Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW INFORMATION PROVIDED THROUGH THE USE OF THE SERVICES PROVIDED BY JAXX TECHNOLOGIES MAY BE USED AND DISCLOSED.  PLEASE REVIEW IT CAREFULLY.

THIS NOTICE GIVES YOU INFORMATION about the privacy practices of JAXX Technologies Inc. and its affiliates (“we” or “JAXX Technologies”) as they pertain to information (“Information”) JAXX Technologies receives from Users when using the services of our platform (“Services”).  JAXX Technologies is committed to protecting the privacy of shared Information that Users provide or store in or through the Services, including through the JAXX Technologies website and the JAXX Technologies app.  For purposes hereof, a “User” includes you, others you authorize to access the Services and your other service providers or vendors (for example, other employees, trustees), and any beneficiary of the Services.

THE EFFECTIVE DATE OF THIS NOTICE IS August 2022.  JAXX Technologies will follow the terms of this Notice until it is replaced.  JAXX Technologies may make changes to the terms of this Notice at any time. Upon your request, JAXX Technologies will provide you with a copy of its current Notice.  JAXX Technologies reserves the right to make the changes to this notice apply to Information maintained by JAXX Technologies before and after the effective date of the new Notice. 

You or a User’s continued use of the Services after we make changes to this Notice is deemed to be your acceptance of those changes.  

Information JAXX Technologies Receives

Users may provide JAXX Technologies with a wide variety of Information, including financial, performance analytics, demographics, and metrics Information.  This information may be of the type: 

• By which Users may be personally identified, such as name, address, email address, telephone number(s), or any other identifier that can be used on its own or with other information to identify, contact or locate a User (“personal information”); or

• That is about a User but individually does not identify the User, such as employment information or geographic location.

JAXX Technologies receives this information:

• Directly from Users, through the Services, and otherwise.

• From third parties that you authorize to access the Services or provide us Information.

Ways JAXX Technologies Typically Uses or Shares Information

JAXX Technologies typically uses or shares Information in the following ways:

• To run our organization.  JAXX Technologies can use and share Information to improve our Services and to conduct quality reviews.

  
  

• To carry out its duties as a holder of a Limited Power of Attorney.  JAXX Technologies may use and share Information to perform any of the duties delegated to it pursuant to a Limited Power of Attorney.

  
  

• To JAXX Technologies’s contractors.  JAXX Technologies may share Information to JAXX Technologies’s contractors and service providers who perform services for the beneficiary.  JAXX Technologies requires any contractors or service providers with access to Information to commit to protecting the confidentiality of that Information.

  
  

• To recommend products or services.  JAXX Technologies may share the Information with service providers to identify products or services that may be of interest to you.

  
  

• To create de-identified data.  JAXX Technologies may de-identify Information such that it is no longer personally identifiable and use that de-identified data for any purpose JAXX Technologies deems appropriate.

  
  

JAXX Technologies does not require your consent to use or share the Information for any of these purposes.

Other Uses And Disclosures Without Your Consent

JAXX Technologies may share Information provided in other ways without your consent if such disclosure relates to the public good or for the safety of you or the beneficiary.  JAXX Technologies has sole discretion in deciding whether Information may be used or shared for these purposes.  Reasons JAXX Technologies may use or share Information for the public good or safety could include:

• To comply with federal or state laws;

• To comply with legal proceedings, such as a court or administrative order or subpoena;

• For law enforcement purposes;

Using and Sharing Information With Your Written Consent

Except as described in this Notice, JAXX Technologies will not use or share or sell Information unless you provide your prior written and express consent. 

You may provide written consent to allow JAXX Technologies to use or share Information in any other manner not discussed in this Notice.  If you give JAXX Technologies written consent to use or share  Information, then you may revoke your written consent in writing at any time.  Your revocation will not affect instances where JAXX Technologies or others already took action in reliance upon your written consent.

Your Other Rights

You may make a written request to JAXX Technologies to place additional restrictions on JAXX Technologies’s use and disclosure of Information or to communicate with you in confidence about Information by a different means or at a different location than JAXX Technologies is currently using.  JAXX Technologies will consider your request and, if it determines, in its sole discretion, that it is reasonable, JAXX Technologies will implement it.

Your Responsibilities

You, and not JAXX Technologies, trustees, or other named fiduciaries, determine who, other than JAXX Technologies, may access Information through the Services and the permission levels granted to each User.  It is your responsibility, and not JAXX Technologies, to control who is authorized to access Information stored by JAXX Technologies. Permissions granted by you which are necessary for the administration of the trust, to provide necessary services, or carry out the intent of the trust, may only be revoked by the beneficiary under limited circumstances to be evaluated on a case-by-case basis at the reasonable discretion of JAXX Technologies.