Xnurta Privacy Statement

Last Updated: March 23, 2026

Effective Date: March 23, 2026

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SparkX Marketing Co., Limited, doing business as (“DBA”) Xnurta, Inc., (“Xnurta,” “we,” “us,” or “our”) is committed to protecting the privacy of its users. This Privacy Statement explains how we collect, use, and process personal data that we may obtain from or about you through your use of our websites, applications, and services (“Platform”).

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Definitions

“Xnurta” or “Xnurta, Inc.” means  SparkX Marketing Co., Limited, doing business as (“DBA”) Xnurta, Inc or its affiliates entities.

“Personal data” or “Personal information” means any information which are related to an identified or identifiable natural person.

“Platform” means the software-as-a-service (SaaS) application offering advertising analytics, optimization, reporting, and AI-enabled tools and the website platform, respectively available at https://ai.xnurta.com and https://www.xnurta.com. 

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Information We Collect

In connection with your use of the Platform, we collect personal information in various categories, depending on how you interact with the Platform. A detailed description of these categories is provided in the chart below:

Category(ies) of Personal Data Examples of Personal Information Collected Source of Information Business / Commercial Purpose Disclosed to Third Parties (Y/N) Sold / Shared Retention Period
Identifiers Name, business email address, phone number, account username, IP address Directly from users during account registration and profile updates; automatically through platform use Account creation and administration; authentication; customer support; security and fraud prevention; performance monitoring Y No 30 days, or as required for Business Operations.
Personal Information Categories Listed in Cal. Civ. Code §1798.80(e) Name, business contact information, billing contact details Directly from users or business customers Contractual necessity; billing, invoicing, and account management Y No 30 days, or as required for Business Operations.
Internet or Other Electronic Network Activity Information IP address, browser type, operating system, device information, login timestamps, referring URLs Automatically through use of the Platform Platform security; access control; auditing; system integrity; performance monitoring Y No 30 days.
Geolocation Data Approximate location derived from IP address (city, state, country) Automatically through platform use Security monitoring; fraud detection; compliance and system diagnostics; customer support N No 30 days.
Professional or Employment-Related Information Company name, job title (if provided), business contact details Directly from users Account administration; customer relationship management; service communications Y No 30 days, or as required for Business Operations.
Inferences Drawn from Personal Information Account-level usage patterns and platform interaction trends Derived from platform usage data Service improvement; troubleshooting; security and operational analytics N No 30 days.

Legal Bases for Processing Personal Information

We process personal information where necessary to perform our contractual obligations to users, including providing access to and operating our Platform. We also process personal data where necessary to support our legitimate interests in maintaining the Platform, ensuring its reliability and performance. Xnurta also relies on consent as a legal basis for processing personal information, where explicitly required by applicable law.

How We Use Your Information

We process personal data in a manner that is proportionate, necessary, limited, and aligned with data protection laws.

Personal information is used to:

  • Provide, operate, improve and maintain the Platform;
  • Create, administer, and manage user accounts;
  • Authenticate users and enforce access controls;
  • Monitor platform usage and system performance;
  • Detect, prevent, and investigate security incidents or misuse; and
  • Communicate with customers regarding onboarding, support, updates, and service notices.

Xnurta does not “sell” personal information, does not share personal information for cross-context behavioral advertising, and does not use personal data for consumer marketing or targeted advertising purposes.

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How We Share Your Information

We may share your personal information with our service providers, such as payment processors and email service providers, as necessary to provide our services to you.

We may also share your personal information with law enforcement agencies, regulators, or other third parties if required by law or if we believe that such disclosure is necessary to protect our rights or the rights of others.

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How Long We Retain Your Information

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide and operate the Platform, comply with our contractual obligations, and meet applicable legal, regulatory, accounting, or reporting requirements. Retention periods vary depending on the nature of the data, the purpose of processing, and applicable legal obligations. When personal information is no longer required, we take reasonable steps to securely delete or anonymize it in accordance with our data retention and deletion practices.

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Children’s Data

Xnurta does not knowingly collect personal information from children, and the Platform is not designed for or directed to individuals under the age of 18. In the event we become aware that the personal information of a child has been collected, we will promptly take reasonable measures to remove such information from our systems, subject to applicable legal requirements.

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Marketing Communications

We may also use your information to send you marketing communications and other information about our services that we think may be of interest to you. You may opt out of receiving these communications at any time by following the unsubscribe instructions in the communication or contacting us at info@xnurta.com.

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Security of Your Information

We implement reasonable and appropriate technical and organizational measures designed to protect the availability, confidentiality, and integrity of personal information. These measures include, among other things, role-based access controls, network segmentation, encryption of data in transit, security monitoring and logging and backup and recovery procedures. In addition to this, access to personal information is restricted to authorized personnel who require such access for legitimate business purposes and who are subject to confidentiality and security obligations. Despite these safeguards, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee the absolute security of your information.

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Cookies and Other Tracking Technologies

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. Xnurta uses strictly necessary first-party cookies to support the functionality, authentication, and security of the Platform. These cookies are required for the Platform to operate and are not subject to user preference or opt-out controls. They are used solely for session management and security purposes and collect only the information necessary to maintain a secure login session, such as a session identifier. We do not use cookies for analytics, behavioral tracking, or advertising. Most cookies are session-based and expire when you log out or close your browser. A limited number of strictly necessary persistent cookies may be used for authentication and security and generally expire within approximately twenty-four (24) hours.

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Artificial Intelligence

We use artificial intelligence (“AI”) technologies in certain features of our Platform. When you use AI-powered features of the Platform, we process the personal data you provide or authorize us to access in order to support the requested functionality. The AI technology operates on the data you provide; it does not independently gather personal data outside of your authorized input.  Where applicable law requires additional disclosures about the use of automated processing or profiling, those disclosures are provided in this Privacy Statement. We do not use AI to make decisions that produce legal or similarly significant effects about individuals.

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Your Rights and Choices

Depending on your location and applicable laws, you may have certain rights with respect to your personal information. These rights may include the right to:

  • Access personal information we hold about you;
  • Request a copy of personal information we hold about you;
  • Request correction or updating of inaccurate or incomplete personal information;
  • Request deletion of personal information, where permitted by applicable law;
  • Request restriction or limitation of certain processing activities;
  • Object to certain processing activities, where applicable;
  • Withdraw consent, where personal information is processed based on consent;
  • Request personal information in a portable, commonly used, and machine-readable format, where applicable;
  • Request that we stop disclosing personal information to third parties in certain circumstances;
  • Opt-out of certain uses or disclosures of personal information, such as sale or sharing, where required by law;
  • Limit or refuse certain automated decision-making or profiling, where applicable;
  • Receive information about how your personal information is collected, used, and disclosed;
  • Not be discriminated against or retaliated against for exercising privacy rights; and
  • Lodge a complaint with a relevant data protection authority or regulator, where applicable.

You may exercise your rights by contacting us at info@xnurta.com or you may fill in our online form here.  Where applicable, we may require verification of your identity before responding to a request relating to your personal information. Verified requests will be handled within the time limits prescribed by applicable data protection laws. In some cases, we may limit or decline a request where doing so is permitted or required by law.

You may opt out of receiving marketing communications from us at any time by following the unsubscribe instructions in the communication or contacting us at info@xnurta.com.

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Changes to this Privacy Statement

We may update this Privacy Statement from time to time. We will post the updated Privacy Statement on our website and indicate the date of the last update. Your continued use of the Platform after the posting of the updated Privacy Statement will constitute your acceptance of the changes.

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If you have any questions or concerns about this Privacy Statement, please contact us at info@xnurta.com or you may fill in our online form here.