EXaholics LLC (EXaholics) is committed to protecting and respecting your privacy.
This is an anonymous recovery program and we protect your anonymity by collecting as little personal information as possible. We will only approve accounts with anonymous usernames. First and last names as usernames are not permitted. We repeat, nowhere on this site will your real identity appear, as long as you do not use your real name or any personally identifiable details (such as names of family, friends, or your ex) in your profile or when using the Site.
We do require a very minimal amount of personal information for our Services to function. The only such information we require are your email address and login details, NONE of which will appear in public on the site. Personal data, or personal information is defined as information about an individual from which that person can be identified. This is not for public use. And it does not include data where the identity has been removed (anonymous data).
This policy sets out the basis on which the minimal personal data we collect from you, or that you provide to us, will be processed, stored and disclosed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.exaholics.com (the Site) or using any services offered through or associated with our Site (the Services), you are deemed to have accepted and consented to the practices described in this policy.
The Site is owned and operated by EXaholics LLC, a New York limited liability company of PO Box 381 Radio City Station, New York, NY, 10101 (our Company Address). If you are an EU citizen, note that EXaholics processes personal data as a data controller, as defined in the Directive and the General Data Protection Regulation (GDPR).
The Site contains links to and from the websites of our partner networks, advertisers and affiliates or to websites shared by other users. If you follow a link to any of these other websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
1. Data We Collect About You
We collect and process your email and login details, considered personal information, so we can provide our Services to you. It’s important that the personal data we hold about you is accurate and current. Please keep us informed if this personal data changes during your relationship with us.
The data we collect and process about you is explained in the sections below.
1.1 Data You Give Us
You give us information about you by filling in forms on our Site or by corresponding with us by e-mail or otherwise. This includes information you provide when you register to use the Site, subscribe to our marketing database, subscribe to our services, use a search function on our Site, place an order on our site, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey, report a problem with the Site, use live chat, forums, direct messages to other member and watch or comment on videos. These activities are seen on the site as exercised by the username you create.
The only personal information we require to use our Services is your email address and login details. This data is necessary for our legitimate interest in providing the interactive features of our Services to you.
You may, but do not need to, provide your name if you contact us via our Contact Form, but we will never display or share this information. We collect this information for our legitimate interest in responding to your communications.
1.2 Data We Automatically Collect
Each time you visit or use our Site, we automatically collect the following information (but we do NOT publicly share this information on the Site or App):
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, network data, browser plug-in types and versions, languages, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
We use this information as statistical data about your browsing actions and patterns, for system administration, and to evaluate, provide, protect or improve our Services (including by developing new products and services). Because we collect, use and share this information in the aggregate, it does not identify any individual.
1.3 Data We Receive From Third Parties
We use third parties such as Tidio Chat Services to collect IP addresses, Mailchimp to store email addresses and Google Analytics to process non-specific user information. For more information on how these companies handle your personal data, please refer to their privacy policies.
This data is necessary for us to fulfill our legitimate interest in providing and marketing our Services, and we rely on this as a lawful basis to use and process the data described above.
2. How We Use Your Data
We use your data to carry out our Site and Services in the following ways:
To administer and manage your account, to provide you with information you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.
To ensure that content from our Site is presented in the most effective manner for you and for your device.
To allow you to participate in interactive features of our Service when you choose to do so.
To respond to communications from you and to provide you with information about our Services, including notifying you about changes to our Site or Services.
We also use your data to make our Site and Services better in the following ways:
To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
As part of our efforts to keep the Site safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.
We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable data protection laws. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about services similar to those which were the subject of a previous enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have expressly consented to this.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us in writing or by email at info@exaholics.com.
3. How We Secure Your Data
All of your personal information is protected and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect. Your information is stored on secure cloud databases, internal servers, and on third party softwares. Your information is only accessible by employees who have authorised access rights to such information. All of your payment information is encrypted using SSL technology.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we use strict procedures and the security features described above to try to prevent unauthorised access.
4. How Long We Store Your Data
We only keep your personal information for as long as it’s necessary for our original legitimate purpose for collecting the information and for as long as we have your permission to keep it. We will delete your personal information when you delete your account by unsubscribing from our Services.
5. Disclosure to Third Parties
5.1 Parties with whom we share your information
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. As we mentioned above, we use third parties such as Tidio Chat Services to collect IP addresses, Mailchimp to store email addresses and Google Analytics to collect non specific user information. These third parties have access to data we share with their platforms.
The only other circumstances under which we would share your personal data are:
If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
In the event that we sell or buy any business or assets, in which case we may disclose your personal data (email address and login/username info) to the prospective seller or buyer of such business or assets.
If the Company or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.
If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
5.2 Parties with whom you may choose to share your information
Please note that EXaholic is an anonymous recovery program. Any content you may choose to share on the Site must not in any way reveal personal information that can result in having your personal identity be known. However, any information you choose to share, be it photographs or other content that you voluntarily submit to the Site either on private messages or to public forums or other public areas of the Site, may be re-shared by others. Content you share should be anonymous and should not include information that could identify you.
If you choose to connect to social media networks from our Site or post any of your content on our Site to those networks, then in accordance with your social media privacy settings, the personal information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of those networks and we have no control over such viewing and use and cannot prevent further use of such information by third parties. When you interact with us through social media networks, you acknowledge that we may access your information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any information posted via social media through our Site or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that information visible to third-parties who can use that information at their discretion.
You may review, modify, update, correct or remove any personal data you have submitted to the Site by a timely edit or by request to the administrators of the Site. If you remove information that you posted to the Site, copies may remain viewable in cached and archived pages of the Site, or if other users or third party APIs have copied or saved that information.
It is against the rules of the Site to post personal data (other than the username you create). Always think carefully before disclosing personal information to other users or otherwise posting personal information or data on the Site. It’s important that you’re aware that any data or information you choose to disclose on the Site may then be viewed and even used by other users (in accordance with your settings and this Privacy Policy). Nothing you post should give anyone the opportunity to deduce who you are. (For example, do not share the date of your breakup, your age, birthday, city you live in, where you work or what you do.) We do not control the contents of communications made between users (although you can make a complaint about another user by contacting us using the information provided in the Contact section below).
You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons (including your ex).
6. International Transfers
The data that we collect from you is transferred to, and stored at, a destination outside the European Economic Area (EEA). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated as securely as it would be within the EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of Commission-approved Model Contractual Clauses. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in the Contact paragraph below.
7. EU Citizens’ Rights under the GDPR
The following sections apply to EU citizens.
7.1 Lawful Bases
We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one of the following bases applies:
You have given your clear consent to the processing of your personal data for a specific purpose.
Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
Processing is necessary for our compliance with the law.
Processing is necessary to protect someone’s life.
Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests, such as allowing us to effectively and efficiently manage and administer the operation of our business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials, offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.
7.2 Data Subject Rights
Under the GDPR, EU citizens have the right to:
Withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
Correct or supplement any information we hold about you that is incorrect or incomplete.
Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
Object to the processing of your data.
Obtain your data in a portable manner and reuse the information we hold about you.
Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
You have the right to ask us not to process your personal data for marketing purposes. We will get your express opt-in consent before we use your data for such purposes or share your personal data with any third parties for such purposes, but you can exercise your right to prevent such processing by contacting us at the Company Address, via email at info@exaholics.com, or by unsubscribing using the links contained in the marketing emails.
You may revoke your consent for us to use your personal data as described in this Privacy Policy at any time by emailing us at info@exaholics.com, and we will delete your data from our systems. To enforce any of the above rights, please contact us at our Company Address or via email at info@exaholics.com.
We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.
Cookies
A cookie is a small file of letters and numbers that we store on your browser. Cookies contain information that is transferred to your computer's hard drive (or the hard drive of another relevant device). We use cookies to distinguish you from other users on the Site, to tailor your experience to your preferences, and to help us improve the Site.
Some of the cookies we use are essential for the Site to operate. If you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Site.
Before any non-essential cookies are placed on your device, you will be shown a pop-up message requesting your consent to setting those cookies. By default, most internet browsers accept cookies, but you can choose to enable or disable some or all cookies via the settings on your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. For further details, please consult the help menu in your internet browser.
Functionality cookies. These cookies are used to recognize you when you return to the Site. They enable us to personalize our content for you and remember your preferences.
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Changes To Our Privacy & Cookie Policies
Any changes we may make to our Privacy & Cookie Policies in the future will be posted on this page and, where appropriate, notified to you by email. You will be deemed to have accepted the terms of the updated Privacy & Cookie Policies on your first use of the Site following the alterations. Please check back frequently to see any updates or changes to our Privacy & Cookie Policies.
Contact
Questions, comments and requests regarding this Privacy & Cookie Policy are welcomed and should be addressed to our Company Address or to our email at info@exaholics.com
