Privacy Policy

Effective as of February 14, 2024

This Privacy Policy explains how XTEN Limited ("XTEN", "we", "us" and "our"), the data controller, collects information about you, including personal information when you interact with our website www.joinufl.com ("Website"), our mobile application UFL Assistant (“App”) and related products, services, or other online activities (collectively, the “Services”). Capitalized terms that are not defined in this Privacy Policy have the meaning as defined in our Terms of Use or Cookie Policy.

This Privacy Policy explains what information we collect, why we collect it, how we use it, who we share it with, where it is processed, how we handle it, and your rights and choices regarding this information. 

For further information about this Privacy Policy or our processing of your personal information, please contact us or our data protection officer:

Postal address:

XTEN Limited 

169 Archiepiskopou Makariou III, 

CEDARS OASIS TOWER, Floor 7, Flat/Office 701,

3027, Limassol

Republic of Cyprus

Email address: 

privacy@strikerz.inc

dpo@strikerz.inc 

XTEN Limited is registered in Cyprus under company number HE365174. XTEN Limited is the controller for the personal information we process, unless stated otherwise.

XTEN provides privacy notice through this Privacy Policy and other timely means, like popups and cookie notifications to let you know about our privacy practices.

Information we collect or receive

XTEN collects different types of personal information about you when you use the Services. Anonymized or aggregated information is not personal information.

Information you provide to us

We collect the information that you directly provide to us when you enter it on the Website or include it in an email or other messages that you send to us. Such kind of information collection would happen during usual business support processes, such as technical support. We may ask you to provide information such as name, email address, date of birth, country if you decide to take part in promotions and other events, market research surveys, beta and other user testing research, and if you agree to receive marketing information from us.

Information we collect automatically

We may also automatically collect information when you use the Services. Some of this information may be collected with the help of cookies and similar technologies. Please read more about our cookies use in our Cookie Policy.

We may collect device-specific and device event information, such as hardware model and settings, operating system version, device memory information, browser type, browser language, unique device identifiers, system activity, crashes data. 

Some information that we collect automatically may be location information, such as Internet protocol address, geolocation/tracking details, cookies, and similar tracking technologies. 

We may collect information of how you use our Services, such as your general use patterns, search queries details, engagement with the Services features and areas, frequency of visits and use.

Information received from third parties

We may receive information from third-party sources and combine it with the information we receive directly from you. We will handle this information in accordance with this Privacy Policy.

Processing of personal information

XTEN endeavors to provide you with the best level of information privacy and security practices recognized globally and strives to guarantee the highest level of information protection. The personal information is processed in compliance with the General Data Protection Regulation 2016/679 (GDPR), the Law 125(I)/2018 of the Republic of Cyprus and other applicable data protection laws and regulations of the respective data protection supervisory authorities. We are transparent about our privacy practices and follow the principles of data minimization, purpose limitation, accuracy and accountability.

With regard to the rules and principles of the applicable data protection laws and regulations, we have adopted appropriate technical and organizational measures in order to ensure protection of personal information and your rights as the data subjects.

We limit the retention period of personal information to the terms necessary to achieve the purposes of processing it or as far as this is stipulated in laws and regulations to which XTEN is subject to. For example, XTEN may retain personal information for the term needed to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

We process personal information under the following legal bases and for the designated purposes.

If we ask for your consent as the legal basis for processing of your personal information, you have the right to withdraw your consent at any time. However, our processing of your personal information preceding such withdrawal will remain lawful. 

You also have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, and thus we avoid any automated decision making, including profiling that can produce any legal or similarly significant effects for our Website visitors or Service recipients.

Third-party and further processing

We engage third-party service providers that help us make the Website run and help us support the Services. Such third-party service providers are, among others, cloud storage providers, IT and security service providers, product development and customer support tools, marketing and analytics tools.

We will never sell or otherwise disclose your personal information. Only our service providers, conditionally to ensuring adequate security and protection measures, may process information as an essential part of their services provision to us.

We will process your personal information only for the designated purposes, and in case we need to process it for any new purpose, we will do so only upon your consent. 

International transfers of personal information

We may transfer your personal information in and outside the EEA, EU, UK, Switzerland or the U.S.A in the course of the Services provision. We apply the EU Standard Contractual Clauses approved by the European Commission, the UK International Data Transfer Agreement and other appropriate mechanisms for any such transfer and ensure that such transfers occur only if there are adequate levels of protection in place. 

By using our Website and Services or providing us with any information through them, you acknowledge such transfer, processing, and storage of your personal and other information in countries in which privacy regulations may be not as comprehensive as those in the country of your residence. 

Your privacy rights

You have the rights to your personal information as described below and you can exercise them by contacting us at privacy@strikerz.inc. We shall consider your request under applicable legal provisions. In case we receive particular rights request, we may be obligated to verify such request and thus, ask you to verify your identity before complying with the request to protect your privacy and security.

Right of access and portability. You have the right to request that we inform you which personal information associated with you we process and to request that we provide you with a copy of that information without undue delay in a structured, commonly used, and machine-readable format, or to request that we transfer your personal information directly to another data controller in case that would be technically feasible and would not adversely affect the rights and freedoms of others. 

Right of rectification. You have the right to request that we correct or update any inaccurate or outdated personal information associated with you. 

Right of erasure. You have the right to request that we erase the personal information associated with you in some circumstances as defined by law. You may request that we erase the personal information that we process on basis of your consent, and you no longer consent to our processing it, you may request that we erase the personal information in case it is no longer necessary for the designated purposes, or the personal information that we process for activities to which you object, and we do not have any overriding legitimate basis for processing.

Right to restriction of processing. You have the right to restrict our processing of your personal information in case the accuracy of your personal information is under question and you have made the request to correct such information, you can also restrict our processing of your personal information if you claim that it is unlawful and you do not request to erase it, or you may restrict our processing of your personal information when we do not longer need it for the designated purposes, but you need it to establish, exercise, or defend legal claims.

Right to object to processing. You have the right to object to our processing of your personal information when we process it on the basis of consent, contract, or legitimate interests, for example, you can object to processing of your personal information for direct marketing purposes. However, we can continue to process your personal information if it is necessary to defend a legal claim, or under any other legally permitted exception.

If you have any questions or concerns about our processing of your personal information, please get in touch with us first at privacy@strikerz.inc, and we will do our best to resolve your query. You are also entitled to contact and lodge a complaint with a data protection supervisory authority, you may find the list of EEA national data protection authorities here, the contact details of the UK Information Commissioner’s Office here, and the contact details of the Swiss Federal Data Protection and Information Commissioner here.

Protection of children’s personal information

We pay particular attention to protecting the rights of children. Thus, we recommend that all persons under the age of 18, notwithstanding their place of residence and the age of consent under the local law, first ask their parents or other legal guardians to explain to them the meaning of this Privacy Policy. We will ask parents or other legal guardians to provide their consent to send some advertisement materials about our future products to persons under the age of 18. We will never collect or process any sensitive personal information concerning children. In case we have concerns about the age of consent or have reasonable doubts about the age of our Services recipients, we will ask for identity, and take immediate actions to erase all personal information and cease its processing as soon as possible. 

Changes to this Privacy Policy

We may, in our sole discretion, from time to time amend this Privacy Policy. You are deemed responsible for reviewing this page for the latest information regarding our privacy practices. If you continue to use the Website and (or) our Services after any such amendments come into effect, you acknowledge your acceptance of the amendments made to this Privacy Policy. In case you do not accept the terms of this Privacy Policy and do not want your personal information to be processed in accordance with it, you should discontinue to use the Website and the Services.