Privacy Policy

Introduction

Xenia Platform Inc. (“Xenia”, “we”, “us”, or “our”) provides a software-as-a-service operations, communication, workforce-management, and frontline execution platform through websites, mobile applications, AI-enabled features, and related services (collectively, the “Services”). This Privacy Policy explains how we collect, use, disclose, retain, and protect information when individuals visit our websites, use our applications, access or use the Services, communicate with us, or otherwise interact with us.

If you use the Services on behalf of an organization, that organization may control information submitted to the Services. In that case, we process certain information on behalf of that organization in accordance with our agreement with that organization. If you have questions about information controlled by your organization, contact that organization first.

Our Role

(a) We act as the controller, or business, for the information we collect directly and decide how to use for our own purposes. That is the information this Policy describes about website visitors, prospective customers, marketing and event recipients, and job applicants, together with the account, billing, collections, and legal-compliance records we keep about our customers and their administrators. Where you are in the European Economic Area, the United Kingdom, or Switzerland, the EEA, U.K., and Switzerland section below states our legal bases, your rights, and how to exercise them.

(b) We act as the processor, service provider, or contractor for Customer Data, meaning information submitted to or generated through the Services on behalf of a customer. That remains the case when we operate, secure, monitor, support, or troubleshoot that information, because the customer, and not Xenia, decides why and how it is used. The applicable customer agreement and data processing addendum govern that processing.

(c) Where an individual creates an account with us directly rather than through an organization, we act as the controller for that account.

Information We Collect

(a) We may collect the following categories of information:

• ‍(i) Account and contact information. Name, email address, telephone number, job title, company, work location, account credentials, administrator settings, billing contact information, and related account details.
• (ii) Customer Data and service content. Information submitted to or generated through the Services, including tasks, work orders, inspections, audits, checklists, SOPs, templates, forms, communications, resources, training materials, images, photographs, files, attachments, operational records, location-specific records, analytics, reports, prompts, AI Inputs, AI Outputs, and similar content.
• (iii) AI-related information. Prompts, AI Inputs, AI Outputs, customer-configured workflows, templates, image or document analysis, search or retrieval data, customer-specific configurations, embeddings or vector-store information where used to provide the Services, model or service logs, usage data, feedback, and related operational information.
• (iv) Usage and device information. Log data, IP address, device identifiers, browser type, operating system, app version, pages or features used, date/time stamps, referring pages, crash data, diagnostic data, and other usage information.
• (v) Mobile and location information. Depending on user settings, customer configuration, and enabled features, the Services may collect device permissions, camera or file access, approximate or precise location information, image metadata, and related mobile-app information.
• (vi) Workspace and administrator information. If you use the Services through an organization, information about your account, activity, content, messages, tasks, permissions, and workspace may be visible to that organization, its administrators, and other users according to account settings and permissions.
• (vii) Communications and support information. Information provided through support requests, chats, emails, forms, demos, sales communications, training, onboarding, surveys, and other communications with us.
• (viii) Payment and transaction information. Billing information, plan information, subscription records, invoices, payment status, and related transaction details. Payment-card information may be processed by payment processors on our behalf.
• (ix) Website, cookie, and marketing information. Information collected through cookies, pixels, SDKs, analytics tools, local storage, and similar technologies, including website usage, campaign performance, preferences, and marketing interactions.
• (x) Information from third parties and integrations. Information received from customers, authorized users, integration partners, identity providers, HRIS systems, communication tools, analytics providers, service providers, and other third-party services connected to or used with the Services.
• (xi) Sensitive or regulated information. Xenia does not configure the Services to collect biometric identifiers, payment card information, or children’s information, and Xenia’s customer agreements prohibit customers from submitting them. Operational content that users submit, such as photographs of a worksite, inspection records, and free text, may incidentally contain information that privacy laws treat as sensitive, including images of individuals, health or safety information, and location information carried in image metadata. A customer may enable additional categories only where its agreement with Xenia expressly authorizes them and states the safeguards that apply.

Notice at Collection

(a) The table below summarizes the categories of personal information we may collect and the purposes for which we may use them.

How We Use Information

(a) We use information to:

• (i) Provide, operate, maintain, secure, support, configure, and troubleshoot the Services.
• (ii) Create and manage accounts.
• (iii) Authenticate users and administer access controls.
• (iv) Process subscriptions, payments, renewals, cancellations, and invoices.
• (v) Provide onboarding, implementation, customer success, training, and support.
• (vi) Generate workflows, reports, analytics, summaries, recommendations, templates, automations, classifications, visual-verification results, and other product functionality.
• (vii) Provide AI-enabled features as described below.
• (viii) Monitor, debug, and maintain the Services.
• (ix) Develop and improve the Services using aggregated or deidentified information or other information permitted by this Policy and our agreements.
• (x) Communicate about the Services, updates, security, billing, support, and administrative matters.
• (xi) Send marketing communications where permitted and manage preferences.
• (xii) Measure and improve marketing and website performance.
• (xiii) Detect, prevent, and respond to fraud, abuse, security incidents, and unlawful activity.
• (xiv) Comply with legal obligations, enforce agreements, and protect rights.
• (xv) Create aggregated or deidentified information.

(b) References to improving, developing, or enhancing the Services do not authorize Xenia to use Customer Data or AI Outputs to train, fine-tune, adapt, distill, or improve artificial intelligence or machine-learning models for cross-customer, provider, or general product use without customer permission.

AI-Enabled Processing

(a) We use AI-enabled technologies to provide, operate, support, secure, analyze, and configure the Services. Depending on the features you or your organization use, we may process account information, user information, Customer Data, uploaded files, images, voice recordings, communications, work orders, inspections, audit records, templates, prompts, AI Inputs, AI Outputs, usage data, device information, and related operational data through AI models or AI-enabled systems.

(b) We use this processing to generate or assist with workflows, summaries, templates, recommendations, classifications, analytics, visual verification, search, automation, support, security, and other product functionality.

(c) The AI providers we use, and the features each supports, are these. Anthropic PBC supports the Insights Agent, the Photo Agent and Photo Agent Explorer, AI summaries, Builder Copilot, AI search over documents, document topic cards, workspace search, prompt assist, Lookback Insight, the Insights Knowledge Base, and the Xenia Data Cloud. OpenAI, LLC supports the Template Agent, document import, grid-report insights, and content moderation. Apple Inc. and Google LLC provide speech-to-text transcription for voice entry in our mobile applications, which means audio recorded on the speaking individual’s device is sent to those providers for transcription. We are evaluating Google LLC’s Gemini models as an additional provider and will update this Policy before that processing begins.

(d) Information sent to AI providers includes names, email addresses, job titles, business location names and identifiers, photographs of identifiable individuals submitted for personal protective equipment and compliance checks, the contents of uploaded documents, free-text entries such as inspection answers, notes, and messages, and retained conversation history. We do not apply a filtering, redaction, or de-identification step to that content before sending it. Content is sent as the user submitted it.

(e) Anthropic PBC and OpenAI, LLC each retain inputs and outputs for up to thirty days under their standard commercial application-programming-interface terms, and we do not hold a zero-retention or reduced-retention arrangement with either provider. Google’s speech recognition service retains audio and transcripts for five days. Apple’s speech recognition service does not retain them unless the individual has enabled Apple’s Improve Siri and Dictation setting, in which case the provider may retain transcripts for up to two years. Provider retention periods for each component are stated in the schedule to our data processing addendum, and a provider may apply its own abuse monitoring and trust-and-safety review to content it receives.

(f) We offer a model context protocol server at mcp.xenia.team. Where an administrator or user connects a Xenia workspace to an external AI assistant through that server, workspace content within that user’s permissions becomes available to the connected assistant, and the operator of that assistant receives it. That connection is made by the user, and the receiving assistant is governed by its own terms rather than by this Policy.

(g) We do not use Customer Data or AI Outputs to train, fine-tune, adapt, distill, or improve artificial intelligence or machine-learning models for cross-customer, provider, or general product use without customer permission, and we do not authorize our subprocessors to do so. We use our AI providers under their standard commercial application-programming-interface terms, which restrict those providers from using inputs and outputs to train or improve their own models; we rely on those terms rather than on a separate agreement, and we will update this Policy if that position changes. Neither commitment reaches a model provider’s automated abuse monitoring, safety classification, or trust-and-safety review of content the provider receives, which we do not control. We may process Customer Data through AI-enabled systems to provide the Services to the applicable customer, including by operating customer-specific configurations, retrieval, prompts, and workflows, and we may use aggregated or deidentified information for analytics, security, reporting, and product improvement as described in this Policy and our agreements.

(h) Customer permission for training, fine-tuning, adaptation, evaluation, validation, or model improvement may be provided only through an order form, a written authorization the customer signs or approves, or an administrator-controlled product setting that records the permission and logs it for audit. Passive website terms, continued use, beta or preview enrollment, and individual end-user consent are not sufficient.

(i) AI Outputs are generated to assist customer review and operational decision-making. Customers and authorized users are responsible for reviewing AI Outputs before relying on them and for determining whether AI Outputs are appropriate for the applicable use case.

How We Disclose Information

(a) We may disclose information under the following circumstances:

• (i) Customers and authorized users. If you use the Services through an organization, information may be visible to that organization, its administrators, and other users according to account settings and permissions.
• (ii) Service providers and subprocessors. We may disclose information to vendors, service providers, subprocessors, and infrastructure providers that help us provide the Services, including cloud hosting, authentication, communications, analytics, customer support, security, payment, integration, observability, and AI model or AI infrastructure providers.
• (iii) Third-party integrations. If Customer enables integrations or directs us to connect the Services with third-party systems, we may disclose information to those systems as directed by Customer or its administrators.
• (iv) Professional advisors. We may disclose information to attorneys, accountants, auditors, insurers, bankers, and other professional advisors.
• (v) Legal, safety, and rights protection. We may disclose information where we believe disclosure is necessary to comply with law, legal process, government requests, enforce agreements, protect rights, investigate security or fraud issues, or protect the safety of Xenia, customers, users, or others.
• (vi) Business transactions. We may disclose or transfer information in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction.
• (vii) With consent or direction. We may disclose information with consent or at the direction of the applicable customer or user.

Cookies, Analytics, Marketing, and Preference Signals

(a) We and our service providers use cookies, pixels, software development kits, local storage, log files, and analytics tools to operate our websites and the Services, remember preferences, understand usage, improve performance, support marketing, measure campaigns, secure accounts, and detect fraud or abuse. The technologies in use are described below.

(b) Consent management. We use HubSpot to manage cookie consent on xenia.team. Where applicable law requires consent before a cookie or similar technology is set, that tool is the mechanism through which consent is requested and recorded.

(c) Product and website analytics. We use Segment, which collects user identifier, name, email address, telephone number, workspace name, and subscription status; Datadog Real User Monitoring, which collects event telemetry including page views, taps, network requests, and errors; Google Analytics 4; PostHog, which collects device identifier, session identifier, referring page, and landing page; and Plausible, which collects aggregate website statistics.

(d) Session recording. We use Datadog Session Monitoring, Microsoft Clarity, and Hotjar. These tools record and replay how an individual moves through a page, including pointer movement, clicks, scrolling, and navigation, and Clarity and Hotjar also produce heatmaps. Form fields are masked in Datadog Session Monitoring.

(e) Advertising and identity resolution. We use Google Ads for conversion tracking, using a cookie that persists for ninety days. We use LiveIntent and LiveRamp for identity resolution and first-party identity matching, using cookies that persist for two years.

(f) Mobile applications. Our mobile application includes the Datadog Real User Monitoring, Firebase Crashlytics, and Stream Chat software development kits.

(g) Local storage. The Xenia application uses local storage in your browser for session management and authentication.

(h) You may control cookies through the consent tool on our website and through your browser settings. Additional choices about analytics, targeted advertising, sale, or sharing may be offered through supplemental notices, cookie tools, privacy links, or account settings where they apply.

(i) Preference signals. Our websites do not currently detect or respond to Global Privacy Control or other opt-out preference signals, and do not respond to “Do Not Track” signals. We will update this Policy when that changes.

(j) We do not use Customer Data processed on behalf of a customer to target advertising to individuals across third-party sites or services unless directed by the customer or permitted by the applicable agreement and law.

Retention

(a) We retain information for as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, maintain accounts, comply with legal obligations, resolve disputes, enforce agreements, preserve security, maintain backups, and support legitimate business purposes.

(b) Retention periods vary depending on the type of information, customer configuration, account status, legal requirements, backup cycles, and applicable agreements. Enterprise customers may have additional return, deletion, or retention terms in a data processing addendum or order form.

(c) We retain AI conversation history and supply it as context to a model on later requests in the same workspace. We will delete each conversation no later than twelve months after the date of that conversation, on a rolling basis, while the account is active, subject to any shorter period an enterprise customer’s agreement states and to the deletion terms of that agreement when it ends.

Security

(a) We use administrative, technical, and organizational safeguards designed to protect information. No system is completely secure, and we cannot guarantee that unauthorized access, loss, misuse, or alteration will never occur.

(b) Specific security commitments apply only if stated in an applicable customer agreement, order form, data processing addendum, security exhibit, or other written agreement executed or expressly incorporated by Xenia.

Your Choices and Rights

(a) Depending on your relationship with Xenia and your jurisdiction, you may have choices or rights to access, correct, delete, obtain a copy of, restrict, object to, or opt out of certain processing of personal information.

(b) If you use the Services through an organization, that organization may be responsible for responding to certain requests involving Customer Data. We may refer your request to that organization.

(c) You may submit a privacy request by emailing compliance@xeniaplatform.io or writing to the address in the Contact Us section. If your request relates to Customer Data controlled by your organization, we may route the request to that organization.

(d) We may need to verify your request and may ask for additional information to do so.

State Privacy Rights

(a) Depending on your jurisdiction and our legal obligations, you may have rights to know, access, correct, delete, obtain a copy of, opt out of certain disclosures or targeted advertising, limit certain uses of sensitive personal information, or appeal a rights decision.

(b) In the preceding twelve months, we may have collected the categories of personal information described in this Policy. We may disclose categories of personal information to service providers, subprocessors, customers, integrations, advisors, authorities, and transaction counterparties for the purposes described in this Policy.

(c) If our use of website, cookie, analytics, or advertising technologies constitutes a “sale”, “sharing”, or targeted advertising under applicable law, we will provide opt-out rights as required by that law. Customer Data processed by Xenia as a processor, service provider, or contractor is governed by the applicable customer agreement, DPA, or data processing terms.

(d) Depending on the features enabled by a customer, the Services may generate recommendations, summaries, classifications, alerts, rankings, analytics, visual-verification results, workflow suggestions, or similar AI-assisted outputs. These features are intended to support customer review and operational decision-making. Xenia does not intend the Services to make decisions with legal or similarly significant effects about individuals without appropriate customer-controlled human review and legally required notices, rights, and controls. Xenia may route Customer Data requests, automated decision-making requests, or profiling requests to the applicable customer organization where that organization controls the relevant Customer Data or decision.

International Transfers

(a) Xenia is based in the United States and hosts and processes information in the United States. Information may also be accessed or otherwise processed in other countries where Xenia, its personnel, service providers, or subprocessors operate. Those countries may have data protection laws different from the laws where an individual is located. Xenia participates in the EU-U.S. Data Privacy Framework and its United Kingdom Extension, as the Data Privacy Framework Compliance section below describes.

(b) Where Xenia processes personal data on a customer’s behalf, that customer determines the purposes and legal basis for the processing, and individuals should contact that customer first.

(c) Biometric information: retention and destruction. If Xenia comes into possession of a biometric identifier or biometric information as the Illinois Biometric Information Privacy Act, 740 ILCS 14, defines those terms, Xenia will destroy it when the purpose for collecting it has been satisfied or within one year after Xenia’s last interaction with the individual, whichever comes first. Xenia will not sell, lease, trade, or otherwise profit from a biometric identifier or biometric information, and will not disclose it except with the individual’s written consent, to complete a transaction the individual requested, as law requires, or under a valid warrant or subpoena.

(d) When Xenia processes Customer Data on behalf of a customer, the applicable customer agreement and data processing addendum govern international transfers. Where a customer requires a transfer that needs a mechanism under European Economic Area, United Kingdom, or Swiss law, that transfer runs under a separate international transfer addendum to that customer’s agreement.

(e) A customer agreement or Quote may designate a region for primary hosting of specified Customer Data. Unless the agreement expressly states otherwise, a regional-hosting designation does not mean that every support, security, backup, telemetry, integration, AI, subprocessor, or legally required processing activity occurs exclusively in that region.

(f) AI-enabled features may involve processing by AI model or infrastructure providers in the countries identified in the applicable subprocessor information or customer agreement. Xenia applies the transfer mechanism and contractual restrictions applicable to that processing and does not use Customer Data or AI Outputs for cross-customer, provider, or general model training without customer permission as described in this Policy and the applicable agreement.

(g) For Customer Data controlled by an organization, that organization determines the purposes and lawful basis for the transfer and should be contacted first about the transfer. Xenia will provide information and assistance as required by the applicable agreement and law.

EEA, U.K., and Switzerland

(a) This section applies to individuals in the European Economic Area, the United Kingdom, and Switzerland, and to the information for which Xenia is the controller. Where you use the Services through an organization, that organization is the controller of the information you submit to the Services, and you should contact that organization about it.

(b) Our legal bases. We process account and contact information, and billing and transaction information, to perform our contract with your organization or with you, and to comply with legal obligations including tax and accounting obligations. We process usage, device, and security information for our legitimate interests in operating, securing, and improving the Services, and in preventing fraud and abuse. We process website, cookie, and marketing information with your consent where the law requires consent, and otherwise for our legitimate interests in understanding and improving our marketing. We process job applicant information to take steps at your request before entering into a contract and for our legitimate interests in recruiting. Where we rely on legitimate interests, you may ask us for a description of the balancing we carried out.

(c) Your rights. You have the right to ask us for access to the personal data we hold about you, for its correction, for its erasure, for the restriction of our processing, and for a copy in a portable format. You have the right to object to processing we carry out for our legitimate interests, and to object at any time to processing for direct marketing. Where we rely on your consent, you may withdraw it at any time, and withdrawing it does not affect the lawfulness of what we did before you withdrew it. To exercise a right, email compliance@xeniaplatform.io.

(d) Complaints. You have the right to lodge a complaint with the supervisory authority of the country in which you live or work, or in which you consider the problem arose. In the United Kingdom that authority is the Information Commissioner. In Switzerland it is the Federal Data Protection and Information Commissioner.

(e) EU Representative (GDPR Article 27).

Xenia Platform Inc. has appointed Engage Data Consulting B.V., trading as Engage Compliance, as its EU Representative under GDPR Article 27.

Contact the representative:
https://www.engagecompliance.co/representatives/xeniaplatforminc
By email: xeniaplatforminc@engagecompliance.co
By post: Engage Data Consulting B.V., KvK 82538638, Cruquiuskade 251, 1018 AM Amsterdam, Netherlands

Engage Compliance maintains a public record of this appointment.

Verification of representative status:
https://www.engagecompliance.co/representatives/verify?id=1DuBFMdAfhyaTX1domkRZqH0

(f) UK Representative (UK GDPR Article 27).

Xenia Platform Inc. has appointed Engage Compliance UK Ltd, trading as Engage Compliance, as its UK Representative under UK GDPR Article 27.

Contact the representative:
https://www.engagecompliance.co/representatives/xeniaplatforminc
By email: xeniaplatforminc@engagecompliance.co
By post: Engage Compliance UK Ltd, 124 City Road, London, EC1V 2NX, United Kingdom

Engage Compliance maintains a public record of this appointment.

Verification of representative status:
https://www.engagecompliance.co/representatives/verify?id=FvCXueI7BziQBmvOGVsCEINZ

(g) Transfers. We are in the United States and we process this information there. Where we transfer personal data for which we are the controller out of the European Economic Area, the United Kingdom, or Switzerland, we rely on the standard contractual clauses the European Commission has approved, together with the International Data Transfer Addendum the Information Commissioner has issued and the modifications the Swiss authority requires. You may ask us for a copy at compliance@xeniaplatform.io. Where we process information on behalf of a customer, the transfer runs under that customer’s agreement, as the International Transfers section above describes.

(h) Retention. We keep account and contact information for as long as the account is open and for six years afterwards, to meet our tax, accounting, and limitation obligations. We keep website, cookie, and marketing information for the periods the Cookies, Analytics, Marketing, and Preference Signals section states. We keep job applicant information for twelve months after the application is decided unless you ask us to keep it longer.

(i) Automated decisions. We do not make decisions about you that produce legal effects concerning you, or similarly significantly affect you, based solely on automated processing.

Data Privacy Framework Compliance

(a) Xenia Platform Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Xenia Platform Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension. If there is any conflict between this Privacy Policy and the DPF Principles, the Principles shall govern.

(b) To learn more about the Data Privacy Framework program, and to view our certification, visit https://www.dataprivacyframework.gov/.

(c) Xenia Platform Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission with respect to compliance with the EU-U.S. DPF Principles.

(d) Our certification covers personal data received from the European Union and the United Kingdom in the course of providing the Services.

(e) In compliance with the EU-U.S. DPF Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union and United Kingdom individuals with inquiries or complaints regarding our handling of personal data in reliance on the DPF should first contact Xenia Platform Inc. at: compliance@xeniaplatform.io. Xenia Platform Inc. has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you. If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for more information on this process.

(f) Individuals in the European Union and the United Kingdom have the right to access the personal data we hold about them, to request correction of inaccurate data, and to request deletion or restriction of processing in certain circumstances. To exercise these rights, contact us at compliance@xeniaplatform.io. We will respond within a reasonable period.

(g) Individuals in the European Union and the United Kingdom have the right to opt out of disclosures of their personal data to third parties where the disclosure is for a purpose materially different from the purpose for which the data was originally collected or later authorized. To opt out, contact us at compliance@xeniaplatform.io.

(h) We are potentially liable for the processing of personal data by our subprocessors if they process personal data in a manner inconsistent with the DPF Principles, unless we can demonstrate that we are not responsible for the event giving rise to the damage.

(i) The categories of personal data we collect and the purposes for which we process it are described in the Information We Collect, How We Use Information, and AI-Enabled Processing sections above. Contact details for questions, complaints, and requests about this Policy and about our Data Privacy Framework compliance are in the Contact Us section below.

Government and National Security Requests

(a) We may be required to disclose personal data to public authorities, including law enforcement and national security agencies, where U.S. law requires it, including under the Foreign Intelligence Surveillance Act and the Clarifying Lawful Overseas Use of Data Act. Our policy is to review every government request for personal data to assess its legal validity, to notify the affected customer where we are legally permitted to do so, to challenge a request that is overbroad or unlawful, and to provide only the minimum data necessary to comply with a legally valid request.

(b) As of August 4, 2026, and to the knowledge of our executive officers, we have not received a request for personal data from a national security authority. U.S. law may prohibit a recipient from confirming or denying the existence of certain national security requests, and this statement is subject to that limitation.

Canada

(a) Where applicable, individuals may have rights to access and correct personal information and to withdraw consent subject to legal or contractual restrictions.

Children and Minors

(a) The Services are intended for business use and are not directed to children or minors. Users may use the Services only if they are at least eighteen years old, unless the applicable customer agreement or customer-controlled use case permits younger authorized users and the customer is responsible for legally required notices, consents, authorizations, and safeguards.

(b) Outside customer-controlled use of the Services, we do not knowingly collect personal information from children under thirteen. If you believe a child under 13 has provided personal information directly to us outside a customer-controlled use of the Services, contact us at compliance@xeniaplatform.io.

(c) Customers are responsible for determining whether their use of the Services involves minors, students, applicants, employees under eighteen, youth-facing operations, or children’s data and for obtaining any notices, consents, or authorizations required for Customer Data.

Changes to This Policy

(a) We may update this Policy from time to time. Updated versions are effective when posted or on the later effective date stated in the updated Policy. Additional notice may be provided where required by law.

Version and Effective Date

We adopted and implemented this Version 3.16 of our Privacy Policy on, and effective as of, September 25, 2026. This Version 3.16 of our Privacy Policy amends, restates, and replaces in their entirety all previous versions of our privacy policy.

Contact Us

Xenia Platform Inc.
405 West Superior Street, Suite 712
Chicago, Illinois 60654
USA
compliance@xeniaplatform.io