Effective as of February 04, 2020. 

This Privacy Policy describes and explains how XM ONLINE LLC (“XM ONLINE”, “we”, “our”, “us”) as the data controller collects and processes information relating to individuals (“Personal Information”, “Personal Data”). 

1. What is covered by this Policy? 

This Privacy Policy applies to and covers the processing of Personal Information which may be collected by XM ONLINE when you visit and/or interact with our website https://www.xm-online.com/ (hereinafter - the “Website”); contact us via email or phone or in other cases as described below where we act as the controller of your Personal Information.

2. What Personal information do we collect and how we use this information?

We may collect and process the following Personal Information about you and use such Personal Information as described below: 

  • when you interact with us, contact us via correspondence, through our website, otherwise, contact us or sending us requests. When you fill and submit our “Contact Us” form or fill and submit any request/inquiry form via our Website you may be asked to provide the following information: name; email address or your phone number. This information will be used to reply to your request and contact you using the data you provided for those purposes. If you choose to contact us via our email we will use your email address to reply to your email.

  • when you subscribe to marketing emails. On our Website, you may choose to subscribe to our marketing communication. If you chose to subscribe to our marketing newsletter we will process the email address you provided to us to send you information about our products and services, events and news. You have the option to unsubscribe and withdraw your consent to the marketing communication at any time.

  • when you apply for a job. If you apply for a job using the application form at our Website or sending us your CV via email we will collect the information you send to us in your CV during the application process. We will use this information for the purposes of processing your job application and may further keep such Personal information at our records upon your consent.

While interacting with our Website, applying for a job, please, be sure you do not send to us any special or sensitive categories of personal data (e.g. data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, etc). We do not collect any special or sensitive categories of Personal data.

Purposes for which we process your Personal data:

  • replying to your requests, following up on incoming requests from you; 

  • performing of direct sales activities in cases where you have expressed the interest in our Services and where the legitimate interest is established;

  • performing contractual obligations, providing our services to you;

  • sending marketing communications upon your consent;

  • processing of job applications if you have applied for a job at XM^ONLINE.

3. Legal basis for the processing of Personal Information we rely on.

We process Personal Information based on the following legal basis:

  • Consents. In cases we collect Personal information based on consents, such collection of Personal information will be made through consent forms specifying the specific purpose of the processing of your personal data. For example, we may ask you to give consent for sending marketing emails, news digests, etc. 

  • Performance of the contract. We may use and process Personal Information to the extent it is necessary for the performance of a contract between you and XM^ONLINE. 

  • Legitimate interests. We may process Personal information when such processing is necessary for the purposes of the legitimate interests pursued by us, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

  • Compliance with legal obligations. In some cases, we may process personal Information when the applicable law requires us to do so in order to comply with a legal obligation to which XM^ONLINE is subject.

4. Who do we share your Personal Information with?

We may share Personal Information with other exclusively when we are legally permitted to do so. We do not sell or trade your information with any third parties. We do not share your personal information with any third parties except as explicitly specified herein:

  • with your consent - when you have given us an explicit and affirmative consent to share your data with third parties;

  • third-party service providers - when we use the services of third-party service providers that help us provide our services, run and manage our systems (e.g., storage services, customer relations management systems, cloud data services, etc). Personal information may be submitted to, stored or accessed by such third party services providers exclusively to the extent necessary to provide us with the relevant services.

  • when required by law - we will disclose Personal Information if such disclosure is required by law or necessary to comply with judicial proceedings, a court order or legal process.

5. Storage and transfer of Personal Information

The Personal Information we collect will be processed by us in the countries and locations where XM^ONLINE is operating. Your Personal Data may be transferred to and stored by our third-party service providers as stated herein that may be located in other countries. 


In cases your Personal data are transferred to third-party service providers we ensure the necessary adequate level of protection by entering into the appropriate data processing agreements, standard contractual clauses approved by the European Commission, if required, or we will ask you to provide the prior written consent for such international transfer of your personal data if required. 

6. Children

Our websites and services are not directed at children. We do not knowingly collect any Personal Information from children under 18.

7. How long do we keep your PD?

We store Personal Information for a period of time necessary to fulfill the purposes for which the Personal Information was collected. Sometimes we need to store Personal Information for a period of time as required to comply with legal requirements under applicable laws.


When the Personal Information is no longer required it will be securely deleted. We may process data for statistical purposes, and in such cases information will be anonymized.

8. Your rights relating to your Personal Information and how You can exercise them. 

  • Right of access to Personal Information. You have the right to obtain from XM^ONLINE the confirmation as to whether or not personal data concerning you is being processed by XM^ONLINE. You have the right to request a copy of your Personal information that XM^ONLINE holds about you as the controller and obtain the relevant information about the purposes and the ways we process your Personal Information. 

  • Right to request rectification/correction of your Personal Information. In cases where the Personal Information is inaccurate or out of date (e.g. you have changed your email address) you have the right to obtain from us without undue delay the rectification or correction of inaccurate personal data concerning you. If you use XM^ONLINE Services with the registered account you may update or correct information about you by “Editing your profile” functions within the Services. In other cases, please, contact us at privacy@xm-online.com

  • Right to request the erasure or deletion of your Personal Information. You have the right to obtain from Us the erasure or deletion of personal data we hold about you in cases where:

  • the personal information is no longer necessary in relation to the purposes for which that information was collected and processed;

  • the processing is based on your consent and you withdraw your consent to such processing;

  • you object to the processing of your Personal Information for direct marketing purposes;

  • where the processing is necessary for the purposes of the legitimate interests pursued by us and you object to such processing and we have no overriding legitimate grounds for the processing; 

  • your Personal Information has been unlawfully processed;

  • your Personal Information has to be erased for compliance with a legal obligation to which XM^ONLINE is subject.

  • Right to restrict the processing. You have the right to restrict our processing of your Personal Data in the following cases:

  • the accuracy of your Personal Information is contested by you, and We can not verify the accuracy of that Personal Information;

  • the processing of your Personal Data is unlawful and you oppose the erasure of your Personal Data and request the restriction of the use of your Personal Data instead;

  • we no longer need your Personal data for the purposes of the processing but you require your Personal data for the establishment, exercise or defense of legal claims;

  • you have the right to restrict processing for a period of time necessary for us to verify whether our legitimate grounds override your interests when you have objected to the processing of your Personal Information where the processing is based on the legitimate interest.


  • Right to withhold your consent in cases the processing of your Personal Information is based on your consent. For example, you have the right to opt-out of our marketing emails. To exercise this right you can either follow the unsubscribe link in the text of our marketing email or contact us at privacy@xm-online.com.

  • Right to object to the processing of Personal Information where the processing is based on the grounds of legitimate interests, processing for direct marketing purposes. 

  • Right to receive the Personal Information which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller to the extent possible (Right to data portability).

  • Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects. We do not use automated processing (automated decision making).

You may exercise all of those rights by emailing us at privacy@xm-online.com.


If you have any queries with regard to your privacy rights, any complaints about our use of your Personal data, please, contact us at privacy@xm-online.com.

You may also file a complaint with the appropriate data protection authority if you consider your rights have been violated.  

9. How we secure your PD?

We take necessary organizational, technical and administrative measures used in the industry to secure Personal information we collect and process. Those measures are aimed to safeguard the Personal Information against accidental loss, unauthorized disclosure, unauthorized access. 

10. The use of cookies 

Our website may use cookies. Cookies are small text files placed on your device by the website you visit. Cookies and information contained in cookies may be used to make the websites perform more efficiently, understand how visitors use the website, detect and prevent security threats, etc. 


We use the Wix.com platform for hosting of our website. Wix.com Privacy Policy is available at https://www.wix.com/about/privacy.  Information about types of cookies placed at websites built with and hosted at Wix.com is available here: https://support.wix.com/en/article/cookies-and-your-wix-site. At our website the following types of cookies are placed: 

Analytical cookies. At our website, we use analytical cookies and Google Analytics as a third-party service provider. More information and privacy policy are available at https://support.google.com/analytics/answer/6004245?hl=en 

To disable Google Analytics at your browser, please, follow the link: https://tools.google.com/dlpage/gaoptout?hl=en 


Most of the browsers allow you to manage and control your cookies. You can manage and administer your cookies settings at your browser. Please, note that disabling some types of cookies may prevent you from receiving access to some elements of our websites, or lead to some features being not available. 

More information on how to manage and administer cookies at your browser can be found at: 







11. Changes to this Privacy Policy

We can modify this Privacy Policy from time to time. We encourage you to periodically review our Privacy Policy. We will notify you about any material changes to this Privacy Policy through the notice at our website or through email which address you provided.

12. Contacting us 

To exercise your rights with regard to your Personal information or if you have any questions, complaints relating to this Privacy Policy, please, email us at privacy@xm-online.com.

You can also contact us at:


26 Starokyivska Street,

Kyiv, Ukraine, 

Postcode: 04116