Personal Information”). We treat information
that is specifically connected or linked to any Personal Information – as long as such connection or linkage
exists – as Personal Information. We may also disclose Personal Information we have collected with our
service providers for a business purpose (as further detailed in “Business/Commercial Purpose for Collection”
section below), subject to a contract that describes the purpose and restricts the use of Personal Information
disclosed, or with other third parties for a commercial purpose, which may be considered a sale under the CCPA,
as detailed in the following chart: In the 12 preceding months, we have collected, disclosed and/or sold
the following categories of Personal Information:
Category of Personal Information Collected Personal Information Collected Categories of service
providers to whom Personal Information was disclosed Categories of third parties to whom Personal
Information was sold Identifiers Full name, email address, physical address, IP, social media
credentials and identifiers Affiliate Companies Ad networks Data analytics providers Email
and cloud providers Auditors and advisors Other users Ad networks Data analytics
providers
Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code §
1798.80(e)) Telephone number Affiliate Companies Email and cloud providers Auditors and
advisors
Internet or Other Electronic Network Activity Information Browsing history, search history,
information on a consumer’s interaction with a website, application, or advertisement. Affiliate
Companies Ad networks Data analytics providers Email and cloud providers Auditors and
advisors Ad networks Data analytics providers
Geolocation Data Approximate geolocation Affiliate Companies Ad networks Data
analytics providers Email and cloud providers Auditors and advisors Ad networks Data
analytics providers
We may share or transfer Personal Information to third parties as assets that are part of a merger,
acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of the
Company. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a
sale of Personal Information under the CCPA.
Sources of Personal Information In the 12 preceding months, we have collected the above-mentioned
categories of Personal Information from the following categories of sources: Consumer directly; Advertising
networks; Data analytics providers; Operating Systems; Social Networks;
Business/Commercial Purpose for Collection Company only collects and processes Personal Information
in a way that is compatible with and relevant for the purpose for which it was collected or authorized. As a
general matter, for all categories of data we collect, we may use the information we collect (including Personal
Information, to the extent applicable) to: provide, operate, maintain, improve, and promote the Service; enable
you to access and use the Service; send transactional messages, including responses to your comments,
questions, and requests; provide customer service and support; and send you technical notices, updates, security
alerts, and support and administrative messages; send commercial communications, in accordance with your
communication preferences, such as providing you with information about products and services, features,
surveys, newsletters, offers, promotions and events about us and our partners; and send other news or
information about us and our partners. monitor and analyze trends, usage, and activities in connection with
the Service and for marketing or advertising purposes; comply with legal obligations as well as to
investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal
activities; personalize the Service, including by providing features, content or ads that match your
interests and preferences; and process for other purposes for which we obtain your consent.
User Rights under the CCPA The CCPA provides consumers with specific rights regarding their Personal
Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Personal Information You may request, up to two times each year, that we disclose to you
the categories and specific pieces of Personal Information that we have collected about you, the categories of
sources from which your Personal Information is collected, the business or commercial purpose for collecting
your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any
categories of Personal Information about you that we sold, the categories of third-parties with whom we have
shared your Personal Information, and the business or commercial purpose for selling your Personal Information,
if applicable.
Deletion Requests You have the right to request that we delete any Personal Information collected
from you and retained, unless an exception applies. Once we receive and confirm your verifiable consumer
request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your
Personal Information, unless an exception applies.
Right to Opt-Out of the Sale of Personal Information In the event that we sell your Personal
Information, you have the right to submit a request to opt-out of the sale of your Personal Information. You may
change your decision at any time and permit us to sell your Personal Information. If you do not want us to
sell your Personal Information to third parties, please submit your request to our email address:
contact@marketing66.com After you opt-out, we may continue to share some Personal Information with our
partners (who will function as our service providers in such instance) to help us perform business-related
functions such as, but not limited to, providing the Service, ensuring that the Service is working correctly and
securely, providing aggregate statistics and analytics and/or preventing fraud. If you access our Service from
other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to
the Personal Information collected when you use those devices or browsers.
Exercising Your Rights You can exercise your rights (such as access and deletion) by submitting a
verifiable consumer request to our email address: contact@marketing66.com Only you or a person authorized
to act on your behalf may make a consumer request related to your Personal Information. The request
must: Provide sufficient information to allow us to reasonably verify you are the person about whom we
collected Personal Information or an authorized representative. Describe your request with sufficient
details to allow us to properly understand, evaluate, and respond to it. We cannot respond to your request
or provide you with Personal Information if we cannot verify your identity or authority to make the request and
confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to
create an account with us. We will only use Personal Information provided in a verifiable consumer request to
verify the requestor's identity or authority to make the request. We will only use Personal
Information provided in a verifiable consumer request to verify the requestor's identity or authority to
make the request. You may only request a copy of your data twice within a 12-month period. If you have
any general questions about the Personal Information that we collect about you how we use it, please contact us
at contact@marketing66.com.
Response Timing and Format Our goal is to respond to a verifiable consumer request within 45 days of
its receipt. If we require more time, we will inform you of the reason and extension period in writing within
the first 45 days' period. We will deliver our written response, by mail or electronically, at your option.
Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we
will provide your Personal Information in a format that is readily useable and should allow you to transmit the
information without hindrance. We do not charge a fee to process or respond to your verifiable consumer
request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a
fee, we will tell you why we made that decision and provide you with a cost estimate before completing your
request. In case of rejection, the response we provide will explain the reasons for which we cannot comply
with your request. Please note that these CCPA rights are not absolute and requests are subject to any
applicable legal requirements, including legal and ethical reporting or document retention obligations.
Designating Agents You can designate an authorized agent to make a request under the CCPA on your
behalf if: The authorized agent is a natural person or a business entity registered with the Secretary of
State of California; and You sign a written declaration that you authorize the authorized agent to act on
your behalf. If you use an authorized agent to submit a request to exercise your right to know or your
right to request deletion, please mail a certified copy of your written declaration authorizing the authorized
agent to act on your behalf using the contact information below. If you provide an authorized agent with
power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps
and we will respond to any request from such authorized agent in accordance with the CCPA.
Non-Discrimination
You have a right not to receive discriminatory treatment for exercising your privacy rights under the CCPA. Unless
permitted by the CCPA, we will not: Deny you goods or services. Charge you different prices or rates
for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide
you a different level or quality of goods or services. Suggest that you may receive a different price or
rate for goods or services or a different level or quality of goods or services.
Record Keeping We will maintain records of consumer requests made pursuant to the CCPA and our
responses to said requests for a minimum period of 24 months. Such information will be used for any other
purpose other than records keeping requirements under the CCPA or other legal requirements such as law, court
order, subpoena, warrant or other legal judicial process. Below are metrics about the number of requests we
received and the median number of days it took us to respond to such requests: Type of Request Number
of Requests Median Number of Days to Respond Right to Know
Right to Delete
Right to Opt-Out of a Sale
Children's Information Our Service is not intended for minors below the age of 16 years or
otherwise below the legal age for providing consent that is not subject to authorization by the holder of
parental responsibility, in accordance with the laws in the jurisdiction your reside (“Age of Consent”), and we
will not knowingly collect Personal Information from children. If we become aware that a user is under the age
of Age of Consent, we will remove their information from our files. We reserve the right to request proof of age
at any stage so that we can verify that children are not using the Service.
Updates or Amendments to the Privacy Notice We reserve the right to change this Privacy Notice at any
time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy
Notice on the Service and/or we will send you an e-mail regarding such changes to the e-mail address that you
volunteered. Such substantial changes will take effect seven (7) days after such notice was provided on any of
the above-mentioned methods. Otherwise, all other changes to this Privacy Notice are effective as of the stated
“Last Revised” date, and your continued use of the Service after the Last Revised date will constitute
acceptance of, and agreement to be bound by, those changes.
How to Contact Us If you have any questions (or comments) concerning this Privacy Notice, you are
welcome to contact our Data Protection Officer here: contact@marketing66.com or through the following contact
details: Marketing66 Ltd., Bezalel Bazrawi 24, Jerusalem ISRAEL We will make an effort to
reply within a reasonable timeframe. Please feel free to reach out to us at any time.
For Brazilian users: The processing of your personal information is not a condition for the use our
Service. However, certain parts of our Service may not be available without processing of personal
information. If you reside in Brazil, under the Brazilian Data Protection Law (Lei Geral de Proteção de
Dados) you have the following rights regarding your Personal Information: (1) Receive confirmation as to whether
or not Personal Information concerning you is being processed; (2) Access to your stored Personal Information;
(3) Request correction of incomplete, inaccurate or out-of-date Personal Information; (4) Request anonymization,
blocking or deletion of unnecessary, excessive Personal Information; (5) Request data portability to another
service provider or product, upon express request, as may be provided by the appropriate law; (6) Request
deletion of Personal Information processed with your consent; (7) Obtain information about the public or private
entities with whom we share your Personal Information; (8) Request information on the possibility of you not
providing consent, as well as being informed about the consequences should consent not be given; (9) Revocation
of your consent. If you wish to exercise any of the abovementioned rights or raise a complaint on how we
have handled your Personal Information, please contact us directly at: contact@marketing66.com. We will
retain your personal information for the duration required to provide our Services, and as necessary to comply
with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined
taking into account the type of information that is collected and the purpose for which it is collected, bearing
in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the
earliest reasonable time. Under applicable regulations, we will keep records containing personal data,
communications and anything else as required by applicable laws and regulations. We may rectify, replenish
or remove incomplete or inaccurate information, at any time and at our own discretion. Security and
Confidentiality The Company treats your Personal Information in strict confidentiality, and the server in
which this data is to be stored includes the necessary industry-standard security measures to prevent accidental
or unlawful destruction, loss, alteration, unauthorized disclosure or access. However, we cannot completely
guarantee the security of your information, which might be accessed, disclosed, modified, or destroyed, and it
should be emphasized that you share this information at your own risk.
Links to Other Websites This Privacy Policy applies only to the Service, and to our web tools which
are integrated or implemented in other third party websites. The Policy does not apply to third party websites,
linked to our Website. Third party websites or services may have their own privacy policies and we advise you to
read them carefully. Inclusion of a link to a third party website or service is not a recommendation of such a
website or service. Third party sites may contain information or services that are illegal or that some people
may find inappropriate or offensive. Before using third party sites and services or before making a purchase, we
recommend that you read and understand the privacy policies and terms and conditions of such third party
websites and services, and the warranties for purchased products. You are knowingly and voluntarily assuming all
risks of using third party sites to purchase products and services. You acknowledge and agree that we shall have
no liability whatsoever with respect to such third party sites and your use of them.
Assignment Subject to applicable law, we may transfer or assign your information, without any notice,
and without a need to receive your consent, to any third party as a result of change of control, consolidation,
merger, acquisition or reorganization. You acknowledge that in the event of bankruptcy, insolvency or
receivership, we may have no control over the use and transfer of your Personal Information.
Updates to this policy This Privacy Policy is subject to modifications. Please check the “Last
Modified” heading at the bottom of this document to see when this Privacy Policy was last updated. Any changes
to this Privacy Policy will become effective when we post the revised Privacy Policy on the Website. In case of
material changes to this Privacy Policy, we will provide a notice in the Website. Your use of the Website or the
Service, or your provision of personal information following any changes means that you accept the updated
Privacy Policy.
