EFFECTIVE DATE:  July 16, 2020

Xigo, LLC, an NTT Ltd company, (“us” or “we”), has created this Privacy Policy to explain what information we collect from individuals (“you”) who access the CLM platform (“Website”) and use the services provided through this Website for personal or business uses.  It also explains how we may use and share information you provide through this Website.  If you have any questions about our Privacy Policy, please contact us using the information provided at the bottom of this Privacy Policy.

Please read this Privacy Policy carefully. By accessing, using, registering for an account, or otherwise interacting with this Website, you acknowledge that you have read, understand, and agree to be bound by all the terms of this Privacy Policy.  IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE EXIT THIS WEBSITE AND DO NOT ACCESS OR USE THE WEBSITE OR PROVIDE PERSONAL INFORMATION TO US THROUGH THIS WEBSITE.


We may collect two types of information from End Users of this Website: Personal Information and Non-Personal Information. 

Personal Information.  Personal Information is information that identifies a particular individual. We collect Personal Information in several ways at different points on the Website. For example, some information is gathered when you register to open an account. Additionally, we may ask you to provide Personal Information when you engage in certain activities on the Website. These activities include, but are not limited to, creating an account, requesting service through the Website, uploading content to us through the Website, completing surveys, sending feedback to us, requesting information about us or our services, applying for a job, or signing up for special offers from third parties through the Website. The types of Personal Information we may collect through any of these activities may include, without limitation, your first and last name, mailing address including postal code, email address, and telephone number.  Additionally, we may ask for your credit card number, expiration date, and authentication or other billing information when you order services through the Website.  If you provide us access to download and/or review your telecommunications invoices, pursuant to the Xigo Terms of Use or Terms of Service Agreement, we may obtain personal information from your phone bill, including but not limited to the numbers that you dial or receive calls from in any month.  Depending on the activity that you are engaging in, some of the information that we ask you to provide is mandatory and some is voluntary. Where practical, we will identify which information is mandatory and which is voluntary. If you contact us to report a problem with the Website or our services, we may keep a record of that correspondence.  Wherever we collect Personal Information, we make an effort to include a link to this Privacy Policy on that page.

We use Personal Information to provide services to you, improve our service offerings, enhance our Website operation, improve our marketing and promotional efforts, analyze Website use, tailor your experience with the Website or our services, and for any other purpose specified at the time of collection. You can always decline to provide information, although this may limit your ability to use certain services or engage in certain activities on the Website. We may also use Personal Information to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements with you, comply with applicable laws, and cooperate with law enforcement activities.

We may also use Personal Information as a data processor providing services on behalf of a data controller. The data controller may be a company that has engaged Xigo to provide services on their behalf, including the processing of Personal Information for their employees.

Non-Personal Information.  Non-Personal Information is anonymous information that cannot be associated with a particular individual. For example, we, and/or our authorized third party service providers and advertisers, may automatically collect non-personal information about your computer and navigation patterns when you visit the Website. This information may include, but is not limited to, your browser type, operating system, IP address, and the website you visited immediately before and after coming to our website. We collect this information through the use of electronic tools like cookies, web beacons, and pixel tags, which are described in Section 7 of this Privacy Policy.

We use Non-Personal Information to troubleshoot problems, administer the Website, analyze trends and demographic data, to comply with the law, and cooperate with law enforcement.  We may also share Non-Personal Information with authorized third party service providers and advertisers to analyze the quality and effectiveness of our Service offerings, advertising, and Website content.


In addition to any other information sharing or disclosure practices described in this Privacy Policy, we may share your Personal Information with companies that assist us in providing the services to you and/or perform some of our business functions on our behalf.  These functions may include, without limitation, sending administrative and promotional emails and service processing and fulfillment.  For example, we may disclose your billing information to payment processors to process fee payments or other financial transactions, or we may disclose your email address to email fulfillment contractors to send you emails from us.  Those companies are authorized to use your Personal Information only as necessary to provide these services to us. 

We may share some or all of your Personal Information with our subsidiaries and affiliates, joint venturers, or other companies under a common control (collectively, “affiliates”), in which case we will require these affiliates to honor this Privacy Policy.  If we or our assets are acquired by another company, that company will possess the Personal Information collected by us and it will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

We may disclose Personal Information if required to do so by law or to comply with a valid legal process (such as a search warrant, subpoena, or court order), to protect the company’s rights or property (including, without limitation, in the event of a transfer of control of company or substantially all of its assets), or during emergencies when safety is at risk.


We may disclose or share Non-Personal Information with certain business partners including, but not limited to, individuals and companies with whom we have business relationships.  We may share aggregated demographic information (which does not include any Personal Information) with third parties. Additionally, we may use third party service providers to track and analyze Non-Personal Information usage and volume statistics in order to administer and improve our Website. These statistics may also be used for promotional purposes, or to provide a representative audience for advertisers. This information provides only general summaries of Website visitor activities, and it does not include Personal Information.


If your Personal Information changes, please log in to your Account and make the appropriate correction, change, or update.  You may have your Account information deleted or removed; however, you cannot delete information associated with any past transactions conducted through the Website. Because we periodically backup our information, we may not be able to completely delete all of your information. In cases where your Personal Information may have been provided to us by your employer, your request will be referred to that corporate entity, which acts as data controller, and provides direction to us as a data processor. 


We take information security seriously and take reasonable precautions to protect your Personal Information from unauthorized access and/or use, loss, disclosure, or alteration. Your password and email address are required for you to access your Personal Information on our Website.  In addition, we store your Personal Information on a secure server using industry recognized measures, and access to this server is limited to select personnel and contractors. We facilitate transmission of certain sensitive information from you to our Website using Secure Socket Layer (SSL) technology to protect your Personal Information as it is transmitted to us.

Nonetheless, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies which do the same, there are security and privacy limitations of the Internet which are beyond our control. Accordingly, we cannot absolutely guarantee the security, integrity, and privacy of any and all information exchanged between you and us through the Website. We make no warranty, express, implied, or otherwise, that we will prevent unauthorized access to your private information.


Cookies.  This Website stores cookies on your computer in order to improve your experience in using the Website. Cookies are small text files stored by your browser on your computer’s hard drive used to record a User's preferences and session information. We use cookies to remind us who you are and track your interests so that we can provide you with a more customized experience. We may also use cookies to collect Non-Personal Information (such as the links you clicked on and other pages you visited) in order to improve our service.

Advertisers may display advertisements on the Website, and these companies may place separate cookies on your computer. We have no control over these cookies, and such cookies are not covered by this Privacy Policy. Most browsers automatically accept cookies, but you may change your browser settings to limit which cookies you accept or to disable cookies altogether. If you decline or delete our cookies, some parts of the Website may not work properly.

Pixel Tags and Web Beacons.  We, along with third party service providers working on our behalf, may use technologies such as pixel tags and web beacons to track your use of our Website. Pixel tags and web beacons are tiny graphic images that we place on certain portions of our Websites or in our emails that generate a non-personally identifiable notice when a user performs a specific action. We also use pixel tags to measure visitor traffic, visitor behavior on the Website, our promotions, and our performance. Pixel tags and web beacons may also be provided by our affiliates and/or marketing partners, and we use them for the same purposes.



Third Party Websites.  This Privacy Policy only applies to our Website. Our Website may include links to third party websites. These other sites are outside of our control. Please be aware that these websites may collect information about you, and they may operate according to their own privacy practices which may differ from those contained in our Privacy Policy. Please read carefully that website's own privacy policy, as once you leave our Website, any information you submit is no longer in our control.

Children.  Individuals under the age of legal capacity in their local jurisdiction (18 throughout most of the United States) may not use the Website. We do not sell products or services for purchase by children or minors.  If we become aware that a minor child has provided us with Personal Information without parental consent, we take steps to remove such information and terminate the minor's account. We do not collect or maintain information from anyone known to be under the age of legal capacity.

Public Areas.  The Website may have public areas where you can communicate with other customers, write reviews, or submit content.  Please note that this information may be accessible to others, and it may appear on other websites or in web searches where it can be seen and used by others.  We cannot control who accesses and uses information (including Personal Information) you post in a public forum, so please use discretion when disclosing any personal information in these areas.  Your use of such public areas may be subject to additional terms and conditions, including any applicable terms and conditions included in the Website Terms of Use.

Notice of Privacy Rights to California Residents. Companies that collect Personal Information from California residents and disclose such information to third parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide a mechanism by which a consumer may opt-out of having his or her information shared with third parties.  We have elected the second option, and you may request that your Personal Information not be shared with third parties by sending your request, including your full name, email address, and postal address, to:  Xigo, LLC, 5870 Trinity Parkway, Suite 250, Centreville, VA 20120.  California residents are also entitled to know that they may file grievances and complaints with the California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov.


This Privacy Policy replaces the old policy in relation to Safe Harbor and EU-US Privacy Shield and is effective from 16th July 2020. It sets forth the privacy principles that Xigo follows with respect to transfers of personal information between the European Economic Area or EEA, Australia and the United States. In accordance with our commitment to protect personal privacy, Xigo adheres to the principles of the GDPR and Standard Contractual Clauses.


We reserve the right, in our sole discretion, to modify this Privacy Policy at any time to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the “Effective Date” at the top of this Privacy Policy.  If we make any material changes in the way we collect, use and/or share personal information that may impact you, we will notify you by sending an e-mail to the e-mail address you most recently provided to us, and/or by prominently posting notice of the changes to this Website.  If we post those changes on this page of the Website and update the “Effective Date” at the top of this page. 


If you have additional questions or comments regarding this policy, please send them via email to US.CLM.Security@global.ntt with the words "Privacy Policy Issue" in the subject line, or via regular post to our Corporate Address listed below:

Corporate Address

Xigo, LLC
5870 Trinity Parkway Suite 250
Centreville, VA 20120
Email: US.CLM.Security@global.ntt

For Customers

Customer Service Inquiries | US.CLM.Security@global.ntt