Data Privacy Notice

We are X / X Delivery, LLC with registered EIN 81-4689100 and address 410 Baylor St Suite B Austin, TX 78703. Our Data Protection Lead can be contacted at [email protected].  We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”). The terms “Personal Data”, “Special Categories of Personal Data”, “Personal Data Breach”, “Data Protection Officer”, “Data Controller”, “Data Processor”, “Data Subject” and “process” (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation. “Data Protection Lead” is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer.

What are your rights?

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:

  • The right to be informed of how your Personal Data is used (through this notice);
  • The right to access any personal data held about you;
  • The right to rectify any inaccurate or incomplete personal data held about you;
  • The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy;
  • The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
  • The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.

You can exercise your right to access personal data held about you by emailing [email protected] with the subject line: “Subject Access Request”. When you submit a ‘subject access request’, you will need to provide confirmation of your identity by contacting us using the email address associated with your profile. This is provided free of charge and our response will be made within thirty (30) days unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section ‘Who can you complain to?’.

If you have questions about any of the rights mentioned in this section, please contact our Data Protection Lead at [email protected].

Who is the Data Controller?

  • If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are the joint Data Controller. We will contact you to let you know before we first start to use your data, or, at the latest, within one month of acquiring it.
  • If we have collected your personal data directly from you to provide you with services, we are the Data Controller.
  • If your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. Please refer to their own privacy notices. For a list of Data Controllers that we process personal data for, the section below ‘Third Party Interests’.

What are the lawful bases for processing personal data?

Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR. They are sub-sections:

  1. ‘your consent’;
  2. ‘performance of a contract’;
  3. ‘compliance with a legal obligation’;
  4. ‘protection of your, or another’s vital interests’;
  5. ‘public interest/official authority’; and
  6. ‘our legitimate interests’.

What are X / X Delivery, LLC’S ‘legitimate interests’?

Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact [email protected].

About our processing of your data

We might collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

Identity Data such as names, usernames or similar; marital status; title; date of birth; sex and gender.

Contact Data such as addresses; email addresses and telephone numbers.

Financial Data such as bank account and payment card information.

Transaction Data such as information about payments and details of purchases you have made.

Technical Data such as IP addresses; login data; browser info; time zone; location; browser plug-ins; operating systems; platforms and other technology on the device used to access this website.

Profile Data such as usernames; passwords; security answers; purchases/orders; interests; preferences; feedback and responses to surveys, blogs and messages.

Usage Data such as analytics relating to how you use the website.

Marketing and Communications Data such as your preferences about receiving communications from us or third parties.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data can be derived from your Personal Data but is not itself Personal Data as it cannot be used to reveal your identity. If Aggregated Data is ever used in combination with your Personal Data and becomes identifiable, it will be treated in accordance with this notice.

X / X Delivery, LLC does not collect any Special Categories of Personal Data about you or any information about criminal convictions/offenses.


What categories of information about you do we process?

Why are we processing your data?

Where did we get your personal data from?

Direct Marketing

  • Identity Data
  • Contact Data
  • Transaction Data
  • Technical Data
  • Marketing and Communications Data

If you are a current or previous customer – providing that you haven’t opted-out before or since we collected your personal data – we may occasionally send you marketing related to the products that you purchased. These messages might contain cookies, web-beacons, unique identifiers or similar to monitor our marketing distribution. This processing is conducted lawfully on the basis of ‘our legitimate interests’.

Directly obtained at the point of sale.

Customer Services

  • Identity Data
  • Contact Data
  • Transaction Data
  • Any unsolicited data you provide as part of your query

If you wish to contact us regarding an aspect of our service, including complaints or enforcing your consumer rights in relation to a product or service that we have sold you, we will use your personal data in order to investigate a claim, evaluate your needs and/or possibly take action, such as sending you a replacement product. This processing is conducted lawfully on the basis of ‘performance of a contract’.

Directly obtained at the point of sale, and at the time of enquiry (if applicable).

B2B Relations

  • Identity Data
  • Contact Data

If you are an employee of one of our European business partners, we may use your personal data to communicate with you and your business about achieving our respective business objectives. This processing is conducted lawfully on the basis of ‘performance of a contract’.

Directly obtained from you or referred to us by one of yours or our partners.

What happens if I refuse to give X / X Delivery, LLC my personal data?

We process some personal information as part of a contractual relationship with a Data Controller. Any requests to restrict this type of processing should be forwarded to the Data Controller; they will be responsible for discussing your concerns and making any decisions.

What do we do with Cookies?

Our website uses cookies. A cookie is a small file of letters and numbers that is stored on your device when you visit a website.  

Cookies are useful as they help us to provide you with a good experience when you browse our site, for example by storing your preferences and maintaining your shopping cart.  They also help us to improve the site.  Please note that information gathered by the cookies on our site is anonymous and cannot be used to identify you personally. For further details, please see our Cookie Policy [INSERT LINK TO COOKIES POLICY ON YOUR WEBSITE].

What profiling or automated decision making does X / X Delivery, LLC perform?

X / X Delivery, LLC does not perform any profiling or automated decision making based on your personal data.

How long will your personal data be kept?

X / X Delivery, LLC holds different categories of personal data for different periods of time. Wherever possible, we will endeavor to minimize the amount of personal data that we hold and the length of time for which it is held. 

  • If we process your data on the basis of ‘legitimate interests’, we will retain your data for as long as the purpose for which it is processed remains active. We review the status of our legitimate interests every twelve (12) months and will update this notice whenever we determine that either a legitimate interest no longer exists or that a new one has been found.
  • All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of two (2) years, as determined by statute of limitations for Texas for the purposes of exercising or defending legal claims.

Who else will receive your personal data?

X / X Delivery, LLC passes your data to the third parties listed in the section ‘Third Party Interests’ below.

Where does your data go?

Personal data we collect from you may be transferred to and stored at a destination outside the European Economic Area (“EEA’). Details are included in the section ‘Third Party Interests’ below.

Third Party Interests

Data Controllers

Name/Category of Third Party Controller

What processing are we performing for them?

If applicable – who is their representative within the EU?

Regulatory authorities

We are joint Controller with these authorities who require reporting of processing in some situations.


Payment Services Providers

We use these providers so that we can take electronic or card payments securely and without the requirement for you to disclose this data to us.

Please refer to the Privacy Notices of the specific payment provider applicable to your service.

Our Data Processors

Name/Category of Third Party Processor

Purposes for carrying out processing

If applicable – where does data leaving the EEA go and what safeguards are in place?

Web hosting providers

Website hosting, including the storage of data forming the website content and processing your Technical Data (and Profile Data, where applicable) in order to provide you with access to our websites.

In the interests of providing a quality service, we use providers located in the United States. These providers are bound by the contractual provisions of the EU Commission’s model clauses.

Internal technology providers

  • Software providers, whose services we use in order to manage our business with you.
  • Telephony providers.
  • Office software providers, such as email clients.

In the interests of providing a quality service, we use providers located in the United States. These providers are bound by the contractual provisions of the EU Commission’s model clauses.

Marketing technology providers

Providers who enable us to send you our marketing emails and push targeted web advertising.

In the interests of providing a quality service, we use providers located in the United States. These providers are bound by the contractual provisions of the EU Commission’s model clauses.

Who can you complain to?

In addition to sending us your complaints directly to [email protected], you can send complaints to the relevant supervisory authority.



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