Privacy Policy

For Nano Composite Products’ customers and other external parties

Version 1, last updated 4/28/2020

We at Nano Composite Products, Inc. (including our subsidiaries) are committed to the protection of your personal data. Below you will find information regarding the types of personal data we collect, the reasons and purposes of processing your personal data, as well as your rights.

Nano Composite Products has the role of ‘controller’ for the processing of personal data under the covered services (see sec. 1).
Nano Composite Products will be ‘joint controller’ with advertisers like Facebook and Google if you consent to us sharing your personal data with an advertising platform for targeted marketing (see sec. 5).

Contact information for Nano Composite Products is:

Email Address: privacy@xonano.com
Mailing Address: 1461 East 840 North, Suite 200, Orem, Utah 84097
Telephone Number: 801-709-0659

This privacy policy applies to the following websites:

• www.xonanosmartfoam.com
• www.xocomfort.com

The policy also applies to the following services:

• XOnano Data Logger App

The personal data we collect from our users depends on the websites and services that are used, as well as the information that is provided during purchases, registrations, or communications.

We collect the data which is provided by you while registering for our services, subscribing to our updates or when contacting us directly. Furthermore, information is automatically collected while you use our digital content such as our web pages and apps.

We may process personal information of the following categories:

• Basic information, such as name, employer, title and contact information that you have submitted to us.
• Information about your customer relationship with us and any contact with our support services.
• Information generated by the use of our webpages, such as page visits and downloaded files. You can read more about this in our marketing and cookie policy.
• Potentially other information processed based on your consent. In such cases, you will receive specific descriptions of what information is processed and what it is used for.

Our web pages and digital channels are not meant for nor targeting children under 13 years of age. We do not deliberately process information about minors.
If we, to your knowledge are processing information about children under 13 years of age, you may contact us, and we will delete the information from our systems.

We process personal data through our webpages, Customer Relations Management system (CRM), Enterprise Resource Planning system (ERP) and other digital systems.

This is done for the following purposes:

• Providing services: We process personal information to provide and deliver services to you. For example, we process your information in relation to identification of customers, invoicing and payments, customer service, technical support and customer complaint handling. Such processing is neccesarry to fulfil our agreements with you, and/or to provide services at your request.
• Development and analysis: We process personal data to improve our services and digital channels. Such processing is based on legitimate interest.
• Sales and marketing: We use both anonymized and personal data for marketing purposes. These activities include direct marketing, such as:
  • defining target groups; based on consent (if required)
  • adapting and targeting the marketing; based on consent (if required)
  • distribution of newsletters and other forms of direct marketing; based on consent or another applicable legal basis; and
  • marketing analysis and customer satisfaction surveys; based on consent and/or legitimate interest.
• Information security: We may process personal information to ensure the security of our systems, and to detect and prevent certain types of misuse of our services. Such processing is based on a legitimate interest.
• Legal compliance: We process personal information to meet legislative requirements, for example in relation to accounting and providing information to authorities when required by law. Such processing is based on compliance with our legal obligations.
• Collection and disputes: If our agreement terminates, or if other bases for processing of your personal data therefore lapses and/or if a dispute has arisen between us, the following applies: We do not need to delete your data if we may need it to process it for the purpose of collection of any outstanding amount and/or for the purpose of dispute handling (see GDPR art. 17 (3) e).
• Other purposes to which you have given consent: We may process your personal information for any other purpose to which you have given us your consent.

We use “cookies” and similar technologies on our digital webpages.
See how in our marketing and cookie policy.

We prioritize highly the protection of your personal data, and continuously work to safeguard it and other confidential information. Our security measures include physical, technical, and organizational measures, use of protective software, IT infrastructure, internal and external networks and technical facilities, as well as internal policies and access control.

Our security work is based on regular risk assessments and internal controls to ensure that sufficient security measures are imposed to prevent the unauthorized access of personal data. 

We only store your personal data for as long as necessary and for the purpose the data was collected, unless a legal requirement demands a longer storage period, or if you have given us your consent to extended storage. See in particular our marketing and cookie policy and below in this section.

Your personal information will be processed for as long as you have an active relationship with us or our digital channels, or until you request us to delete the information in our systems. We consider a relationship with us as:

1. being a customer or customer contact of Nano Composite Products, Inc.;
2. having given consent to receive marketing material or other notifications from us;
3. having actively asked to be contacted by us via social media, electronic messages, electronic forms or on exhibitions, seminars, etc.;
4. having requested to follow us on Facebook or another advertising platform, or
5. been active in our digital channels after giving your consent.

The relationship to us is defined as ‘active’ as long as:

• activity has been recorded in our digital channels within the last 24 months,
• your contact information or user profile is needed to maintain the relationship to you or your company, or
• you have not explicitly withdrawn your consent.

Storage of anonymized information is not subject to such limitations or demands, as anonymized information is not considered personal data. We work to ensure that personal information and other customer information is at all times updated and correct, and that we do not store information that is unrelated to the stated purposes for processing of personal information.

You have the right to access, correction, and in some cases deletion of your personal data processed by us. You may also have the right to restrict or object to the processing, as well as the right to data portability. 

If our processing is based on your consent, you can always withdraw your consent to our processing of your personal data. To assert your rights, please send us a request to privacy@xonano.com. We will answer your request as soon as possible, and in all cases no later than in 30 days.

If you are of the opinion that our processing of your personal data breaches the terms of this policy, or in other ways breaches the General Data Protection Regulation (GDPR), you can file a complaint to us by emailing us at privacy@xonano.com.