Privacy and Compliancy

Effective and Revised June 1, 2020

Privacy Policy

XACT Acquisition, LLC dba XACT (“XACT”, “we”, “our” or “us”) is committed to protecting the privacy of those who entrust us with their personal information. Our clients and team members trust and expect that we will protect their personal information in accordance with the promises we make. “Personal information” means any information pertaining to an identified or identifiable individual and may include, for example, contact details, email addresses and any similar information provided to us in the course of our normal business. Personal information that is de-identified or anonymized is not considered personal information.

Our Privacy Policy details our commitment to your privacy.

What does this policy cover?

  • XACT  is a full-service provider of customer solutions, headquartered in Orlando, Florida, dedicated to providing customized and specialized chat, voice, SMS, and email solutions, technology, marketing,  user interface solutions, and back office support for a variety of clients. This Privacy Policy describes our privacy practices regarding personal information we receive in connection with the services and products we provide to our clients (the “Services”), as well as through our website (the “Site”).

What information do you collect? How is it shared and used?

  • What information do you collect? How is it shared and used?

    For the 12-month period prior to the data of this Privacy Policy, we explain here what categories of personal information we have collected, where we got it from, and with whom we have shared it:

CategoryPurposes
Contact Information

Example such as name, address, and phone number.

Where do we get it from? Client contacts, including employees and representatives we work with provide this information when they visit the Site, call us, or otherwise interact with us.

Why do we collect it? To communicate with and respond to our clients about the work we do for them and deliver the Client Services to them and their customers, including validation of identity or to meet legal obligations.

Browsing information

Example such as your IP address, MAC address or other device identifier, the kind of browser or computer you use, pages and content that you visit on the Site, what you click on, the state and country from which you access the Site, date and time of your visit, and web pages you linked to our Site from.

Where do we get it from? Client contacts, including employees and representatives we work with provide this information when they visit the Site, call us, or otherwise interact with us.

Why do we collect it? To communicate with and respond to our clients about the work we do for them and deliver the Client Services to them and their customers, including validation of identity or to meet legal obligations.

Who may see it? We may share this information with select marketing or other service providers and partners.

Payment Information

Example such as name, card issuer and card type, credit or debit card number, expiration date, CVV code, and billing address.

Where do we get it from?From our clients and their payment card issuers.

Why do we collect it?Authorizing of credit card and other financial transactions for our clients and their customers.

Who may see it? Our service providers who process payments for us—they are prohibited from using personal information for any other purposes and are contractually required to comply with all applicable laws and requirements, which includes the Payment Card Industry Data Security standards.

Health and Safety Data

Example such as details about your health, travel and exposure to infectious diseases, including temperature, risk factors, and medical symptoms.

Where do we get it from? From team members and visitors to our contact centers or corporate offices.

Why do we collect it? To help ensure that our campuses are safe for employees and visitors and meet applicable legal requirements.

Who may see it? Our Human Resources Department and third-party providers who assist with health and safety screenings, in all cases subject to strict confidentiality and applicable law.

Accident and Injury Data

Example such as details about any accident or injury in our facilities, or health incident.

Where do we get it from?From you, witnesses or observed about you.

Why do we collect it?To get you the help you need, deal with the emergency services, insurance and claims.

Who may see it? Law enforcement and other governmental authorities in accordance with applicable law, and our professional advisors.

Crime and Fraud Data

Example such as details of your identity, image, name and address, suspected or alleged thefts, fraud, assault or other criminal behavior.

Where do we get it from?From crime and fraud prevention agencies, from you, witnesses, and from the police.

Why do we collect it? To protect clients, the public and our business against risks and crime.

Who may see it? Law enforcement and other governmental authorities in accordance with applicable law, and our professional advisors.

  • XACT will only use personal information to the extent it is necessary to deliver the Services and the Site. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights which are described below. In all cases, any service providers will be contractually limited in the way they may use personal information maintained by XACT, including requirements that such information be maintained in a confidential and secure manner.

  • In the event that a division, a product or all of XACT is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.

  • XACT may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our clients, our clients’ customers or employees or others, in accordance with or as authorized by law.

  • XACT processes transactions or applications that are supplied and managed by our clients. As a result, although we may access certain personal information of our client’s customers pursuant to the contractual relationships with have with our clients, we typically do not collect and store personal information in our own systems, with the exception of call recordings and screenshots/recordings. Typically, our clients are responsible for complying with all notices, notifications and alerts to individuals whose information is entered into our systems or portals. We do not use or share that personal information except as directed by our Clients.

What are cookies?How do we use them and other technologies?

  • A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer’s hard drive for use in subsequent visits to the website or online application. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. If you reject cookies, you may not be able to participate in certain activities or receive a promotion tailored to you. XACT does not control and does not guarantee the effectiveness of browser-based tools for managing cookies.

  • XACT may use Google Analytics to evaluate use of the Site for our internal purposes such as evaluating usages of the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.

  • Any and all personal information collected on the Site will be kept strictly confidential and will not be sold, reused, rented, disclosed, or loaned to third parties, except as otherwise described in this Privacy Policy.

    Do Not Track (DNT):This is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognizable DNT signals, and therefore XACT and the Site do not recognize DNT.

How does XACT protect personal information?

  • Where applicable, XACT uses industry-standard technology in connection with our Services and on the Site to help protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Personal information received from our clients or others in connection with Services is typically stored on servers hosted by our clients or their vendors and XACT — with limited exceptions, such as call recordings and screenshots/recordings required by our client contracts for quality assurance or other legitimate purposes, personal information collected by our clients is not stored on our or our service provider’s services.

How long does XACT retain my personal information?

  • Personal information that we collect, access or process will be retained only as long as necessary for the fulfillment of the purposes for which it was collected, unless otherwise provided for under services contracts with clients or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or de-identified.

What are my choices concerning my personal information with XACT?  

  • XACT depends primarily on our clients to notify and provide their customers and employees choices regarding the personal information that they provide. Our clients are therefore responsible for notification of purpose and for obtaining appropriate consent, to the extent required by law, when they collect personal information that is transferred to XACT.

    In addition, as part of the  Services, our clients may use personal information that we have collected on their behalf for their own communication and promotional purposes. Our clients are responsible for ensuring that any commercial emails sent by them to their employees or customers comply with applicable law. If we are instructed by our clients to transmit communications on their behalf, clients remain responsible for ensuring that recipients have consented to receiving such communications and that the information contained in the communications are accurate and complete.

    We do not sell, rent, or share the personal information of our clients’ employees or their customers with third parties for their own marketing purposes.

    XACT may, subject to applicable laws, use personal information from our clients and their employees to contact them about our Site and Services, including to provide them with information on additional products from XACT that may be of interest to them. Client contacts may exercise choices regarding these communications as follows:

    • Mail or Telephone Marketing, Surveys and Quality Control Communications. You may decide that you prefer XACT not to use your personal information to promote new and/or additional products and/or services which may be of interest to you and refuse that we contact you by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting Privacy and Compliance.
    • Emails/Commercial Electronic Communications. You can always limit the communications that XACT sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account or services.

What are my choices concerning online advertising with XACT?

  • We may use third-party advertising companies that use tracking technologies to serve our advertisements across the Internet. These companies may collect information about your visits to the Site and other websites and your interaction with our advertising and other communications.

    These advertising companies serve ads on behalf of us and others on non-affiliated sites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to the Site and elsewhere over time. Other companies may also use such technology to advertise on our Site.

    You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in. If you would like more information about this practice and to know your choices concerning interest-based ads, visit:

    http://www.networkadvertising.org/choices

How is this Privacy Policy enforced with XACT?

  • XACT has put in place mechanisms, processes and procedures to monitor and verify our ongoing adherence to this Privacy Policy. We encourage individuals covered by this Privacy Policy to raise any concerns that they have about the way that we process their personal information by contacting XACT as described below. We take your questions and concerns seriously, and will do our best to resolve them.

What is the XACT policy on children’s privacy?

  • XACT and our Site are not directed toward children and we do not knowingly solicit or collect personal information online from children under the age of 13 without prior verifiable parental consent. If XACT  learns that a child under the age of 13 has submitted personal information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under age 13, please contact our Privacy and Compliance team.

Your Access, Objection, Correction and Deletion

  • In certain jurisdictions, you may have the right to obtain confirmation as to whether your personal information is being processed, information about the purposes of that processing, and information about the recipients to whom your personal data have been or will be disclosed. You may also have the right to receive a copy of the personal data you have provided and/or request its deletion.

    Our clients are responsible for managing any request made by their employees or customers regarding access to and rectification of their personal information that is transferred to us. However, if you have questions about your rights, please feel free to contact our Privacy and Compliance team.

Your California Privacy Rights

  • If you are a California resident, California law provides you with the following rights with respect to your personal information:

    • The right to know what personal information we have collected, used, disclosed and sold about you. To submit a request to know, you may call us at 1-877-XACT-877 or visiting https://www.myxact.com/contact. You also may designate an authorized agent to make a request for access on your behalf on our website at https://www.myxact.com/contact.
    • The right to request that we delete any personal information we have collected about you.  To submit a request for deletion, you may call us at 1-877-XACT-877 or visiting https://www.myxact.com/contact. You also may designate an authorized agent to make a request for deletion on your behalf on our website at https://www.myxact.com/contact.

    When you exercise these rights and submit a request to us, we will verify your identity by asking you for your email address, telephone number, information about your company’s contract with XACT, or the last four digits of a credit or debit card used at XACT. We also may use a third party verification provider to verify your identity.

    Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.

    For the 12-month period prior to the date of this Privacy Policy, XACT has not sold any personal information about its Clients or their employees or about the customers of our Clients; nor does it have any plans to do so in the future.

    Please note:  If you are a customer of one of our Clients, you should contact them first concerning your California Privacy rights.  

Right to File a Complaint

  • We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside.

Changes to this Privacy Policy

  • XACT will review and update its Privacy Policy as required to keep current with rules and regulations, new technologies and security standards. We will post those changes on the Site and/or update the Privacy Policy modification date below. In certain cases and if the changes are material, we will provide written notice to clients directly by email or otherwise.

    This policy is effective as of the date listed at the top of this page.

Contacting the XACT Privacy Office

  • If there are any questions regarding this Privacy Policy or to request a copy of this Privacy Policy in another format, you may contact us using the information below. 

    XACT
    429 South Keller Road, 3rd Floor
    Orlando, FL 32810
    compliance@myxact.com
    1-877-XACT-877