PRIVACY POLICY

Effective Date: September 10, 2020


This Privacy Policy explains how Oxx Group LLC (“OXX GROUP,” “we,” “our,” or “us”) collects,
uses, and discloses information about you when you access or use our OXX GROUP website
located at https://www.oxxgroup.com/, and related services (collectively, the “Site”). We take
your privacy seriously.


We may change this Privacy Policy from time to time. If we make changes, we will notify you by
revising the date at the top of the policy and, in some cases, we may provide you with additional
notice (such as adding a statement to our website homepage or sending you a notification). We
encourage you to review the Privacy Policy whenever you access the Site or otherwise interact
with us to stay informed about our information practices and the choices available to you.


A. COLLECTION OF INFORMATION


1. INFORMATION YOU PROVIDE TO US


We collect information you provide directly to us. For example, we collect information when you
request information, fill out a form, communicate with us via third party social media sites,
request support, send us an e-mail, or otherwise communicate with us. The types of information
we may collect include your name, contact information (such as email address, postal address,
and phone number), and any other information you choose to provide. We collect this
information to help better provide you services.


2. AUTOMATICALLY COLLECTED INFORMATION


When you access or use our Site, we may automatically collect non-identifying and/or
anonymized information about you, including your log and usage information, device
information, and location information.


Information Collected by Cookies and Other Tracking Technologies


We (and our service providers) use different technologies to collect information, including
cookies and web beacons. Cookies are small data files stored on your hard drive or in device
memory that help us improve our Site and your experience, see which areas and features of our
Site are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are
electronic images that may be used in our Site or emails and help deliver cookies, count visits,
and understand our customers to provide better services. For more information about cookies
and how to disable them, see Your Choices below.


B. USES OF INFORMATION


We may use the information we collect to:

  • Provide, maintain, and improve our Site;

  • Provide and deliver the information you request;

  • Send you technical notices, updates, security alerts, and support and administrative messages and provide technical support;

  • Respond to your e-mails, submissions, comments, questions and requests;

  • Communicate with you about our services, such as sending you information to keep you informed about various news and information we think will be of interest to you (see Your

  • Choices below for information about how to opt out of these communications at any time);

  • Create and maintain a customer relationship management system, member directories and invitation lists for OXX GROUP events;

  • Anonymize and aggregate information for analytics and reporting;

  • Monitor and analyze trends, usage, and activities in connection with our Site;

  • Carry out any other purpose described to you at the time the information was collected.


C. SHARING OF INFORMATION


We may share information about you as follows or as otherwise described in this Privacy Policy:

  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;

  • To affiliates and other entities within OXX GROUP’s group of companies, other OXX GROUP customers, and service providers;

  • To a buyer or other successor in the event of a merger, divestiture, restructuring reorganization, dissolution, or other sale or transfer of some or all of OXX GROUP’s assets;

  • When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests, claims or legal authorities, including responding to lawful subpoenas, warrants, or court orders;

  • If we believe your actions are inconsistent with the spirit or language of our policies, or to protect the rights, property, and safety of our staff or others;

  • For any other purpose disclosed by us when you provide your Personal Information; or

  • With your consent or at your direction.


D. DATA RETENTION


We store the information we collect on you for as long as is necessary for the purpose(s) for
which we originally collected it, or for other legitimate business purposes, including to meet our
legal, regulatory or other compliance obligations. For any questions, comments, or requests,
please see the Contact Us Section.


E. LINKS TO OTHER WEBSITES


The Site may contain links to other websites. Any personal information you provide on such
linked pages is provided directly to that third party and is subject to that third party’s privacy
policy, and not this privacy policy. We encourage you to learn about their privacy and security
practices and policies before providing them with personal information.


F. SOCIAL SHARING FEATURES


The Site may offer social sharing features and other integrated tools (such as the Facebook
“Like” button), which let you share actions you take on our Site with other media, and vice versa.

Your use of such features enables the sharing of information with your friends or the public,
depending on your privacy settings for the relevant social media site. For more information
about the purpose and scope of data collection and processing in connection with social sharing
features, please visit the privacy policies of the entities that provide these features.


G. ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS


We may allow others to provide analytics services and serve advertisements on our behalf
across the web and in mobile applications. These entities may use cookies, web beacons,
device identifiers and other technologies to collect information about your use of the Site and
other websites and applications, including your IP address, web browser, mobile network
information, pages viewed, time spent on pages or in apps, links clicked, and conversion
information. This information may be used to, among other things, analyze and track data,
deliver advertising and content targeted to your interests on our Site, and better understand
your online activity.


For more information about interest-based ads, or to opt out of having your web browsing
information used for behavioral advertising purposes, please visit www.aboutads.info/choices.
You can also change your browser settings to block cookies, although doing so may disable
some features of our Site.


H. YOUR CHOICES


1. PROMOTIONAL COMMUNICATION


We may send promotional e-mails or text messages. You may opt out of receiving promotional
emails or text messages from us by following the instructions in those emails or text messages.
If you opt out, we may still send you non-promotional emails, such as those about your use of
the Site.


2. UPDATING INFORMATION


You may update and correct certain information you provide to us by contacting us. If you wish
to delete information we have collected from you, please contact us, but note that we may retain
certain information as required by law or for legitimate business purposes. We may also retain
cached or archived copies of information about you for as long as necessary for our business
purposes.


I. COOKIES


Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to
set your browser to remove or reject browser cookies. Please note that if you choose to remove
or reject cookies, this could affect the availability and functionality of our Site.


J. MOBILE PUSH NOTIFICATIONS/ALERTS


With your consent, we may send promotional and non-promotional push notifications or alerts to
your mobile device. You can deactivate these messages at any time by changing the notification
settings on your mobile device.


K. CHILDREN

The Site is not directed at children and we do not knowingly collect personal information directly
from children under the age of thirteen (13) or from other web sites directed at children.


L. YOUR NEVADA PRIVACY RIGHTS


This Section applies solely to Nevada residents. Under Nevada law (NRS § 603A.300), Nevada
residents can opt out of the sale of certain types of personal information. If you are a Nevada
resident, you may submit a verified request to opt out of sales and we will record your
instructions and incorporate them in the future. Opt-out requests may be sent using the contact
information at the bottom of this notice.


We reserve the right to amend this Section concerning your Nevada Privacy Rights at our
discretion and at any time.


M. TRANSFER OF INFORMATION TO THE U.S.


We are based in the United States and process and store information in the United States. It is
possible that non-U.S. residents may access and use the Site. If you are located outside the
United States, we and our service providers may transfer your information to, or store or access
to your information in, jurisdictions that may not provide equivalent levels of data protection as
your home jurisdiction. By providing personal information, you consent to the transfer of your
personal information to the United States and the use of your personal information, in
accordance with this Privacy Policy. If we collect personal information from European Union
residents, we strive to do so in a manner in compliance with Regulation (EU) 2016/679 of the
European Parliament and of the Council of April 27, 2016 (the “GDPR”), which includes
acknowledgment of European Union residents’ rights, including the following:

 

  • to withdraw your consent to the processing of personal information about you to which you have previously given consent;

  • to object to processing of personal information about you for the purpose of direct marketing; and

  • to have incorrect personal information about you corrected.


European Union residents also have the right to obtain a copy of the personal information we
have about you, although we reserve the right to charge a fee for this.


N. YOUR CALIFORNIA PRIVACY RIGHTS


Under the California Consumer Privacy Act of 2018 (“CCPA”) and Cal. Civil Code § 1798.83,
California residents have certain rights to know what information we collect, how we use that
information, and rights and choices concerning that information. This Section of the Privacy
Policy applies solely to visitors, users, and others who reside in the State of California.


1. INFORMATION WE COLLECT


We collect information that identifies, relates to, describes, references, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular consumer
or device (“personal information”). We have collected the following categories (as listed in Cal.
Civ. Code § 1798.140(o)(1)) of personal information from consumers within the last twelve (12)
months: A. Identifiers (e.g., email addresses), B. Personal information categories in Cal. Civ.

Code § 1798.80(e) (e.g., names, addresses), F. Internet information (e.g., information regarding
a consumer’s interaction with a website), G. Geolocation data, and K. Inferences drawn from
other Personal Information (e.g., profile reflecting your preferences, characteristics, and
behavior.)


Personal Information does not include publicly available information from government records,
de-identified or aggregated consumer information, and information excluded from the CCPA’s
scope. We obtain the categories of personal information listed above from the following
categories (as listed in Cal. Civ. Code § 1798.140(o)(1)) of sources:


Please see Section B, Uses of Information, for more information on how the information is used.


2. SHARING PERSONAL INFORMATION


We may disclose your personal information to a third party for a business purpose. When we
disclose personal information for a business purpose, we enter a contract that describes the
purpose and requires the recipient to both keep that personal information confidential and not
use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal
information for a business purpose to the following third parties:

In the preceding twelve (12) months, we have not sold any personal information of anyone
(including California residents) to any third parties. Even though we do not sell personal
information, if you are a California resident, you still may submit a verified request to opt out of
the sales and/or disclosure and we will record your instructions and incorporate them in the
future if our policy changes. If you are a California resident and would like to opt out of the sale
or disclosure of your personal information, please contact us using the contact information at the
bottom of this notice.


3. YOUR RIGHTS AND CHOICES


The CCPA provides consumers (California residents) with specific rights regarding their
personal information. This section describes your CCPA rights and explains how to exercise
those rights.


Right to Know


You have the right to request that we disclose certain information to you about our collection
and use of your personal information over the past 12 months. Once we receive and confirm
your verifiable consumer request, we will disclose to you:

 

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    • sales, identifying the personal information categories that each category of recipient purchased; and

    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights


You have the right to request that we delete any of your personal information that we collected
from you and retained, subject to certain restrictions. We may deny your deletion request if
retaining the information is necessary for us or our service providers to:


1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities.
2. Debug products to identify and repair errors that impair existing intended functionality.
3. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §
1546 seq.).
4. Comply with a legal obligation.
5. Make other internal and lawful uses of that information.


Only you or a person registered with the California Secretary of State that you authorize to act
on your behalf may make a verifiable consumer request related to your personal information.


You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a
12-month period. The verifiable consumer request must:

 

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.


Response Timing and Format


We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we
require more time (up to 90 days), we will inform you of the reason and extension period in
writing.  Any disclosures we provide will only cover the 12-month period preceding the verifiable
consumer request's receipt.  The response we provide will also explain the reasons we cannot
comply with a request, if applicable. You may be required to provide additional information to
verify your identity and request before further action is taken.


4. ADDITIONAL INFORMATION


We will not discriminate against you for exercising any of your CCPA rights. We reserve the
right to amend this Section concerning your California Privacy Rights at our discretion and at
any time. When we make changes to this privacy notice, we will notify you through a notice on
our website homepage. For any questions, comments, or requests, please see the Contact Us
Section.


O. CONTACT US


If you have any questions or comments about our Privacy Policy, the ways in which we collect
and use your personal information, your choices and rights regarding such use, or wish to
exercise your rights under California law, please do not hesitate to contact us or, if applicable,
submit a verifiable consumer request to us, by either:

 

  • Calling us at 786-774-7435; or

  • Sending correspondence to: 7311 NW 12th ST STE 14 Miami, FL 33126

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