Privacy Policy

EXCELLE, LLC, a Rhode Island limited liability company (“EXCELLE,” “we,” “us,” or “our”), has created this

personal information in connection with the Service. All capitalized terms used but not defined in this Privacy

Policy have the meanings ascribed to them in EXCELLE’s Terms of Use.

By accessing or using the Service in any way, you consent to EXCELLE’s collection, use, retention, and disclosure

of your personal information as provided in this Privacy Policy.

EXCELLE reserves the right to update and modify this Privacy Policy from time to time in its sole discretion, and

all such modifications will be effective immediately upon being posted on the Service and are hereby incorporated

by reference. Your continued use of the Service after such modifications have been posted constitutes your

acceptance of such changes, and you agree your use of the Service will be subject to the then-current version of the

agreement with any aspect of the Privacy Policy, then you are not authorized to and may not access or otherwise use

the Service.

1. EXCELLE’S COLLECTION OF PERSONAL INFORMATION

As used in this Privacy Policy, “personal information” means information that relates to an identified or identifiable

individual. When you interact with the Service, EXCELLE may collect the following categories of personal

information from or about you:

● Contact Information: We may collect your contact information, including first and last name, company

name, and email address.

● Contributions: We may collect any content, information, or materials you post, upload, submit or share

through the Service, including through forms, the member directory, the Member Area, or other

information you submit to the Service, including through the interactive features contained in the Service

or, occasionally, through surveys that we may administer (the “Contributions”).

● Member Profile Information: If you are an EXCELLE member with access to the Member Area, we may

collect and display certain profile information you provide, including your photograph, LinkedIn profile,

professional title, and place of employment. This information may be visible to other EXCELLE members

through the member directory.

● Demographic Information: We may collect demographic details about users of the Service, such as

occupation, language fluency, professional title, employment, zip code, and area code.

● Device Information: When you interact with the Service, we may learn about your browser, device type,

IP address, MAC address, internet service provider, the name and version of your operating system, the

name and version of your browser, the date and time of your visit, the pages you visit, and any search terms

you enter while using the Service.

● Service Interactions: When you interact with the Service, we may collect information about your

interactions, including pages visited, links clicked and buttons clicked.

There may be circumstances where we collect or retain some of the above-described information in an anonymized

and/or aggregated form, such that it cannot be associated with you. We consider such information to be non-personal

information that is not subject to this Privacy Policy.

Cookies and Similar Technologies

EXCELLE relies on cookies and similar technologies to collect the Device Information and Service Interactions

described above. “Cookies” are data files that are placed on your computer or device and often include an

anonymous unique identifier.

For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. “Log files”

track actions occurring on the Service and collect data including your IP address, browser type, Internet service

provider, referring/exit pages, and date/time stamps. “Web beacons,” “tags,” and “pixels” are electronic files used to

record information about how you browse the Service. Cookies, log files, web beacons, tags, pixels, and similar

technologies are referred to in this Privacy Policy as “Tracking Technologies.”

EXCELLE may use Tracking Technologies to analyze user activity, administer the Service, deliver a better, more

efficient, and more personalized experience (for example, by identifying you and maintaining your “signed-in”

status on the Service), to estimate EXCELLE’s user base and usage patterns, and to promote trust and safety among

the EXCELLE community of users. The Service also relies on the web analytics service Google Analytics, which

uses Tracking Technologies. The information collected and generated via Google Analytics will be transmitted to

and stored by Google and will be subject to Google’s privacy policy, which can be viewed at

https://policies.google.com/privacy. To learn more about Google’s partner services and to learn how to opt out of

analytics tracking by Google, visit https://tools.google.com/dlpage/gaoptout.

EXCELLE currently uses the following third-party Tracking Technology and analytics provider: Squarespace, and

from time to time, Google Analytics.

Where required by applicable law, EXCELLE will provide a cookie banner or similar mechanism allowing you to

accept or reject non-essential Tracking Technologies before they are set.

2. EXCELLE’S USE OF PERSONAL INFORMATION

EXCELLE uses personal information (including through the disclosures described in Section 3 below): (a) to

deliver, administer and provide access to the Service; (b) to respond to user inquiries and to administer and verify

users’ accounts; (c) to allow you to use the Service to make information available to and communicate with other

users and vice versa; (d) to customize and improve the Service to fit user preferences and to determine which

advertisements, sponsor messages, and interactive communications will appear on various pages of the Service; (e)

to inform users about the Service and updates to the Service and to communicate promotional offers about products

and services EXCELLE believes may be of interest to you (you can opt out of receiving promotional

communications from EXCELLE at any time by emailing: connect@excelle.me); (f) to troubleshoot and resolve any

issues or concerns users may have with the Service; (g) to perform statistical, demographic, and marketing analysis

of users of our Service and their behavioral patterns; (h) to enforce this Privacy Policy or EXCELLE’s Terms of Use

and its other rules, guidelines, and policies; (i) to discover, investigate, and stop unlawful or prohibited activities by

any of its users if EXCELLE believes in good faith such actions are necessary to protect the Service, EXCELLE’s

systems or business, its users or strategic partners, or as required by law (e.g., to comply with a lawful subpoena,

search warrant, court order, or other legal process); and (j) to prevent or respond to a physical threat to you or others,

to protect property, or to defend or assert legal rights.

3. EXCELLE’S DISCLOSURE OF PERSONAL INFORMATION

We may share personal information with third parties for certain purposes. For example, we may share information

with:

● Service Providers: We may from time to time engage service providers to perform functions relating to

the Service on our behalf, such as hosting, content management, membership management, email

communications, payment processing, social media integration, and analytics. These entities may have

access to personal information if necessary or useful to the performance of their functions. If providing

such entities with such access, we will make reasonable efforts to ensure they are subject to confidentiality

and security obligations with respect to such information. Current third-party service providers include, but

are not limited to:

○ Hosting / website platform: Squarespace (privacy policy: https://www.squarespace.com/privacy)

○ Membership / association management platform: HubSpot (privacy policy: https://legal.hubspot.com/privacy-policy)Email / newsletter platform: Squarespace (privacy policy: https://www.squarespace.com/privacy)

○ Payment processor: QuickBooks (privacy policy: https://www.intuit.com/privacy/statement/)

○ Community platform: Community Box (privacy policy: https://www.communitybox.co/privacy-policy)

○ Social media: Instagram and LinkedIn (for outreach and engagement) (LinkedIn privacy policy: https://www.linkedin.com/legal/privacy-policy and Instagram privacy policy: https://about.instagram.com/data-policy)

● Other Users; Public: Your Contributions, including information contained in your profile or that you

choose to post, upload or share using the Service, may be visible to other Service users and/or the public,

depending on which features of the Service you use and how you use those features. You acknowledge and

agree that you have no expectation of privacy with respect to any such Contributions, and by sharing any

Contributions, you consent to the public dissemination of all information contained therein, both via the

Service and search engines and other similar tools online.

● EXCELLE Affiliates and Advisors: We may share your personal information with our affiliates,

attorneys, accountants, or other professional advisors.

● Sponsors and Partners: From time to time, EXCELLE may share limited member information, such as

names and email addresses, with sponsoring organizations that partner with EXCELLE in connection with

its programs and events. You may opt out of such sharing at any time by contacting us using the

information in the “Contacting EXCELLE” section below.

● Recorded Content: EXCELLE may record virtual roundtables and other gatherings with the knowledge

and consent of participants. These recordings, along with related materials such as slides and presentation

documents, may be made available to EXCELLE members through the password-protected area of the

Service.

● Parties to a Business Transaction: Your information may be transferred to another entity that succeeds to

all or part of EXCELLE’s business in connection with a sale, reorganization, consolidation, or merger, or in

the event of any insolvency, bankruptcy, or receivership. Your information may be shared under

obligations of confidentiality and non-disclosure to a prospective successor or purchaser of EXCELLE’s

business.

EXCELLE does not sell personal information for money. As described further below, some uses of Tracking

Technologies (such as analytics or advertising cookies) may be considered a “sale” or “sharing” of personal

information under certain state laws, even though no money changes hands.

4. SECURITY, ACCURACY AND RETENTION OF PERSONAL INFORMATION

We take steps to help protect the confidentiality and security of your personal information. Although we use

measures to protect your personal information, in general, information transmitted through the Internet may not be

completely secure. Accordingly, we cannot and do not guarantee, represent, or warrant that any information

transmitted via the Internet is secure, or that such transmissions are or will be free from error, delay, interruption, or

interception. All such transmissions of personal information are at your own risk, and you remain solely and entirely

responsible for the security of your personal information.

You can protect your information by selecting strong, unique passwords for your EXCELLE account and any

associated email addresses. You are also responsible for ensuring the accuracy of the personal information you

submit to EXCELLE. In creating an EXCELLE User Account, your display name will be public and visible to all

other users of the Service. Accordingly, EXCELLE encourages you to refrain from using information when creating

your display name that may be used to personally identify you. In establishing an EXCELLE User Account, you will

be asked to create a password for your User Account. EXCELLE recommends you use unique combinations of

letters, numbers, and special characters to reduce the likelihood that third parties may be able to gain access to your

EXCELLE User Account. You will at all times remain solely and entirely responsible for actions taken in the name

of your EXCELLE user ID. Therefore, if you believe your password has been compromised, you should

immediately notify EXCELLE at connect@excelle.me and take appropriate steps to change your password. You

agree to update your personal information with EXCELLE if at any time it changes or becomes inaccurate. To

review and update your personal information, simply log in to your EXCELLE User Account and follow the

relevant link. Upon the closure of User Accounts, EXCELLE will remove personal information in accordance with

applicable law and as soon as is reasonably practicable; however, EXCELLE reserves the right to retain personal

information associated with closed User Accounts for purposes of complying with legal requirements, fraud

prevention, resolution of claims, to collect payments owed, to enforce the Terms of Use and other rules, guidelines,

and policies of EXCELLE, in connection with any investigation of unlawful or unauthorized activity, and for other

actions permitted under applicable law. In addition, EXCELLE has no obligation to remove or modify Contributions

shared by you via the Service prior to or after any closure of your User Account.

5. YOUR CHOICES AND RIGHTS

Managing Preferences Regarding Notifications, Newsletters, and Other Communications

In connection with your use of the Service, you may receive certain notifications, newsletters, and other

communications. You may select whether or not you wish to continue to receive notifications, newsletters, or other

communications by changing the settings and preferences in your User Account. In addition, you may “opt out” of

receiving subscription, marketing, or promotional communications from EXCELLE, or being notified of responses

to Contributions you share via the Service, by following the unsubscribe instructions or using the unsubscribe links

provided in these communications.

Rights and Requests

You can contact us at any time using the contact information listed in the last section of this Privacy Policy to

request we do any of the following: (i) erase or delete all or some of your personal information; (ii) change, update,

or correct your personal information; (iii) restrict how we use all or some of your personal information; (iv) access

your personal information and, where applicable and feasible, request to receive that personal information in a

commonly used electronic format (or ask for this information to be provided in that format to a third party); or (v)

disclose what personal information we collect, use, disclose, or sell. We will consider and respond to any such

requests promptly, and otherwise in accordance with applicable laws. Although we use good faith efforts to respond

to your request, we may not be able to provide and/or correct the requested user information in all situations. For

example, we may not be able to provide the personal information requested if it imposes an undue burden or

expense, requires us to release confidential commercial information, requires the disclosure of personal information

relating to another person, or requires authentication of the request that is not feasible.

EXCELLE will not discriminate against you for exercising any of these rights.

California and other U.S. state residents, as well as European residents, should also review the additional

information applicable to them in the sections that follow.

Note for California Residents

If you are a resident of California, this section applies to you and supplements the rest of this Privacy Policy, to the

extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the

“CCPA”), applies to your interactions with EXCELLE.

The CCPA generally gives California residents the right to:

● Know/Access: Request that we disclose certain information to you about our collection, use, disclosure,

and sale or sharing of your personal information.

● Delete: Request that we delete your personal information.

● Correct: Request that we correct inaccurate personal information we maintain about you.

● Opt Out of Sale/Sharing: Opt out of the “sale” or “sharing” of your personal information, including

sharing for cross-context behavioral advertising.

● Limit Use of Sensitive Personal Information: Direct us to limit the use or disclosure of sensitive personal

information to that reasonably necessary to provide the Service.

● Non-Discrimination: Not receive discriminatory treatment by a business for the exercise of your consumer

privacy rights conferred by California law.

We collect and use personal information as described above under “EXCELLE’s Collection of Personal

Information” and “EXCELLE’s Use of Personal Information.” We disclose personal information to third parties as

described above under “EXCELLE’s Disclosure of Personal Information.” We retain each category of personal

information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, unless a

longer retention period is required by law. We do not sell personal information for money, and we do not use or

disclose sensitive personal information for purposes other than those permitted under the CCPA.

EXCELLE currently honors opt-out preference signals, such as the Global Privacy Control (“GPC”), as an opt-out

of sale/sharing where legally required.

You may, by using the contact information listed in the last section of this Privacy Policy, submit a request to

know/access, delete, correct, or otherwise exercise your rights described above. Should you submit such a request,

we may ask you for additional information in order to verify your identity before responding to such requests, but

we will use such additional information only for purposes of such verification. You may also use an authorized

agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized

agent provide written proof to us that they are authorized to act on your behalf, and we may also require your

authorized agent to verify their own identity.

Note for Other U.S. State Residents

Depending on your state of residence, you may have similar rights under other U.S. state privacy laws (for example,

laws in effect in Virginia, Colorado, Connecticut, Utah, and other states), which may include the right to access,

correct, delete, or obtain a copy of your personal information, and to opt out of certain processing, including targeted

advertising, the sale of personal information, and profiling in furtherance of certain automated decisions. If

applicable state law grants you these or similar rights, you may exercise them by contacting us using the information

in the “Contacting EXCELLE” section below. We will not discriminate against you for exercising any rights

available to you under applicable state law.

Note for European Residents

If you are a European Economic Area (EEA), United Kingdom, Iceland, Liechtenstein, or Norway resident, this

section applies to you and supplements the rest of this Privacy Policy.

While our focus is generally on the United States, insofar as we may from time to time process personal data of

individuals in the European Union, Iceland, Liechtenstein, Norway, or the United Kingdom, which processing may

be subject to the European Union’s General Data Protection Regulation (“GDPR”), please note the following:

● EXCELLE is headquartered in Rhode Island, in the United States.

● We will only process your personal data to the extent applicable law allows us to do so.

● The United States has not sought nor received a finding of “adequacy” from the European Union under

Article 45 of the GDPR. We rely on derogations for specific situations as set forth in Article 49 of the

GDPR. In particular, we collect and transfer to the U.S. personal information only: with your consent; to

perform our contractual obligations; or to fulfill a compelling legitimate interest in a manner that does not

outweigh your rights and freedoms.

If you have any complaints regarding our privacy practices or how we handle any requests you make in accordance

with the “Rights and Requests” section above (which requests you may have a legal right to make and we may have

a legal obligation to honor, as dictated by applicable law), you may also lodge a complaint with your national data

protection authority.

6. MINORS

EXCELLE does not knowingly collect personal information from individuals under the age of 18. If EXCELLE

learns it has collected the personal information of an individual under the age of 18, then EXCELLE will delete such

information as soon as practicable. By using the Service, you represent that you are at least the age of majority in

your state or province of residence.

7. CONTACTING EXCELLE

For more information about EXCELLE’s privacy practices, or if you have questions, or if you would like to submit

a complaint, please contact EXCELLE via email at connect@excelle.me or by mail at:

EXCELLE, LLC

130 Prospect Street

Providence, Rhode Island 02906

Attn: Privacy Policy