- Use of our websites, including mobile websites and applications (“Websites”)
- Attendance at coin shows and other events in which we participate
- Phone and email communications
- Social media interactions on our Websites and other third party websites like
- Facebook, YouTube, Pinterest, Google+, Instagram and Twitter
- Viewing our online advertisements or emails
- Through our authorized service providers
Personal Information We Collect
As described below, XILLO may collect or has collected in the preceding 12 months the following categories of personal information (“Personal Information”):
Examples include real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
- Other elements
Examples include name, signature, characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number.
- Characteristics of protected classifications
Examples include race, religion, and age.
- Commercial information
This includes services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Education information
This includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
- Internet or other electronic network activity
Examples include browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation data
This might include location information while using one of our apps.
- Audio, electronic, visual, thermal, olfactory, or similar information
Examples of this category including identifiable information obtained about you while speaking with our customer service representatives on the telephone.
- Professional or employment-related information
- Biometric Data such as your fingerprint
- Consumer profile
This includes inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.
We may add to the categories of Personal Information on which we collect Personal Information. In that case, we will inform you.
Purposes We Collect Your Personal Information
The business or commercial purposes for which we may collect or have collected your Personal Information are listed below.
- To provide you with information, products or services that you request from us.
- To fulfill or meet the reason for which the information is provided. For example, if you purchase a product from us, we will collect your address for shipping purposes or to fulfill our tax collection and reporting obligations.
- To contact you and/or provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
- To engage in marketing activities, including to help design products and services appropriate for our customers.
- To communicate with you in social media concerning our products and services.
- To carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
- To review, improve, and monitor our Website, applications, online services, and overall client experience, including to provide customization to meet the specific needs, ensure a consistent experience, and to assess trends, interests, and the demands of customers.
- To provide customer service and engage in quality control activities concerning our products and services.
- To engage in testing, research, analysis and product and service development.
- To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
- As described to you when collecting your Personal Information.
- As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
We may change or add to the purposes for which we collect Personal Information. In that case, we will inform you and obtain your consent when required by law.
Sources of Personal Information
The categories of sources of Personal Information are described below. The examples provided are for illustration purposes and are not exhaustive.
Examples of when we collect that information include:
- During a Website visit or from a completed form, or when you interact with you at a coin show or other event
- If you submit a request, submit information, or post other digital content through one of our Websites, applications or via social media interactions on third party websites like Facebook or Twitter
- If you register for a referral or loyalty program
- If you participate in a sweepstake, contest or promotion
- If you request a quote, warranty or other information
- If you use a rebate
- If you apply or inquire about employment
- In connection with your interactions with us as a registered user of our Websites
- We may use tracking tools like browser cookies, flash cookies, and web beacons
- Your friends and family, such as when they provide your information through one of our refer-a-friend type features or programs. Persons who share such information in connection with those features or programs should only submit email addresses of individuals with whom they have a close personal or family relationship, who would be interested in receiving the communication, and who have authorized the sharing of their email address.
- News outlets
- Social media and related services
- Users of a third party website that give us access to their profiles
Sharing Personal Information
Of the categories of Personal Information noted above, during the past 12 months, we shared the following Personal Information:
Categories of Personal Information Disclosed
Characteristics of protected classifications under California or federal law
Internet or other electronic network activity
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Categories of Third Parties to Whom Disclosed
- Third parties as directed by you. We will share your Personal Information with those third parties to whom you direct. For example, if you decide to send one of our products as a gift, we may include your name.
- Our business collaborators. For example, we might share your Personal Information with one of our business collaborators for purposes of collaborating on providing services to you. These business collaborators should also have their own privacy statements that set out the manner in which they will collect, use, and disclose Personal Information. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them.
- Third parties who perform services on our behalf. For example, we share information with certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies.
- Third parties that participate in, provide assistance with, or sponsor our promotions or otherwise provide marketing or promotional assistance.
- Governmental entities, legal service providers. We may share your Personal Information in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request.
- Successors to all or portions of our business. If all or part of our business is sold, we may disclose Personal Information in preparation for or as part of that transaction.
We do not sell your Personal Information and do not have actual knowledge that we have sold personal information of minors under age 16.
Using of Your Personal Information On Our Website
As is true of most websites, we gather some Personal Information automatically and store it in log files. This information may include the Internet Protocol (IP) address, browser type, language, internet service provider (ISP), referring and exit page, operating system, and date/time stamp. In addition to the purposes above, we use this Personal Information to understand and analyze trends, to administer the Websites, to learn about user behavior on the Websites and to gather demographic information about our user base as a whole. To monitor use of the Websites and improve its quality, we may compile statistical information concerning the use of the Websites through analytics services, such as those provided by Google Analytics for Display Advertisers and Google Display Network (DoubleClick). Examples of this information may include: the number of visitors to the Websites or to sections or pages within the Websites, patterns of traffic flowing through the Websites, length of time spent on the Websites, or in sections or pages of the Websites, the other sites that refer visitors to the Website, the pages of the Websites that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Websites. The data collected may be used to display banner advertisements and other advertising tailored to your interests when you visit certain websites. We also may use this Personal Information in our marketing and advertising services.
We may use various kinds of software devices to collect Personal Information about use of our Websites. Small files called “cookies” may be attached to your Web browser. These files identify your browser and save information such as passwords, pages visited time and time spent on the Websites so that our Websites can recognize you, facilitate site navigation and personalize your experience. It also allows us to select which of our advertisements and offers are most likely to appeal to you. You can set your browser to disable cookies, but some portions of the Websites (and possibly other sites) may not work properly if you do this. We may also use a pixel tag, a transparent graphic image sometimes known as a web beacon, to review how visitors navigate the Websites; a pixel tag may tell your browser to get contact from another server. Network publishing companies and publishers are not permitted to collect Personal Information directly from the Websites. If you would like more information about this practice, and your choices and how they relate to this practice, please contact us.
The Websites may use social media plugins (e.g. Facebook and LinkedIn) to enable you to easily share information with others. When you visit our Websites the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Websites if you are logged into the social media website (e.g. Facebook, Twitter) while browsing our Websites, the social plugins allow that social media website to share data about your activities on our Websites with other users of their social media website. For example, Facebook Social Plugins allow Facebook to show your likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website. We do not control any of the content form the social media plugins. For more information about social plugins from other media websites you should refer to those sites’ privacy and data/information sharing statements/policies.
IMPORTANT: By using the Websites, you consent to the processing of any Personal Information provided or collected for the analytics purposes and functions described above.
You may always direct us not to share your Personal Information with third parties, not to use your Personal Information to provide you with information or offers, or not to send you newsletters, e-mails or other communications by: (i) sending us an e-mail at firstname.lastname@example.org with the word “Remove” as the subject header; (ii) calling us at (302) 485 0571; or (iii) following the removal instructions in the communication that you receive. Your opt-out request will be processed within 30 days of the date on which we receive it.
You can opt-out of Google Analytics for Display Advertising and customize Google Display Network (DoubleClick) ads using the Ads Preferences Manager.
If you wish to verify, correct, or update any of your personal information collected through the Websites, you may edit your profile preferences or contact us at the above address or e-mail.
In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Websites. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.
Do Not Track
“Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Websites are not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.
Our Websites and Children
We do not knowingly collect or solicit Personal Information from children under 13 years of age. We are concerned about the safety of children when they use the Internet and will never knowingly request Personal Information from anyone under the age of 13. If the parent or guardian of a child under 13 believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us and ask to have this Personal Information deleted from our files. If we otherwise obtain knowledge that we have Personal Information about a child under 13 in our files, we will delete that information from our existing files so that it is not in retrievable form.
While we use reasonable measures to protect our Websites and your information, the Internet is never 100% secure. The measures we use are appropriate for the type of information we collect. We cannot guarantee use of our Websites or mobile applications are 100% secure. We encourage you to use caution when using the Internet.
Notice to Website Users Located Outside the U.S.
XILLO operates in accordance with the laws of the United States. When you access our Websites from outside the United States, we may transfer the Personal Information that we collect from you to a location outside of your jurisdiction, including the United States. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using these Websites, you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the United States.
Effective Date: March 31th, 2022
For California Residents
The California Policy describes XILLO’s policies and practices regarding the Personal Information we collect, use, and disclose about you, including Personal Information you submit or we obtain when you access the Websites and other sources. This California Policy is adopted in part to comply with the California Consumer Privacy Act (“CCPA”).
Note, however, that Personal Information as used in this California Policy does not include:
- Publicly available information from government records
- De-identified or aggregated consumer information
- Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
Pursuant to the CCPA, and as detailed below, consumers have various rights with respect to their Personal Information.
- Request to Delete
You have the right to request that we delete your Personal Information from our records and direct any service providers to delete your Personal Information from their records, subject to certain exceptions. Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers to delete your personal information from our records, subject to the exceptions provided by law.
XILLO is not required to comply with your request to delete your Personal Information if it is necessary for us (or its service provider) to maintain your Personal Information in order to:
Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between XILLO and you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when XILLO’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with XILLO.
- Comply with a legal obligation.
- Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the Personal Information.
- Request to Know
You have the right to request that we disclose the following to you as it relates to the 12-month period preceding its receipt of your verifiable consumer request:
- The categories of Personal Information we have collected about you
- The categories of sources from which the Personal Information was collected
- The business or commercial purpose for collecting Personal Information
- The categories of Personal Information we disclosed for a business purpose
- The categories of third parties with whom we share Personal Information
- The specific pieces of Personal Information we collected about you
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
In addition to the CCPA, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of XILLO to third parties for the third parties’ direct marketing purposes. Consumers that have provided their Personal Information to us may request information about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such request must be submitted to us by calling (302) 485 8571 or by submitting a request to email@example.com. Please mention in your call that you are making a “California Shine the Light” inquiry. Within 45 days of receiving such a request, we will provide a list of the categories of such Personal Information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than twice per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
We will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA.
Submitting Consumer Rights Requests
To submit any of the Consumer Rights requests as outlined above, please contact us at (302) 485-0571 or by submitting a request emailing us at firstname.lastname@example.org.
We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual that is:
- The consumer who is the subject of the request
- A consumer on behalf of the consumer’s minor child
- By a natural person or person registered with the California Secretary of State authorized to act on behalf of a consumer
If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive Personal Information to verify your identity. We may not be able to 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. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. Personal Information collected from an individual to determine whether a request is a verifiable consumer request may not be used or disclosed for any other purpose except as required by law. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.
You may authorize a natural person or a business registered with the California Secretary of State to act on your behalf with respect to the right under this California Policy. When you submit a Request to Know or a Request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.