2. How We Use Information 

We use your information to: 

• Provide, operate, and improve our Services. 

• Respond to inquiries, provide support, and communicate with you. 

• Send newsletters, updates, and promotional content (if you opt in). 

• Deliver training experiences, track performance, and provide analytics. 

• Ensure security, prevent misuse, and comply with legal obligations. 

We do not sell or rent your personal information. We may share it only with: 

• Trusted Service Providers who process data on our behalf (e.g., hosting, analytics, email delivery, payment processing). 

• Business Partners where needed for joint projects or integrations. 

• Legal Authorities if required to comply with law or protect our rights. 

• Business Transfers if XD is involved in a merger, acquisition, or sale of assets. 

Some of our Services may be used in educational settings, including by schools and organizations that serve children under the age of 13 (or the age of digital consent in your jurisdiction). 

• Direct Collection: We do not knowingly collect personal information directly from children under 13 without appropriate consent and authorization. 

• School/Institution Responsibility: When our Services are provided through a school, district, or other educational organization, that institution is responsible for obtaining any required consents and for ensuring compliance with applicable privacy and data protection laws (such as the Children’s Online Privacy Protection Act “COPPA” in the United States). 

• Limited Use: Any student information processed through our Services is used solely to provide the educational functionality requested by the school or organization. We do not use student personal information for advertising or marketing. 

• Requests for Access/Deletion: Parents, guardians, or eligible students who have questions about access, correction, or deletion of student information should first contact their school or institution. We will support the institution in responding to such requests as required by law. 

4. Student Data

When our Services are used in educational settings, we may process information provided by schools, districts, teachers, or administrators about their students (“Student Data”). 

Our Commitments: 

• Educational Purpose Only: We use Student Data solely to provide and improve our educational Services. 

• No Sale or Advertising: We do not sell Student Data or use it for targeted advertising or marketing. 

• School/Institution Control: Student Data is collected and processed on behalf of, and under the direction of, the school or educational institution. The institution determines what data is shared and how it is used within our Services. 

• Compliance with Laws: We comply with applicable student privacy laws, including the Family Educational Rights and Privacy Act (FERPA) and the Children’s Online Privacy Protection Act (COPPA) in the United States, as well as any additional regional or institutional requirements. 

• Parental Rights: Parents, guardians, or eligible students who wish to access, correct, or delete Student Data should direct their request to the educational institution. We will support the institution in fulfilling such requests as required by law. 

• Data Security: We implement appropriate technical and organizational safeguards to protect Student Data from unauthorized access, disclosure, alteration, or destruction. 

• Data Retention: We keep personal information only as long as necessary for the purposes described in this policy or as required by law. For example:
  - Marketing contact details are retained while you remain subscribed.
  - Training or LMS data is retained while your organization maintains an account with us. 

5. Your Choices & Rights 

You can: 

• Unsubscribe from marketing emails via the link in any message. 

• Request access, correction, or deletion of your personal information by emailing xennial@xennialdigital.com. 

• Limit cookies/analytics through your browser or device settings. 

• Depending on your location (e.g., EU/EEA or California), you may have additional rights to restrict processing or opt out of certain data uses. 

6. Security

We use reasonable administrative, technical, and physical safeguards to protect personal information. However, no system is completely secure, and we cannot guarantee absolute security. 

9. Contact Us

Questions or requests? Contact us at: 

Xennial Digital, LLC 
15751 Sheridan St, #165 
Ft. Lauderdale, FL 33331 
United States of America 
Email: xennial@xennialdigital.com