Privacy Policy

This Privacy Policy is effective from 17th June 2019

Please read XPT’s Privacy Policy before using XPT’s services because it will tell you how we collect, store, use and disclose your personal information when providing these services to you.


“XPT,” or “we” or “us” refers to XPT in this Privacy Policy. This privacy policy does not apply to XPT services offered by or through our partners, resellers or other third parties, or other third party services or websites, and we encourage you to read the privacy policies of those parties.

This Privacy Policy applies whenever you access any of our products, services, content, and/or the other domains provided by XPT, together referred to as “Services.” This Privacy Policy describes:

  1. what information we collect, how we collect it, and why
  2. how we use that information and with whom we share it
  3. how you can access and update that information
  4. the choices you can make about how we collect, use, and share your information
  5. how we protect the information we store about you

In order to communicate with you and to provide our products and services and related support, it is necessary for XPT to transfer your personal data outside where you are located. In such case, the data controller for this data is XPT.

If you do not want XPT to collect, store, use or share your information in the ways described in this Privacy Policy, you may not use XPT’s Services.

Information We Collect and How We Collect It

For example, XPT may collect and store some or all of the following information:

  1. your first and last name;
  2. your profile picture or its URL;
  3. your user ID number (like your Facebook ID number), which may be linked to publicly-available information like your name and profile photo;
  4. the user ID number and other public data for your friends;
  5. the login e-mail you provided;
  6. your physical location and that of the devices you use to access our Services;
  7. your gender;
  8. your birthday and/or age range;
  9. other publicly-available information on the third-party application; and/or
  10. any other information that you or the provider of the third-party application share with XPT.

If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Policy.

If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

Cookies and Automated Information Collection

We and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as:

cookies, which are small pieces of data transferred to your mobile device or computer for record-keeping purposes;

web beacons, which let us know if a certain page was visited or whether an e-mail was opened;

tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively; and

local shared objects, also known as flash cookies, which help us to reduce fraud, and speed up load times.

Except requested, we will either delete the Application Log Data or remove any account identifiers, such as your username, full IP address, or email address, after 12 months.

We and our service providers use these log files, tags, and tracking technologies to collect and analyze certain kinds of technical information such as diagnose and improve our services, including:

  1. IP addresses;
  2. the type of computer or mobile device you are using;
  3. your operating system version;
  4. your mobile device’s identifiers, like your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
  5. your browser types;
  6. location;
  7. your browser language;
  8. referring and exit pages, and URLs;
  9. platform type;
  10. the number of clicks on a page or feature;
  11. domain names;
  12. landing pages;
  13. pages viewed and the order of those pages;
  14. the amount of time spent on particular pages; and

In some cases, we will connect this information with your social network ID or XPT user ID.

We collect information from you when you (i) request for quotation or place an order for a XPT product or other product or service, (ii) apply for access to our managed service platforms, (iii) subscribe to our newsletter, (iv) use our online chat service, (v) register for marketing event, (vi) respond to a survey, (vii) fill out a form for pre/post sales assistance, (viii) open a support ticket, or (ix) your use of social media.

XPT is an internet service provider and a trusted third party. To fulfill requests for our products or services, you may be asked to enter your name, email address, physical address, phone number, credit card information and/or organizational details or other personal information.

We may develop and acquire additional information about you using third‐party sources, browsing, and purchasing history, and so on in order to process certificate requests and to improve our services.

XPT treats personal information as confidential, except for the information included in an issued digital certificate. Such information may be verified using third party commercial and government resources, and as such, is deemed to be public information.

Information About You That You Share With Us Directly

When you use our Services (whether through a social network or through XPT directly), you may give us information directly (like when you’re setting up your account) and we will store that on our systems and use it for the purposes described in this Privacy Policy.

Parts of our Services may use a more traditional registration or account set-up process where you may be asked to give us some or all of the following information:

  • your age or birthday;
  • your first and last names;
  • your e-mail address;
  • a password; and
  • other information that helps us make sure it’s you accessing your account or helps us improve our services.

To fully access our Services, you may be asked to provide following identity information:

  • Identity card or Passport;
  • Phone number;
  • Contact information;
  • Payment information.

We may also let you create a player profile, separate from your social networking site profile (for example, your Facebook profile), that other XPT players can see. Your player profile may include information like:

  • a profile photo;
  • username(s);
  • your gender;
  • biographic details (like your age or age range);
  • approximate location information that you provide;
  • links to your profiles on various social network;
  • a XPT ID number that is created by XPT and used to identify your profile.

You are responsible for providing XPT with true, accurate, current and complete personal information. Also you are responsible to maintain and promptly update the information to keep it true, accurate, current and complete.

You have the right to access and modify your personal data stored on XPT customer portal. You can request to access or modify your personal information by contacting us in writing. We will require you to provide identification in order to verify the authenticity as the data subject. We will make reasonable effort to respond to and process your request in a timely manner.

If you provide any information that is untrue, inaccurate, not current or incomplete, or if we have reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, we have the right to suspend or terminate your account and refuse any and all current or future services.

Payment Information

If you purchase a license to use virtual currency or virtual items on, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address and financial information. XPT does not collect or store your financial information, like credit card numbers. However, XPT’s payment processors may share non-financial information with us related to your purchases, like your name, billing address and the items purchased in order to fulfill your order. XPT may also obtain the billing and payment information that you provide when your purchase is processed by someone else (like Apple or Google) such as when you purchase something or that you downloaded on your mobile device. Our Term of Services explain our policies and terms relevant to our charges, billing practices, third-party credits and virtual currencies. Please note that purchases of third party credits or currencies may also be subject to those parties’ policies.

Customer Support Correspondence

Except as provided herein, when you ask for help from us, we will collect and store the contact information you give them (generally, your name and e-mail address), activity on our Services, and your XPT player and/or social network ID number. We will also store the communications you have with Us and any information in those communications in order to provide support and improve the Services.

Other Sources

We may collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly.

How We Use the Information We Collect

The main uses of the information we collect and store is to provide a better Services and facilitate communication, but there are other uses as well. Your information, whether public or private, will not be sold, exchanged, transferred outside of our group company, or given to any other company for any reason without your consent, other than for the purposes specified in below:

  • to operate, improve and optimize our Services;
  • to personalize our Services to you;
  • to provide technical support, respond to your inquiries, and keep you informed of your activity;
  • to protect the safety and well-being of XPT users;
  • to protect XPT's rights and property in connection with our Services;
  • to prevent fraud or potentially illegal activities, and to enforce our Terms of Service;
  • to manage and deliver contextual and behavioral advertising;
  • to send you renewal notices for your expiring product subscriptions;
  • to send you periodic company newsletters, new service updates, security updates, related product or service information, and status updates on maintenance windows or service availability;
  • to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
  • to comply with our legal obligations, resolve any disputes we may have with you, and to enforce our agreements with third parties; and
  • to conduct research.

How We Share Your Information

We may disclose or publish aggregated information and other non-personal information about our customers for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.

In addition, we may share your information (which may include personal information) with third parties (in other words, parties other than XPT) or allow third parties to collect this information from our Services in the following circumstances:

Your Consent

With your consent, we may share your information with third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy.

We will process your data for the purpose of performance of our contract with you or the legitimate interest of our business. In other cases, we will request your consent for the processing of the personal data you may submit.

Your refusal to provide personal data to us for certain products and services may hinder us from fulfilling your order for those products or services. Also, if you deny or withdraw your consent to use personal data or opt out of receiving information about XPT products and services this may result in you not being made aware of sales promotions, renewal notices, periodic company newsletters, new service updates, security updates, related product or service information, and status updates on maintenance windows or service availability.

Third-Party Advertising Including Tailored Advertising and Analytics

We have advertising on our Services so we can continue to offer many of our Services for free.

We do not actively share personal information with third-party advertisers for their direct marketing purposes unless you give us your consent.

When advertisers or ad networks place ads in our Services, they may collect or we may share the following types of information from within our Services:

  • performance data (like the number of clicks on an advertisement);
  • aggregated and/or de-identified information about you and other players collectively that is not intended to specifically identify you (like people between the ages of 30 and 45);
  • certain technical information (for example, IP addresses, non-persistent device identifiers such as IDFAs);
  • your social network ID;

The information collected may be used to:

  • measure how effective ads are, to offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioural advertising), and/or
  • undertake web analytics (like Google Analytics which is used to analyse traffic and other player activity to improve your experience).

Please note, after clicking on a third party advertisement, you may no longer be on a site hosted by XPT.

Safety, Security and Compliance with Law

Your information, and the contents of all of your online communications in our Services and between You and XPT may be accessed and monitored as needed to provide our Service and may be disclosed:

  • when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena);
  • to satisfy any laws or regulations that apply;
  • where we believe in our sole discretion that the Service is being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
  • when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and
  • to protect the rights or property of XPT and other applicable third parties, including to enforce our Terms of Services.

It is our policy to notify customers of requests for their data from law enforcement unless we are prohibited from doing so by statute or court order. Law enforcement officials who believe that notification would jeopardize an investigation should obtain an appropriate court order or other process that specifically precludes member notification.

Partner Organizations and Third-Party Service Providers

XPT partners with a few global organizations with business processes and technical systems in various countries. As such, we may share information about you within our group company and transfer it to countries in the world where we do business in connection with the uses identified and in accordance with this Privacy Policy. In these cases, personal data will be transferred to countries that do not provide an adequate level of protection so we ensure your data is protected by entering into agreements containing standard contract clauses with each of our group companies.

XPT do not sell or trade your personal information to outside parties.

We may also transfer your personal data to trusted third parties in order to serve purposes that are specified in this Privacy Policy. In circumstances where data is shared with such third parties, they are required to agree to confidentiality terms. This prohibits such third parties from selling, trading, using, marketing or otherwise distributing XPT customer data.

Sale or Merger

In the event that XPT undergoes a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part its assets, we may disclose or transfer all of your information, including personal information, to the successor organization in the transition. We will make reasonable efforts to let you know of the business transition before transferring your personal information.

How to Access, Update and Manage Your Information

Accessing and Updating Your Information Held by XPT

If you want to review, delete, or change the information XPT has about you or have additional questions.

Stopping Use of Your Information

If you no longer want XPT to make active use of your information, you may send an e-mail to Us at [email protected] to withdraw consent anytime. Place "Delete My Account" in the subject line and include your first name, last name, e-mail address and your social network ID for the social network from which you access our Services (if applicable) in the body of the e-mail. Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have sent content through or posted content on the Service, we may not be able to delete it.

Opting Out of Promotional Emails from XPT

If you want to stop receiving promotional e-mails from XPT, click on the "unsubscribe" link in any promotional email from XPT. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly.

Opting Out of Cookie Tracking

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies.

Privacy Policies of Linked Third-Party Services and Advertisers

Our websites may contain advertisements from Third-Party Services, which are companies other than XPT that may link to their own websites, online services or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your information, you should review their policies and contact them directly.

How Long We Keep Your Information

How long we retain your information depends on why we collected it and how we use it. We will retain your personal information for a period required for our business purposes or by law or regulation that XPT is obligated to follow. For instance, we may retain some information for a few years after you have closed your account with us if this is necessary to meet our legal obligations or to exercise, defend or establish legal rights.

Even if you request deletion or erasure of your data, we may retain your personal data to the extent necessary and for so long as necessary for our legitimate business interests or performance of contractual obligations.

After the retention period is over, XPT securely disposes or anonymizes your personal information in order to prevent loss, theft, misuse, or unauthorized access.

Security of Your Information

We implement security measures to help protect the security of your information both online and offline. We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your information.

We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL).

After a transaction, your transaction‐related information will be kept on file to meet audit requirements and facilitate renewals. We do not retain any credit card details.

XPT uses a reputable third party to process credit card payments and needs to provide credit card numbers and identifying financial data directly to the third party credit card processor. Such information is shared securely.

If you have an account registered directly with XPT, your profile information is protected by the password you use to access your XPT account. It is important that you protect and maintain your XPT account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your XPT account, the Service allows you to request that instructions be sent to you that explain how to reset your password. We urge you to log out of your XPT account after you use it.

When you sign into your XPT account or enter payment information, we or our third-party payment processor use encryption to transmit that information.

While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk.

  • We use the data you submit only for purposes identified in section 3 of this privacy policy.
  • You have the right to review your personal data that XPT holds and check it for accuracy.
  • You have the right to correct data in the case that errors may be found in our records.
  • You have the right to request that any of your personal data be erased. i.e. right to be forgotten.
  • You have the right to obtain and reuse use your personal data for your own purposes.
  • You have the right to request that XPT restrict the processing of your personal data under certain circumstances.
  • You have the right to object to our processing of your personal data.

Changes to Our Privacy Policy

If we decide to make material changes to our Privacy Policy, we will tell you and other players by placing the new Privacy Policy on or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. You should periodically check and this privacy page for updates.