Last updated February 19, 2017
This XTGlobal Online Privacy Notice (Notice) applies to www.xtglobal.com, www.circulus.io and app.circulus.io. The term “XTGlobal” or “we” or “us” or “our” in this Notice refers to XTGlobal and its affiliates or subsidiaries that link to this Notice. This Notice describes how Sites may collect, use and share information from or about you and explains how information may be collected and used based on online interactions with our advertisements that appear on the Sites and third party websites. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged XTGlobal.
XTGlobal complies with the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. XTGlobal has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view XTGlobal certification, please visit https://safeharbor.export.gov/swisslist.aspx
XTGlobal participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. XTGlobal is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]
XTGlobal is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. XTGlobal complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, XTGlobal is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, XTGlobal may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
XTGlobal provides other online interfaces not covered by this Notice. If you visit or access your accounts from one of these sites, please review the online privacy practices of that site to understand how your online information may be collected, used and shared.
Please note the terms and conditions of this Notice control. By using the Site, you agree to the terms and conditions of this Notice.
Personal Information We Collect Online
We collect the following personal information on this Site: name, postal or email addresses, telephone, fax or mobile numbers, social security number, date of birth, credit card and bank account information.
We may use Personal Information collected on our Site:
We may use Personal Information in our Service:
XTGlobal also collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processed. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our Service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
We obtain credit information about you from an outside credit reporting agency to help us with customer authentication and credit-related decisions.
We will share your personal information with third parties only in the ways that are described in this privacy notice. We do not sell your personal information to third parties. We may provide your personal information to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.
In certain situations, XTGlobal may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We may also disclose your personal information:
Our Site offers a publicly accessible blog pages. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our pages, contact us at contact@XTGlobal.io. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Upon request XTGlobal will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at contact@XTGlobal.io.
If your personal information changes, or if you no longer desire our service, you may correct, update, amend, ask to deactivate your account by making the change on your member information page or by emailing our Customer Support at contact@XTGlobal.io or by contacting us by telephone or postal mail. We will respond to your request to access within 30 days.
XTGlobal has no direct relationship with the individuals (who do business with XTGlobal’s Client) whose personal data it processed. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the XTGlobal’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.
If you have signed up to receive marketing communications from us, you may choose to stop receiving these emails by you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can email us.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. XTGlobal will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We and our third-party service providers may collect and use Other Information in a variety of ways, including:
XTGlobal advertises on pages within the Sites as well as on other websites and mobile apps not affiliated with XTGlobal. Information collected by us or our advertising service providers through cookies and other technologies includes the number of people who look at each of the pages on the Sites, search engine referrals, browsing patterns within the Sites, and responses to advertisements and promotions on the Sites and on websites where we advertise.
Advertising on our Sites
XTGlobal advertises our products and services on pages within the Sites. These advertisements may take the form of banner ads, splash ads (ads that appear as you sign on or sign off of your online accounts), and other formats.
Relationship based advertising
XTGlobal may customize content and advertisements for our products and services on the Sites we own. In order to make the content and advertising as informative and useful as possible, we may use information about your relationship with us (such as types of accounts, transactional information or the state in which you bank).
Online Behavioral Advertising
We also use advertising service providers to help us determine which of our advertisements are most likely to be of interest to you using certain Other Information such as web pages visited, search keywords entered, or your activities on our Site. We limit access and collection of information for specific purposes by advertising service providers.
Advertising on third party sites
XTGlobal contracts with advertising companies to advertise our products and services on websites and mobile apps not affiliated with us. We may use Aggregated and De-identified Data and information provided by you to these third party websites to select which of our advertisements or offers may appeal to you, display them to you and monitor your responses. Third Party websites are not subject to XTGlobal Privacy Notices. Please visit the individual websites for additional information on their data and privacy practices and opt-out policies.
Online Behavioral Advertising
Some of our customized ads are behavioral advertising, and may be served using data collected through cookies and other technologies by third party websites. Cookies placed on our behalf by these companies, do not contain or capture Personal Information. We limit companies that place our ads from using information for any purpose other than to assist us in our advertising efforts.
XTGlobal’s Mobile Applications for U.S. accounts (“Applications”) allows you to access your account balances and pay bills on your mobile device. This Notice applies to any personal information or other information that we may collect through the Applications.
Linking to other sites
We may provide links to third party websites, such as credit bureaus, service providers or merchants. If you follow links to websites not affiliated or controlled by XTGlobal, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our Sites. XTGlobal does not guarantee and is not responsible for the privacy or security of these websites, including the accuracy, completeness, or reliability of their information.
You may also use your Intuit account to log into your XTGlobal account. If you are an Intuit QuickBooks user, you may choose to import information to your XTGlobal account.
Social media sites
To protect Personal Information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. These measures may include device safeguards and secured files and buildings as well as oversight of our third party service providers to ensure information remains confidential and secure.
Our fraud prevention and security systems protect you with the latest encryption technology and secure email communications. Computer anti-virus protection detects and prevents computer viruses from entering our computer network systems while firewalls block unauthorized access by individuals or networks.
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at contact@XTGlobal.io
XTGlobal uses encryption technology, such as Secure Socket Layer (SSL), on its website to transmit sensitive information, such as financial information. This protects data in 3 key ways:
Using other aggregation websites
Other companies offer aggregation websites and services that allow you to consolidate your financial account information from different sources (such as your accounts with us or with other financial institutions) so that you can view all your account information at one online location. To do this, an aggregation provider may request access to Personal Information, such as financial information, usernames and passwords. You should use caution and ensure that the aggregator company has appropriate policies and practices to protect the privacy and security of any information you provide or to which they are gaining access. We are not responsible for the use or disclosure of any Personal Information accessed by any company or person to whom you provide your Site username and password.
If you provide your Site username, password or other information about your accounts with us to an aggregation website, we will consider that you have authorized all transactions or actions initiated by an aggregation website using access information you provide, whether or not you were aware of a specific transaction or action. If you decide to revoke the authority you have given to an aggregation website, we strongly recommend that you change your password for the Site to ensure that the aggregation website cannot continue to access your account.
Making sure information is accurate
Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please use the Contact Us option on our Site, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials. You can also speak to a customer representative or account representative.
Protecting individual health information
To the extent that we receive, maintain, or process an individual’s protected health information, XTGlobal may disclose that information electronically as authorized by and in accordance with applicable federal and/or state law.
Updates to this Privacy Notice
We may update this Notice to reflect changes to our information practices. If we make any significant changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Please review this Notice periodically. If we make changes to the Notice, we will revise the “Last Updated” date at the top of this Notice.
Toll Free: (866) 446-2910
Direct: (972) 755-1800
2701 North Dallas Pkwy Ste 550
Plano, TX 75093
The Circulus Security Policy applies to the security policies, safeguards and procedures as implemented throughout the Circulus web application housed on app.circulus.io. The terms “Circulus,” “we,” “us,” and “our” in this document refer to Circulus and its affiliates or subsidiaries that link to this document. Circulus recognizes that protecting our customer’s data is a fundamental and paramount priority, and the details below outline our security and access controls in place to ensure the highest levels of online security: