Updated October 2026

Your Personal Information belongs to you.

We do not sell your Personal Information for money. If you use Xapa on your own (not through your employer), we share a limited amount of data with advertising and measurement partners so we can understand how people discover Xapa and whether our ads are working. If you use Xapa through your employer, we do not share your information with advertising partners. See “Advertising and Measurement” below for details, and “Your Privacy Choices” to opt out.

You have control over what, if any, aspects of your profile or preferences are made available to other users of Xapa. If you use Xapa through your employer, data in your profile including name, title and summary are shared within your company.

Xapa uses the information you provide and choices you make within the Application to improve the service and customize/personalize the experience for you. As you complete assessment quests such as communication style or work style, these are added to your profile. If you use Xapa through your employer, they may be shared with your company.

Xapa World, Inc. (“Xapa,” “our,” “us,” or “we”) is committed to protecting the privacy and security of the information of people who use our Services (“you”). This Privacy Policy covers our mobile app, our web app at xapa.ai (together, the “Application”), our website at xapa.com (the “Website”), and our related services (together with the Application and the Website, the “Services”). We want you to understand how we collect and use information through the Services so you can interact with us with confidence. By using the Services, you accept and agree to the practices this Privacy Policy describes. If you do not agree to any of the terms in this Privacy Policy, you should not use the Services.

What Information Do We Collect?

When you use our Services, we may collect, store, and process various kinds of data, including Personal Information about you. “Personal Information” refers to information about you that can be used to identify you, such as your name, address, telephone number or e-mail address.

Specifically, we may collect, store, or process information when you:

• Register for the Services;
• Submit a form on the Website or in the Application;
• Contact us with inquiries, including via email;
• Subscribe or otherwise sign up to receive communications;
• Share content or otherwise communicate in the Application;
• Complete quests in the Application;
• Visit the Website or click on one of our ads; or
• Voluntarily provide information.

More specifically, when you use the Services, we may collect the following types of information:

a. Personal Information: This includes your name, email address, and other information you voluntarily provide when you use the app or participate in activities such as quests or surveys.

b. Usage Information: We collect information on how you interact with the app, including in-app activities, progress, preferences or posts.

c. Device Information: We collect information about your device, such as the type of device, operating system, device identifiers (including advertising identifiers like Apple’s IDFA or Google’s Advertising ID, where you have allowed it), and IP address.

d. Location Data: We may collect your approximate location based on your IP address.

e. Website and Advertising Information: When you visit the Website or web app, or click on one of our ads, we and our partners may collect information through cookies, pixels, and similar technologies, such as pages viewed, the ad or link that brought you to us, browser type, and IP address.

Why We Collect Information

We use your information for the following purposes:

• Provide, maintain, and improve the app and its features.
• Personalize your experience, including tailoring in-app content and providing targeted learning experiences.
• Respond to user inquiries and provide customer support.
• Analyze Usage Information to better understand user behavior and optimize app design.
• Measure how well our advertising works, understand how people discover Xapa, and show Xapa ads to individual users on other platforms (see “Advertising and Measurement”).
• Detect and prevent fraud, cheating, or other malicious activities.
• Comply with legal obligations and enforce our Terms and Conditions.
• Send you promotional materials and updates about our products, if you have opted in to receive them.
• To present our Services to you.
• To process transactions.
• For any other purpose with your consent.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of our Services is among the assets transferred.

How We Use Cookies and Tracking Technologies

Our Services use various technologies to collect data about how you use them. On the Website and web app, this includes cookies, pixels (also called tags), and similar technologies. In the mobile app, this includes device identifiers and software development kits (SDKs). The specific tools we use may change over time, but they all fall within these groupings:

1. Device Identifiers: The Application may use unique device identifiers, to understand user behavior. These identifiers are unique to each device and can be reset by the user.
2. Local Storage: The Application can store data locally on the device. This data can be used to save user preferences, game progress, or other information that helps personalize the user experience.
3. Analytics SDKs: The Application may integrate third-party analytics tools or software development kits, to collect and analyze user behavior data. These tools track in-app events, user interactions, and other metrics to help us understand how users engage with the app and improve its features.
4. Server-Side Tracking: The Application can also send data directly to servers, where it can be processed and stored. This method allows us to collect more detailed information about user behavior and interactions within the app, while also centralizing data storage for easier analysis.
5. Cookies and Pixels: The Website and web app use cookies and pixels, including those from our advertising and measurement partners, to remember your preferences, understand site traffic, and measure and improve our ads. You can control cookies through your browser settings, and you can opt out of advertising sharing as described in “Your Privacy Choices.”

Advertising and Measurement

This section applies only if you use Xapa on your own as a consumer. If you use Xapa through your employer, we do not share your information with advertising partners.

We work with these advertising and measurement partners: Meta (Facebook and Instagram), Google, TikTok, Reddit, and PostHog.

What we share. We share a limited set of information:

• Device and advertising identifiers
• IP address
• Hashed (encoded) email address, which lets a partner match you to an account you already have with them
• Basic account events, such as signing up, starting a trial, or subscribing

We do not share your quest answers, assessment results, journal entries, sentiment or feelings data, Xapa AI conversations, or what you do inside Xapa experiences.

Why we share it.

• To measure whether our ads work and understand how people discover Xapa
• To improve and optimize our ad campaigns
• To show Xapa ads to people who have visited our Website or used the Application (retargeting)

We do not sell your Personal Information for money. Some U.S. state privacy laws treat this kind of advertising sharing as a “sale,” “sharing,” or “targeted advertising,” and you can opt out of it at any time (see “Your Privacy Choices”).

Each partner handles information under its own privacy policy: Meta, Google, TikTok, Reddit, PostHog.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. You can always change your user preferences by reviewing your user account. If you do not wish to have your e-mail address/contact information used by Xapa to promote our own products or services, you can opt-out by clicking the unsubscribe link in the promotional email.

Your Privacy Choices

You can opt out of advertising sharing in any of these ways:

• In the App. Review settings under your Profile in the App. This applies to your account on any device where you’re signed in.
• Global Privacy Control (GPC). If your browser or a browser extension sends a GPC signal, we treat it as a request to opt out of advertising sharing for that browser. Learn more at globalprivacycontrol.org.
• By email. Email info@xapa.com with the subject “Opt out” and we will process your request for the account associated with that email.

You can also limit ad tracking on your device: on iPhone, turn off “Allow Apps to Request to Track”; on Android, delete or reset your advertising ID.

Some browsers send “Do Not Track” signals. Because there is no common standard for them, we do not respond to Do Not Track, but we do honor GPC as described above.

How Do We Share Your Personal Information?

We may disclose your Personal Information as follows:

• With affiliates, contractors, service providers, and other third-parties we use to support our business (your individual answers to quest questions and assessment free-text responses remain private; see the “Users registered through your employer” section below for how information is shared with employers who provide your license);
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information;
• With your consent;
• With affiliates if you opt-in to receiving communications from affiliates;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about users of our Services is among the assets transferred;
• To enforce any agreement, including any applicable terms of service;
• To establish or exercise our right to defend against legal claims;
• To law enforcement and other government authorities such as legislatures, courts, agencies and litigants if we reasonably believe that such action is necessary to: (a) comply with the law and the reasonable requests of governmental authorities; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) protect the security or integrity of the Services’ information systems; and/or (e) exercise or protect our rights, privacy, safety or those of affiliates, clients, you or others; and
• If we reasonably believe disclosure is necessary or appropriate to protect the rights, property, or safety of Xapa or others.

Users registered through your employer

Most Xapa users are registered through their employer. If you are registered to use Xapa through your employer, these additional sharing categories apply:

• Profile information. Your profile information (such as name, title, summary, and assessment results like communication style or work style) is shared within your organization. You can edit your profile within the application and choose not to share certain elements.
• Aggregate sentiment and trend reports. For sentiment and feelings-based features, we provide aggregate-only information to your employer, and only for groups of more than 6 people. For example: employers may receive reports such as “30% of employees were excited this month” or “10% were tired.”
• Aggregate participation reports. Employers may also receive aggregate participation information, such as how many employees took a particular program or quest (for example, “300 employees took the Burnout journey this month” or “505 people took Communications Styles”).
• Individual-level engagement and progress metrics. Your employer’s authorized administrators may have access to individual-level engagement and progress information about you, including but not limited to: experience points (XP), quests completed, programs started or finished, login and activity dates, and ranked leaderboards displaying your name, work email, and score relative to other users in your organization. These reports are intended to help your employer measure engagement and program effectiveness. If you have questions about how your employer uses this information, please contact your employer directly.
• What remains private. Your individual answers to quest questions, assessment free-text responses, journal entries, and similar content you provide within quests or programs are not disclosed to your employer at the individual level. These are used only to personalize your experience and may be reflected in aggregate reports as described above.

Xapa AI Usage

Xapa AI is an optional feature within our app that you may choose to use. When you first access the Xapa AI, you will be presented with a notice and you will be asked to explicitly agree to the AI Terms before continuing. Xapa AI has the ability to read your profile information and share with other users in your company. You can edit your profile at any time and you can turn off specific data elements.

If you choose to use Xapa AI features:

• Voluntary Use – The feature is a voluntary, opt-in service. You may stop using it at any time.
• Data Used – The feature may access certain information you have chosen to share in your profile (such as your communication style, title, or preferences) to personalize its responses.
• Third-Party Processing – We use a third-party provider to process AI queries. This means that your queries, and any related profile data you have opted to share, will be transmitted to and processed by that provider.
• No Sensitive Data – We recommend that you do not submit any personal, sensitive, financial, medical, or confidential information in your AI queries.
• Accuracy Limitations – Xapa AI may sometimes provide incorrect, incomplete, or outdated information. You should verify important information from other sources before relying on it.
• Retention – AI interactions will be stored for quality assurance, troubleshooting, and improvement of the service, in accordance with this Privacy Policy.

Communications

You may have the opportunity to communicate with other Application users through our Xircles feature. Other users will be able to see your name and avatar. Any information you voluntarily provide in the chat will be available to other users. Please exercise caution when providing information to other users.

How Do We Protect Your Information?

To protect your Personal Information, we take commercially reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed. However, no data protection procedures are entirely infallible. As a result, while we strive to protect your Personal Information, we cannot guarantee that it will be 100% secure. Your transmission of your information to our Services is done entirely at your own risk.

Third-Party Applications and Social Media

Our Services may contain links to other applications or websites, including those of third parties or partners. While we seek to link only to applications or websites that share our high standards and respect for privacy, we cannot be responsible for the privacy practices other applications or websites use. By accessing other third party websites or applications through our Services, you are consenting to the terms and privacy policies of those websites or applications.

International Visitors

Our Services are hosted and operated in the United States (“US”). By using the Services, you are consenting to the transfer of your personal information to the US. If you are accessing the Services from outside the US, please be advised that US law may not offer the same privacy protections as the law of your jurisdiction. We do adhere to GDPR and offer in-app options to delete personal information or to request your information.

Your U.S. State Privacy Rights

Depending on the U.S. state where you live (for example, California, Colorado, Connecticut, Texas, or Virginia), you may have the right to:

• Know and access the Personal Information we have about you, and get a copy of it
• Delete your Personal Information
• Correct inaccurate Personal Information
• Opt out of the sale or sharing of your Personal Information and of targeted advertising (see “Your Privacy Choices”)

How to make a request. You can make requests in the App under your profile, or by emailing info@xapa.com. We will verify your request by confirming your account email. You may use an authorized agent to make a request on your behalf. We respond within 45 days. If you use Xapa through your employer, we may need to coordinate with your employer to fulfill some requests.

Appeals. If we decline your request, you can appeal by replying to our response. If you’re not satisfied with the outcome, you can contact your state attorney general.

No discrimination. We will not treat you differently for exercising your privacy rights.

California “Shine the Light.” California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@xapa.com.

Users Only of Legal Age of Majority

Our Services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on the Services or through any of its features, register on the Services, or provide any information about yourself to us — including your name, address, telephone number, e-mail address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from anyone under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18 without verifiable parental consent, please contact us at info@xapa.com.

Review and Correction of Your Information

You may review and edit the information we collected about you at any time in the App, or by emailing us at info@xapa.com. See “Your U.S. State Privacy Rights” for more.” If your information has been shared with a third party, as described elsewhere in this Privacy Policy, then that third party has received its own copy of your data. If you have been contacted by one of these third parties and wish to correct or delete your information, please contact them directly.

Privacy Policy Updates

We update the Privacy Policy from time to time, so please review it regularly. If we materially change our Privacy Policy, we will notify you by contacting you through your provided e-mail address or by posting a notice on our Services. Your continued use of our Services will be deemed your agreement that your information may be used in accordance with the new policy. If you do not agree with the changes, then you should stop using the Services and notify us that you do not want your information used in accordance with the changes.

Contacting Us

We welcome any questions, comments, or complaints you may have regarding this Privacy Policy. Please do not hesitate to contact us by email.