Thank you for choosing to be part of our community at NeXL (PTY) Ltd. ("NeXL ", "we", "us", "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy, or our practices with regards to your personal information, please contact us at info@nexl.online.

When you use our mobile application (the "App"), websites, including (www.nexl.online) and more generally, use any of our services (the "Services", which include our websites and the App), you are trusting us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Services immediately.

This privacy policy applies to all information collected through our Services (which, as described above, includes our website and App), as well as, any related services, sales, marketing or events.

Please read this privacy policy carefully as it will help you understand what we do with the information that we collect.

WHAT INFORMATION DO WE COLLECT

• Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on our website or App, express an interest in obtaining information about us or our products and Services, when you participate in activities on our website or App or otherwise when you contact us.The personal information that we collect depends on the context of your interactions with us and our website or App, the choices you make and the products and features you use. The personal information we collect may include the following:



• Personal information provided by you.We collect your names.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.



• Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our website or App.




We automatically collect certain information when you visit, use or navigate the App or our website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website or App and other technical information. This information is primarily needed to maintain the security and operation of our website or App, and for our internal analytics and reporting purposes.

We collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice.

The information we collect when you use our App includes:

• Log and usage data.Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our App and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the App (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
• Device data.We collect device data such as information about your computer, phone, tablet or other device you use to access the App. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system and system configuration information.
• Location data.We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the App. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services. Please refer to our Terms of Use, FAQs and Policy Documents for more information.


• Information collected through our App

In Short: We collect information regarding your geo-location, mobile device, push notifications and when you use our App.




If you use our App, we also collect the following information:

• Geo-location information.We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services. Please refer to our Terms of Use, FAQs and Policy Documents for more information.
• Mobile device access.We may request access or permission to certain features from your mobile device, including your mobile device's Bluetooth, camera, sensors, storage, background location and other features. If you wish to change our access or permissions, you may do so in your device's settings. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services. Please refer to our Terms of Use, FAQs and Policy Documents for more information.
• Mobile device data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID and information about the features of our App you accessed.
• Push notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to offer you the product benefits associated with our product and changing these permissions could affect your eligibility to receive or make use of these benefits. Second to that, this information is needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes

• Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.




In order to provide you with customised products and services in line with your needs, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion.

HOW DO WE USE YOUR INFORMATION?

• In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.



We use personal information collected via our website or App for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, to provide products and services to you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.




We use the information we collect or receive:

• Request feedback. We may use your information to request feedback and to contact you about your use of our App.
• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• To protect our Services. We may use your information as part of our efforts to keep our App and website safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To deliver and facilitate delivery of services to the user.We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support to users.We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• We may use your information to develop and display personalised content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information see our Cookie Notice.
• For various other purposes permitted by law.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

• In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
  
  We may process or share your data that we hold based on the following legal basis:
• Consent:We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a contract:Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal obligations:We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital interests:We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Business transfers.We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Vendors, consultants and other third-party service providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the App and our website, which will enable them to collect data on our behalf about how you interact with our App or website over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• Business partners. We may share your information with our business partners to offer you certain products, services or promotions.



WHO WILL YOUR INFORMATION BE SHARED WITH?

• In Short: We only share information with the following third parties.



We only share and disclose your information with the following third parties. We have categorised each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".

• Web and mobile analytics - Google Analytics, Firebase
• Website testing - TestFlight, Firebase Remote Config and Google Play Console
• Credit and personal information - Credit bureau

Various other third party service providers which enable us to service you and for you to access all the features on the App.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

• In Short: We may use cookies and other tracking technologies to collect and store your information.



We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

HOW LONG DO WE KEEP YOUR INFORMATION?

• In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.



We will only keep your personal information for a period of 5 (five) years after the termination of the user's policy.




When the 5 (five) years is complete, we will either discard or de-identify your personal information, whichever is applicable.

HOW DO WE KEEP YOUR INFORMATION SAFE?

• In Short: We aim to protect your personal information through a system of organisational and technical security measures.



We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our website and App is at your own risk. You should only access our website and App within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

• In Short: We do not knowingly collect data from or market to children under 18 years of age.



We do not knowingly solicit data from or market to children under 18 years of age. By using our website or App, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the App or website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@nexl.online.

WHAT ARE YOUR PRIVACY RIGHTS?

• In Short:You may review, change, or terminate your account at any time.



If you have questions or comments about your privacy rights, you may email us at info@nexl.online.




Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account and update your user account.
• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and from our active databases. Your information will be handled as noted in this Privacy Policy, App FAQs and policy documents.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our App. For further information, please see our Cookie Notice.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

• Contact us at info@nexl.online

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this notice, you may email us at info@nexl.online
or by post to: NeXL (Pty) Ltd., 18 Davey Road, Maydon Wharf, Durban 4001, South Africa

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email info@nexl.online. We will respond to your request within 30 days.

This privacy policy must be read in conjunction with the Terms of Use, FAQs (where applicable), and/or where applicable, your Policy Documents with NeXL.