Version 1.0
2024-02-22 (Effective Date)
1. Introduction to Our Privacy Commitment
Welcome to DeepX Elysium Inc.
At DeepX Elysium, we are dedicated to safeguarding your privacy and handling your personal information with care and respect. Understanding that your privacy is of paramount importance, our practices are designed to protect the confidentiality and security of your personal data while providing you with the high-quality service you expect from us.
This Privacy Policy serves as our commitment to you, detailing how we handle the personal information you share with us in the course of using our services, visiting our websites, or engaging with us through other channels. We encourage you to read this policy carefully to understand the measures we take to protect your privacy, the types of information we collect, and how that information is used and shared.
By accessing our services, you acknowledge and agree to the practices described in this policy and our Terms of Service. Should you have any questions or require clarification on any aspect of our privacy practices, please do not hesitate to contact us at privacyprotection@deepxelysium.com.
Your trust is the cornerstone of our relationship, and we strive to preserve it through transparency and integrity in all our data handling practices.
2. Consent
2.1 Your Acknowledgment and Agreement
By choosing to use our Services, you explicitly consent to the collection, use, disclosure, and storage of your Personal Information as described in this Privacy Policy. We collect personal information in various ways—directly from you, from your interactions with our Services, and through third parties we work with. Your use of our Services signifies your acceptance of these practices and your agreement to allow us to process your information accordingly.
2.2 Withdrawing Consent
You have the right to withdraw your consent at any time. If you wish to do so, please contact us at privacyprotection@deepxelysium.com. Note that withdrawing consent may result in certain services becoming unavailable to you, as the processing of particular information is essential for the functionality of those services.
2.3 Consent for International Users
If you are accessing our Services from outside the United States, please be aware that by providing your Personal Information to us, you are consenting to its transfer to, storage in, and processing in the United States and other countries where we or our service providers operate, under the privacy protections described in this policy.
2.4 Changes to Your Personal Information
It is essential that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
3. Privacy Policy Overview
This Privacy Policy delineates the practices of DeepX Elysium Inc., together with its affiliates and subsidiaries (collectively, “we,” “us,” or “our”), regarding the collection, storage, utilization, disclosure, and processing of personal information about you (“Personal Information”) in the ambit of our operations. This encompasses data gathered through our websites that reference this policy, including deepxelysium.com; our proprietary Causal AI API known as “ODIN AI” (or any other name we may decide from time-to-time); and our marketing and sales endeavors. Moreover, this document provides crucial details concerning your rights related to privacy.
Our commitment to safeguarding your Personal Information and respecting your privacy rights is paramount, and this policy is designed to ensure transparency in our practices and to inform you of your privacy rights and how they can be exercised.
4. Effective Date and Version Control
4.1 Policy Governance
This Privacy Policy is effective as of the Effective Date listed at the top of this Privacy Policy document. This version of the policy supersedes and replaces any prior versions.
4.2 Updates and Revisions
We regularly review and update our Privacy Policy to reflect changes in our practices, technologies, legal requirements, and other factors. We encourage you to review this policy periodically to stay informed about how we are protecting your information.
When we make changes to this policy, we will revise the “version number” and the “effective date” at the top of the policy and take appropriate measures to inform you, consistent with the significance of the changes we make.
5. Definitions of Key Terms
In the spirit of transparency and to ensure clarity, the following definitions are provided for key terms used throughout this Privacy Policy:
“Personal Information” refers to any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. It may include, but is not limited to, names, addresses, email addresses, phone numbers, business correspondence details, login information, social security numbers, and payment information.
“Services” encompasses all products, services, features, technologies, and functionalities offered by us and includes our websites, applications, and any other engagements or interactions you may have with DeepX Elysium Inc without limitation.
“User” or “You” means any individual who uses our Services, regardless of whether they have created an account or not.
“Data Processing” refers to any operation or set of operations performed on personal data, whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting, retrieving, consulting, using, disclosing by transmission, disseminating, or otherwise making available, aligning or combining, restricting, erasing, or destroying.
“Affiliates” refers to any entity that directly or indirectly controls, is controlled by, or is under common control with DeepX Elysium Inc. Control for the purposes of this definition signifies ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.
“Third Party Sites” are websites or online services not owned or controlled by DeepX Elysium Inc., including websites or services to which we may provide links or access through our Services.
“Data Retention” signifies the period during which we store your Personal Information in our systems or databases.
“Minors” are individuals under the age of 16, who are not the target audience for our Services and from whom we do not knowingly collect Personal Information.
“Data Controller” is the entity that determines the purposes and means of the processing of Personal Information.
“Data Processor” is the entity that processes Personal Information on behalf of the Data Controller.
“Data Subject” is any living individual who is the subject of Personal Information.
“Consent” is the freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which they, through a statement or a clear affirmative action, signify agreement to the processing of personal data relating to them.
“Anonymization” is the process of either encrypting or removing personal information from data sets, so that the data subject cannot be identified by the remaining information.
By providing these definitions, we aim to make our Privacy Policy easier to understand and to ensure that you are fully informed about your rights and our responsibilities.
6. Collection of Personal Information
6.1 Scope of Personal Information Collection
We, DeepX Elysium Inc., along with our affiliates and subsidiaries, collect Personal Information that is capable of identifying you, either on its own or when combined with other information we hold. We process this Personal Information in the following contexts:
6.1.1 Personal Information Provided by You: The creation of an account to utilize our Services or any direct communication with us may necessitate the submission of Personal Information.
6.1.2 Communication Information: Engagements with our company will lead to the collection of your name, contact information, business correspondence details, and any message contents, referred to as “Communication Information.” This includes, without limitation, any Personal Information provided for the purposes of a job application.
6.1.3 Payment Information: Transactions related to our Services will require billing details such as credit card numbers, expiration dates, and billing addresses, or the engagement of third-party payment processors.
6.1.4 Social Media Interactions: Information provided through interactions with our Social Media pages on platforms including YouTube, LinkedIn, and others may be collected. Such Social Information may include contact details you choose to provide, and we may also receive aggregated usage data from the hosts of our Social Media pages.
6.1.5 Automated Information Collection:
6.5.1 Log Data: Visits to our Site automatically generate Log Data, which includes your IP address, browser type and settings, request timing, and site interaction patterns.
6.5.2 Cookies: Cookies are utilized for website functionality, preferences, and performance analytics. They are critical for site navigation, remembering login credentials, and optimizing user experience. We currently only deploy Essential Cookies for site navigation and access to secure areas. We do not currently use Performance, Analytics of Functional Cookies. Users have the option to disable cookies through browser settings or specialized software, although this may impact Service functionality.
6.1.6 Customer Support Information: Support-related interactions will lead to the collection of names, email addresses, and other relevant information to assist or address your inquiries or concerns.
6.1.7 Analytics: We do not currently use analytical tools that may employ cookies to analyze user interaction patterns.
6.1.8 Online Tracking and Do Not Track Signals: Our website does not currently recognize or alter its practices when receiving “Do Not Track” signals.
6.2 Disclosure Statement on Personal Information Handling
This section elucidates (1) the specific types of Personal Information we collect, (2) the sources from which we gather this information, (3) the particular uses we have for each category of such information, and (4) the manner in which we may disclose this information. Please note that this statement does not restrict our ability to utilize or disclose information as detailed elsewhere in this policy.
Categories and Treatment of Personal Information:
6.2.1 Social Information:
- Collection: Acquired when you engage with our social media platforms.
- Usage: Employed for analytical assessment and communication purposes.
- Disclosure: Shared with our affiliate entities.
6.2.2 Payment Information:
- Collection: Obtained when you execute financial transactions for our Services.
- Usage: Utilized to process payments, including interactions with third-party payment facilitators.
- Disclosure: Conveyed to affiliate groups and third-party payment handlers.
6.2.3 Communication Information:
- Collection: Captured directly from our interactions with you.
- Usage: Applied in the delivery of our Services and in correspondence with you.
- Disclosure: Released to our affiliates and select service providers.
6.2.4 Technical Information:
- Collection: Amassed through your utilization of and engagement with our Services.
- Usage: Directed towards analytical insights and, occasionally, for safeguarding against fraud and malevolent activities.
- Disclosure: Passed on to our affiliates and analytics partners.
6.2.5 Support Information:
- Collection: Collected when you seek assistance regarding our Services.
- Usage: Instrumental in refining customer support, enhancing the Services, and providing responses to you.
- Disclosure: Shared with our affiliate companies.
This statement is crafted to provide a transparent overview of our practices surrounding the collection, use, and sharing of your Personal Information. We uphold a commitment to the responsible management of Personal Information in accordance with the principles outlined in our comprehensive Privacy Policy.
7. Utilization of Personal Information
7.1 Commitment to Privacy
DeepX Elysium Inc. firmly upholds your privacy; accordingly, we categorically do not engage in the sale of your Personal Information.
7.2 Purposes for Using Personal Information
Our use of Personal Information is specifically confined to the following objectives:
- Service Provisioning: To deliver, manage, refine, and evaluate the efficacy of our Services.
- Support Services: To furnish you with assistance related to our offerings.
- Communication: To engage in dialogue with you, including discussions regarding potential uses of our ODIN API, discussions regarding potential employment opportunities among others.
- Innovation: To cultivate and launch new functionalities and services.
- Security and Fraud Prevention: To avert and investigate fraudulent or illicit activities, and to fortify the security of our information technology infrastructure.
- Legal Compliance: To adhere to our legal duties, respond to legal proceedings, and protect the rights and safety of our corporation, our affiliates, you, and others.
7.3 Aggregated Data Usage
We may amalgamate Personal Information to form aggregated data sets that assist us in assessing our Service’s performance, enhancing existing features, and designing new ones. We may share such consolidated information with third-party entities, disclose it publicly, or utilize it for broader analytical purposes. This aggregated data is devoid of any personally identifiable information and reflects generalized traits and behaviors of our Service users.
8. Sharing of Personal Information
Scope of Disclosure
Under specific scenarios, we may disclose your Personal Information to third parties without additional notification, as permitted by law, particularly in the following instances:
8.1. Service Providers and Partners: Operational Partners
To support our business requirements and to render various services and functions, we may relay Personal Information to third-party vendors, service providers, and data processors. Such entities may include hosting, cloud computing, information technology services, event coordination services, email communication, advertising, and marketing services, as well as web analytics providers. Under our directive, these parties may handle or store Personal Information as part of their service delivery to us.
8.2. Corporate Transactions: Business Restructuring
In the event of a strategic deal, reorganization, insolvency proceedings, receivership, or service handover to another entity (collectively termed as a “Transaction”), your Personal Information, along with other data, may be disclosed during the due diligence phase and consequently transferred to a succeeding entity or affiliate, bundled with other assets.
8.3. Legal Obligations: Compliance and Safety
Should legal circumstances demand, we may be obliged to disclose Personal Information to meet legal or regulatory requirements, support national security, cooperate with law enforcement, defend our legal rights, prevent fraud, respond to emergencies that threaten individual or public safety, or to avert legal liabilities.
8.4. Affiliates: Internal Sharing
Your Personal Information might be shared with our affiliates. Affiliates will utilize shared Personal Information in alignment with this Privacy Policy.
8.5. Community Visibility: User Interactions
Please be mindful that certain activities you engage in may be observable by other users within our services.
9. User Rights and Requests
Submission of Requests
9.1 Rights Requests:
Should you wish to request access to, erasure, correction, limitation of processing, or data portability
regarding your Personal Information, kindly reach out to us via email at: privacyprotection@deepxelysium.com. Please note, our support for these requests is confined to the extent mandated by prevailing law.
9.2 Identity Verification:
To safeguard your Personal Information from unauthorized inquiries or alterations, we necessitate identity verification prior to processing any requests for access or deletion. Absent satisfactory identity verification (including any necessary proof of residency), we reserve the right to refuse action on your Personal Information.
9.3 Authorized Agents:
Requests to access or delete your Personal Information may be conducted through a legally authorized representative. Such a representative must provide a signed authorization to act on your behalf, coupled with satisfactory verification of your identity (and residency, where pertinent).
9.4 Non-Discrimination Assurance:
We affirm that your decision to invoke any of the above rights will be met without prejudicial treatment.
10. Information Security Measures
Commitment to Protection
We engage in prudent and suitable measures to secure your Personal Information against loss, misuse, and unauthorized access, exposure, alteration, and destruction. To safeguard your data, we implement strategic technical and organizational protocols, which may encompass:
10.1 Access Control
Implementing stringent access controls to physical spaces, ensuring only authorized individuals can access sensitive information.
10.2 Data Encryption
Utilizing encryption technologies to secure data both in transit and at rest.
10.3 Surveillance and Monitoring
Employing intrusion detection systems and network monitoring tools tailored to the data’s sensitivity and the scale of processing.
10.4 Confidentiality Obligations
All personnel with access to your Personal Information are subject to confidentiality agreements and are expected to treat the information with utmost secrecy.
These measures are carefully designed to provide a high level of security appropriate to the risks presented by the processing and the nature of the Personal Information we hold.
11. Data Breach Notification
Commitment to Data Security
DeepX Elysium Inc. places the highest priority on protecting your Personal Information. Despite our stringent measures, should there ever be a security breach that affects your Personal Information, the following protocols will be enacted:
11.1 Notification Procedures
11.1.1 Immediate Action:
Upon discovering a data breach, we will promptly assess the risk to your Personal Information and take immediate steps to secure it and prevent any further breaches.
11.1.2 Assessment and Investigation:
We will investigate the breach thoroughly to understand the cause and implement measures to prevent similar occurrences in the future.
11.1.3 Legal Compliance:
We will notify the appropriate data protection authorities as required by applicable data protection laws, such as the GDPR for EU residents, within 72 hours of becoming aware of the breach.
11.1.4 User Communication:
If the breach poses a high risk to your rights and freedoms, we will inform you without undue delay. This notification will describe the nature of the data breach, the likely consequences, the measures we have taken or propose to take to address the breach, and suggestions for you to mitigate potential adverse effects.
11.1.5 Transparency:
All communications regarding the breach will be clear, straightforward, and without any unnecessary delay, subject to law enforcement or other overriding safety considerations.
11.2 Ongoing Measures
11.2.1 Monitoring:
We will continue to monitor the situation and may provide updates as new information becomes available or as we are legally required to do so.
11.2.2 Support:
We will offer appropriate support to those affected by the breach, including guidance on protective steps to take and how to access further information or assistance.
11.2.3 Record-Keeping:
All data breaches will be recorded in our internal logs and we will document our response, in accordance with our obligations under the GDPR and other data protection laws.
By outlining these procedures, DeepX Elysium Inc. demonstrates its commitment to the privacy and security of our users’ Personal Information.
12. Data Retention and Disposal Policy
Preservation of Personal Information:
12.1 Purpose and Necessity
We retain your Personal Information solely for the duration necessary to realize the objectives for which it was originally gathered, except when extended storage is mandated or sanctioned by law.
12.2 Retention for Business Purposes
There may be occasions where we hold onto your Personal Information for legitimate business purposes, such as for the fulfillment of our legal responsibilities, the resolution of disputes, and the management of our records.
12.3 Deletion and Anonymization
Upon the cessation of the need for your Personal Information, we are committed to either eradicating or anonymizing it in alignment with our internal data retention guidelines and prevailing legal requirements.
12.4 Handling Inaccessible Data
In instances where immediate deletion is not feasible—for instance, if your Personal Information is secured within backup systems—we will ensure the secure storage of your Personal Information and restrict any further processing. We will retain such Personal Information in isolation until deletion can be achieved.
13. Use by Minors
Youth Protection:
13.1 Intended User Age
Our websites and services are designed for and directed towards users over the age of sixteen (16). It is not our policy to intentionally gather Personal Information from individuals under the age of sixteen (16).
13.2 Age Verification and Data Collection
In compliance with our commitment to protect the privacy of young individuals, we do not knowingly solicit or collect Personal Information from anyone under sixteen (16) years of age.
13.3 Reporting and Removing Minor’s Information
If you become aware of any Personal Information submitted to us by a minor under sixteen (16), please inform us immediately at privacyprotection@deepxelysium.com. Upon notification, we will take swift action to remove such information from our records.
14. External Links Policy
Third-Party Site Links:
14.1 Presence of External Links
Our Services may feature links to external websites that are not under the jurisdiction or operational control of DeepX Elysium Inc., which may include various social media platforms and other online services (“External Sites”).
14.2 Independent Privacy Policies
Any Personal Information you disclose to these External Sites will be subject to the respective privacy statements and terms of service of each External Site, rather than those of this Privacy Policy.
14.3 No Implied Endorsement
The inclusion of any link to External Sites does not constitute an endorsement, nor does it reflect our review of such External Sites. We recommend that you directly consult the External Sites for information regarding their privacy policies and practices.
15. Global Data Transfer and Protection
International Data Usage:
15.1 International Transfer of Data
By engaging with our Services, you acknowledge and consent to the transfer of your Personal Information to our operational facilities and servers located in the United States, as well as to other jurisdictions where our service providers may be situated.
15.2 Adherence to International Privacy Regulations
We are committed to ensuring the secure and lawful transfer of Personal Information across borders. To this end, we adhere to recognized international data protection agreements and frameworks, such as those established by the European Commission, the United Kingdom, and Switzerland, which are deemed to provide an adequate level of data protection.
15.3 Inquiries and Data Protection Authorities
For inquiries concerning our privacy policy and data protection, please reach out to us at: privacyprotection@deepxelysium.com. Additionally, you have the right to contact your local data protection authority with questions or concerns, and we pledge to cooperate with such authorities to resolve any issues.
16. International Considerations
16.1 Tailored Data Protection Compliance
DeepX Elysium Inc. operates on a global scale, and as such, we recognize the importance of complying with international data protection laws and regulations. Our commitment to data privacy is unwavering across all the markets we serve, including the United States, the European Union, the United Kingdom, and Asia. Here is how we address regional data protection:
- United States: We comply with applicable U.S. privacy laws and regulations. We participate in and have certified our compliance with the EU-U.S. Privacy Shield Framework where applicable.
- European Union: In accordance with the General Data Protection Regulation (GDPR), we have implemented measures and safeguards to protect personal data. We also engage in contractual obligations that ensure the same level of data protection when transferring data outside the EU.
- United Kingdom: Post-Brexit, we continue to align our data protection practices with the UK’s data protection laws, which currently mirror the GDPR, ensuring the protection of data for our UK users.
- Asia: Recognizing the diversity in data protection laws across Asian countries, we take specific measures to comply with national regulations, such as the Personal Data Protection Act (PDPA) in Singapore, and other relevant laws in the jurisdictions we operate in.
16.2 Regional Specifics and User Rights
16.2.1 User Rights:
Regardless of your location, you are afforded comprehensive rights over your personal data. These include the right to access, rectify, restrict processing, erase, and port your data, among others.
16.2.2 Legal Bases for Processing:
We process personal information on various legal bases as required by the specific laws of your region, including but not limited to, your consent, the necessity to perform a contract with you, our legitimate business interests, and compliance with legal obligations.
16.2.3 Data Protection Contacts:
Should you have concerns or inquiries about your personal data, we are here to assist. You can contact us at the details provided in this policy, and we will guide you through the process of addressing your concerns. We also respect the authority of local data protection agencies and will cooperate fully with them as needed.
This section reflects our nuanced approach to international data protection, recognizing and respecting the varied legal landscapes in which we operate.
17. Cross-Border Data Transfer Mechanisms
Safeguarding International Data Transfers
DeepX Elysium Inc. operates globally, which involves transferring and accessing Personal Information across borders. To ensure the protection of your Personal Information, we adhere to the following mechanisms and safeguards when conducting international data transfers:
17.1 Compliance with Privacy Shields
Privacy Shield Frameworks: Where applicable, we comply with the principles of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, which set forth the conditions for the transfer of Personal Information from the European Union and Switzerland to the United States, ensuring adequate protection and compliance with data protection requirements.
17.2 Standard Contractual Clauses and Binding Corporate Rules
- EU Standard Contractual Clauses (SCCs): We utilize approved SCCs for data transfers from the EU to non-EU countries, providing contractual guarantees around the privacy and security of the data transferred.
- Binding Corporate Rules (BCRs): For intra-organizational transfers of Personal Information across borders within our corporate group, we may adopt BCRs, which are company-wide data protection policies approved by European data protection authorities.
17.3 Local Data Transfer Agreements
Country-Specific Agreements: In addition to the above, we also respect and follow data transfer agreements or mechanisms recognized or required by specific countries in Asia and other regions, aligning with local data protection laws.
17.4 Assessment and Documentation
Transfer Impact Assessments: Prior to any cross-border data transfer, we conduct assessments to evaluate the impact on the protection of Personal Information and implement supplementary measures where necessary.
17.5 User Consent
Informed Consent: When required, and where no other transfer mechanism is in place, we will seek your explicit consent for the transfer of your Personal Information to other jurisdictions, ensuring you are informed about the possible risks of such transfers due to the absence of an adequacy decision and appropriate safeguards.
By engaging with our Services and providing your Personal Information to us, you consent to the cross-border transfer and processing of your data as described in this section and throughout this Privacy Policy.
18. Contact Information
Connecting with Us
Should you have any questions regarding this Privacy Policy, or if you wish to exercise any of your rights related to your Personal Information, please do not hesitate to get in touch with us. We are available and ready to assist you with any concerns or requests you may have.
Contact Details: privacyprotection@deepxelysium.com. We aim to respond to all inquiries and requests promptly and in accordance with applicable laws.
19. Privacy Policy Modifications and Communication
Policy Amendments
We reserve the right to revise this Privacy Policy periodically. Any modifications will be reflected by the posting of an updated version on this page. Should the law or contractual obligations demand a different mode of notice, we will adhere to such requirements. Your continued engagement with our Services, or the provision of Personal Information following the notification of changes, constitutes your acceptance of our updated Privacy Policy.
Contacting Us
For any inquiries or concerns regarding our Privacy Policy or data practices, please reach out to us via email at: privacyprotection@deepxelysium.com. We are committed to addressing your questions and upholding the confidentiality and integrity of your Personal Information.