Privacy Policy

Last Updated: 08/06/2025

Welcome to XFA.AI.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request. We collect, use, and are responsible for certain personal information about you. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible for your personal information as a "business" under the CCPA/CPRA.

  1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:
We, us, our XFA.AI, Inc.
Data protection officer contact information nathan@xfa.ai
Personal information Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household.
Sensitive personal information Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, and citizenship or immigration status.
Biometric Information An individual's physiological, biological, or behavioral characteristics, including information about an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
  1. Personal Information We Collect About You. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Categories Examples Collected in Last 12 Months?
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Yes
Personal information described in the California Customer Records Statute A signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Yes
Characteristics of protected classifications under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Yes
Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
Biometric information Physiological, biological, or behavioral characteristics, DNA information. Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, or voice recordings. Keystroke patterns or rhythms, gait patterns or rhythms, or sleep, health, or exercise data. No
Internet and network activity Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. Yes
Geolocation data Information about physical locations or movements. No
Sensory information Audio, electronic, visual, thermal, olfactory, or similar information. Yes
Professional or employment-related information Current or past job history or performance evaluations. Yes
Non-public education information (per the Family Educational Rights and Privacy Act) Non-public education records that are directly related to a student which are maintained by an educational agency or institution or by a party acting on its behalf (for example, grades, transcripts, class lists, student schedules, identification codes, financial information, and disciplinary records). No
Inferences drawn from other Personal Data Information used to create a user profile which reflects the users’ preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes. Yes
  1. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text, email, or via our website. However, we may also collect information from the following categories of sources:

    • (a) Third party with your consent (e.g., your bank)
    • (b) Advertising networks
    • (c) Internet service providers
    • (d) Data analytics providers
    • (e) Government entities
    • (f) Operating systems and platforms
    • (g) Social networks
    • (h) Data brokers
    • (i) Publicly accessible sources (e.g., property records)
    • (j) Cookies on our website
    • (k) Our IT and security systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems.
  2. How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

    • To comply with our legal and regulatory obligations
    • For the performance of our contract with you or to take steps at your request before entering into a contract
    • For our legitimate interests or those of a third party –or–
    • Where you have given consent

    A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

    • We collect the categories of Personal Data listed above for the following business purposes:
    • To take steps at your request before entering into a contract for services
    • To provide the Services to you for their intended purposes, as well as to customize and/or enhance your use of the Services.
    • For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.
    • To send communications to you, including marketing communications (unless you opt-out).
    • To accomplish the purposes outlined in our Terms of Service.
    • To process your payments if you make a purchase through the Services, including sharing your payment information with third party payment processors. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
    • To comply with our legal and regulatory obligations.
  3. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our services, including exclusive offers, promotions or new services.

    We have a legitimate interest in processing your personal information for promotional purposes (see above "How and why we use your personal information"). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

  4. Who We Share Your Personal Information With. We routinely share personal information with:

    • Our affiliates, including companies within the XFA.AI, Inc. group
    • Service providers we use to help deliver our services to you, such as payment service providers, warehouses and delivery companies
    • Other third parties we use to help us run our business, such as marketing agencies or website hosts
    • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
    • Credit reporting agencies
    • Our insurers and brokers
    • Our banks

    We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO or Investors in People accreditation and the audit of our accounts.

    We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

    We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

    We will not share your personal information with any other third party.

  5. Personal Information We Sold or Shared. We will not sell your Personal Information to any third parties. Notwithstanding the preceding statement, in the preceding 12 months, we have shared the following categories of personal information:

Categories Shared in the last 12 months? Recipients:
Identifiers No ☐ Affiliates
☐ Service Providers
☐ Other Recipients
Personal information described in the California Customer Records Statute No ☐Affiliates
☐Service Providers
☐Other Recipients
Characteristics of protected classifications under California or federal law No ☐Affiliates
☐Service Providers
☐Other Recipients
Commercial information N/A N/A
Biometric information N/A N/A
Internet and network activity No ☐Affiliates
☐Service Providers
☐Other Recipients
Geolocation data N/A N/A
Sensory information N/A N/A
Professional or employment-related information N/A N/A
Non-public education information (per the Family Educational Rights and Privacy Act) N/A N/A
Inferences drawn from other Personal Data N/A N/A
  1. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have not disclosed for a business purpose any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

    [Option when there was a disclosure.] In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

    • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
    • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
    • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
  2. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

Disclosure Description Note
Disclosure of Personal Information We Collect About You You have the right to know, and request disclosure of:
- The categories of personal information we have collected about you, including sensitive personal information
- The categories of sources from which the personal information is collected
- Our business or commercial purpose for collecting, selling, or sharing personal information
-The categories of third parties to whom we disclose personal information, if any –and–
- The specific pieces of personal information we have collected about you
Please note that we are not required to:
- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–
- Provide the personal information to you more than twice in a 12-month period
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
- The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–
- The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose
You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.
To opt-out of the sale or sharing of your personal information, visit our homepage and click on the lock icon on the bottom right of any page on https://www.xfa.ai.
Right to Limit Use of Sensitive Personal Information You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
- Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services
- To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and–
- As authorized by further regulations
You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
To limit the use of your sensitive personal information, visit our homepage and click on the “Limit the Use of My Sensitive Personal Information” link here: https://www.xfa.ai.
Right to Deletion Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your personal information from our records –and–
- Direct any service providers or contractors to delete your personal information from their records
- Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort
Please note that we may not delete your personal information if it is reasonably necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 you and us
- Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes
- 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
- 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
- Comply with an existing legal obligation –or–
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
Right of Correction If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:
- Deny goods or services to you
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
- Provide a different level or quality of goods or services to you –or–
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.
  1. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can email us at ntamedhighvibes@gmail.com.

    • Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
    • If you choose to contact us directly by website or email, you will need to provide us with:
      • Enough information to identify you [(e.g., your full name, address and customer or matter reference number)]
      • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
      • A description of what right you want to exercise and the information to which your request relates.
    • We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
    • Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
  2. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

  3. Changes to This Privacy Notice. This privacy notice was published on 08/06/2025 and last updated on 08/06/2025.

    We may change this privacy notice from time to time. Any such modifications shall be effective immediately. You can view the most recent version of these terms at any time at Untamed High Vibes/privacy. We will inform you via email.

  4. How to Contact Us Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

    Our contact details are shown below: nathan@xfa.ai

    Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see "How to contact us" above).

CONSENT

By using our Service, you hereby consent to our Privacy Policy. If you are using the Service on behalf of an organization, you are agreeing to these Terms for that organization and promising that you have the authority to bind that organization to these terms. In that case, "you" and "your" will refer to that organization.

ELECTRONIC AGREEMENT

This Agreement is an electronic contract that sets out the legally binding terms of your use of the Service. By registering for the Service, clicking "I Agree" or "Accept" (or similar button or checkbox) at the end of this Agreement, or by using the Service in any manner, you agree to these Terms, as they may be updated or amended from time to time by XFA.AI, Inc. in its sole discretion. This electronic agreement acknowledges that you are able to electronically receive, download, and print this Agreement.

ACKNOWLEDGEMENT

By using the Service, you acknowledge that you have read these Privacy Policy and agree to be bound by them.