Privacy Policy

This Privacy Policy describes in greater detail the privacy practices of Xion.AI Pte Ltd (“Xion”)

If you have questions or complaints regarding our Privacy Policy or practices, please contact us at [email protected].

1. WHEN THIS PRIVACY STATEMENT APPLIES.

This Privacy Policy (“Policy”) applies to our sites, products, and services (collectively, “Services”) that link to this Policy. Currently those Services include Counto (https://mycounto.com), and AI.TaxAssist (https://xion.ai).

2. WHAT WE DO WITH YOUR INFORMATION. We want to be clear about what information we collect and how we use it to deliver our Services to you, operate our business, and help make our Services work better for you. We do not sell or share your PII with third parties for their own commercial uses without your consent.

We comply with the Singapore Data Privacy Act of 2012 in the practices we adopt to protect and use your information for the purpose of providing you the Services.

a) Types of Information . We do not sell or share your Personal Identifiable Information (“PII”) with third parties for their own commercial uses without your consent. In connection with accessing our Services, we may collect information from you which can be used to identify your PII, such as your name, billing address, email address, phone, username, password, and financial data.

We collect information when you register or open an account, sign in, pay a bill, purchase a Service, call us for support, or give us feedback. We may also get information from other companies or third parties, such as when you sync a third party account or service with your Xion Service, or when we may use service providers to supplement the PII you give us (e.g., validate your mailing address) to help us maintain the accuracy of your data and provide you with better service. Finally, we also collect content or other information that you may provide or create when you interact with our Services.

We may also automatically collect certain usage information when you access our Services (“Performance Analytics”), such as Internet Protocol (“IP”) addresses, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, and other usage information collected from cookies and other tracking technologies. For example, we may collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate to our Services in order to maintain the integrity and security of your account. We may also collect IP addresses from users when they log into the Services as part of our log-in and security features. We may also, when you enable location-based Services, collect Global Positioning System (GPS) location data and/or motion data.

Our Services may change over time and we may introduce new features that may collect new or different types of information.

b) How We Use Your Information. We may use your information, including your PII, for the following purposes:

When you give us your personal information, we may use it:

• for the specific purpose for which it was collected;
• to deliver Service to you;
• to personalize your experience on Service;
• to provide customer service to you and/or to address your technical support questions;
• to alert you of new products or services, features, or enhancements;
• to provide important information about Service, such as changes to Service or updates to our policies;
• to improve Service;
• as permitted by law; and
• for any other purpose with your consent.

You have the right at any time to prevent us from contacting you for marketing purposes. You can opt-out of promotional communications by following the unsubscribe instructions provided in each promotional email that we send to you. We may continue to send you administrative emails including, for example, periodic updates to this Privacy Policy, even if you indicate that you no longer wish to receive promotional email from us.

 We will retain your personal information only for as long reasonably necessary for the purposes set forth above. We may retain your personal information for legitimate business purposes, if it may be necessary to prevent fraud or future abuse, if required by law, or as retained in our data backup systems or cached or archived pages. All of your personal information that we keep will continue to be subject to the terms of this Privacy Policy to which you have agreed.

“We might retain your information for research, including publishing or sharing aggregated information from many users, but anonymized so as not prevent identification of any person. Only in a way that would not allow you or any other person to be identified, we may prepare and share information about our customers with third parties, such as advertisers or partners, for research, academic, marketing and/or promotional purposes. For example, we may share demographic data that describes the percentage of our customers who use mobile services or who use a particular operating system. We or our third party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow you or any other person to be identified.“

c) How We Share Your PII. From time to time, we may need to share your PII with others.

Third Party Service Providers. We may share your information, including PII and Performance Analytics, with third party service providers who perform various functions to enable us to provide our Services and help us operate our business, such as website design, sending email communications, fraud detection and prevention, customer care, or performing analytics. Our contracts with these third parties require them to maintain the confidentiality of the PII we provide to them, only act on our behalf and under our instructions, and not use PII for purposes other than the product or service they’re providing to us or on our behalf.

Response to Subpoenas and Other Legal Requests. We operate under the laws of Singapore. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we’re required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.

Protection of Xion and Others. We may share account information, PII and Performance Analytics when we believe it is appropriate to enforce or apply our products’ Terms of Service and other agreements; or protect the rights, property, or safety of Xion, our Services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing PII of our customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.

Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you’d like to stop receiving promotional information following any change of control.

With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your PII may be shared with other third parties.

d) Syncing, Linking, Connecting Your Bank Account or Other Third Party Services with Your Xion Service.

You may choose to sync certain Xion Services with information from other financial accounts. To sync your financial account information, we must access your online account with your financial institution. We will request and help you set up auto email forwards from your systems and bank accounts into our system so that we can automate the delivery of the Service to you. We will request your user name, password, and any other login data that you have set up with your financial institution to enable access. We may also request your completion of GIRO forms to enable bank transactions. We use this information to update and maintain the account information you download, to assist with the download process, and to enhance the Services we may provide in the future.

We work with other companies or developers to offer you products and services and you may choose to sync, link or connect other third party services with your Xion Service. Sometimes Xion may let you know about the service or product, or another company may let you know about a Xion service or product. It will be clear who is referring the service or product, and who is providing the service or product. If you choose to accept these services, providing your consent to either the third party or to us, we may exchange your information, including your PII, as well as information about how you interact with each company’s service or product. This exchange of information is necessary to maintain business operations and to provide the ongoing service you’ve requested. By requesting or accepting these products or services, you are permitting us to provide your information, including your PII, to the other party.

We may work with some partner firms including technology, accounting, tax and audit firms, in order to provide you certain Services. We ensure that these partner firms comply with our Terms of Service and Privacy Policy. Where they do not, we ensure that their privacy policy is substantially similar to ours. You hereby consent to give us the right, power, and authority to act on your behalf to access and transmit to them information from your financial accounts that may be held with these partner firms or with us. 

3 WHAT YOU CAN DO TO MANAGE YOUR PRIVACY. You can view and edit information that identifies you online through your Xion Service. How you can access and control information that identifies you will depend on which Services you use. You have a choice about the use of information that identifies you, marketing communications you receive from us, and our use of cookies and other tracking technologies

• a) Updating Your PII. In connection with your right to manage your PII you provide to us, you may access, update, change, correct or request deletion of your information either through the Service or through our customer support. You can reach our customer support by using the contact information provided in the “How to Contact Us” section of this statement.
• b) Managing Marketing Communications From Us. We will honor your choices when it comes to receiving marketing communications from us. Remember that even if you choose not to receive marketing communications from us, we will continue to send you mandatory service or transactional communications.
• c) Cookies and Other Tracking Technologies. The following is a high level summary of our practices and your controls for cookies and other tracking technologies.

In accordance with applicable law, Xion and our service providers may use commonly-used tools to recognize your visit and track your interactions with our Services such as cookies, web beacons, pixels, local shared objects, and similar technologies (collectively, “Cookies”). Sometimes this tracking is necessary in order for us to provide you the Service you requested. Other times, we combine Performance Analytics collected from Cookies with that of other customers to improve your and other customers’ experience. Information on changing your browser settings to opt out of Cookies can be found in your browser settings. If you opt-out and later delete your Cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices.

• d) Do Not Track. Like most other companies, our Services are not currently configured to respond to browsers’ “Do Not Track” signals because at this time no formal “Do Not Track” standard has been adopted.

 4 DATA RETENTION AND YOUR ACCESS RIGHTS

• a) Data Retention. In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable regulations and Xion’s records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud
• b) Your Access Rights. As required by applicable law, you may contact us to confirm whether we maintain, or process on behalf of a third party, any of your PII and to review it in order to verify its accuracy and the lawfulness of our processing of such PII. Where you have determined that the PII we collected about you is inaccurate or processed in violation of applicable law, you may also request that your PII be corrected, amended, or deleted. Requests for access to your PII and to have it corrected, amended, or deleted should be sent to [email protected].

5 SECURITY OF YOUR INFORMATION. Keeping your Information safe is important to us.

We provide reasonable and appropriate security measures in connection with securing PII we collect.

For example, we:

• a) Constantly work to update our security practices to implement accepted best methods to protect your PII, and review our security procedures carefully.
• b) Comply with applicable laws and security standards.
• c) Securely transmit your sensitive PII.
• d) Train our staff and require them to safeguard your data.
• e) Transmit, store, protect, and access all cardholder information in compliance with the Payment Card Industry’s Data Security Standards.

6 INTERNATIONAL DATA TRANSFERS.

In accordance with and as permitted by applicable law and regulations, we reserve the right to transfer your information, process and store it outside your country of residence to wherever we or our third party service providers operate.

7 HOW TO CONTACT US. If you have questions or comments about this Privacy Policy, please contact us at [email protected]. We want your feedback and comments.

8 CHANGES TO OUR PRIVACY STATEMENTS. From time to time we may change or update our Privacy Policys. We reserve the right to make changes or updates at any time. More information about how we will notify you is below.

If we make material changes to the way we process your PII, we will provide you notice via our Service or by other communication channels, such as by email or community post. Please review any changes carefully. If you object to any of the changes and no longer wish to use our Services, you may close your account(s). All changes are effective immediately upon posting and your use of our Service after a notice of material change or posting of an updated Privacy Policy shall constitute your consent to all changes.