Privacy Policy for X18agency by Headson, LLC EIN : 35-2834563

Last updated: 15/05/2025

This Privacy Policy outlines how X18agency ("the Software," "we," "our") collects, uses, and shares personal information from users who use our platform X18agency is a software designed to help local businesses enhance their online reputation through various features such as review aggregation, automated review responses, review request campaigns, analytics, and process automation. We are committed to complying with all applicable data protection laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

1. Personal Data We Collect

We collect the following types of personal data from our users:

  • Identifying and contact information: Name, email address, IP address, phone number, login credentials.
  • Platform usage data: Information about reviews, responses sent via the platform, interactions with the review widget, performance and reputation analytics.
  • Data collected through automations and review request campaigns: Data from end-users (customers of local businesses), including names, email addresses, private feedback, public reviews, video testimonials, and information submitted via landing pages.
  • Browsing data: IP address, platform usage details (including cookies and similar tracking technologies). Our website uses Google Analytics 4 and Google Ads conversion tracking (Google LLC), Meta Pixel (Meta Platforms, Inc.) and Smartlook (Smartlook.com, s.r.o.) to measure site traffic, advertising performance and product usage. These tools set cookies and collect device and usage information such as IP address, pages viewed and approximate location. You can opt out of Google Analytics via the browser add-on at tools.google.com/dlpage/gaoptout, and manage or block cookies in your browser settings.
  • Data processed through artificial intelligence (AI): AI is used to generate automated responses to reviews. The data processed includes the content of the reviews and any responses generated via our platform.

2. Purposes of Data Processing

We collect and process personal data for the following purposes:

  • Review aggregation: We collect reviews from multiple platforms (Google, Trust-Pilot, Facebook, etc.) and display them in a unified interface on the platform.
  • Automated AI responses: Reviews may be responded to automatically using AI, which generates responses based on the content of the reviews and pre-set parameters.
  • Review request campaigns: We send SMS's campaigns to end-users (customers of local businesses) to encourage them to leave reviews or submit private feedback and video testimonials via a landing page.
  • Review sharing: We share the collected reviews on users' websites via widgets and on social media platforms by generating images based on the written reviews.
  • Analytics and reporting: We provide analytics tools that allow users to monitor their reputation and the performance of review request campaigns.
  • Process automation: We automate the sending of review requests through pre-configured workflows that users can set up.

3. Legal Basis for Data Processing

Under the GDPR, we process users' personal data based on the following legal grounds:

  • Consent: For sending email campaigns and using AI for automated review responses.
  • Performance of a contract: To provide the services offered by X18Agency as requested by users.
  • Legal obligation: When we are required to comply with legal obligations.
  • Legitimate interests: To improve our services, protect platform security, and monitor the effectiveness of platform features.

4. User Rights (GDPR and CCPA)

Users of X18Agency have specific rights regarding their personal data, including:

  • Right of access: Users have the right to request information about the personal data we hold about them.
  • Right to rectification: Users can request the correction of inaccurate or incomplete personal data.
  • Right to erasure (right to be forgotten): Users can request the deletion of their personal data.
  • Right to restrict processing: Users can request to limit the processing of their personal data in certain cases.
  • Right to data portability: Users have the right to receive a copy of their data in a structured, commonly used, machine-readable format.
  • Right to object: Users can object to the processing of their personal data in certain circumstances.

Under the CCPA, California residents have additional rights, including:

  • Right to know: California consumers can request details about the categories and specific personal data collected, the purposes for processing, and any third parties with whom data is shared.
  • Right to opt-out: Consumers can opt-out of the sale of their personal data.
  • Right to non-discrimination: Users will not be discriminated against for exercising their rights under the CCPA.

5. Data Sharing

We only share users' personal data in the following circumstances:

  • Service providers: We share data with third-party service providers who assist us in delivering the services (e.g., hosting, email delivery, analytics tools).
  • Third-party integrations: X18agency integrates with third-party platforms (e.g., Google, Facebook) to collect and display reviews, as well as social media networks for sharing reviews.
  • Legal obligations: We may share personal data when required to comply with legal obligations or to protect the rights and safety of our users or the public.

6. Data Security

We implement appropriate technical and organizational measures to protect users' personal data from unauthorized access, alteration, disclosure, or destruction. However, no system is completely secure, and we cannot guarantee absolute security of the data.

7. Data Retention

We retain users' personal data only for as long as necessary to fulfill the purposes for which it was collected or to comply with applicable legal requirements.

8. Marketing and Publicity

Per our Privacy and Conditions, you agree to permit X18agency to identify you as a customer and to use your name and/or logo in X18agency website and marketing materials.

9. Changes to This Privacy Policy

If we decide to make material changes to our Privacy Policy, we will notify you by e-mail through the primary e-mail address specified in your account and/or post those changes to this Privacy Policy on the Website homepage prior to the changes taking effect. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you.

You are also responsible for regularly reviewing the Privacy Policy and related documents. We reserve the right to modify this Privacy Policy at any time. No amendment to or modification of this Policy will be binding unless in writing and signed by a duly authorized representative of X18agency, or posted to the Site by a duly authorized representative of X18agency.

In the event that X18agency goes through a business transition, such as a merger, an acquisition by another company, or a sale of a portion of its assets, users' personally identifiable information will, in most instances, be part of the assets transferred. Users will be notified via prominent notice on the site for 30 days after a change of ownership or control of their personally identifiable information. If, as a result of the business transition, a user's personally identifiable information will be used in a manner different from that stated at the time of collection, users will be given a choice consistent with our notification of changes section.

10. Sale of Personal Information

X18agency does not sell, rent, or trade your private information to any third parties in any way.

11. Compliance with Google's Limited Use Policy

X18agency use and transfer of information to any other application of information received from Google APIs will adhere to Google API Services User Data Policy including the Limited Use requirements.

12. Our Use And Disclosure of Information

X18agency will not disclose any personally identifiable information about any individual except as set forth in this Privacy Policy. This applies to information about our customers and information our customers provide to us about their customers. We are not limited in any way in our use of non-personal information that does not permit direct association with any specific individual or non-identifiable aggregate information about our users (such as the number of customers who use our services, the geographic distribution of our users, the amount of information located and/or removed, etc.).

Internal Uses of Your Personally Identifiable Information

  • We collect, store and process your personally identifiable information on servers located in the United States. Due to the unpredictable nature of Internet routing, your information may pass through other countries while in transit to our servers. We use the information we collect about you in order to:
    • Develop and deliver our services;
    • Process your transactions;
    • Provide customer service and manage your account;
    • Improve our products, services and marketing.
  • We provide access to personally identifiable information about our users only to those who require it for the above purposes.
  • X18agency will not sell or rent any of your personally identifiable information to third parties. X18agency will not share any of your personally identifiable information with third parties except in the limited circumstances described below.
    • We share information with service providers under contract who help with our business operations such as payment and order processing, fraud investigation, bill collection, and information management and analytics. If content generation is included in your services, we may share information with service providers under contract to create, edit and/or publish such content. These third parties are obligated to protect your information and are contractually prohibited from using your personally identifiable information for any other purpose. They are never permitted to share your information with any third parties. They are authorized to use your personal information only as necessary to provide these services to X18agency.
    • We disclose information that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activity, to conduct investigations of violations of our Privacy of Use and/or to protect our right, protect your safety and the safety of others. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we reserve the right to provide that person or entity's contact information (but not bank account or credit card information) to victims who request it.
    • We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. If the subpoena seeks information about an identified subscriber or limited group of subscribers, we will make reasonable business efforts to contact the subscriber(s) before providing information to the party that requests it. We cannot guarantee that we will be able to do so in all cases, whether due to a time limit, court order, inability to effectively contact a subscriber, or other circumstances.
    • When a user signs up for a co-branded version of our service through links to X18agency.com from our co-branded partner's website, X18agency will share with the co-branded partner that user's name, e-mail address and physical address in order to provide enhanced integration between X18agency's services and the services of our co-branded partner. If you do not want your information shared with X18agency's co-branded partner, sign up for X18agency directly through X18agency.com/enterprise and other sub-domains and not through a link from our partner's website.
    • We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
    • We share information with companies that provide public relations and marketing services for us. Such information will only be shared by us to customize, measure and improve our products, services and advertising. It will not be shared with third parties for their marketing purposes. These third parties are contractually obligated to protect your information and are prohibited from using your personally identifiable information for any other purpose.
    • As with any other business, it is possible that in the future, X18agency could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by X18agency, including customer account information, but would continue to be bound by this Privacy Policy until it is amended.
    • We share your information with our parent, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.
    • The implementation of our Services, by its very nature, may require using your personally identifiable information to locate other information about you. Such use may include, but not be limited to, using your information to search the publicly accessible Internet sites as well as searching private information databases and sites.
    • The implementation of our Services, by its very nature, may require revealing your personally identifiable information in order to effect removal of Internet content about you. For example, we may have to disclose your name to a website in order to notify them to remove Internet content about you. This occurs with your express permission for a specific, given purpose.

13. Australian users

If you are an Australian user accessing or using the Services from Australia, the Privacy Act 1988 (Cth) and the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) ("APP") applies to personal information collected or held by X18agency or its Affiliates with an "Australian link" (within the meaning of the Privacy Act). In addition, X18agency is committed to complying with other applicable Commonwealth, State or Territory privacy and data protection laws and regulations.

14. Contact Information

For questions or requests regarding this Privacy Policy or the processing of personal data, users can contact us at Info@x18agency.com.

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